On January 17, 2025, the Department of State’s Directorate of Defense Trade Controls (DDTC) published an Interim Final Rule that will amend §§ 121.0 and 121.1 of the International Traffic in Arms Regulations (ITAR) by revising certain U.S. Munitions List (USML) definitions, adding new definitions, and updating certain parts of the USML under categories II
BIS, DDTC Publish a Series of Rules to Modernize U.S. Space-Related Export Controls
On October 17, 2024, the Commerce Department’s Bureau of Industry and Security (BIS) released three rules—one Final Rule, one Interim Final Rule, and one Proposed Rule—to reduce controls on a variety of less sensitive space-related items, thereby ensuring the U.S. space industrial base remains globally competitive while also bolstering the U.S. international space partnerships. Concurrently…
Commerce and State Departments Issue Proposed Rules Addressing Restrictions on U.S. Persons’ Support for Foreign Military, Intelligence, and Security Services and Controls to Protect National Security and Human Rights
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 Commerce’s…
BIS Revises Export Controls on Firearms Licensing Requirements
On April 30, 2024, the Department of Commerce’s Bureau of Industry and Security (BIS) issued an interim final rule (IFR) updating the Export Administration Regulations (EAR) to enhance the control structure for firearms and related items under BIS’s jurisdiction. This IFR will be effective on May 30, 2024, and public comment will be accepted until…
DDTC Issues New ITAR Compliance Guidelines
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…
Transfer of 3D-Printed Gun Technology and Software to the EAR from the ITAR Becomes Final
By Scott E. Diamond** on
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…
BIS Issues FAQs on Foreign Military Sales
By Scott E. Diamond** on
On May 12, 2021, the Department of Commerce’s Bureau of Industry and Security (BIS) issued a series of Frequently Asked Questions (FAQs) in an effort to respond to numerous questions from industry regarding the export of items that have been moved from the U.S. Munitions List under the International Traffic in Arms Regulations (ITAR) to…
Updated: United States Implements Multiple Sanctions and Export Restrictions on Russia
By Thompson Hine International Trade on
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…
United States Implements Multiple Sanctions and Export Restrictions on Russia
By Thompson Hine International Trade on
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 the Russian Federation’s imprisonment and alleged previous poisoning of opposition figure Aleksey Navalny. These actions follow similar sanctions imposed by the European Union and the United Kingdom. Dozens…
State Department Imposes Export and Other Restrictions on Chinese and Russian Entities for Transfers of Controlled Items to Iran, North Korea and Syria
By Scott E. Diamond** on
On November 25, 2020, the State Department issued a Federal Register Notice announcing the imposition of nonproliferation measures against certain Chinese and Russian entities for the transfer of goods, services, or technology controlled under multilateral control lists (Missile Technology Control Regime, Australia Group, Chemical Weapons Convention, Nuclear Suppliers Group, Wassenaar Arrangement) or otherwise having the…