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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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The State Department’s Directorate of Defense Trade Controls (DDTC) on June 1, 2021 announced that a final rule from January 2020, which moved 3D-printed guns out from control under the International Traffic in Arms Regulations (ITAR) over to the Export Administration Regulations (EAR), is now in effect. See Federal Register notice of January 23, 2020…

On April 12, 2021, the State Department’s Directorate of Defense Trade Controls (DDTC) issued additional guidance regarding changes that have been made to the International Traffic in Arms Regulations (ITAR) pertaining to export of defense articles or services to Russia. The guidance summarizes changes that were implemented on March 18, 2021, when the Departments of…

Note: This previously published client update has been revised to provide links to the official notices published by the Departments of Commerce and State on March 18, 2021.

On March 2, 2021, the Departments of Commerce, State and the Treasury imposed sanctions and export restrictions on numerous Russian officials and government entities in response to…