In a digital world with rapid ways of moving technology, controlling these transfers creates significant challenges as illustrated just last month in the $51 million settlement between a global aerospace and defense company and the US Department of State. The company committed close to 200 violations of the International Traffic in Arms Regulations (ITAR), most of which had occurred prior to 2020. These violations included Unauthorized exports of defense articles and technical data designated as Significant Military Equipment, which require non-transfer and use certificates.