On September 3, 2024, the US Department of Stateās Directorate of Defense Trade Controls (āDDTCā) issued revised Guidance for U.S. Persons Abroad (āUSPABsā) Authorization Requests (āUSPAB Guidanceā) and updated FAQs on Defense Services and USPABs. Under the International Traffic in Arms Regulations (āITARā), all USPABs need DDTC authorization before they can furnish ITAR-controlled defense services to any foreign person, including USPABsā non-US employers. The principal changes to the USPAB Guidance are as follows:
On July 22, 2024, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued guidance relating to OFAC’s implementation of the 21st Century Peace Through Strength Act (“Act”), included in H.R. 815 and signed into law on April 24, 2024, which extended the statute of limitations for civil and criminal violations of the International Emergency Economic Powers Act (“IEEPA”) and the Trading with the Enemy Act (“TWEA”) from five to 10 years. Together, the…
On May 16, 2024, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) published a final rule amending the Iranian Transactions and Sanctions Regulations, 31 C.F.R Part 560 (“ITSR”), to incorporate OFAC General License (“GL”) D-2 and the preexisting list of items deemed incident to communications that are authorized for export or reexport to Iran under GL D-2, and to concurrently update such list. OFAC also published one new and 26 revised…
On March 29, 2024, the US Department of Commerce’s Bureau of Industry and Security (“BIS”) released an interim final rule, effective April 4, 2024 (“April 2024 IFR”) to correct inadvertent errors made in prior semiconductor-related rules in the Export Administration Regulations (“EAR”) and further clarify such rules. The April 2024 IFR clarifies the (1) “Implementation of Additional Export Controls: Certain Advanced Computing Items; Supercomputer and Semiconductor End Use; Updates and Corrections” (88 FR 73458, October…