Mar

16

First Let’s Make Sure We’ve Got the Name Right


Posted by at 10:05 pm on March 16, 2011
Category: Part 122

Yippee!It’s been a while since this blog has seen one of the infamous press releases from a company announcing that the company has registered with the Directorate of Defense Trade Controls (“DDTC”). A reader today brought to my attention a press release from Rave Computer announcing that it is now “ITAR registered.”

As is normal in these cases, the company does its best to try to leave the impression that registration is a certification or endorsement by DDTC of the company’s compliance policies:

Rave Computer developed and implemented ITAR policies, procedures and employee training.

But in the previous sentence, Rave says:

The Office of Defense Trade Controls in the State Department interprets and enforces ITAR. Its goal is to safeguard U.S. national security and further U.S. foreign policy objectives.

Oops. DDTC hasn’t called itself the Office of Defense Trade Controls for almost a decade. Do you think Rave may be using ten-year old copy of the ITAR as the basis for certifying its compliance with the regulations and obtaining registration?

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Copyright © 2011 Clif Burns. All Rights Reserved.
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2 Comments:


Clif:

I took a break to read this post, but am supposed to be reviewing a contract with a major player in the aviation industry.

One of the corrections I’ve made to the contract is the exact one your post mentions. So, it’s not just newbies and the little guys.

Comment by Linda Mills on March 17th, 2011 @ 2:12 pm

@Linda: I suspect I know who you’re talking about. Sometimes, you just have to wonder exactly what it takes to get certain companies to amend their boilerplate.

Comment by Mike Deal on March 20th, 2011 @ 7:48 pm