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Unmanned Aerial Systems (UAS)

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On January 12, 2021, the US Department of Commerce issued a final rule (the ā€œFinal Ruleā€) amending the Export Administration Regulations (ā€œEARā€) to implement recent licensing review policy changes for exports of US-origin unmanned aerial systems (ā€œUASā€), also known as ā€œdrones.ā€ Our prior blog posts on UAS export policy developments are available here and here. The Final Rule implements the more flexible export license review policy applicable to a specific subset of UAS with maximum…

On July 24, 2020, the Trump Administration announced a new policy (the ā€œUpdated UAS Policyā€) on exports of US-origin unmanned aerial systems (ā€œUASā€), also known as ā€œdrones.ā€ The Updated UAS Policy follows the Trump Administrationā€™s UAS policy reforms announced in April 2018 (ā€œApril 2018 UAS Export Policyā€), which allowed exports of certain US-origin armed and unarmed UAS to occur via direct sales between US companies and foreign end users. Our previous blog post on the…

On April 19, the US Government issued a fact sheet outlining a new policy (the ā€œNew UAS Policyā€) on exports of US-origin unmanned aerial systems (ā€œUASā€) and a new National Security Presidential Memorandum (ā€œNSPMā€) updating the United States Conventional Arms Transfer Policy (the ā€œNew CAT Policyā€). These changes do not directly impact the export licensing requirements on UAS under the International Traffic in Arms Regulations (ā€œITARā€) or the Export Administration Regulations (ā€œEARā€). However, according to statements made in a press briefing on these developments, the new policies reflect the Trump Administrationā€™s interest in enabling US manufacturers of UAS to ā€œlevel the playing fieldā€ and increase exports of these products to US allies and partners. They also evidence a broader effort to increase considerations of economic interests in arms transfer decisions.