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Extract to table / tcp-requirements-memo.docx
tcp-requirements-memo.docx
Parties
Harkness LLP
Marlowe Asset Management Photonics Inc
Halcyon US Holdings Inc
Halcyon US Inc
Ironclad Defense Systems Inc
Whitmore Compliance Group LLC
Dates
November 17, 2023
June 1, 2023
December 31, 2022
June 5, 2023
June 10, 2023
February 14, 2009
July 14, 2023
July 21, 2023
August 4, 2023
August 18, 2023
Amounts
$1.42
$193
€14.8
€6.12
€1.37
$34.6
$287.4
$61.2
$52.3
$41.7
Obligations
The TCP must be integrated with VPI's existing export compliance program, which has been in place since VPI's initial DDTC registration in 2011 (Registration No
VPI's defense-related R&D activities, which involve ITAR-controlled technical data and classified programs, must remain ring-fenced within VPI's U
Our recommendation is that HSAG can comply with the TCP requirements while preserving the fundamental commercial value of the acquisition, but the company must be prepared to invest in robust compliance infrastructure and accept significant limitations on cross-border technology integration in the near term
The TCP must account for these contract-specific requirements in addition to the general ITAR and EAR obligations
M-24817 must be maintained continuously post-closing
4(a), VPI is required to notify DDTC of any change in its ownership or control within sixty (60) days of the effective date of the change