The Directorate of Defense Trade Controls (“DDTC”) within the US State Department recently issued a number of announcements regarding submissions related to Mergers, Acquisitions, and Divestitures (“MAD”) of US businesses regulated under the International Traffic in Arms Regulations (“ITAR”). These changes by DDTC were prompted by the COVID-19 crisis and end the need for parties in MAD transactions involving ITAR-regulated entities to submit hard copies to DDTC. By way of background, ITAR Section 122.4(b) requires…
On July 15, 2020, the US Department of State (“State Department”) updated its guidance (“Updated Guidance”) regarding the implementation of Section 232 of Title II of the Countering America’s Adversaries Through Sanctions Act (“CAATSA” see our previous blog post on CAATSA here and our previous blog post on the 2017 State Department guidance on CAATSA Section 232 here). The Updated Guidance expands the scope of CAATSA Section 232 to target certain investments or other activities related to the…
On May 29, 2020, the president announced in a White House press conference the Administration’s determination that Hong Kong is no longer sufficiently autonomous from the People’s Republic of China (“PRC”), and that the US Government would take “strong and meaningful” steps to “begin the process” of reviewing and revoking the “full range of agreements” that currently provide Hong Kong with preferential treatment under US law. This determination follows Secretary of State Michael Pompeo’s certification…
As of May 1, the State Department has made a temporary change in the Tier I, Tier II, and new registrant payment guidelines on the Directorate of Defense Trade Controls (“DDTC”) website to reflect certain reduced registration fees to mitigate the economic impact of the COVID-19 pandemic. The DDTC is reducing fees for Tier I and Tier II registrants to $500 (reduced from $2,250 and $2,750, respectively) for registrations whose original expiration date is between…