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…
On March 14, 2024, the U.S. Department of State’s Directorate of Defense Trade Controls (“DDTC”) and the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) announced more restrictive export controls on Nicaragua stated to be in response to the Nicaraguan Government’s human rights abuses, attacks on civil society, and increased cooperation with Russia. The DDTC and BIS press releases are available here and here. DDTC: New ITAR Export Controls The State Department announced…
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…