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

On March 2, 2021, the Biden Administration announced the intelligence community’s finding that Russia’s Federal Security Service (FSB) used a banned chemical nerve agent to poison Russian opposition leader, Aleksey Navalny.  Shortly following the White House’s press briefing, the Departments of State, Commerce, and Treasury issued press releases announcing new sanctions and export controls, summarized

The State Department’s Directorate of Defense Trade Controls (DDTC) issued a Federal Register Notice on December 11, 2020, announcing a “second extension to certain temporary suspensions, modifications, and exceptions to certain provisions of the International Traffic in Arms Regulations (ITAR) to provide for continued telework operations during the current SARS-COV2 public health emergency… This

On May 1, 2020, the Department of Defense Trade Controls (DDTC) issued a Federal Register notice informing companies of the temporary suspension, modification, and exception to several International Traffic in Arms Regulations (ITAR) provisions because of the COVID-19 pandemic.

DDTC is now requesting comments from the public regarding the temporary changes announced May 1st