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	<title>Comments on: Better Late Than Never, I Suppose</title>
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	<link>http://www.exportlawblog.com/archives/274</link>
	<description>Latest News on DDTC, BIS, OFAC, and other export law matters</description>
	<pubDate>Wed, 07 Jan 2009 02:32:09 +0000</pubDate>
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		<title>By: Ladyx</title>
		<link>http://www.exportlawblog.com/archives/274#comment-7029</link>
		<dc:creator>Ladyx</dc:creator>
		<pubDate>Wed, 09 Jan 2008 13:06:35 +0000</pubDate>
		<guid isPermaLink="false">http://www.exportlawblog.com/archives/274#comment-7029</guid>
		<description>Oh what chaos this could be causing for all of their competitors!  I saw this announcement via an email news brief and I am sure that many more saw it as well.  I took a look at their website and there wasn't anything there, although I half expected to see "ITAR Registered" on the front page!</description>
		<content:encoded><![CDATA[<p>Oh what chaos this could be causing for all of their competitors!  I saw this announcement via an email news brief and I am sure that many more saw it as well.  I took a look at their website and there wasn&#8217;t anything there, although I half expected to see &#8220;ITAR Registered&#8221; on the front page!</p>
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		<title>By: An Old Hand</title>
		<link>http://www.exportlawblog.com/archives/274#comment-7021</link>
		<dc:creator>An Old Hand</dc:creator>
		<pubDate>Wed, 09 Jan 2008 00:40:29 +0000</pubDate>
		<guid isPermaLink="false">http://www.exportlawblog.com/archives/274#comment-7021</guid>
		<description>It's interesting to see that the "press release" is not on the Trilogy website - granted I did a very quick search - but is on a newsletter type site.  

Clif was the release ever on the Trilogy site?  It would be interesting to find out if the newsletter took a tidbit garnered somewhere else and ran with it.  As Philip and Evelyn point out we're all having to "certify" that we're ITAR registered.</description>
		<content:encoded><![CDATA[<p>It&#8217;s interesting to see that the &#8220;press release&#8221; is not on the Trilogy website - granted I did a very quick search - but is on a newsletter type site.  </p>
<p>Clif was the release ever on the Trilogy site?  It would be interesting to find out if the newsletter took a tidbit garnered somewhere else and ran with it.  As Philip and Evelyn point out we&#8217;re all having to &#8220;certify&#8221; that we&#8217;re ITAR registered.</p>
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		<title>By: Evelyn Morales</title>
		<link>http://www.exportlawblog.com/archives/274#comment-7020</link>
		<dc:creator>Evelyn Morales</dc:creator>
		<pubDate>Tue, 08 Jan 2008 20:38:17 +0000</pubDate>
		<guid isPermaLink="false">http://www.exportlawblog.com/archives/274#comment-7020</guid>
		<description>Sigh.  I can speak to the misleading "certification" term from personal experience.  My company has an internal ITAR certification program whereby we require anyone that needs to touch technical data first take an ITAR training class. We used to call someone who had been through the training an "ITAR-certified" employee.  When that term got published into some marketing literature, we put a stop to it right away.  Now we call our trained employees just that:  ITAR-trained.  It's really a matter of education.  Take your marketing and PR people out to lunch sometime. It's a win-win. :)</description>
		<content:encoded><![CDATA[<p>Sigh.  I can speak to the misleading &#8220;certification&#8221; term from personal experience.  My company has an internal ITAR certification program whereby we require anyone that needs to touch technical data first take an ITAR training class. We used to call someone who had been through the training an &#8220;ITAR-certified&#8221; employee.  When that term got published into some marketing literature, we put a stop to it right away.  Now we call our trained employees just that:  ITAR-trained.  It&#8217;s really a matter of education.  Take your marketing and PR people out to lunch sometime. It&#8217;s a win-win. <img src='http://www.exportlawblog.com/wp-includes/images/smilies/icon_smile.gif' alt=':)' class='wp-smiley' /></p>
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		<title>By: Philip Zerbe</title>
		<link>http://www.exportlawblog.com/archives/274#comment-7018</link>
		<dc:creator>Philip Zerbe</dc:creator>
		<pubDate>Tue, 08 Jan 2008 19:43:49 +0000</pubDate>
		<guid isPermaLink="false">http://www.exportlawblog.com/archives/274#comment-7018</guid>
		<description>Lately, I am constantly asked if my company is “ITAR Certified” or not, and I now see these press releases trumpeting this all over the place.  Apparently the word is out that non-exporting defense manufacturers need to be registered, and I see that contract language now requires this “certification” in many cases. The word ‘certification’ is a misleading spin word. There is no such thing, and it implies a level of expertise where none exists.</description>
		<content:encoded><![CDATA[<p>Lately, I am constantly asked if my company is “ITAR Certified” or not, and I now see these press releases trumpeting this all over the place.  Apparently the word is out that non-exporting defense manufacturers need to be registered, and I see that contract language now requires this “certification” in many cases. The word ‘certification’ is a misleading spin word. There is no such thing, and it implies a level of expertise where none exists.</p>
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		<title>By: John Liebman</title>
		<link>http://www.exportlawblog.com/archives/274#comment-7016</link>
		<dc:creator>John Liebman</dc:creator>
		<pubDate>Tue, 08 Jan 2008 18:47:02 +0000</pubDate>
		<guid isPermaLink="false">http://www.exportlawblog.com/archives/274#comment-7016</guid>
		<description>Given the number of non-exporting manufacturers of defense articles who are completely clueless about their registration obligations, this is not surprising.  In recent months, also, DDTC has become increasingly interested in "front end" issues in dealing with 2032s, and has interposed numerous requirements as conditions for registration, none of which can be found in Part 122.</description>
		<content:encoded><![CDATA[<p>Given the number of non-exporting manufacturers of defense articles who are completely clueless about their registration obligations, this is not surprising.  In recent months, also, DDTC has become increasingly interested in &#8220;front end&#8221; issues in dealing with 2032s, and has interposed numerous requirements as conditions for registration, none of which can be found in Part 122.</p>
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