The International Traffic in Arms Regulations (ITAR) represent one of the most stringent data protection frameworks in existence, governing how defense-related technical data can be handled, stored, and shared. As defense contractors and government agencies increasingly adopt cloud computing and hybrid work environments, traditional perimeter-based security models have proven inadequate for maintaining ITAR compliance while enabling operational efficiency.

GCC Moderate + XQ for ITAR

This implementation plan outlines how to leverage XQ's data sovereignty, geo-fencing, and role-based access controls to make Microsoft's Government Community Cloud (GCC Moderate) fully compliant with International Traffic in Arms Regulations (ITAR). The solution combines GCC Moderate's foundational security framework with XQ's advanced data protection capabilities to meet stringent ITAR requirements for defense-related technical data.

ITAR Regulations

ITAR regulations state that only the U.S. Persons can access items on the USML list unless otherwise authorized. ITAR exists to protect national security by preventing the military and defense-sensitive technical data from falling into the wrong hands. 

US Companies and Persons are prohibited from sharing ITAR technical data with foreign employees unless the release of the tech data is authorized.

The US government strongly recommends a compliance program that allows companies to ensure their compliance through documentation, tracking, monitoring, and auditing of shipments and transfers of Defense Articles. 

ITAR noncompliance can result in significant brand and reputation damage as well as heavy fines. In egregious cases, the company may even lose the privilege to export US goods or see the incarceration of those criminally involved.

Simplify ITAR Compliant Digital Workflows

  • True Privacy

    Prevent foreign entities, hackers, cyber-spies, and cloud vendors from accessing data or the keys protecting it with end-to-end encryption providing a unique key for every data object and customer-controlled keys.

  • Compliance

    Ensure only the intended recipients can read private consumer data. Meet ITAR compliance requirements with end-to-end encryption preventing unauthorized access to email, chat, support, forms, files and data in flight to the cloud and throughout its lifecycle.

  • Chain of Custody Visibility Across Environments

    Each interaction with your data, whether it is IoT, CCTV, email, or chat, is logged with who, where, and when the access was attempted. XQ provides a complete auditable trail.

  • Secure Sharing

    As private consumer data is shared across cloud environments and disparate networks, XQ keeps it secure with continuous protection and lets you govern access throughout the data lifecycle.

  • Ease of Use

    XQ is the easiest way to have digitally secure workflows and to extend that security to customers, vendors, and coworkers. XQ is layer on security and control that works where you already work.

  • Data Control

    Your data is most at risk after it leaves your possession. With XQ, you retain the ability to know what happens to your data, revoke access to it or reprovision it with granular access controls for Data Lifecycle Management.

  • On-Prem to Hybrid Cloud Data Transfer

    XQ Secure Gateway is the most secure, scalable, and simple to maintain offering for a completely auditable trail of your micro-segmented data wherever it travels. For the first time, connect GCP, AWS, and Azure seamlessly and compliantly for new powerful workflows.

    For the first time, GCP, AWS, and Azure can be connected seamlessly while maintaining compliance and allowing you to unlock new and powerful workflows.

  • Data Residency

    XQ uniquely geolocates each data access request. This also means XQ can geofence data. This is the only solution providing geofencing at the data level for ITAR compliance. With XQ data stays where it is supposed to and doesnt go where it shouldn’t. XQ’s unique geofencing capabilities support ITAR regulation 22 CFR 122.5 to prevent storage in Russia and other proscribed countries.

  • Key Management

    XQ offers flexible hosting, including SaaS, Private Cloud, and On-Prem deployments to give you complete data provenance. Host your XQ Key and Policy Node so unauthorized parties can never access your data.

The International Traffic in Arms Regulations (ITAR), codified under 22 CFR Parts 120-130,  mandate strict controls over the handling of defense-related technical data. 

This includes data sovereignty, encryption, access restrictions, and recordkeeping requirements, with explicit definitions of what constitutes a “release” of technical data (22 CFR § 120.56), exemptions for certain activities when using end-to-end encryption (22 CFR § 120.54), and detailed obligations for registrants to maintain records (22 CFR § 122.5).

Non-compliance can result in severe legal, financial, and national security consequences, including civil and criminal penalties under the Arms Export Control Act (22 U.S.C. 2778). Violations (22 CFR § 127.11) can result in severe legal, financial, and national security consequences, but the regulations also provide a pathway for voluntary disclosure (22 CFR § 127.12) to mitigate penalties when organizations self-report.

To address these requirements, organizations must implement comprehensive security architectures aligned with established frameworks, including NIST SP 800-53 Rev. 5, FedRAMP High, DoD Impact Level 5/6, and NIST SP 800-171. 

XQ's Zero Trust Data Security Platform provides an automated and modular approach to these challenges through external key management, granular access controls, real-time monitoring capabilities, and immutable recordkeeping, enabling organizations to achieve and maintain ITAR compliance while preserving operational efficiency.

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