On September 3, 2024, the US Department of Stateâs Directorate of Defense Trade Controls (âDDTCâ) issued revised Guidance for U.S. Persons Abroad (âUSPABsâ) Authorization Requests (âUSPAB Guidanceâ) and updated FAQs on Defense Services and USPABs. Under the International Traffic in Arms Regulations (âITARâ), all USPABs need DDTC authorization before they can furnish ITAR-controlled defense services to any foreign person, including USPABsâ 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…
The Bureau of Industry and Security (“BIS”) issued an interim final rule (“IFR”), effective on April 19, 2024, amending the Export Administrations Regulations (“EAR”) to ease most licensing restrictions on exports/reexports to and within Australia and the UK of items subject to the EAR. This is a key change in that export licensing requirements under the EAR for Australia and the UK are now largely similar to those for Canada. The driver for this was…