ITAR Facility Security Requirements for Aerospace Contractors

The Core Mandate: Control of Technical Data

ITAR is fundamentally about preventing foreign persons from accessing defense-related technology. This requires strict control over both physical items (defense articles) and digital information (technical data including blueprints, specifications, and even certain emails).

Physical Security Measures

Your facility must have a documented plan for securing ITAR-controlled hardware and documents. Requirements include defined secure areas with access controls, visitor control and escort policies, comprehensive access logs, document control and destruction procedures, and physical separation of ITAR-controlled areas from general access areas.

Cybersecurity: CMMC and NIST SP 800-171

ITAR data is Controlled Unclassified Information (CUI). You must implement cybersecurity controls outlined in NIST SP 800-171, which is a requirement for CMMC Level 2 certification. Key areas include access control, audit and accountability, configuration management, identification and authentication, and incident response.

"U.S. Persons Only" Access

You must have robust systems to verify that only U.S. citizens or permanent residents access ITAR data. This applies to both physical access and network access. Foreign national employees must be explicitly restricted from ITAR-controlled areas and systems.

The Consequences of Non-Compliance

ITAR violations can result in criminal prosecution, debarment from government contracts, and civil penalties up to $1 million per violation. The Department of State's Directorate of Defense Trade Controls (DDTC) takes enforcement seriously.

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