FR EA

Extract to table

Pull the structured facts out of a document: parties, dates, amounts, obligations.

Extract to table / itar-export-compliance-analysis-memo.docx
itar-export-compliance-analysis-memo.docx · 1019-00003

Parties

Whitmore Aerospace LLC
Halcyon Defense Systems Inc
Meridian Semiconductor GmbH
Rating Whitmore Aerospace LLC
Pinnacle Precision Manufacturing Inc
Rating Halcyon Defense Systems Inc
See Westvale Partners LLC
Meridian Relationship Meridian Semiconductor GmbH

Dates

November 10, 2023
September 15, 2023
September 25, 2023
November 17, 2023
November 9, 2023
November 3, 2023
May 12, 2023
September 22, 2023
March 14, 2023
April 28, 2023

Amounts

$387.5
$92.4
$17.4
$343.8
$361.2
$1,282,564

Obligations

CDRL A015 specified that the ITAR compliance plan submitted by each offeror must address the following eight elements: (i) Identification of ITAR-controlled articles and technical data
308, the SSA is required to document the rationale for any tradeoffs made among cost or price and non-cost factors, including the reasons for the selection decision
However, this latitude is not unlimited, and the SSA must still explain why the specific non-price advantages of the higher-priced offeror are worth the specific price premium being paid
Whether the Meridian transaction is governed by the ITAR or the EAR, Halcyon must navigate a regulatory framework that imposes licensing requirements, compliance monitoring obligations, record-keeping duties, and penalties for non-compliance
If ITAR-controlled technical data must be shared with Meridian for wafer fabrication — a scenario that is highly probable given the custom nature of the GaAs sensor wafers and the need for Meridian to understand the performance specifications of the end-item defense article — Halcyon must obtain and maintain a TAA or MLA from the Directorate of Defense Trade Controls (DDTC)
Halcyon must ensure that its TAA or other authorization covers deemed exports to Meridian personnel and must implement access controls to prevent unauthorized disclosure