Shortly after taking the oath of office today, newly inaugurated President Trump signed a flurry of Executive Orders (āEOsā) and other executive actions. This include several actions related to US sanctions and export controls. Authority to Designate Cartels as Foreign Terrorist Organizations or Specially Designated Global Terrorists Trump signed an EO Designating Cartels and Other Organizations as Foreign Terrorist Organizations and Specially Designated Global Terrorists. This EO creates a legal authority to designate certain international…
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…
On July 29, 2024, the US Department of State’s Directorate of Defense Trade Controls (“DDTC”) issued a proposed rule (“Proposed Rule”) that would revise the definition of “defense service” and the scope of related controls in the International Traffic in Arms Regulations (“ITAR”). The Proposed Rule was issued following a review by DDTC that identified certain military, cyber, and intelligence services furnished to foreign persons that are not currently controlled or are controlled but for…