Compliance Analyst III

The United States Department of State, Bureau of Political-Military Affairs, Office of the Directorate of Defense Trade Controls (PM-DDTC) is responsible for the regulation of defense trade through the Arms Export Control Act (AECA) and its implementing regulations, the International Traffic in Arms Regulations (ITAR). DDTC regulates temporary and permanent exports and the temporary import of defense articles, defense services, and technical data involving items on the United States Munitions List (USML).

DDTC regulates the brokering of defense articles, defense services, and technical data. DDTC maintains the registration of manufacturers, exporters and brokers and issues export authorizations. DDTC administers the commodity jurisdiction process, a formal USG decision process to determine which specific items are controlled by the USML or by the Department of Commerce’s Export Administration Regulations. DDTC ensures compliance with the ITAR and AECA through its support of criminal enforcement actions undertaken by the Department of Justice, civil enforcement actions initiated in-house, disclosure program through which companies are encouraged to report violations they have discovered, and pre- and post-license checks to confirm that goods are being shipped as authorized by the export license.

• Facilitates the registration of exporters, manufacturers, and brokers under Parts 122 and 129 of the ITAR under close supervision.
• In accordance with established office policies and procedures, reviews information submitted by registrants to meet the requirements of Section 122.2 concerning criminal violations or indictments under relevant statutes (Section 120.27), as well as foreign ownership and control, and notices of changes submitted as required under Section 122.4 concerning foreign ownership and control.
• Facilitates attendant review of mergers and acquisitions involving registrants.
• Resolves routine matters with regard to company registration and requests for change in registration and refers unique matters to supervisor and senior staff for resolution.
• Reviews and takes action on license requests that are the subject of a “Watch List” hold for enforcement reasons. The Watch List has entities that are suspected, alleged, indicted or convicted of civil and criminal violations of the AECA and ITAR and certain “enumerated statutes.” Action on a license hold is based on all available information (e.g., Watch List entry, office files and computer database searches), coordination with law enforcement and consultation with the supervisor.
• Takes initial action on all incoming voluntary disclosures from the defense industry on civil violations of the AECA and ITAR. Reviews and writes summaries of incoming voluntary disclosures to be triaged by the supervisor. For disclosures of a minor violation, create a computer record and draft a response for the chief’s signature. For incomplete disclosures, draft a letter with response deadline for the chief’s signature, maintain a tracking system and insure receipt of full disclosure information.
  
  For all other violations, create a computer record and assign to appropriate employee.
• Reviews various cases involving violations of the AECA or ITAR and, after consultation with supervisor, plans an approach, conducts fact-finding, performs record searches and documents conclusions. Using generally established format as a guide, prepares letters of response for supervisor to pursue and close each case.
• Reviews and takes action on voluntary disclosures assigned by the supervisor, initially working minor violations. Follow office policies, procedures, and guidance received from the supervisor or senior specialist. Plan an approach, conduct fact-finding, perform search of records, attend meetings and then document findings. Initiate discovery of additional facts. Consult with supervisor and take action. Prepare letter for supervisor signature responding to the violation, including requirement for corrective action to close each case.
  
  Perform any follow-up as directed by supervisor.
• Performs record searches, reviews and analyzes license approvals, produces…