Does ITAR require that a company that manufactures defense articles” have all visitors US and Foreign checked on the BIS Denied Person List?
No. The ITAR does not require screening of all visitors, US and foreign. Since you did not tell us if you are in the US and you did not identify the origin and nature of your defense articles, we have to make this answer generic. The key issue is whether you will do an activity subject to ITAR restrictions, such as export, reexport, retransfer. If a visitor comes to your facility to change the light in the conference room just inside the front door of your facility and has no access to defense articles, it is unlikely that person will be doing something subject to ITAR restrictions. If you fail to screen, you probably are ok. If you plan to give the person ITAR-controlled technical data, it would be prudent to determine the person’s nationality and, depending on the circumstances, screen that person. In all cases, you could choose to reply upon luck instead of screening, but I do not recommend that. So, companies implement a wide range of visitor policies involving determining the nati
