News from Reeves & Dola, LLP
Dec. 13, 2022 News from Reeves & Dola, LLP State Department Publishes New Guidelines for Export Compliance Programs It's been a long time coming, but finally on December 5 the Directorate of Defense Trade Controls (DDTC) published new Compliance Program Guidelines (CPG) . This 63-page document presents the following key elements of an effective ITAR compliance program (ICP): Management commitment Registration, jurisdiction and classification, authorizations, and other ITAR activities Recordkeeping Reporting and addressing violations Training Risk assessment Audits and monitoring Compliance manual and templates DDTC notes these elements are intended to provide a foundation for an ICP’s basic structure and function but are not exhaustive. ATF Revises the Form 4473 (5300.9) Firearms Transaction Record Last week on December 7, 2022, the Bureau of Alcohol, Tobacco, Firearms and Explosives ("ATF") published on its website a revised Form 4473 Firearms Transaction Re