Tag Archives: ITAR

US ITAR Export Control Workshop in the UK – September 2021

For the past 13 years, EGADD and Squire Patton Boggs have jointly hosted a successful annual workshop series on US export controls regulations. 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 … Continue Reading

US Government Revises Two Previous FAQs Regarding US Persons Abroad

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

Registration Now Open: From EAR to ITARnity: Ever-challenging US Export Controls Compliance – September 16-18, 2019 | Winchester, UK

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

DDTC Fines Alleged Violations of ITAR and Failure to Appoint Qualified Empowered Offcial

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

Regulatory Revisions to International Traffc in Arms Regulations (ITAR)

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

US Export Controls Workshop – “The ITAR ‘Virus’ Continues to EARvolve!” – Stratford-Upon-Avon, UK – July 23-25, 2018

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

US Export Control Reform: Potential Impact to Existing TAAs and MLAs

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

Trump Administration Permanently Lifts Sudan Sanctions

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

Trump Administration Permanently Lifts Sudan Sanctions

  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

US Export Controls Workshop: “The ITAR Continues to EARvolve!” – Stratford-Upon-Avon, UK – 12-14 June 2017

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

Obama Administration Lifts Sanctions on Sudan

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

7th Annual Advanced ITAR & EAR Compliance Conference & Workshops – Northern Virginia – 8-9 February 2017

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

DDTC Publishes Final Rule Revising USML Categories VIII and XIX

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

DDTC and BIS Harmonised Destination Control Statement Rules Go Into Effect

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

BIS Amends EAR to Update Military Arms Embargo Status of Côte d’Ivoire, Liberia, Sri Lanka and Vietnam

US Commerce Department’s Bureau of Industry and Security (BIS) has issued a final rule amending various provisions of the Export Administration Regulations (EAR) to account for changes to controls on exports of arms and related materiel to Côte d’Ivoire, Liberia, Sri Lanka and Vietnam. These actions follow the recent termination of the arms embargos of … Continue Reading

New Rule Harmonises the EAR and ITAR Destination Control Statements

The US Commerce Department’s Bureau of Industry and Security (BIS) and the State Department’s Directorate of Defense Trade Controls (DDTC) each issued companion final rules (see here and here) that will amend the EAR and the ITAR, respectively, to harmonise the destination control statement language provided in both sets of regulations. These actions are the latest in a series taken pursuant … Continue Reading

ITAR and the EAR: US Trade Controls Compliance in Europe – London, UK – 31 January-1 February 2017

George Grammas will participate in C5’s 5th Forum on compliance with ITAR and the EAR and be among the panelists to discuss “How to Work with Conflicting Definitions.” The conference will take place at St. James’ Court, A Taj Hotel in London. The conference will feature Q&A with Kevin Wolf, Assistant Secretary of Commerce for … Continue Reading

Civil Monetary Penalties for Sanctions and Export Control Violations Set to Increase

Under the authority of the Federal Civil Penalties Inflation Adjustment Act of 1990 (the Act), as amended, OFAC is adjusting for inflation the maximum amount of the civil monetary penalties that may be assessed under its relevant regulations. For instance, for penalties assessed under the authority of the International Emergency Economic Powers Act (IEEPA), penalties will increase to the greater … Continue Reading

Export Control Reform Continues Through Changes to Key Terms

In June, the US Commerce Department’s Bureau of Industry and Security (BIS) and the State Department’s Directorate of Defense Trade Controls (DDTC) published companion rules to harmonize the definitions of key terms in the Export Administration Regulations (EAR) and the ITAR, respectively. The terms affected by the rulemaking include such fundamental concepts in export controls as “export”, “reexport”, “release”, “transfer” … Continue Reading
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