Here is some interesting and applicable information on Voluntary Disclosures that was just issued by the DoJ on December 13, 2019. It explains that filing a voluntary self-disclosure in a complete and timely manner creates the presumption that the company will receive a non-prosecution agreement and not pay a fine, absent aggravating factors. If aggravating [...]
Up until now, unless data is on a US-only cloud service, no US export controlled data could be on it – even if it is encrypted. A couple of cloud service companies have attempted to fill this issue like Amazon (ref: http://aws.amazon.com/govcloud-us/). It appears that things may change. Below is an extraction from a proposed ruling: [...]
As an ITAR Auditor, we closely review how and where companies back-up their ITAR controlled technical data. Even when the data is stored onsite, foreign national access must be blocked unless there is a specific State Department authorization. A common finding in this area is when third party suppliers are hired to look [...]
