On March 14, 2024, the U.S. Department of State’s Directorate of Defense Trade Controls (“DDTC”) and the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) announced more restrictive export controls on Nicaragua stated to be in response to the Nicaraguan Government’s human rights abuses, attacks on civil society, and increased cooperation with Russia. The DDTC and BIS press releases are available here and here. DDTC: New ITAR Export Controls The State Department announced…
On October 18, 2023, the US Departments of Commerce, State, Treasury, and Justice issued the Iran Ballistic Missile Procurement Advisory (the “Advisory”) to alert persons and businesses to Iran’s ballistic missile procurement activities. The Departments of State and Justice also issued separate statements related to the Advisory. The Advisory and related statements underscore the US Government’s concerns about Iran’s ballistic missile program and its efforts to stymie that program. In addition, the US Government and…
On December 16, 2022, the US Department of State’s Directorate of Defense Trade Controls (“DDTC”) issued a proposed rule that would treat two additional types of transactions as activities that are not exports, reexports, retransfers, or temporary imports (“controlled events”) (and, thus, not require authorization) under the International Traffic in Arms Regulations (“ITAR”). The two additional activities that would not constitute controlled events are: Taking defense articles outside a previously approved country by the armed…
On December 5, 2022, the US Department of State’s Directorate of Defense Trade Controls (“DDTC”) issued the International Traffic in Arms Regulations (“ITAR”) Compliance Program Guidelines (“ITAR Guidelines”). The ITAR Guidelines set out DDTC’s expectations for an effective ITAR Compliance Program (“ICP”) and an introduction to controls contained in the Arms Export Control Act and ITAR. More specifically, the ITAR Guidelines outline key elements of an effective ICP, and identify suggestions, common compliance pitfalls, and/or…