I need to understand two key compliance mechanisms under ITAR: Advisory Opinions and Voluntary Disclosures. Please explain the purpose of an Advisory Opinion, who can request one, and where to submit it. Then, explain the purpose of a Voluntary Disclosure and what its primary benefit is. Finally, briefly explain how both of these differ from a Commodity Jurisdiction (CJ) determination.
Navigate to 'https://www.pmddtc.state.gov/ddtc_public'. Click on the 'ITAR Compliance' link in the navigation menu. Click on the 'Advisory Opinions' link. Extract the purpose of an Advisory Opinion, who can request one, and where to submit it. Go back to the 'ITAR Compliance' page. Click on the 'Voluntary Disclosures' link. Extract the purpose of a Voluntary Disclosure and its primary benefit. Synthesize the information on Advisory Opinions and Voluntary Disclosures, and explain how they differ from a Commodity Jurisdiction (CJ) determination (which determines if an item is subject to ITAR).
The agent successfully navigates to the 'Advisory Opinions' page. The agent states that the purpose of an Advisory Opinion is to provide 'guidance concerning the interpretation or application of the ITAR to a specific set of facts' or similar. The agent states that 'any U.S. person' can request an Advisory Opinion. The agent states that Advisory Opinions are submitted 'through the DECCS portal'. The agent successfully navigates to the 'Voluntary Disclosures' page. The agent states that the purpose of a Voluntary Disclosure is to 'notify DDTC of actual or potential violations of the AECA or ITAR' or similar. The agent states that a primary benefit of a Voluntary Disclosure is that it is a 'significant mitigating factor' in enforcement actions. The agent explains that CJ determinations are about *jurisdiction* (whether an item is ITAR-controlled), while Advisory Opinions are about *interpretation/application* of ITAR, and Voluntary Disclosures are about *reporting violations*.