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NPR 2190.1C
Effective Date: September 08, 2017
Expiration Date: September 08, 2028
Printable Format (PDF)

Subject: NASA Export Control Program (Revalidated w/change 1)

Responsible Office: Office of International and Interagency Relations

| TOC | Preface | Chapter1 | Chapter2 | Chapter3 | Chapter4 | Chapter5 | Chapter6 | Chapter7 | Chapter8 | AppendixA | AppendixB | Change History | ALL |

Chapter 7. NASA Export Control Program Auditing

7.1 Purpose

The purpose of the NASA Export Control Program Biennial Audit is to ensure adequacy of the overall NASA Export Control Program and verify, via sampling, that required screening and licensing procedures are regularly followed and that required documents are maintained in compliance with the requirements of the EAR and the ITAR. This includes a review to ensure that appropriate records of all exports or transfers effected in support of NASA cooperative international programs are maintained in accordance with relevant regulations and NASA policies.

7.2 Auditor Selection

In accordance with NPD 2190.1, each Center Director shall designate a qualified individual as an ECA to biennially review the operation of the NASA Export Control Program at that Center for the previous two calendar years. The individual selected by the Center Director to serve as the Center ECA to perform the biennial audit should have received audit training and have previous auditing or inspection experience. At a minimum, the appointed auditors should have participated in an ISO 9000, International Standards Organization Certification internal auditor course or other comparable auditor training. Individuals without appropriate training should not be selected, except in exceptional circumstances. The HEA will transmit audit guidance to each ECA in early January. Therefore, Center Directors should make ECA appointments and inform the HEA in writing of such appointments, within 30 days of the appointment being made.

7.3 Auditor Duties and Responsibilities

7.3.1 Each Export Control Auditor (ECA) shall:

a. Understand the tasks required in performing the audit (e.g., conducting interviews, random sampling of international projects conducted at the NASA Center, reviewing policy, export and shipping documents, developing recommendations, and preparing the final report).

b. Have access to and a basic knowledge of the ITAR, EAR, and the NASA Export Control Program.

c. Be independent, motivated, and interested in performing the Export Control Auditor function.

d. Be available to complete the task in the time allotted.

e. Have complete access to the data and parties involved.

f. Audit the Center export control function, including all export control activities and major programs that engage in exports.

g. Determine if support contractors effecting NASA licenses, or exporting at NASA direction, comply with the relevant regulations and recordkeeping requirements.

h. Use the Audit Module and report template developed by the HEA as a tool in conducting the audit. Review export-related files, examining Center documents for effecting exports under NASA obtained export licenses; and examine a sampling of the documentation (e.g., AES/SEDs, and invoices) for other exports, paying particular attention to the items exported and the stated authority for the export.

i. Prepare an audit report using the report template provided by the HEA and coordinate it with the Center Director and CEA.

j. Maintain documentation supporting the audit performed.

7.4 Final Report

The CEA shall review the ECA's report and provide a written response, including concurrence, partial concurrence, or non-concurrence with any findings and recommendations. The CEA will forward the final report, together with comments, recommendations, and actions taken or pending to the HEA 30 days from receipt of the final report each year.

| TOC | Preface | Chapter1 | Chapter2 | Chapter3 | Chapter4 | Chapter5 | Chapter6 | Chapter7 | Chapter8 | AppendixA | AppendixB | Change History | ALL |
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This document does not bind the public, except as authorized by law or as incorporated into a contract. This document is uncontrolled when printed. Check the NASA Online Directives Information System (NODIS) Library to verify that this is the correct version before use: https://nodis3.gsfc.nasa.gov.