Not so long ago, I helped develop a compliance program for a well-known arms contractor whose business was selling communications systems for commercial and military aircraft in the United States. Their main problem was not the licensing of their products, but rather the fact that their distribution and marketing services were in the United States while their research and development facilities were in the United Kingdom. When I spoke to the company`s CEO, he looked me dead in the eye and said, “If we have to wait 60 days before sending an email to [foreign R&D partners], we have to close.” Description of an ITAR Part 120 Technical Assistance Agreement:. .