On July 29, 2024, the US Department of State published a new proposed rule to revise the definition of defense service in the International Traffic in Arms Regulations (22 CFR parts 120-130, “ITAR”) in the Federal Register. Interested parties are invited to submit comments to the State Department through September 27, 2024.… Continue Reading
On April 27, 2023, the U.S. Department of State published an Interim final rule and request for comments to amend the International Traffic in Arms Regulations (ITAR) to “remove from U.S. Munitions List (USML) Category XI certain high-energy storage capacitors and to clearly identify the high-energy storage capacitors that remain in USML Category XI.”… Continue Reading
On January 5, 2023, the Directorate of Defense Trade Controls (DDTC), which administers the International Traffic in Arms Regulations (ITAR), announced updated guidance and FAQs for US persons abroad (USPAB) authorization requests. DDTC also released a submission letter template and sample § 121.13 certification letter to accompany such requests.… Continue Reading
For the past 14 years, we have jointly hosted a successful annual workshop series on US export controls regulations with EGADD. In celebration of its 15th anniversary, this June’s workshop will also be organized in close partnership with BAE Systems, a major, multinational company that has considerable practical experience in dealing with the challenges arising … Continue Reading
On June 1, 2021, the US Department of Commerce’s Bureau of Industry and Security (BIS) published a notification regarding a transfer of jurisdiction of certain software and technology involved in the manufacturing, exporting, importing, or brokering of defense services created with 3D-printing technology. … Continue Reading
For the past 13 years, we have jointly hosted a successful annual workshop series on US export controls regulations with EGADD. In celebration of its 14th anniversary, this September’s workshop will take place immediately after DSEI 2021. This year’s event will also be organized in close partnership with BAE Systems, a major, multinational company that … Continue Reading
On March 18, 2021, the Department of Commerce’s Bureau of Industry and Security (BIS) published in the Federal Register a Notification of Implementation pursuant to sanctions imposed by the Secretary of State under Section 306(a) of the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991 (CBW Act). … Continue Reading
After several rounds of revisions, China finally adopted its first Export Control Law (ECL), which went into force on December 1, 2020. In general, we consider the ECL general, vague and hard to be implemented in practice without further adopting implementation rules. It incorporates many concepts from the US export control laws, but with few … Continue Reading
On April 6, 2020, the US Department of State’s Directorate of Defense Trade Controls (DDTC) announced it had revised two published Frequently Asked Questions (FAQs). The revised FAQs address US persons abroad and requests for authorization to provide defense services. The FAQs read: (1) If I request authorization for defense services that describe my current … Continue Reading
Please mark your calendar for the upcoming three-day US export controls workshops sponsored by our International Trade Practice with EGADD and Rolls Royce – this year in Winchester, UK. Trade Practitioner George Grammas will once again present on export controls topics and host workshops. For additional information about the workshops, please contact Brinley Salzmann and Karen Hayhoe.… Continue Reading
On February 28, 2019, with a civil penalty of US$400,000, Darling Industries, Inc. of Tucson, Arizona settled allegations for violating six counts of the Arms Export Control Act (AECA), as well as the International Traffic in Arms Regulations (ITAR), in connection with unauthorized exports of defense articles, provisions of defense services and failure to appoint a qualified Empowered Official.… Continue Reading
On February 4, 2019, US Department of State’s Directorate of Defense Trade Controls (DDTC) released a new electronic submission software for Advisory Opinions, called Defense Export Control and Compliance System (DECCS). Persons requesting an Advisory Opinion (Applicants) can apply for an account in DECCS.… Continue Reading
On October 4, 2018, the Directorate of Defense Trade Controls (DDTC) announced in the Federal Register revisions to the ITAR titled, “Regulatory Reform Revisions to the International Traffic in Arms Regulations.” The revisions are in response to comments that the Department of State received. The new rule has removed certain notification requirements from the ITAR, and it removed certain items … Continue Reading
Our Aerospace & Defense Group is pleased to partner once again with EGADD and Strategic Shipping Company Ltd to host the upcoming “The ITAR ‘Virus’ Continues to EARvolve!” US Export Controls Workshop in Stratford-Upon-Avon, UK, Monday, July 23 – Wednesday, July 25, 2018. 2018 welcomes the 11th anniversary of the workshop.… Continue Reading
Due to the US Export Control Reform, all Technical Assistance Agreements (TAAs) and Manufacturing License Agreements (MLAs) containing USML Category XI transitioning items approved before the transitioning date of December 30, 2014 may expire at the end of 2017. Now is the time to review all of your active TAAs and MLAs. We explain the … Continue Reading
On 6 October, the Trump administration announced that it would permanently revoke economic sanctions against Sudan, effective 12 October 2017. The State Department published this decision in the Federal Register, 82 Fed. Reg. 47287, on 11 October 2017. This decision means that US companies can invest in Sudan and export their products and services to Sudan, subject to compliance with … Continue Reading
Sudan Sanctions In 1997, the US imposed a comprehensive trade and investment embargo against Sudan. In January 2017, i.e., in the closing days of the Obama Administration, President Obama announced a six-month suspension of US economic sanctions, citing ongoing dialogue with the Sudanese government and the government’s progress in achieving milestones agreed upon in those negotiations. Specifically, the Obama Administration … Continue Reading
Squire Patton Boggs’ Aerospace, Defense & Government Services Industry Group will co-host the three-day ITAR and EAR workshop sessions, popularly known as “The ITAR Virus EARvolves!“, with EGADD and Strategic Shipping Company Ltd. This year marks the 10th anniversary of these annual workshops, as the ITAR and the EAR continue to evolve. The 2017 conference will … Continue Reading
On Tuesday, January 17, 2017, the Treasury Department’s Office of Foreign Assets Control (OFAC) will publish in the Federal Register a far-reaching amendment to its Sudanese Sanctions Regulations (SSR), 31 CFR Part 538. While styled as a “general license,” the amendment will have the practical effect of terminating the embargo of Sudan that the US … Continue Reading
Squire Patton Boggs will once again partner with Marcus Evans to host the two-day gathering. The 2017 conference will provide a forum for professionals in the field to discuss with industry and government experts the evolving Export Control Reform, as well as provide assistance with developing compliance strategies to comprehensively address existing regulations and updates. … Continue Reading
In the latest steps taken to implement the President’s Export Control Reform initiative, DDTC has published a final rule implementing revisions to Categories VIII (aircraft and related articles) and XIX (gas turbine engines and associated equipment) of the United States Munitions List (USML). Among other things, the rule clarifies the scope of items covered by those … Continue Reading
On 15 November 2016, companion rules issued by DDTC and BIS went into effect that adopt a harmonised destination control statement for controlled exports. Exporters must now include the new destination control statement on the commercial invoice for covered items that are exported, retransferred or reexported in tangible form. And, in the case of 9×515 … Continue Reading
