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ITAR-compliant file transfer for primes and suppliers

Published 2026-10-22

A full CAD model and its drawing package rarely fit in an email, so most shops end up with an SFTP server, a prime's portal or a transfer service. The rules care about three things on that path. The connection must be encrypted SC.L2-3.13.8 with FIPS-validated cryptography SC.L2-3.13.11. Any cloud that holds the files on the way must meet the FedRAMP Moderate baseline or its equivalent under DFARS 252.204-7012. And under ITAR, sending technical data abroad or letting a foreign person open it is an export, whatever the protocol.

No transfer product is "ITAR certified", because the ITAR certifies no product. We read 4 services that give primes and suppliers an SFTP endpoint, against both rules. If the files are for people to open and edit rather than for systems to drop, read the ITAR-compliant file sharing comparison instead.

Status as of 2026-10-23
In force today
DFARS 252.204-7012 still applies: NIST SP 800-171 Rev 2 on systems that hold covered defense information, cyber incidents reported to DoD within 72 hours, and FedRAMP Moderate or equivalent for any cloud that holds it. DFARS 252.204-7012(b)(2), (c)
Suspended
Phase 2, due in November 2026, is suspended for every contractor, whatever its size: contracts are not adding the third-party Level 2 (C3PAO) or Level 3 (DIBCAC) requirements. DoW CIO memo of 2026-07-13, applied by Class Deviation 2026-O0025 Rev 3
Not yet known
The outcome of the CMMC Reform Task Force review is not confirmed as of 2026-10-23: no report or rule change has been published. Federal Register search, 2026-10-23

What still applies while Phase 2 is suspended

Best overall

Sharetru Federal

Listed by name at Moderate, run by US-citizen staff, and built to replace an office SFTP server: SSH-key service accounts, five protocols and a log you can export, while your own scheduler keeps the jobs.

Read the Sharetru Federal notes
Best for many channels

Kiteworks Federal Cloud

Certified at Moderate in its own right, with a hosted MFT engine that schedules, polls and triggers transfers, and SFTP, email and sharing under one log.

Read the Kiteworks Federal Cloud notes
Best for a GovCloud shop

AWS Transfer Family (GovCloud)

Inside a FedRAMP High package and operated by US citizens, but it is a building block: you choose the FIPS policy, wire the logs and own the setup.

Read the AWS Transfer Family (GovCloud) notes
Fig. 01
Mezzotint of a closed plywood crate on a pallet by a loading door
A crate is nailed shut before it leaves the dock. A file on an SFTP server is not, unless you seal it first.

Three places a transfer can run

Before comparing products, decide whose system the file passes through. The rules ask different things of each, and the answer is often a mix: you push inspection reports to a prime's server and take drawings from suppliers on your own.

Three places a transfer runs
What the rules ask of a transfer service, your own server and a prime's system
QuestionA transfer serviceYour own serverThe prime's portal or server
Where the files sitOn the provider's servers, in its cloudOn a machine you run, in the office or your own cloud accountOn the prime's system; on your laptop or job server once fetched
The FedRAMP questionYes: FedRAMP Moderate or equivalent, under DFARS 7012Not for the software itself; for any cloud it runs inThe prime's to answer, not yours
Who patches the serverThe providerYou, on your own scheduleThe prime
What goes in your SSPThe Marketplace package ID and the provider's customer responsibility matrixThe server as a CUI asset: inventory, network diagram, all 110 requirementsThe connection as an external system (3.1.20), and the machine that fetches
Usually fitsMany partners, no IT staff, an old server to retireA shop with an IT provider who already runs its CUI systemsA prime that tells you how it wants to receive

Running your own server keeps the FedRAMP question away, but not the work. A machine that stores or transmits CUI is a CUI asset under 32 CFR 170.19, assessed against every Level 2 requirement, and flaw remediation SI.L2-3.14.1 is a 5-point item on your score. The CMMC scoping worksheet helps you put the server, the job box and the laptops that fetch files on the right side of the line.

Map your exchanges

List every partner you swap files with and how. Each row shows what that exchange puts on you, with the rule behind it. Print the result: it is the first draft of the data-flow part of your system security plan.

Exchange register

Edit any row. Pre-filled with a realistic example shop.

Example only
exchanges
4
exchanges
job account to name
1
job account to name
cloud to prove
1
cloud to prove
exchange to check
1
exchange to check
  1. Exchange 01
    • Their system answers the cloud question. Yours: the account you sign in with and the machine the file lands on. 3.1.20
    • The person signs in with multifactor authentication. 3.5.3
  2. Exchange 02
    • Their server answers the cloud question. Yours: the job box that pushes, its key and the record of what it sent. 3.1.20; 3.3.1
    • Give the job its own account and key, so every file in the log traces to one job, not a shared login. 3.5.2; 3.3.2
  3. Exchange 03
    • The service must be FedRAMP Moderate or equivalent; put its package ID and responsibility matrix in your SSP. DFARS 252.204-7012(b)(2)(ii)(D); 32 CFR 170.16(c)(2)
    • The person signs in with multifactor authentication. 3.5.3
    • If the files are covered defense information, the subcontract carries DFARS 7012 too. DFARS 252.204-7012(m)
  4. Exchange 04
    • CheckAn attachment needs encryption in transit with FIPS-validated cryptography, and its trail lives in mailboxes, not in one transfer log. 3.13.8; 3.13.11
    • The person signs in with multifactor authentication. 3.5.3
    • If the files are covered defense information, the subcontract carries DFARS 7012 too. DFARS 252.204-7012(m)
    • CheckAsk who will open the files. A release to a foreign person in the US is an export too. 22 CFR 120.50(b)
  • This register is the start of your record of where CUI flows. If you are registered with DDTC, records of technical data sent are kept for five years from the transaction or the license's expiry. 3.1.3; 22 CFR 122.5(a)

Transfer services against the rule

Rows inside the boundary are what ITAR and DFARS 7012 ask of a service that holds controlled files on the way. Rows outside it are what your scripts and partners will need. Every word was read on the vendor's own pages or the FedRAMP Marketplace on 2026-10-22; vendors that also appear in our file sharing comparison carry the same words there.

4 vendors compared
ITAR-compliant file transfer services compared against the rule
What the rule asksSharetru FederalKiteworks Federal CloudAWS Transfer Family (GovCloud)Progress MOVEit Cloud
Inside the boundary
FedRAMP Moderate or equivalent, for a cloud that holds CUIDFARS 252.204-7012(b)(2)(ii)(D)Certified host (Moderate)Certified (Moderate)Certified (High)Not in Marketplace
FIPS-validated encryption in transit and at rest3.13.11, with 3.13.8 and 3.13.16FIPS 140-3 statedFIPS 140-3 statedFIPS policy, opt-inFIPS 140-2 stated
Administered and supported only by US persons22 CFR 120.50(b), 120.56(a)US citizens statedUS citizens statedUS citizens statedNot stated
Supports 72-hour incident reporting and 90-day image retentionDFARS 252.204-7012(c)–(g)StatedNot stated72 h not statedNot stated
Audit logs you can export3.3.1, 3.3.2Export statedExport statedLogs in your accountExport not stated
Outside the boundary
SFTP or FTPS endpoint for partner systemsStatedStatedStatedStated
Scheduled or event-driven transfersYour schedulerStatedStatedAdd-on stated
API for your own softwareStatedStatedStatedStated
Branded portal for suppliersYour subdomainNot statedStatedStated

What the words mean

MeetsCertified host (Moderate)FIPS 140-3 statedUS citizens statedStatedExport statedCertified (Moderate)Certified (High)Logs in your accountFIPS 140-2 stated
The vendor's own documentation, or the official register, says so. Read on the date shown.
PartialYour schedulerYour subdomainFIPS policy, opt-in72 h not statedExport not statedAdd-on stated
Covers part of the requirement, or the vendor claims it and the official register does not show it.
Check with vendorNot statedNot in Marketplace
Not stated in what we read. Ask the vendor in writing before you rely on it.

SFTP protects the pipe, not the file

SFTP and FTPS encrypt the connection. When the file lands, the server software can read it, whatever it does to protect its disks. That matters for ITAR, because the rule's encryption carve-out asks for more than a secure connection.

Where the file can be read
Where a drawing is readable on two transfer paths
PathYour machineOn the wireOn the serverAt the partner
SFTP or FTPS aloneReadableEncryptedReadable to the serviceReadable
File encrypted first, then sentReadableEncryptedEncryptedReadable

End to end means the file is never decrypted between your security boundary and the recipient's, and no third party, the transfer service included, holds the means to decrypt it. A plain SFTP drop does not meet that test. So a hosted endpoint has to keep files in the United States with only US persons able to reach them, the same test the file sharing comparison applies to cloud storage. Encrypting the file before it leaves, with FIPS-validated modules and keys only you and the partner hold, is how a transfer can reach the carve-out instead. Watch the tooling: Sharetru leaves PGP on your side, while AWS offers a workflow that decrypts PGP files as they arrive, which puts the readable copy back on the server.

No protocol settles the other two export questions. Sending a drawing to a supplier outside the US is an export that needs DDTC authorization first. Letting a foreign person in the US open it is an export too, to every country of their citizenship or permanent residency. And if the file is covered defense information going to a supplier, DFARS 7012(m) puts the clause in their subcontract. The ITAR compliance checklist covers the export side; the clause itself is in DFARS 252.204-7012 explained.

Scripts need names too

Much of the traffic on a transfer server is not people: the ERP pushing an advance ship notice, a quality job dropping inspection reports, a supplier's system collecting a purchase order. The rule counts those processes as users AC.L2-3.1.1, and every action has to trace back to one of them AU.L2-3.3.2. A shared login breaks that on the first night.

Shared login

Example only

Time
2026-10-21 23:00:04
Account
ftpuser
From
10.0.4.17
Action
put FAI-0412.pdf
Who ran it
Unknown: four jobs and two people use this login
One account per job

Example only

Time
2026-10-21 23:00:04
Account
svc-quality-push
From
10.0.4.17, the only address it may use
Action
put FAI-0412.pdf to /prime-a/in
Who ran it
The nightly inspection job, owner: quality lead
Service account set-up
  1. 01

    One account per job

    Name it for the job, not the person who wrote the script, and record its owner in the SSP.

    3.3.2

  2. 02

    A key, not a password in the script

    SSH keys or certificates authenticate the process; a password in a batch file is a password anyone with the file share can read.

    3.5.2

  3. 03

    Pin it down

    One source address, one protocol, one folder. A drop account that can write but not list keeps a stolen key from browsing everyone's files.

    3.1.1; 3.1.2

  4. 04

    Read the log as the assessor will

    Pick a file from last month and trace it to a job and a person. If you cannot, neither can they.

    3.3.1

If you run the server yourself

Plenty of shops run their own transfer server, and products such as MOVEit Transfer are sold to run on premises. That route skips the FedRAMP question for the software, and hands you the patch race. File-transfer servers face the internet by design, and attackers have gone after them again and again: CISA's catalog of vulnerabilities known to be exploited lists 18 entries for the 7 products below, 11 of them marked as used in ransomware campaigns.

CISA exploited list, 2026.10.21
File-transfer server products in CISA's Known Exploited Vulnerabilities catalog
ProductEntriesAdded to the catalogRansomware use
Accellion FTA42021-11-03Known on 4
SolarWinds Serv-U42021-11-03 to 2026-06-05Known on 1
Fortra GoAnywhere MFT22023-02-10 to 2025-09-29Known on 2
Progress MOVEit Transfer12023-06-02Known on 1
CrushFTP32024-04-24 to 2025-07-22Known on 1
Cleo Harmony, VLTrader, LexiCom22024-12-13 to 2024-12-17Known on 2
Wing FTP Server22025-07-14 to 2026-03-16Not known

Source: CISA Known Exploited Vulnerabilities catalog, version 2026.10.21, read 2026-10-22. The date is when CISA added the entry, not when the attacks began. The list is ours: we searched the catalog for these products.

None of this says a hosted service is safer by default. It says who carries the risk. On your own server, flaw remediation SI.L2-3.14.1 means watching that list and patching fast, weekends included, on a box that is a CUI asset in your assessment scope. If no one on your side can promise that, a listed service or your managed service provider should run it.

The services, one by one

Managed file transfer

Sharetru Federal

What it is. A hosted transfer endpoint for CUI and ITAR files: SFTP, SCP, FTPS and an HTTPS REST API for systems, the web app and links for people, all on one hostname. It runs inside the GovPoint Cloud Services FedRAMP Moderate package, where the Marketplace lists it by name. It has no job engine of its own: cron, Task Scheduler or your own code triggers every transfer.

Who it fits. A shop replacing an old SFTP server in the office, with scripts that push inspection reports to primes every night and suppliers who drop files in with their own clients.

What the rule asksWhat we found
FedRAMP Moderate or equivalent, for a cloud that holds CUICertified host (Moderate)
Administered and supported only by US personsUS citizens stated
Scheduled or event-driven transfersYour scheduler

Checked on sharetru.com, 2026-10-22

Check with the vendor before you buy.

Private data network

Kiteworks Federal Cloud

What it is. One platform for managed file transfer, an SFTP server, file sharing, secure email and web forms, under one audit log. Its MFT runs transfers on a schedule, by polling a folder or on an event. Kiteworks Federal Cloud is FedRAMP Certified at Moderate; its Secure Gov Cloud is listed as Agency Authorization In Process at High.

Who it fits. A shop that wants the transfer engine and the schedule hosted for it, and that moves drawings over several channels at once: SFTP to a prime's system, a portal for suppliers, email for the one-off.

What the rule asksWhat we found
FedRAMP Moderate or equivalent, for a cloud that holds CUICertified (Moderate)
Administered and supported only by US personsUS citizens stated
Supports 72-hour incident reporting and 90-day image retentionNot stated

Checked on kiteworks.com, 2026-10-22

Check with the vendor before you buy.

Transfer building block

AWS Transfer Family (GovCloud)

What it is. Amazon's managed SFTP, FTPS, FTP and AS2 endpoint, writing straight into S3 or EFS storage in your own AWS account. In the AWS GovCloud (US) regions it sits inside the AWS GovCloud package, FedRAMP Certified at High. You build the rest: users, keys, storage, the FIPS security policy, logging and any portal.

Who it fits. A shop whose IT provider already runs its CUI enclave in AWS GovCloud and wants partners' SFTP jobs to land in the same account. Not a turnkey service for a shop with no AWS skills in house.

What the rule asksWhat we found
FedRAMP Moderate or equivalent, for a cloud that holds CUICertified (High)
FIPS-validated encryption in transit and at restFIPS policy, opt-in
Administered and supported only by US personsUS citizens stated

Checked on aws.amazon.com, 2026-10-22

Check with the vendor before you buy.

Hosted MFT

Progress MOVEit Cloud

What it is. The hosted edition of Progress MOVEit managed file transfer: SFTP, FTPS and HTTPS, an API, custom branding and tamper-evident logs, run by Progress in the Azure Cloud. Scheduled workflows come from a separate product, MOVEit Automation.

Who it fits. A shop whose prime already trades files with MOVEit and wants the same tool, for data that is not CUI, or once Progress shows written evidence that the hosted service meets the FedRAMP Moderate baseline.

What the rule asksWhat we found
FedRAMP Moderate or equivalent, for a cloud that holds CUINot in Marketplace
FIPS-validated encryption in transit and at restFIPS 140-2 stated
Administered and supported only by US personsNot stated

Checked on progress.com, 2026-10-22

Check with the vendor before you buy.

How we read the services

Questions about moving ITAR files

Questions
Is SFTP ITAR compliant?

No protocol is, because the ITAR certifies no product or protocol. SFTP encrypts the connection, which the 800-171 transmission requirement asks for. The ITAR question is who can read the file at either end and on the server, so an SFTP drop on a hosted service still needs US storage and US-person administrators, unless the file was encrypted end to end before it left.

Is FTPS as good as SFTP for CUI?

Either one encrypts the session; plain FTP does not and should be switched off. What decides 3.13.11 is the cryptographic module underneath, so ask for the CMVP certificate number of the module the server and your client use. A product that is "FIPS compliant" relies on a validated module somewhere; one that is "FIPS validated" is the module itself.

We run our SFTP server on a cloud virtual machine. Does FedRAMP apply?

To the cloud, yes: a provider that stores or transmits covered defense information has to meet the FedRAMP Moderate baseline or its equivalent. Both AWS's commercial US regions (Moderate) and AWS GovCloud (High) are FedRAMP Certified. For ITAR data, GovCloud is the one AWS describes as operated by US citizens on US soil. The server you build on top is yours to secure. The FedRAMP Moderate equivalency guide explains the test for a provider that is not listed.

What should I ask a transfer vendor for before I sign?
  • The FedRAMP Marketplace package ID, or the body of evidence for an equivalency claim.
  • The customer responsibility matrix, for your SSP.
  • The FIPS certificate numbers of the modules used in transit and at rest.
  • A contract line on US data location and US-person administration.
  • How long logs are kept, and how you export them.
  • How they will help you report within 72 hours and preserve images for 90 days.
Our prime sends drawings through its own portal. Is that enough?

For the trip, usually: their portal is their system and their cloud question. Your part starts at download. The laptop that fetches the package holds CUI and is in your scope, and if your staff forward it on by email, the portal's protection ends there. The CMMC- and ITAR-ready email comparison covers that second hop.

Does the CMMC suspension change how we send drawings?

No. The suspension stops contracts adding third-party CMMC assessments. DFARS 252.204-7012, its FedRAMP test for cloud and NIST SP 800-171 Rev 2 still apply, and ITAR is a separate rule from the State Department. What still applies today.