Defence Industry Regulatory Control Tool Enablement

Our customer is a key defence industry supplier in the UK and in the Kingdom of Saudi Arabia (KSA). To maintain their licence to trade they must comply with national and international Export Control regulations. Export controls protect national security and foreign policy ensuring that military or dual use exports are kept out of the hands of unauthorised users.  

The US Department of State (DoS) audited their handling of export control materials and identified a defined number of ITAR and AECA violations. In May 2011, they entered into a Consent Agreement with the US Department of State to address these violations including a substantial fine and plans to implement solutions to prevent a reoccurrence.  

Our customer established a strategic programme in the UK to implement technology to support compliance with Export Control regulations. They decided to adopt three of these solutions to provide a similar level of support for Export Control regulatory compliance in KSA; these solutions would enable business change to heighten awareness of controlled materials handling across the company.  

In July 2018, the consent agreement with the DoS was closed on the basis delivery plans were in place and in flight. They started a planned nine-month programme to deploy the three common solutions in 2017. By January 2022, one of the three common solutions had been made live but had not completed its transition to Business-as-Usual, so the project was still running.  

Until the solutions had been implemented and embedded in daily operations, the business remained at heightened risk of an Export Control breach that was not identified and managed which would lead to reputation and financial damage which could threaten their licence to trade.  

To achieve completion of the common solutions implementation and deliver the business change, they decided to make an exception in a tightened financial climate to use a Project One Programme Manager because they could bring knowledge of the solutions and experience in the KSA environment.  

The key challenges to be addressed included: 

• There had been multiple extensions to the implementation timetable which meant the validity of the requirements, designs and plans had to be re-examined to ensure they were still the right approach for the environment.  
• Many of the stakeholders had changed so new stakeholders had to be identified, engaged and their commitment to the solutions secured.   
• Covid-19 restrictions were still in place in the workplace for the first six months of this engagement. Many staff were still working remotely, which inhibited the ability to communicate in an environment where face-to-face engagement is an acknowledged key success factor.  
• There was significant understaffing in the KSA IM&T environment, this meant the Project One PM had to cover a much wider set of project delivery roles than normally expected e.g. Business Analyst, Service Designer, Implementation Manager, Service transition Lead. 
• Due to a long-term decline in staffing levels caused by local business competition for skilled resources, knowledge of the business operations was reduced. This made defining the business requirements for technical processes a significant challenge; multiple revisits and testing cycles were needed to identify the actual operational behaviour.   

Project One was in a unique position to be able to drive a successful completion of the EC automated solution:  

• Project One had been engaged in the Export Control programme implementation  
• The selected PM had experience and trusted relationships with the supplier and the customer which provided a bridge between both parties which was fundamental to achieve the pace of delivery.  
• The PM continued to provide a relationship bridge even after the end of the delivery providing advice and guidance to KSA and UK teams on engagement and tool operation.  

The organisations now has tools to help it manage the export control and security status of its digital information. By using these tools the benefit that has been enabled to realise is improved protection against intentional and unintentional data loss.  

They now have data insights on cross company document handling making controllers aware of any inappropriate security and Export Control marking, to help avoid MoD or DoD regulatory non-compliance; once a document is declared as export controlled un-declaring it can be problematic even if it definitely isn’t export controlled. 

As a result of the communications and training provided during the roll out, employees, including the security and legal teams, are much more aware of the meanings and implications of the company, security and Export Control marking regimes, heightening the digital security of the whole business. 

There is ongoing training and communications on marking regimes and they use the output from their tools to bring this to life and to focus on problem areas.  

They also have easy visibility of the Export Control status of its purchased materials and automated Export Control declaration renewals. This allows staff to handle and management materials correctly ensuring compliance with DoD and MoD regulations.  

All these changes have strengthened the business security and control on regulated materials and enabled it to avoid audit failure and future fines.  

The Project One value add:

• Solutions implementation was limited and slow before Project One joined. 
• Project One resource covered roles through the whole delivery lifecycle to a high level of quality due to breadth of experience. 
• Project One delivered the solutions on time and under budget, a unique achievement in the environment.  

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If you are struggling to understand your transformation investment, the state of your transformation initiatives or simply struggling to put the right processes in place to prioritise your portfolio investment then come and talk to Project One.

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