On September 3, 2024, the US Department of State’s Directorate of Defense Trade Controls (“DDTC”) issued revised Guidance for U.S. Persons Abroad (“USPABs”) Authorization Requests (“USPAB Guidance”) and updated FAQs on Defense Services and USPABs. Under the International Traffic in Arms Regulations (“ITAR”), all USPABs need DDTC authorization before they can furnish ITAR-controlled defense services to any foreign person, including USPABs’ non-US employers. The principal changes to the USPAB Guidance are as follows:
Join Baker McKenzie and the Customs and International Trade Bar Association (CITBA) National Security and Sanctions Committee for a discussion of top enforcement priorities in sanctions and export controls, best practices for the private sector, and considerations for voluntary self-disclosure. The panelists for this discussion include Ian C. Richardson, Chief Counsel for Corporate Enforcement for the National Security Division of DOJ; John Sonderman, Director of the Office of Export Enforcement at BIS; and Dallas Woodrum,…
On August 23, 2024, the eve of Ukraine’s Independence Day (August 24, 2024), the US Departments of Commerce and Treasury issued new export controls and sanctions in response to Russia’s invasion of Ukraine. The new controls target the procurement networks who support Russia’s war on Ukraine and its military industrial complex and payment channels. The Commerce Department’s Bureau of Industry and Security (“BIS”) made the following changes to the Export Administration Regulations (“EAR”) and…
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…