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Downrange Precision Arms
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Downrange Precision Arms

ITAR COMPLIANCE

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ITAR Compliance Policy

Effective Date: 01 August, 2025
Company: Downrange Enterprises LLC – d/b/a Downrange Precision Arms

1. Purpose

This policy establishes Downrange Enterprises LLC’s commitment to full compliance with the International Traffic in Arms Regulations (ITAR) as administered by the U.S. Department of State, Directorate of Defense Trade Controls (DDTC). ITAR governs the export, re-export, temporary import, and brokering of defense articles, defense services, and related technical data listed on the United States Munitions List (USML).

2. Scope

This policy applies to:

  • All company officers, employees, contractors, and agents.
  • All business activities involving USML items, components, technical data, and defense services.
  • All physical and electronic transfers, including emails, cloud storage, verbal communication, and demonstrations.

3. Policy Statement

Downrange Enterprises LLC:

  • Will not export, re-export, or transfer ITAR-controlled items, technical data, or defense services to non-U.S. persons without proper DDTC authorization.
  • Will register with the DDTC as required by law and maintain current registration status.
  • Will restrict access to ITAR-controlled items and information to U.S. persons unless an export license or other DDTC authorization is obtained.
  • Will maintain documented ITAR compliance procedures and training.

4. Key Definitions

  • U.S. Person – U.S. citizen, lawful permanent resident (green card holder), or protected individual under 8 U.S.C. 1324b(a)(3).
  • Foreign Person – Any person who is not a U.S. person, including foreign corporations and governments.
  • Defense Article – Any item, software, or technical data listed on the USML.
  • Technical Data – Information required for the design, development, manufacture, assembly, operation, repair, testing, maintenance, or modification of defense articles.
  • Export – Sending, transmitting, or otherwise transferring a defense article or technical data to a foreign person, whether in the U.S. or abroad.

5. Compliance Requirements

A. Registration

  • Maintain active registration with the DDTC.
  • Renewal filed annually before expiration.

B. Licensing & Authorization

  • Obtain DDTC export licenses for any transfer of USML items or technical data to foreign persons.
  • No export will occur without written authorization from the Compliance Officer.

C. Access Control & Security

  • ITAR-controlled physical items stored in locked, access-controlled areas.
  • Technical data stored in secure, access-controlled ITAR-compliant IT systems with encryption and user logging.
  • No foreign persons permitted access to ITAR-controlled items or data without DDTC authorization.

D. Employee Screening & Training

  • All employees must complete ITAR compliance training upon hire and annually thereafter.
  • Citizenship status verified before granting access to ITAR-controlled materials.
  • Employees must sign an ITAR Compliance Acknowledgment Form.

E. Recordkeeping

  • Maintain all ITAR-related records (licenses, shipping documents, communications, training records) for a minimum of 5 years after the export or transaction.

F. Reporting & Enforcement

  • All suspected ITAR violations must be reported immediately to the company’s ITAR Compliance Officer.
  • Violations may be self-disclosed to DDTC in accordance with federal law.
  • Disciplinary actions, up to and including termination, may result from noncompliance.

6. ITAR Compliance Officer

The ITAR Compliance Officer is responsible for:

  • Overseeing all ITAR compliance activities.
  • Approving exports and license applications.
  • Conducting periodic audits.
  • Maintaining training programs.

Current Designation:
Name: Anthony Look Jr
Email: Anthony@downrangeenterprises.com
Phone: 931-919-2828

7. Penalties for Noncompliance

Violations of ITAR can result in:

  • Civil penalties of up to $1,272,251 per violation.
  • Criminal penalties up to $1,000,000 and/or 20 years imprisonment.
  • Loss of export privileges.
  • Company and personal liability for employees involved.

8. Employee Acknowledgment

All employees with access to ITAR-controlled materials must sign a statement acknowledging that they have read, understand, and agree to abide by this policy.

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