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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 […]

Iran- Limited Sanctions Relief

A Joint Comprehensive Point of Action (JCPOA) was reached on July 14 by the P5 +1 countries and Iran.  The JCPOA will allow Iran sanction relief once it has met its responsibilities under the proposed treaty for “key nuclear commitments”.  At this time, the US will be providing sanction relief by easing secondary sanctions (i.e. […]

License Exception GOV: Overview

License Exception GOV (§740.11) authorizes exports, re-exports, and in- country transfer of eligible items to U.S. government persons and agencies, agencies of “cooperating governments”, and international inspections under the International Space Station and the Chemical Weapons Convention.   To be eligible for use of license exception GOV, the items must either be for the personal use […]

Cuba: AT Restrictions removed

On July 22nd, the Commerce Department published a rule implementing the May 29th decision to remove Cuba from the State Sponsor of Terrorism list. While Cuba is still subject to a statutory embargo, it is no longer subject to anti-terrorism (AT) level of controls. Due to the statutory embargo all items under the jurisdiction of […]

Export Control Reform: Update and Recap

Export Control Reform: Update and Recap   Over the last 20 months, the State and Commerce Departments have published final rules for the transition of 15 categories.  Additionally, 3 more have had proposed rules published that are expected to be published in the final form in the coming months.  A few especially pertinent transition dates […]

Temporary Change to ITAR USML Category XI

On July 2nd, the State Department announced a temporary change in ITAR USML Category XI.  Due to confusing language prior to the change, some exporters did not realize that certain intelligence analytics software remained under the jurisdiction of ITAR USML Category XI. To end this confusion, a temporary revision to Category XI(b) was enacted on […]

DDTC Registration

Any U.S. company that engages in 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). This information allows the government to know who is engaged in certain manufacturing industries/activities as well as export activities.  DDTC Registration is a requirement […]

Proposed Changes to USML Category XIV and USML Category XVIII

On June 17th, Commerce and State announced a proposed rule that would revise USML Categories XIV (toxicological agents) and XVIII (directed energy weapons). For USML Category XIV, items being moved to the jurisdiction of the EAR are “primarily of dissemination, detection, and protection, ‘equipment’ and related articles”. The new related ECCN will be 1X607. For […]

USML Category XII Proposed Revision-BIS Guidance on Infrared Detection Items

On May 5th, BIS published a proposed rule for the revision of USML Category XII.  This rule would result in the creation of new ECCNs 6×615 and 7×611 for military fire control, range finder, optical and guidance items. Additionally, controls on certain infrared detection items were increased.  On June 16th, BIS published a document providing […]

USMIL Final Rule Published

USMIL final rule published as part of Export Control Reform firearms components no longer controlled On May 21st, the final rule to remove unnecessary items from the United States Munitions Import List (USMIL), under the jurisdiction of the Bureau of Alcohol, Tobacco, Firearms, and Explosives, was published. This rule finalized an interim rule published on March […]