All entities registered with the Directorate of Defense Trade Controls (“DDTC”) as manufacturers, exporters, or brokers of defense articles or defense services are required by the International Traffic in Arms Regulations (“ITAR”) to have an empowered official (“EO”) to sign license applications or other requests to the regulator on their employer’s behalf. EOs have a uniquely important role in a company’s trade compliance program.
Specific requirements for EOs are identified in the ITAR (§ 120....
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