ITAR Compliance

Effective Date: July 23, 2025

Lystrup Maher LLC is fully committed to complying with all applicable U.S. export control laws, including the International Traffic in Arms Regulations (ITAR) (22 C.F.R. §§ 120-130). We maintain a robust, proactive export compliance program to protect sensitive defense-related technology and technical data from unauthorized access by foreign persons. The program is managed under the supervision of a designated Empowered Official who is responsible for adherence to these regulations.

Lystrup Maher LLC maintains pre-existing, hardened protocols for handling controlled information. For each applicable project, we will work with the client to develop and implement a specific Technology Control Plan (TCP) before any ITAR-controlled technical data or defense articles are accepted or handled.

Our procedures include:

• Identification: Proactively identifying and marking all data and hardware subject to ITAR.
• Access Control: Implementing strict physical and logical access controls to ensure only authorized U.S. persons access ITAR data.
• Secure Systems: Utilizing secure, encrypted, and air-gapped computer systems for all ITAR-related work. All deliverables, reports, and documentation are created using offline Microsoft Word and other offline tools; cloud-based platforms such as Google Drive are explicitly prohibited for storing or processing ITAR-controlled data.
• Employee Screening and Training: Ensuring all personnel with potential access are U.S. persons and receive regular training on their ITAR responsibilities.
• Secure Storage and Transmission: Storing all ITAR data in secure, access-controlled environments and using end-to-end encrypted channels for any authorized transmission.

Lystrup Maher LLC will not export, re-export, or transfer any ITAR-controlled item to any foreign person or destination without first obtaining the required export license or authorization from the U.S. Department of State's Directorate of Defense Trade Controls (DDTC).

We are committed to transparent and compliant operations. Any suspected violation of ITAR or this policy will be immediately investigated by our Empowered Official, and any necessary disclosures will be made to the appropriate government authorities.

For questions regarding our ITAR compliance program, please contact our designated compliance officer at privacy@lystrupmaher.com.