On April 23, 2020, the US State Department’s Directorate of Defense Trade Controls (“DDTC”) announced certain measures intended to mitigate the impact of the COVID-19 pandemic, and key measures are summarized below: Compliance/Registration DDTC has extended the ITAR registrations expiring on February 29, March 31, April 30, May 31, and June 30, 2020 for two months from the original expiration date. Effective as of March 13, 2020, this measure implements a temporary suspension of the…
On 24 April 2020, the European Commission published Implementing Regulation (EU) 2020/568 (the “Implementing Regulation”), which prohibits the export from the EU of certain personal protective equipment unless a licence is first obtained from an EU Member State authority. The Implementing Regulation came into force on 26 April 2020. The Implementing Regulation replaces the temporary export controls imposed by the Implementing Regulation (EU) 2020/402 published on 15 March 2020, as amended by Implementing Regulation (EU)…
On April 21, US Customs and Border Protection (“CBP”) issued guidance via a bulletin in its Cargo Systems Messaging Service (available here) (“Bulletin”) on the new temporary final rule published by the Federal Emergency Management Agency (“FEMA”) imposing export restrictions on certain personal protective equipment products (“PPE Products”) used in the response to the COVID-19 pandemic. The Bulletin details CBP’s implementation of the PPE export restrictions and its process for determining whether an export may be covered by…
On April 16, 2020, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) published a Fact Sheet providing a helpful consolidated summary of the various existing exemptions, exceptions, and authorizations relating to the provision of humanitarian assistance that are available under certain U.S. sanctions programs to leverage in response to the COVID-19 pandemic. Separately, on April 20, 2020, OFAC issued a notice encouraging the prompt communication to OFAC of concerns over potential delays in…