Creating ITAR-compliant Technology Control Plans manually requires extensive research across DDTC regulations, USML classifications, and 22 CFR provisions—often taking 12+ hours of attorney time. Compliance teams must cross-reference multiple regulatory sources, verify classifications, and ensure every section meets strict DDTC requirements while maintaining current best practices.
Defense contractors face overwhelming complexity drafting ITAR-compliant Technology Control Plans that satisfy DDTC requirements while addressing organization-specific operations. Manual TCP development requires 40+ hours of specialized legal and regulatory expertise, extensive document review, and detailed knowledge of 22 CFR Parts 120-130, creating compliance delays and potential gaps.
CaseMark automates comprehensive Technology Control Plan generation by analyzing your contracts, USML classifications, and organizational structure to produce DDTC-ready compliance documentation. Our AI extracts critical details from your documents and applies expert regulatory knowledge to create customized TCPs covering access controls, deemed export prevention, training requirements, and incident response protocols in minutes.
This workflow is applicable across multiple practice areas and use cases
Defense contractors with government contracts must maintain ITAR compliance and TCPs as mandatory requirements for handling controlled technical data under federal acquisition regulations.
Government contracts attorneys regularly advise clients on ITAR compliance obligations, and TCPs are essential deliverables for defense contractors to maintain contract eligibility and avoid debarment.
M&A due diligence for aerospace and defense companies requires reviewing existing TCPs and export control compliance to assess regulatory risk and transaction structure implications.
ITAR compliance status and TCP adequacy are critical deal issues in defense sector M&A, affecting valuation, representations/warranties, and potential CFIUS review requirements.
Technology licensing agreements involving defense-related IP require TCPs to ensure controlled technical data transfers comply with ITAR export restrictions and licensing requirements.
IP licensing attorneys must structure agreements with ITAR-compliant technology transfer mechanisms, making TCPs essential for lawful cross-border or third-party licensing of defense technologies.
Cybersecurity frameworks for defense contractors must integrate ITAR technical data protection requirements from TCPs with broader data security and incident response protocols.
Data privacy attorneys working with defense sector clients need to align ITAR-mandated access controls and data handling procedures with CMMC, NIST, and other cybersecurity compliance frameworks.
A Technology Control Plan (TCP) is a comprehensive compliance framework that establishes procedures for preventing unauthorized access to or disclosure of defense articles and technical data under ITAR regulations (22 CFR Parts 120-130). Defense contractors handling USML-controlled items must implement TCPs to satisfy DDTC requirements, prevent deemed exports to foreign persons, and demonstrate due diligence in export control compliance. The TCP serves as the organization's primary defense against civil penalties up to $1,184,165 per violation and potential criminal prosecution.
CaseMark analyzes your uploaded documents including DDTC registration, defense contracts, USML classifications, and organizational structure to extract specific details about your controlled items, programs, facilities, and personnel. The AI applies expert knowledge of ITAR regulations to generate a comprehensive TCP tailored to your applicable USML categories, deemed export risks, and operational requirements. The output includes all required sections with proper regulatory citations, organization-specific procedures, and DDTC-ready formatting suitable for implementation and regulatory submission.
CaseMark generates a complete TCP covering regulatory foundation and executive summary, scope definition with specific programs and facilities, identification and classification procedures for defense articles and technical data, access control frameworks with U.S. person verification, secure handling and transmission protocols, personnel training requirements, monitoring and auditing procedures, incident response and violation management, and TCP governance with continuous improvement processes. Each section includes detailed procedures, regulatory citations, and organization-specific implementation guidance based on your uploaded documents.
Yes, CaseMark produces DDTC-ready Technology Control Plans with proper legal citations, regulatory references in Bluebook format, and comprehensive coverage of 22 CFR requirements. The output is formatted professionally with table of contents, numbered sections, and signature blocks suitable for executive approval and regulatory submission. While the TCP should be reviewed by your legal counsel and empowered official before finalization, it provides a complete, audit-ready framework that demonstrates your organization's commitment to ITAR compliance and can be presented during DDTC inspections or government audits.
The generated TCP includes comprehensive deemed export prevention procedures under 22 CFR §120.54, establishing protocols for U.S. person verification, physical and electronic access controls, visitor management, workspace sanitization, and restrictions on disclosure to foreign persons. It provides specific guidance on screening personnel for U.S. person status, implementing badge systems and network segmentation, obtaining Technical Assistance Agreements or DSP-5 licenses when foreign person access is necessary, and preventing visual or oral exchanges that could constitute unauthorized exports. The plan addresses your specific workforce composition and facility operations based on uploaded documentation.