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International Traffic in Arms Regulations (ITAR)

ITAR overview

The US Department of State is responsible for managing the export and temporary import of defense articles (meaning any item or technical data designated under the US Munitions List, as described in Title 22 CFR 121.1) that are governed by the Arms Export Control Act (Title 22 USC 2778) and the International Traffic in Arms Regulations (ITAR) (Title 22 CFR 120-130). The Directorate for Defense Trade Controls (DDTC) is responsible for managing entities governed under these programs.

Microsoft and ITAR

Microsoft provides certain cloud services or service features that can support customers with ITAR obligations. While there is no compliance certification for the ITAR, Microsoft operates and has designed in-scope services to be capable of supporting a customer's ITAR obligations and compliance program.

Microsoft Azure Government and Microsoft Office 365 U.S. Government for Defense provide support for customers with data subject to the ITAR through additional contractual commitments to customers regarding the location of stored data, and limitations on the ability to access such data to US persons. Microsoft provides these assurances for the infrastructure and operational components of these government cloud services, but customers are ultimately responsible for the protection and architecture of their applications within their environments.

Customers must sign additional agreements formally notifying Microsoft of their intention to store ITAR-controlled data, so that Microsoft may comply with responsibilities both to our customers and to the US government.

The ITAR has specific obligations to report violations, which can provide certain risk mitigation benefits. The Microsoft Enterprise Agreement Amendment enables Microsoft and the customer to work together in reporting such violations.

Customers seeking to host ITAR-regulated data should work with their Microsoft account and licensing teams to learn more, obtain proper agreements, and access relevant system architecture information.

Microsoft in-scope cloud platforms & services

  • Azure
  • Azure Government
  • Azure Government Secret
  • Office 365 U.S. Government - High, Office 365 Defense

Azure, Dynamics 365, and ITAR

For more information about Azure, Dynamics 365, and other online services compliance, see the Azure ITAR offering.

Office 365 and ITAR

Office 365 environments

Microsoft Office 365 is a multi-tenant hyperscale cloud platform and an integrated experience of apps and services available to customers in several regions worldwide. Most Office 365 services enable customers to specify the region where their customer data is located. Microsoft may replicate customer data to other regions within the same geographic area (for example, the United States) for data resiliency, but Microsoft will not replicate customer data outside the chosen geographic area.

This section covers the following Office 365 environments:

  • Client software (Client): commercial client software running on customer devices.
  • Office 365 (Commercial): the commercial public Office 365 cloud service available globally.
  • Office 365 Government Community Cloud (GCC): the Office 365 GCC cloud service is available for United States Federal, State, Local, and Tribal governments, and contractors holding or processing data on behalf of the US Government.
  • Office 365 Government Community Cloud - High (GCC High): the Office 365 GCC High cloud service is designed according to Department of Defense (DoD) Security Requirements Guidelines Level 4 controls and supports strictly regulated federal and defense information. This environment is used by federal agencies, the Defense Industrial Base (DIBs), and government contractors.
  • Office 365 DoD (DoD): the Office 365 DoD cloud service is designed according to DoD Security Requirements Guidelines Level 5 controls and supports strict federal and defense regulations. This environment is for the exclusive use by the US Department of Defense.

Use this section to help meet your compliance obligations across regulated industries and global markets. To find out which services are available in which regions, see the International availability information and the Where your Microsoft 365 customer data is stored article. For more information about Office 365 Government cloud environment, see the Office 365 Government Cloud article.

Your organization is wholly responsible for ensuring compliance with all applicable laws and regulations. Information provided in this section does not constitute legal advice and you should consult legal advisors for any questions regarding regulatory compliance for your organization.

Office 365 applicability and in-scope services

Use the following table to determine applicability for your Office 365 services and subscription:

Applicability In-scope services
GCC High Activity Feed Service, Bing Services, Bookings, Exchange Online, Exchange Online Protection, Intelligent Services, Microsoft Teams, Office 365 Customer Portal, Office Online, Office Service Infrastructure, Office Usage Reports, OneDrive for Business, People Card, SharePoint Online, Skype for Business, Windows Ink
DoD Activity Feed Service, Bing Services, Bookings, Exchange Online Protection, Exchange Online, Intelligent Services, Microsoft Teams, Office 365 Customer Portal, Office Online, Office Service Infrastructure, Office Usage Reports, OneDrive for Business, People Card, SharePoint Online, Skype for Business, Windows Ink

Frequently asked questions

Where can I request Office 365 compliance information for ITAR?

Contact your Microsoft Office 365 account representative.

Resources