On November 1, 2021, the U.S. Department of State’s Directorate of Defense Trade Controls (DDTC) issued a final rule adding Ethiopia to the Proscribed Country List found in the International Traffic in Arms Regulations (ITAR) in § 126.1 and also updating the existing restrictions on Eritrea.

A policy of denial now applies to licenses (or other approvals) for exports of defense articles or defense services to or for the armed forces, police, intelligence, or other internal security forces of either Ethiopia or Eritrea. The details of this policy can be found in ITAR § 126.1(h) and (n).

This policy change was made in response to concerns of the ongoing crisis in northern Ethiopia along with other threats to Ethiopia’s sovereignty, national unity, and territorial integrity. People in northern Ethiopia continue to suffer human rights violations, abuses, and atrocities. But as this occurs, Ethiopian and Eritrean militaries are blocking needed humanitarian relief. The Secretary of State announced in May of 2021 restrictions on security assistance to Ethiopia and Eritrea. This final rule makes the ITAR consistent with this announcement.

The Federal Register notices are available here.

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Photo of Jeffrey L. Snyder Jeffrey L. Snyder

Since 1986, Jeff’s practice has concentrated on the U.S. regulation of international trade. Clients seek him out for troubleshooting and problem solving in cross-border transactions. Jeff advises on import, export, and sanctions laws. He develops approaches for multinationals to manage the impact of…

Since 1986, Jeff’s practice has concentrated on the U.S. regulation of international trade. Clients seek him out for troubleshooting and problem solving in cross-border transactions. Jeff advises on import, export, and sanctions laws. He develops approaches for multinationals to manage the impact of U.S. extraterritorial regulations. Jeff assists companies in day-to-day compliance with these laws, and with interventions — such as audits and investigations, and civil enforcement proceedings.

Photo of Chandler Leonard Chandler Leonard

Chandler S. Leonard is an associate in Crowell & Moring’s Washington, D.C. office and a member of the firm’s International Trade Group. Chandler’s practice focuses on export controls and economic sanctions issues, including voluntary disclosures and enforcement matters before the Departments of Commerce…

Chandler S. Leonard is an associate in Crowell & Moring’s Washington, D.C. office and a member of the firm’s International Trade Group. Chandler’s practice focuses on export controls and economic sanctions issues, including voluntary disclosures and enforcement matters before the Departments of Commerce, State, and Treasury. Chandler has experience analyzing and advising U.S. and non-U.S. companies with respect to proposed transfers of U.S. origin technology, software, hardware, and services. She has performed jurisdictional and classification analyses under the ITAR and EAR, including drafting Commodity Jurisdiction requests and CJ Reconsideration requests. She assists in developing and/or reviewing U.S. export and sanctions compliance programs, including risk assessments. Chandler also has experience training a wide variety of audiences, both U.S. and foreign, on compliance with U.S. export control and sanctions requirements.

Photo of Rachel Schumacher Rachel Schumacher

Rachel Schumacher is an associate in the International Trade and Government Contracts groups in Crowell & Moring’s Washington, D.C. office. Rachel’s practice focuses on transactions, investigations, and compliance and advisory matters involving a variety of government contracts and international trade issues.