On Friday, September 18, 2026, the U.S. Department of State issued two rules amending the International Traffic in Arms Regulations (ITAR). The first, an interim final rule effective October 19, narrows U.S. Munitions List (USML) Category XX(a) controls on certain uncrewed underwater vehicles. The second, a final rule effective immediately, clarifies policy-of-denial provisions, updates country
State Department Proposes ITAR Part 130 Amendments to Reduce Defense Sales Reporting Burden
By Scott Wise, Chandler Leonard, Rachel Ferns & Nate Young on
Posted in Export Controls, ITAR
Key Takeaway: DDTC’s proposed rule would shift ITAR Part 130 reporting from a transaction-linked model to consolidated annual submissions. It also proposes raising monetary thresholds for the first time since 1993. By making notifications of political contributions and fees or commissions related to foreign arms sales simpler and clearer, the proposal will make reporting more…
ATF Catches Up with Export Control Reform (Better Late than Never!)
By Scott Wise, Chandler Leonard & Nate Young on
Key Takeaway: ATF’s latest final rule closes a regulatory gap left by the Export Control Reform (“ECR”) initiative, acknowledging that the Department of Commerce now shares jurisdiction alongside the Department of State over items on ATF’s United States Munitions Import List (“USMIL”).
On May 6, 2026, the Bureau of Alcohol, Tobacco, Firearms and Explosives (“ATF”)…
State Department Removes Cambodia from ITAR 126.1 Proscribed Countries List
The U.S. Department of State (“State”) has decided to lift the defense trade embargo against Cambodia. Accordingly, the Directorate of Defense Trade Controls (“DDTC”) will publish on November 7, 2025, a final rule amending the International Traffic in Arms Regulations (ITAR) at § 126.1 to remove Cambodia from the proscribed countries list.
For countries included…
Department of State Issues Final Rule, Effective Sept. 15, 2025, Updating ITAR and Targeted Revisions to the U.S. Munitions List
By Scott Wise, Chandler Leonard & Andrew J. Schlegel on
Posted in Export Controls, ITAR
On August 27, 2025, the Department of State published a final rule amending the International Traffic in Arms Regulations (“ITAR”) and updating the U.S. Munitions List (“USML”). The rule, effective September 15, 2025, implements changes following public comment and periodic review required under the Arms Export Control Act.
The latest ITAR amendments remove certain items…
Biden Administration Updates Policy Guidance for the Implementation of the Missile Technology Control Regime
By Crowell & Moring on
Posted in ITAR, Missile Technology Control Regime (MTCR)
On January 3, 2025, President Biden issued a National Security Memorandum (NSM) to update policy guidance for the Government of the United States’ implementation of the Missile Technology Control Regime (MTCR). The NSM directs the relevant executive branch agencies to provide increased flexibility for case-by-case review and facilitate support for certain MTCR Category I military…
DDTC Increase in Registration Fee Rates Become Effective
By Crowell & Moring on
Posted in Directorate of Defense Trade Controls (DDTC), ITAR
On January 9, 2025, DDTC’s new registration fee rates become effective. This is the first time in fifteen years DDTC has increased the registration fees charged to those who are required to register with DDTC pursuant to the Arms Export Control Act. Pursuant to the final rule amending parts 122 and 129 of the ITAR…
DDTC Publishes ITAR Amendments to Implement the AUKUS Exemption
By Crowell & Moring on
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…
DDTC Publishes Amendments to the ITAR Definition of Activities That Are Not Exports, Reexports, Retransfers, or Temporary Imports
By Jeremy Iloulian on
Posted in Directorate of Defense Trade Controls (DDTC), ITAR
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…
ITAR and EAR Proposed Rules Expand Controls on U.S. Person Services
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…