International Traffic in Arms Regulations compliance

Trade and geopolitical risk teams operating under International Traffic in Arms Regulations face direct oversight from the U.S. Department of State Directorate of Defense Trade Controls, with enforcement coordination running through the U.S. Department of Justice and, on the export licensing side, the U.S. Department of Commerce Bureau of Industry and Security when commodity jurisdiction questions arise. The ITAR Part 120-130 framework governs defense articles, technical data, and brokering activities with a specificity that catches supply chain and M&A teams off guard: a single unauthorized disclosure to a foreign national can constitute an export violation regardless of physical location. Compliance teams are currently stress-testing their technology control plans and third-party agreements against the State Department's 2023 ITAR amendment expanding the definition of activities requiring prior authorization.