IDR Doc Request

Question 1

1: Oversight and Infrastructure

Answer 1

• Papers of GTC
• Org charts (Corp and local)
• Copies of DDTC registrations for FLIR and M&A. (Corp)

Question 2

2: J&C

Answer 2

• Papers of J&C
• List all self-classifications of DA, TD, and DS
• List all ITAR-controlled DA reclassified to EAR
• List of commodity J requests submitted to DDTC

Question 3

3, Authorization Management

Answer 3

• Papers on management of export authorizations, including licenses, agreements, exemptions, reexports, retransfers, and brokering authorizations
• List of any brokering authorizations received (Corp only)
• List of any imports/exports authorized under ITAR exemption to include transaction number, description of transaction, ITAR exemption used and citation
• List of payments for fees, commissions, and political contributions subject to ITAR Part 130 and any Part 130 reports submitted to DDTC

Question 4

4, Automated Export Compliance System

Answer 4

• Papers related to the use and management of any automated export compliance systems at the site
• List of any automated export compliance systems in use at this site (e.g., OCR EASE, SAP GTS, etc.) and descriptions of export compliance areas each system covers

Question 5

5, Technical Data

Answer 5

• Papers related to the identification, tracking, and overall management of TD
• Papers related to access controls
• Data flow diagrams for how TD moves through the systems at this site
• Network diagrams
• Access allocations (Corp only)
• All TCPs
• List of all systems that are used to store structured and unstructured TD
• List of all systems used to transfer TD
• List of TD transfers that were initiated by this site
• List of all employees and foreign reps, including IT administrators and responsible for issuing IT access
• List of all systems that are NOT used to store TD, mentioning whether they’ve been disclosed to DDTC, volume of data, location, etc.

Question 6

6, Defense Articles

Answer 6

• Papers related to the management of DA

- List of ITAR-controlled end items produced by each business unit for the years 2016, 2017, 2018, and 2019

Question 7

7, Defense Services

Answer 7

• Papers related to the provision of DS

Question 8

8, Brokering

Answer 8

• Papers related to brokering

Question 9

9, Mergers & Acquisitions

Answer 9

• Papers related to M&A

- List of M&A transactions that FLIR or any of its subsidiaries have been involved in between 5 years

Question 10

10, Mechanisms to Identify, Track, and Disclose Possible Violations

Answer 10

• Papers related to identification and disclosure of potential violations and tracking of remedial measures and employee ITAR violation reporting mechanisms
• List of all voluntary disclosures submitted to DTCC between 5 years (Corp only)
• List of all disclosures closed and open referenced in CA Paragraph 23

Question 11

11, Training and Awareness

Answer 11

• Papers related to this site’s ITAR training program that were in place at any point over the last 5 years
• List of all ITAR trainings delivered at the site, to whom this training is delivered, topics covered in each training session, and how often this training is administered

Question 12

12, Screening

Answer 12

• Papers related to restricted party screening, including any procedures for escalation activities, that were in place at any point over the last 5 years
• Diagrams showing points during a transaction when restricted party screening takes place

Question 13

13, Recordkeeping

Answer 13

• Papers related to all phases of recordkeeping required, such as: document storage, retention, and destruction requirements over the last 5 years

Question 14

14, Physical Security

Answer 14

• Papers related to physical security, including visitor controls and international travel, that were in place at any point over the last 5 years
• Papers related to recording, tracking, and resolving physical security and IT incidents
• List of all foreign national employees who have physical access to ITAR at the site
• For U.S. sites: List of all employees hired or terminated for any reason between 5 years

Question 15

15, Audits and Self Assessments

Answer 15

• Papers related to audits (internal and external) and self-assessments that were in place at any point over the last 5 years
• List of audits and self- assessments that have taken place between 5 years