Being an Empowered Official (EO) is not a “paper-pushing,” administrative job, but a position which requires detailed substantive knowledge of the International Traffic in Arms Regulations and the Arms Export Control Act. The position carries within it liability for both the company and the individual – a liability which emphasizes the need for an experienced, well-trained and competent EO. It is not always possible, however, to find an experienced individual within or outside the company capable of fulfilling the requirements of the EO position. The shortage of qualified EOs means that those appointed to the position need to be aware of the exact responsibilities associated with the ITAR-mandated appointment as well as the interpretations and regulatory analyses of the ITAR and AECA that affect their daily jobs. Companies also need to be comfortable with the employees they place in the EO position since the trust, accountability and responsibility vested in these individuals creates risks of incurring liability where the companies believe they may be insulated.
Given these risks, join Patton Boggs for a course designed to provide EOs and officials within companies who appoint them with the “basic training” needed to: 1. understand what 120.25 really means; 2. determine what tools exist (or should be provided) for an EO to perform adequately and responsibly; 3. assess whether an employee should accept an EO appointment; and 4. assist in understanding who within companies should be appointed EO.
The course will provide tools, such as questionnaires for licenses, copies of license administration plans, interpretations of various regulations applicable to how an EO carries out his/her function and certain recordkeeping requirements. In addition, the afternoon session will include a discussion with at least one company EO as we review some hands-on scenarios and hypotheticals designed to sensitize you to the ramifications of the actions an EO takes on behalf of the company.
