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Archive for the ‘ITAR Compliance’ Category.

Canadian Exemption Provision

Exporters who use the Canadian Exemption provision (22 CFR §126.5) for the export of defense services should remember to have a written agreement with the Canadian recipient that satisfies the requirements of 22 CFR §126.5 and the accompanying Supplement No.1.  This agreement should limit delivery of the defense items being produced to DDTC registered company […]

State Department Registration

Any U.S. company that engages in the manufacture, export or temporary import of defense articles or furnishing of defense services is required to register with the Directorate of Defense Trade Controls (DDTC). Registering allows the government to know who is engaged in these manufacturing industries/activities as well as in export activities.  Registration is also a […]

New D-Trade Forms

A new batch of D-Trade forms, including the DS-2032, DSP-5, and DSP-6, were all released earlier this week. Beginning Thursday, November 26, 2015 previous versions of these forms will no longer be accepted.  The revision of these forms will extend the form expiration date. The new batch of forms are available online now via the […]

Canadian Exemption Provision: An Overview

The Canadian Exemption Provision (22 CFR 126.5) is a State Department exemption for the export without a license for items whose end use is in Canada or the United States. To utilize this exemption, items must be covered under the ITAR, Canadian parties must be registered with the Canadian Controlled Goods (CCG) Registration Program, and […]

ITAR Amendment- Clarifying registration/licensing requirements for U.S. persons with foreign employer

The comment period recently closed for a proposed ITAR amendment that would clarify registration and licensing requirements for U.S. persons providing defense services on behalf of their foreign employer. The purpose of this clarification by the DDTC is to establish when U.S. persons are covered by licenses previously acquired by their foreign employer and if […]

Merger, Acquisition & Divestiture

If you are a State Department registered company, it is important to consider the State Department requirements in the event your company engages in a merger or acquisition. If the sale or acquisition involves an ITAR registered entity or business (i.e. product line) of an entity, the burden is on the seller to provide advance notification […]

Export Compliance Audits

Periodic export compliance audits are an integral aspect of a company’s export compliance program. Audits demonstrate adherence both to a company’s internal controls and to U.S. export laws and regulations, including the Export Administration Regulation and International Traffic in Arms Regulations .  Export compliance audits review export invoices and other export documents to ensure compliance with product […]

Air Shows

Air Shows If your company will be participating and exhibiting products at Air Shows (Farnborough Air Show, Paris Air Show, ILA Berlin Air Show, etc.) it is important that any military/defense products, including parts/components, are not forwarded/exported or taken with company employees to the air show without required State Department or Commerce Department licensing authority […]

Spacecraft Licensing Changes

Many  Spacecraft Items Move from USML Cat. XV to EAR 9X515 On May 13, 2014 the Commerce Department released the interim final revisions to USML Category XV-Spacecraft and related items. As of November 10, many items previously controlled by the State Department in the spacecraft USML category will now be controlled by the Commerce Department’s […]

Cloud Application Licensing

DDTC suggests that with “sufficient means” cloud application licensing may not be necessary, provided the recipient is a US person employed by US government or corporation The State Department posted a response to a company’s recent post and subsequent clarification regarding a State Department advisory opinion. In the original opinion, the DDTC said that tokenization […]