Consent Agreement Monitoring

Under an ITAR Consent Agreement, the role of the Special Compliance Officer (SCO) is crucial in ensuring the effective implementation and ongoing compliance with the terms of the consent agreement. The SCO is appointed by the company or person subject to the consent agreement and serves as an independent third party in consultation with the U.S. Department of State. The consent agreement describes the SCO’s authorities, term, and responsibilities, including that their appointment is subject to the written approval of the U.S. Department of State, Directorate of Defense Trade Controls (DDTC), Office of Defense Trade Controls Compliance (DTCC), and that the company must empower the SCO with a written delegation of authority and a statement of work approved by DTCC to permit the SCO to monitor, oversee, and promote the company’s compliance with the consent agreement, the Arms Export Control Act, and the ITAR. While serving in DTCC, Dave Greenlees managed four consent agreements and gained valuable insights into the intricacies of the consent agreement process. He developed strong relationships with key stakeholders in the regulatory field, such as DDTC officials, SCOs, corporate leadership, legal experts, and industry professionals. This experience provides him with valuable insights, industry best practices, and the know-how to most effectively serve in this important role. His experience as a regulator managing consent agreements uniquely positions him as a valuable asset to potential clients seeking an impactful SCO.