ITAR Website Compliance Checklist: What Defense Manufacturers Need to Know

The International Traffic in Arms Regulations are not optional guidance. They are federal law, enforced by the Directorate of Defense Trade Controls (DDTC) under the State Department, and violations carry penalties up to $1.2 million per violation and 20 years in prison. Most defense manufacturers understand ITAR as it applies to shipping hardware, sharing technical drawings, and granting facility access. Far fewer understand how ITAR applies to their website.

Your website is a publication that is accessible to every person on the planet with an internet connection. That means every product page, every capability description, every image, and every downloadable document is effectively being exported to the entire world the moment you hit publish. If any of that content qualifies as technical data under ITAR, you have a compliance problem.

This is not theoretical. In 2023, DDTC issued consent agreements totaling over $40 million against companies whose ITAR violations included unauthorized disclosure of technical data through electronic means, including websites. The regulatory environment is getting stricter, not more lenient. Here is the checklist for getting your website right.

Hosting Location: US-Only Infrastructure

This is the first and most fundamental requirement. If your website handles any ITAR-controlled content, it must be hosted on servers physically located within the United States, operated by US persons. This is not a best practice. It is a legal requirement. ITAR treats the storage of technical data on a foreign server as an export to that country.

What this means in practice: you need to verify with your hosting provider that your servers are located in the continental United States. Major cloud providers like AWS, Azure, and Google Cloud all offer US-region hosting, but you must explicitly configure it. Default configurations may route your data through global infrastructure, and “auto-scaling” features may spin up instances in foreign data centers during traffic spikes.

“The storage of technical data on a server located outside the United States constitutes an export to the country in which the server is located.” — DDTC Advisory Opinion

Your hosting checklist:

• Confirm all web servers are physically located in the US
• Confirm your hosting provider is a US company employing US persons for server administration
• Verify that auto-scaling and load balancing do not route to foreign data centers
• Ensure database servers and file storage are also US-located
• Get written confirmation from your provider documenting server locations
• Review this annually — providers change infrastructure

CDN Considerations: The Hidden Export Risk

Content Delivery Networks present a unique ITAR challenge that most defense manufacturers overlook entirely. A CDN works by caching copies of your website content on servers distributed around the world. When a user in Tokyo requests your page, they get it from a server in Tokyo, not from your US-based origin server. That is great for performance. It is terrible for ITAR compliance if any of that cached content is controlled.

The solution is not necessarily to avoid CDNs entirely. A CDN with US-only edge locations is ITAR-compatible for controlled content. Several CDN providers offer US-only configurations. Alternatively, you can structure your site so that ITAR-controlled content is served exclusively from your US origin server while general marketing content uses the global CDN.

• Audit your CDN configuration for edge server locations
• Configure US-only edge locations for any ITAR-adjacent content
• Use separate CDN zones for public marketing vs. controlled content
• Verify that CDN cache purge operations do not replicate to foreign nodes
• Document your CDN configuration as part of your Technology Control Plan

Technical Data on Product Pages

This is where most defense manufacturers get into trouble. The line between “marketing a capability” and “disclosing technical data” is not always obvious, and the consequences of getting it wrong are severe.

Under ITAR, “technical data” includes any information required for the design, development, production, manufacture, assembly, operation, repair, testing, maintenance, or modification of defense articles. This includes blueprints, drawings, plans, instructions, and documentation. It also includes specific performance data, tolerances, materials specifications, and process parameters that would enable someone to reproduce a defense article.

What you can safely publish on product pages:

• General descriptions of product categories and applications
• Form, fit, and function information that is already in the public domain
• General capability statements (“we manufacture precision components for naval systems”)
• Industry certifications and quality standards you meet
• General material categories (“we work with titanium alloys, high-strength steels, and composites”)

What you cannot publish:

• Specific tolerances or dimensions of defense articles
• Performance specifications or test results for defense items
• Manufacturing process parameters for controlled items
• Technical drawings, even partial ones
• Specific material specifications tied to defense applications (e.g., alloy compositions for armor plate)
• Assembly instructions or maintenance procedures for defense articles

Export-Controlled Imagery

Photographs and images are treated as technical data under ITAR when they reveal technical details of defense articles. This is an area where manufacturers frequently make mistakes, often by posting shop floor photos that inadvertently show controlled items, tooling configurations, or manufacturing setups.

Before any image goes on your website, it needs to pass through the same ITAR review as your written content. The review should evaluate:

• Does the image reveal the design or configuration of a defense article?
• Does it show proprietary tooling, fixtures, or process setups for controlled items?
• Are there any drawings, specifications, or labeled components visible in the background?
• Does the image show test equipment configurations or measurement setups for controlled items?
• Could a foreign person use this image to gain insight into your manufacturing processes for defense articles?

Generic facility photos (exterior shots, clean rooms without visible product, general CNC machine images) are generally safe. Close-up photos of defense components on machines, assembly sequences, and test setups are not. When in doubt, use generic capability imagery rather than actual production photos.

Access Controls for Restricted Content

Some defense manufacturers need to share technical content through their website with authorized customers, but cannot make it publicly accessible. This requires a properly implemented access control system that goes well beyond a simple password gate.

An ITAR-compliant access control system for web-based content should include:

• Identity verification — every user accessing controlled content must be verified as a US person or properly licensed foreign person before access is granted
• Authentication — individual user accounts with strong passwords and multi-factor authentication, not shared logins
• Authorization — role-based access ensuring users only see content they are cleared to access
• Audit logging — complete records of who accessed what content and when, retained per your records retention policy
• Session management — automatic timeout, secure session tokens, no persistent login for controlled content
• Encryption — TLS 1.2 or higher for all data in transit, AES-256 for data at rest

A login page with a username and password field is not sufficient. You need a process for verifying citizenship or export license status before provisioning accounts, and that process needs to be documented as part of your compliance program.

Employee Information and OPSEC

Your team page can be an ITAR and operational security risk if not managed carefully. Publishing detailed biographical information about employees working on classified or controlled programs can create foreign targeting risks and may reveal information about your program involvement.

Guidelines for employee information on your website:

• Do not list employees by program or contract assignment
• Do not publish information about security clearance levels
• Limit biographical details to general professional background, not specific program history
• Do not publish organizational charts that reveal program structure
• Be cautious with job postings — requirements for specific clearances or program experience can reveal sensitive information
• Consider whether naming key personnel creates foreign intelligence collection opportunities

This does not mean you cannot have a team page. It means the content on that page should be reviewed through an OPSEC lens, not just an HR lens. Your facility security officer should be part of the review process for any employee-related web content.

The Complete ITAR Website Compliance Checklist

Use this checklist as a starting point for your ITAR website review. This is not a substitute for legal counsel, but it covers the critical areas that every defense manufacturer needs to evaluate.

Infrastructure

• All servers hosting ITAR content located in the US
• Hosting provider is a US company with US person administrators
• CDN configured for US-only edge locations (or controlled content excluded from CDN)
• TLS 1.2+ enforced on all pages
• Database and file storage US-located
• Backup storage US-located

Content Review

• All product descriptions reviewed by empowered official or export compliance officer
• No technical data (tolerances, specs, process parameters) for controlled items published
• All images reviewed for inadvertent disclosure of controlled information
• Case studies and past performance descriptions vetted for controlled content
• Employee information reviewed through OPSEC lens
• Job postings reviewed for inadvertent disclosure of program involvement

Access Controls (if sharing controlled content with authorized users)

• US person verification process documented and implemented
• Individual user accounts with MFA
• Role-based access control
• Complete audit logging
• Automatic session timeout
• Encryption in transit and at rest

Documentation and Process

• Written website content review procedure as part of your Technology Control Plan
• Designated reviewer with ITAR authority for all web content changes
• Content review documented and archived
• Annual website ITAR audit scheduled
• Hosting and CDN configuration documented and reviewed annually
• Incident response plan for inadvertent disclosure via website

Building ITAR Review Into Your Workflow

The biggest mistake defense manufacturers make with ITAR web compliance is treating it as a one-time audit rather than an ongoing process. Every time content is added or updated on your website, it needs to go through ITAR review. That means building the review into your content management workflow, not running it as an annual checkbox exercise.

Designate an empowered official or export compliance officer as the required approver for all website content changes. Create a simple review form that documents the content, the reviewer, the date, and the determination. Archive these reviews. If DDTC ever comes knocking, your documented review process is your first line of defense.

The companies that do this well treat their website the same way they treat their facility — as a controlled environment where information flow is managed, documented, and auditable. The companies that get into trouble are the ones where the marketing team publishes content without any compliance review, or where the review process exists on paper but is not actually followed.

ITAR compliance on your website is not optional, and it is not something you can delegate entirely to your web developer. It requires coordination between your marketing team, your export compliance function, your IT team, and your facility security officer. Get it right, and your website becomes a competitive asset that drives business while staying on the right side of federal law. Get it wrong, and you are one DDTC complaint away from a consent agreement that could end your company.