Think Strategically, Llc

Description

With the increasing number of enforcement actions taken against businesses and with DDTC ratcheting- up its focus on small businesses it is important to ensure your business complies with the Arms Export Control Act, the Export Administration act, and the export- control regulations that implement those laws (i.e., the ITAR and the EAR). Violations of the export control regulations can carry heavy fines, up to $1 million dollars per violation, and can include imprisonment. In many cases one act of illegally exporting an item contains several violations. Based on discussions Think Strategically has had with DDTC Compliance personnel, DDTC recognizes that such penalties would kill most small businesses; therefore, they are developing new guidelines on penalties for small businesses so they can increase their enforcement of export- control violations by small businesses. It may simply be a coincidence that the new guidelines were developed in the same time frame that the DFARS were modified to provide explicit export- control guidelines for defense contractors. Or maybe it wasn't a coincidence.

Think Strategically is a small consulting firm that advises business and government organizations on technology development projects, strategic planning activities, and export control compliance. Our customers include Department of Defense organizations and their contractors as well as several small DoD contractors. Think Strategically provides an alternative to maintaining in- house resources for these highly- specialized and critical capabilities. We do this by applying experts with widely- recognized, highly- valued contributions in these fields, a record of respect and protection of sensitive information, and numerous contacts in all aspects of their work. Our experts and staff focus on providing extraordinary customer service in a surprising timely manner. The company's services deliver a premium value to our customers at a price that is reasonable considering the importance and quality of the work. Think Strategically technology development and strategic planning consulting services assist companies ensure their short- term and long- term plans are sound.

Our job: tell you how to achieve your objectives, not tell you why you can't. Today, small businesses that develop and/or manufacture defense article or wish to export their products can face what seems to be a bureaucratic nightmare. According to the ITAR, any business that develops or manufactures defense articles or technical data, or provides defense services must be registered with the State Department's Directorate of Defense Trade Controls (DDTC). In addition, most DoD contracts issued since 2008, including Small Business Innovative Research (SBIRs) contracts, have a DFARS clause 252.204- 7008 that requires the contractor to comply with the export control regulations which includes registering with DDTC. Businesses that wish to export their products, including providing defense articles or defense services to a foreign person within the United States, are generally required to obtain an approved license or agreement before they export.

Think Strategically is a consulting firm. We do not develop technology, we advise others on their technology development projects and plans. We advise customers on their competencies, the DoD markets they are best suited for, and on new or on- going technology development projects, primarily for space system components. We do not advise on any particular space or weapon system, but on component development projects (e.g., space electronic devices) for all space technology customers. The customers we work with are all experts in their fields that value the innovation and different perspective we bring to their processes. The benefit of this relationship is that we bring familiarity with the needs and interests of various DoD offices and experience in establishing DoD technology development projects. Our customers are fully capable of evaluating the approaches or changes we recommend and generally recognize that our advice and recommendations add value to their plans.

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