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Archive for October 2018

The Foreign Investment Risk Review Modernization Act of 2018 (FIRRMA) Pilot Program

The Department of Treasury has issued interim regulations to conduct a pilot program, commencing on November 10, 2018, that expands the scope of transactions subject to review by the Committee on Foreign Investment in the United States (CFIUS) and makes FIRRMA’s mandatory declaration provisions effective. The program expands CFIUS’s jurisdiction to include investments that do […]

ITAR Recent Changes – Return of Licenses and USML Clarifications

On Thursday, October 4, the U.S. Department of State eliminated the requirement to return licenses for technical data. Prior to the change, exporters were required to return licenses after the initial export of technical data, and all licenses that were exported against but not electronically decremented. The language regarding license return was removed from ITAR […]