It is strongly recommended that any acquiring party conduct a thorough review of divesting party’s export compliance practices and procedures. Such a review will provide a more complete understanding of possible past ITAR or EAR violations and may assist the acquiring party in determining if there are specific internal controls weaknesses that should be addressed.

Wilmarth & Associates’ due diligence reviews include a thorough review and written analysis of a company’s export transactions and activities in the following areas:

  • Adequacy, accuracy, and effectiveness of export control policies, procedures and practices
  • Accuracy of export documentation and maintenance of documents and records
  • U.S. export licensing jurisdiction/classification of product
  • Review of existing EAR and ITAR licenses, applications, use of licenses and license exceptions and exemption provisions
  • Review of procedures for technical data and assistance provided to foreign customers and suppliers
  • Review of control over Foreign Nationals including employees and subcontractors
  • Review of facility controls related to export compliance
  • Adherence to denial/debarment and other restricted parties list restrictions and required controls
  • Legal liability and responsibility for export transactions
  • Evaluation of service providers’ liability and responsibility


For more information please call Wilmarth & Associates at (860) 651-8544 to speak with one of our export consultants.

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