DFARS Subpart 204.73 – SAFEGUARDING UNCLASSIFIED CONTROLLED TECHNICAL INFORMATION

By Dennis Andrie, On November 18, 2013, The Defense Acquisition Regulatory Council (DARC) issued its final ruling for Defense Acquisition Regulations System (DFARS) Subpart 204.73 and associated contract clause 252.204-7012, Safeguarding of Unclassified Controlled Technical Information.The new subpart presents a high level guide to actions that need to be undertaken by companies that contract or … More DFARS Subpart 204.73 – SAFEGUARDING UNCLASSIFIED CONTROLLED TECHNICAL INFORMATION

Can we turn off Snowden’s access after the fact?

By E.K. Koh In my last blog, Would data-level controls have stopped Snowden, I highlighted the importance to separate system rights from data rights. But what if Snowden was using a login credential that in fact grants him rights to sensitive data? Accounts vary, but in the blog What the Snowden affair taught us , … More Can we turn off Snowden’s access after the fact?

A “Cheat Sheet” on the Obama Export Control Reforms

By Gary Stanley. The initial Obama export control reforms became effective on Oct 15th.  Although these reforms promise less licensing, they come at the price of more complex controls and more extensive record keeping.  The new rules must be approached in a systematic manner.   Here’s a “cheat sheet” to help you take advantage of these … More A “Cheat Sheet” on the Obama Export Control Reforms

Export Control Reform – Are you Ready?

By E.K. Koh. Parts of the US Export Control Reform went into effect on October 15th, 2013.  Are you ready? The current system has two different control lists administered by two different departments, Commerce and State, and there are three primary export licensing agencies, Commerce, State, and the Treasury.  A multitude of agencies – Commerce, … More Export Control Reform – Are you Ready?

Managing Export Compliance with Trade Management IT Systems

By Soujanya Madhurapantula. Let’s start with what a trade management system is, what it does, and what are some of its shortcomings. What is a Trade Management System Export control can get pretty messy, especially when you consider how a typical company will be operating according to the rules of multiple jurisdictions at any given … More Managing Export Compliance with Trade Management IT Systems