ITAR Compliance Readiness Checklist: What Your Tech Stack Must Be Able to Prove

Even though ITAR has no formal certification body, organizations are still expected to self-audit, maintain rigorous internal controls, and be prepared to demonstrate compliance during:

• Government inquiries
• Voluntary disclosures
• Internal audits
• External security assessments
• Legal or regulatory reviews

In all of these scenarios, your tech stack must do more than enforce policies. 

It must prove them.

It must demonstrate, with evidence, who accessed what data, when and where, and under what conditions.

This checklist breaks down the capabilities your systems need to demonstrate ITAR readiness with confidence.

What an ITAR Review Is Looking for in Your Tech Stack

1. Access Control Enforcement

You must be able to show:

• Who can access export-controlled technical data
• When and how access was granted
• Whether least-privilege and segregation-of-duties principles are enforced
• Whether contextual conditions (device, location, project) are checked

Verbal explanations and written policies are not enough; assessors want proof from your systems.

2. Encryption Requirements: Beyond “In Transit and At-Rest”

This is where many organizations fall short.

ITAR’s cloud rule requires end-to-end encryption (E2EE) for controlled data stored or processed in cloud environments.

That means:

• Not just in-transit
• Not just at-rest
• But encrypted from creation to use  - and the means of decryption must never be provided to a third party (e.g. passing your key to a cloud provider)

Additionally, ITAR states that encryption must meet or exceed FIPS 140-3 standards.

Using FIPS-validated modules strengthens your compliance posture and provides defensible evidence during reviews.

This is a critical area where modern tools either pass or fail decisively.

3. Audit Trails That Hold Up Under Scrutiny

You should be able to produce logs showing:

• Every access event to controlled files
• User ID, time, location, device, and action taken
• Immutable history with no gaps
• Clear evidence that policy violations trigger alerts and actions

Logs must be formatted in a way that regulators or investigators can interpret without guesswork.

4. Real-Time Alerts & Incident Detection

Your systems need to proactively detect and respond to:

• Unauthorized access attempts
• Unusual download or file-movement patterns
• Users attempting to access data outside approved contexts
• Suspicious or anomalous behavior

This proves you’re not just documenting controls. You’re actively enforcing them.

5. Secure Key Management & Rotation

A common ITAR readiness checkpoint:

• Who generates encryption keys?
• Who can access them?
• How often are they rotated?
• Are these processes logged?

Weak key management undermines all other controls.

Which Tools Demonstrate ITAR Readiness?

File-Level Encryption + E2EE

• Protects files regardless of their storage location
• Meets ITAR’s cloud encryption requirement for end-to-end protection
• Ensures data is only decrypted by authorized individuals

RBAC + Dynamic Conditional Access Policies

• Restrict access based on user, project, device, location, or time
• Demonstrates least privilege with real evidence

Comprehensive Logging + Immutable Audit Trails

• Full visibility into access events
• Exportable for assessors, regulators, and legal teams
• Essential for voluntary disclosures or investigations

Real-Time Alerting & Behavioral Monitoring

• Proves proactive control, not passive compliance
• Enables responsive, well-documented incident handling

Secure Key Management

• Demonstrates strong cryptographic governance
• Supports FIPS 140-3-aligned practices

How Theodosiana Strengthens Your ITAR Compliance Posture

Theodosiana is designed for organizations that need defensible, provable ITAR compliance, without slowing teams down.

🔒 End-to-end, file-level encryption

Protects controlled data at-rest, in-transit, and in-use. Meets ITAR’s cloud-based E2EE requirement.

✅ FIPS 140-3 validated encryption modules

Cryptography that meets and exceeds the standards referenced by ITAR.

🏛 FedRAMP-authorized processing environment

All data processing takes place within a secure, federally compliant environment.

📊 Immutable audit trails & real-time alerts

Evidence-ready logs for regulators, assessors, and internal review.

🧩 Integration with your existing identity stack

Use your current IAM tools while adding stronger controls and file-level visibility.

Together, these capabilities demonstrate that export-controlled data is locked, logged, and only accessible under compliant conditions.

Your ITAR Compliance Readiness Checklist