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On August 15, 2024, the Department of State’s Directorate of Defense Trade Controls (DDTC) published a final rule adding two activities to the definition of “activities that are not exports, reexports, retransfers, or temporary imports” in § 120.54 of the International Traffic in Arms Regulations (ITAR). The final rule, which goes into effect September 16…

On July 29, 2024, both the Departments of Commerce and State issued separate but complementary proposed rules seeking public comment on enhanced restrictions on exports, reexports, or support to military or intelligence end users and end uses in countries of concern, consistent with the Fiscal Year 2023 National Defense Authorization Act (NDAA). The Department of…

On May 1, 2024, the State Department published a proposed rule to amend the International Traffic in Arms Regulations (ITAR) and establish an exemption to the licensing requirement for exports, reexports, transfers, or temporary import of defense articles to or within Australia and the United Kingdom. This proposed rule is intended to promote the goals…

On December 5, 2022, the Department of State’s Directorate of Defense Trade Controls (DDTC) released updated Compliance Program Guidelines that provide an overview of what it considers an effective compliance program. The document also provides both an introduction to the Arms Export Control Act (AECA), the International Traffic in Arms Regulations (ITAR), and the manufacturing…

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…

On February 14, 2022, the Department of State’s Directorate of Defense Trade Controls (DDTC) released Revision 5.0 of its Guidelines for Preparing Agreements. Under the International Traffic in Arms Regulations (ITAR), an “agreement” approved by the Office of Defense Trade Controls Licensing (DTCL) is required for the provision of a defense service, transfer of manufacturing…

On February 2, 2022, the State Department’s Directorate of Defense Trade Controls (DDTC) issued a Federal Register notice proposing various amendments and clarification to the International Traffic in Arms Regulations (ITAR). Most significantly, DDTC is proposing to revise the definitions of “export” and “reexport” to clarify that any release of technical data to a foreign…

On December 9, 2021, the Department of Commerce’s Bureau of Industry and Security (BIS) announced that it was amending the Export Administration Regulations (EAR) to apply more restrictive treatment to exports and reexports to, and transfers within, Cambodia of items subject to the EAR.  BIS stated that it is taking this action “to address recent…

Effective November 1, 2021, the Department of State’s Directorate of Defense Trade Controls (DDTC) amended the International Traffic in Arms Regulations (ITAR) to add and update entries for Ethiopia and Eritrea, respectively. As a result, it is now the policy of the United States to deny licenses and other approvals for exports of defense articles…

Key Notes:

  • Proposed rule would allow persons working under a long-term contract to be considered “regular employees” under the International Traffic in Arms Regulations (ITAR) even if they work remotely.
  • Remote work would be permitted so long as people were not working in Belarus, Burma, China, Cuba, Iran, North Korea, Russia, Syria or Venezuela, or

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