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DDTC Company Visit Program

DDTC Company Visit Program

The State Department’s Office of Defense Trade Controls Compliance (DTCC) relaunched their Company Visit Program (CVP) this year. This program provides for visits by DTCC compliance personnel, or other representatives of the Directorate of Defense Trade Controls (DDTC), to various DDTC registered entities, as well as other parties involved in ITAR activities (to include foreign parties). The purpose of these visits by DDTC is for one of two reasons: 1) outreach and 2) compliance related review.

The outreach visits are to ensure companies are properly implementing the new Export Control Reform policies and that they have a comprehensive compliance program in place.

The compliance visits will typically be scheduled as an outcome of compliance cases reviewed by DTCC to ensure that correct compliance programs have been implemented post violation. These visits will be more in-depth than the outreach visits.

DDTC has stated that these visits are not an audit or an inspection, and companies will not receive a pass/fail grade but will receive recommendations. It is a means for DDTC to offer assistance and help companies prevent violations.

DDTC registered companies may have already received a letter from DDTC stating that they are starting to implement the CVP program. Companies chosen for a visit will be contacted by DDTC to schedule the visit. DDTC plans to visit 2 to 4 companies per quarter and will choose the companies based on specific criteria.

Items that DDTC will be reviewing in their visit will be Export Compliance Policies and Procedures, Technology Control Plans, training logs and other aspects of a company’s compliance program.

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