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 August 15, 2024, the US Department of State’s Directorate of Defense Trade Controls (“DDTC”) published the long-awaited final rule (“Final Rule”), effective September 16, 2024, expanding the definition of “activities that are not exports, reexports, retransfers, or temporary imports” pursuant to Section 120.54 of the International Traffic in Arms Regulations (“ITAR”). Please see our previous blog here when DDTC issued a proposed rule (“Proposed Rule”) to make these changes. The Final Rule adds…
The US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”), the US Department of State (“State”), the US Department of Commerce (“Commerce”), and the US Department of Energy (“DOE”) issued rules adjusting maximum civil monetary penalties (“CMPs”) under the Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015, as outlined below. (For additional years of CMPs, see our previous blog post available here.) OFAC CMP Adjustments Under OFACās final rule issued on January 13,…
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…