ITAR

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On August 20, 2024, the Department of State’s Directorate of Defense Trade Controls (DDTC) published an interim final rule to streamline defense trade between and among Australia, the United Kingdom (UK), and the United States in furtherance of the trilateral security partnership (the “AUKUS” partnership). The interim final rule implements the proposed rule DDTC published…

On August 15, 2024, the DDTC published a final rule to expand the ITAR’s definition of “activities that are not exports, reexports, retransfers, or temporary imports.”  The final rule implements the amendments the DDTC originally proposed on December 16, 2022 with six changes.  The rule is effective on September 16, 2024 and codifies longstanding DDTC…

On July 25, 2024, the U.S. Departments of State and Commerce issued new proposed rules that, if implemented, would (1) increase the restrictions associated with U.S. persons providing services in support of non-U.S. military-related end users / uses; and (2) implement new controls associated with exports, reexports, and transfers of items subject to the EAR…

On May 1, 2024, the Department of State’s Directorate of Defense Trade Controls (DDTC) published a proposed rule that, if implemented, would streamline defense trade between and among Australia, the United Kingdom (UK), and the United States in furtherance of the trilateral security partnership (the “AUKUS” partnership).

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On July 10, 2023, the State Department released a Fact Sheet with additional details on the AUKUS Trade Authorization Mechanism (ATAM). ATAM appears likely to operate as a license exemption under the International Traffic in Arms Regulations (ITAR), leveraging the existing ITAR §126.4, to authorize transfers of certain approved categories of defense articles and…

On December 5th, the Department of State’s Directorate of Defense Trade Controls (DDTC) issued new Compliance Program Guidelines (CPG) intended to provide an overview of an effective compliance program.

The CPG is broken down into elements covering the spectrum of ITAR compliance from company management commitment, registration, jurisdiction and classifications, authorizations, recordkeeping, violations…

On December 9, 2021, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) and the U.S. Department of State’s Directorate of Defense Trade Controls (DDTC) both issued final rules adding export restrictions on Cambodia.

BIS amended the Export Administration Regulations (EAR) to implement more restrictive export controls for Cambodia to ensure that items…

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…

On June 17, 2021, a federal grand jury in Los Angeles from the U.S. District Court for the Central District of California unsealed an indictment that accuses five defendants of having conspired to unlawfully export thermal imaging riflescopes and night-visions goggles to Russia. All five defendants are charged with conspiring to violate the Arms Export…

In an update to our prior post published on March 8, the Bureau of Industry and Security (BIS) and State Department published additional actions against Russia in response to the poisoning of Aleksey Navalny on March 18. The new sanctions and export controls are summarized below.

Bureau of Industry and Security

The Secretary of…