The Office of Defense Trade Controls Compliance has relaunched its Company Visit Program (CVP). Click here for an overview (PDF, 441KB).
What is the Company Visit Program?
The Company Visit Program (CVP) entails visits by Directorate of Defense Trade Controls (DDTC) officials to U.S. entities registered with DDTC as manufacturers, exporters, or brokers of defense articles and defense services, as well as others involved in ITAR-regulated activities, to include foreign companies and foreign governments. The CVP is administered by the Office of Defense Trade Controls Compliance (DTCC); however, representatives from DDTC’s Licensing and Policy offices, or other entities in the Department or elsewhere in the U.S. government, may also participate in the visits.
What is the purpose of the Company Visit Program?
The CVP has several purposes. First, the CVP ensures DTCC understands how compliance programs are implemented in accordance with the International Traffic in Arms Regulations (ITAR). Second, the program enables DDTC to gather information to support the Directorate’s development of regulatory policy and practice. Finally, DTCC uses site visits to glean, assess, and disseminate industry best practices, provide feedback to individual companies on their compliance programs, and share information on compliance programs industry-wide. Note that the CVP includes two (2) types of visits:
Is a CVP visit considered an audit or inspection? What is DDTC looking for during a CVP visit?
Both CVP-O and CVP-C type visits are neither an audit nor an inspection. Visits do not produce a grade or pass/fail assessment for internal or external use, and generally do not include review of transactional records. DDTC will request information from the company to gain a better understanding of their compliance program. CVP-C visits may require a more in-depth look at a company’s compliance program because the visits are focused on overseeing compliance matters already known to DTCC.
How is the visit not an audit if DDTC provides recommendations for improvements to our program?
DDTC may provide recommendations for improvements to a company's compliance program during both CVP-O and CVP-C type visits. If we make recommendations, it is an effort to offer assistance, help prevent violations and share best practices. The CVP is intended to serve as a learning tool for both parties.
What happens if the DDTC team discovers or learns of a violation during the visit?
DTCC will recommend that the company review the issue and submit a disclosure, if appropriate.
How many companies do DDTC personnel plan to visit each year?
DDTC plans visits for each quarter based on other engagements requiring travel and available resources. Generally, DDTC aims to conduct between two and four CVP visits per quarter. In 2015, DTCC conducted eight company visits under CVP auspices; three of those visits were pursuant to consent agreement monitoring.
How are companies selected for a CVP visit?
DTCC selects companies based on its CVP goals. DTCC considers a variety of factors when selecting companies to visit, including proximity to other activities DDTC is participating in, registration status, volume of licensed activity, experience conducting ITAR activities, nature of business, type and sensitivity of technology, geographic location, monitoring of an existing consent agreement, and value to ongoing work within the Directorate.
How is the DDTC team staffed for each CVP visit?
A CVP team typically consists of two or more staff from DTCC, depending on the size of the individual company/site being visited and number of companies/facilities visited per trip. On some CVP visits, staff members from the Offices of Defense Trade Controls Licensing and Policy, or other relevant agencies, may participate. One DTCC team member serves as team lead and primary point of contact with the company. This primary contact is responsible for coordinating the site visit with the company.
How is a CVP visit conducted and what should a company expect?
What is DTCC's Annual Trend Analysis Report and how does it relate to CVP?
DTCC may use insights gained from a CVP visit in its Annual Trend Analysis Report to be published on the DTCC website. Annual Trend Analysis Reports will list the companies visited without associating compliance program observations, good or bad, with individual companies. In general, Annual Trend Analysis Reports will assess the success of the previous year’s company visits based on CVP’s goals, highlight any notable observed compliance program weaknesses without attribution, include DDTC recommendations addressing such weaknesses, highlight any notable observed industry best practices without attribution, and analyze other noteworthy industry compliance trends. The 2015 Report will identify areas of interest and possible trends to examine in future Reports. Annual Trend Analysis Reports are meant to be resources for DDTC and the wider defense trade community.
Are Blue Lantern Checks the same as Company Visits for foreign companies?
The Blue Lantern program is not the same as the Company Visit Program. The Office of Defense Trade Controls Policy manages the Blue Lantern program; end-use checks are conducted by embassy personnel overseas and focus on end-user and end-use verifications related to DDTC authorizations.
Thank you for your interest in the Company Visit Program (CVP). To ensure full consideration and help us make optimal selections, please email your request to DDTC-CVP@state.gov and include the below information. Please note, DDTC cannot guarantee your company will be selected for a visit (see above for more information on how participants are chosen).