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PCB-July2017

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16 The PCB Magazine • July 2017 by Didrik Bech ELMATICA ITAR is usually the topic when compliance with DoD regulations is discussed. But what about DFARS? This article will examine strate- gies one can implement to ensure that one is compliant with all DoD regulations, by analys- ing internal and external factors in relation to procurement and compliance, and by asking the vital questions: what, how, where and to whom? Governments regulate the import and ex- port of defence-grade material and equipment, to ensure that their restrictions, laws and regu- lations are implemented and enforced. Govern- ments and their domestic exporting companies are aware, educated, and receptive to ensuring that export compliance is implemented and documented in their compliance programs. The challenge arises when the importing country has restrictions regarding compliance for the exporting country, and how the export- ing companies in these countries can address these compliance demands in their local supply chain, consisting of domestic and foreign mate- rials and components! The largest actor on the global defence mar- ket is the United States Department of Defense (DoD). The DoD has imposed regulations re- garding procurement, design, development and manufacturing. The most central regulations for DoD are described in the Federal Acquisition Regulations (FAR) [1] , Defense Federal Acquisi- tion Regulations Supplement (DFARS) [2] and In- ternational Traffic in Arms Regulation (ITAR) [3] . The logical deduction is that DoD regula- tions will affect most acquisitions and the ques- tion is hence, how does this affect your trade, when comparing DoD regulation with your na- tional export regulation? A foreign state trad- ing with DoD will in principle not be allowed any exemptions from these regulations except perhaps some elements regarding a country's privacy laws. Or putting it simply, if you do not abide by DoD regulations, then you will not be able to sell to or buy from the United States. Severe Consequences and No Excuses A company supplying an article to a sup- ply chain of a defence product, and particularly one purchased by the DoD, must be aware of the strict compliance DoD places on all exports Strategies for Compliance with DoD Regulations Including ITAR and DFARS FEATURE

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