On May 11, 2020, the Directorate of Defense Trade Controls (DDTC) published nine new Frequently Asked Questions (FAQ) on exemptions related to §126.4 of the International Traffic in Arms Regulations (ITAR), Transfers by or for the United States Government (USG).

In April 2019, DDTC issued the long-awaited final rule to modernize §126.4 exemptions for exports in support of the U.S. Government (please click).  The FAQs discuss certain clarifying requirements for use of §126.4(a) and §126.4(b), though remain silent on Defense Technology Security Administration (DTSA)’s anticipated guidelines regarding the process for certification of exemption under 126.4(b)(2) for Department of Defense contracts.