The Department of State’s Directorate of Defense Trade Controls (DDTC) announced on February 25, 2022, that effective immediately, DDTC has implemented a policy of denial for any licenses or other approvals under the International Traffic in Arms Regulations (ITAR) for exports, reexports, retransfers, temporary imports of, and brokering activities related to defense articles and defense services, destined for or originating in the so-called Donetsk People’s Republic (DNR) or Luhansk People’s Republic (LNR) regions of Ukraine (collectively, the “Covered Regions”). Only limited ITAR exemptions will apply for transfers in furtherance of the conduct of the official business of the U.S. government.