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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 they must be independently registered with the DDTC.


The amendment adds language to the definitions of “Regular Employee” “Affiliate” and “Natural person” in 22 CFR §120.  Additionally, the amendment proposes a note to the registration requirements which would clarify that all persons who are directly employed by a DDTC registered entity (or an affiliate/subsidiary listed on the registration) are considered registered.

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