With Susan Kovarovics
On July 12, 2005, the Department of Defense ("DOD") proposed an amendment to the Defense Federal Acquisition Regulation Supplement ("DFARS") which would require parties subject to the DFARS to implement an Internal Controls Programs ("ICP") to ensure their compliance with the International Traffic In Arms Regulations ("ITAR" 22 CFR 120-130) and the Export Administration Regulations ("EAR" 15 CFR 730-774).