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…
On December 5, 2022, the US Department of State’s Directorate of Defense Trade Controls (“DDTC”) issued the International Traffic in Arms Regulations (“ITAR”) Compliance Program Guidelines (“ITAR Guidelines”). The ITAR Guidelines set out DDTC’s expectations for an effective ITAR Compliance Program (“ICP”) and an introduction to controls contained in the Arms Export Control Act and ITAR. More specifically, the ITAR Guidelines outline key elements of an effective ICP, and identify suggestions, common compliance pitfalls, and/or…
Following initial announcements last year, on July 20, 2022, the US Department of State’s Directorate of Defense Trade Controls (“DDTC”) published two Open General Licenses (“OGLs”) permitting certain reexports and retransfers to certain parties under the International Trade in Arms Regulations (“ITAR”). The OGLs, which are part of a DDTC pilot program, will be valid for one year, effective from August 1, 2022 through July 31, 2023. The related DDTC fact sheet can be found…
On December 9, 2021, the US Departments of State and Commerce amended their regulations to strengthen US export controls targeting Cambodia. According to the Federal Register notices announcing these final rules, these enhanced export control measures were adopted in response to the expanded Chinese military presence in Cambodia, as well as the corruption and human rights abuses allegedly committed by the Cambodian Government. This action builds on various public statements from the US Government this…