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Archive for the ‘ITAR Compliance’ Category.

DDTC agreements

In addition to issuing export licenses, U.S. State Department’s DDTC also reviews and approves agreements between U.S. companies and foreign companies that involve the transfer of technical data and/or distribution rights of hardware.  Agreements in themselves do not authorize hardware exports but exports of hardware can be covered in the scope of the agreement and […]

Agreement Amendment Requirements for USML Category XI and XV

November 10, 2017 will mark three years from the effective date of the Export Control Reform transition of USML Category XV and December 30, 2017 will mark three years from the effective date of the Export Control Reform transition of USML Category XI. It is vital that all agreements including items that have transitioned to the EAR be amended, or alternative licensing […]

ITAR Canadian Exemption Provision

Prior to utilizing the ITAR Canadian exemption provision to export hardware and technical data related to defense services, exporters must receive a certification that ensures that the end use of the item is allowed under the exemption provision. Additionally, the certification should limit delivery/end use of the defense article being produced directly to an identified […]

Material Changes to Registration

If there is a material change to information submitted as part of your State Department registration application (on your DS-2032), you are required to submit the proper notification to DDTC. Material changes include changes in subsidiaries/affiliates, changes in senior officers, or change in address of the company (note: this list is not exhaustive). DDTC must […]

O Canada! (The Blog Edition)

Exporting to Canada can most often done without having to first apply for a license. For products and technical data under the jurisdiction of the State Department, the Canadian exemption provision (22 CFR 126.5) can usually be utilized.  22CFR 126.5(b)(1) should be reviewed by exporters prior to using the Canadian exemption provision as it lists […]

Updating DDTC after Merger or Acquisition

As a reminder, companies who are registered with DDTC are required to notify DDTC of any mergers, acquisition or divestitures of ITAR manufacturing/exporting subsidiaries or affiliate. If the transaction does not involve a sale to a foreign party, DDTC must be notified within 5 days of the sale. Both buyers and sellers are required to […]

DDTC Company Visit Program

DDTC Company Visit Program The State Department’s Office of Defense Trade Controls Compliance (DTCC) relaunched their Company Visit Program (CVP) this year. This program provides for visits by DTCC compliance personnel, or other representatives of the Directorate of Defense Trade Controls (DDTC), to various DDTC registered entities, as well as other parties involved in ITAR […]

DDTC Agreement Guidelines Revision

On September 1, 2016, the DDTC Guidelines for Preparing Agreements (Revision 4.4) went into effect. The revised guidelines take into account the revised definitions for export, reexport, and retransfer, as described in the State Department Rule published on June 3.  This rule harmonized definitions of the above words and also went into effect September 1st.   […]

Foreign National Licensing

If you have foreign national employees, it may be necessary to secure BIS or DDTC licensing for those employee to access controlled technical data and/or product.  Foreign national employees are employees who are neither U.S. citizens, lawful permanent residents (i.e. Green Card holder), nor an individual who is granted status as a “protected person” under 8 U.S.C. 1324b(a)(3). […]

Transition Deadline Approaching for Category VIII Agreements

October 15, 2016 will mark three years from the effective date of the Export Control Reform transition of Categories VIII and XIX. It is vital that all agreements including items that have transitioned to the EAR be amended, or alternative licensing secured, by that time.  If all items on your DDTC agreement have transitioned to […]