Export Regulatory and Policy Update Roundup: July 2026

DDTC Proposes Changes to Part 130 Reporting

On June 15, 2026, the Department of State, Directorate of Defense Trade Controls (DDTC) published a proposed rule (91 FR 35926) which would revise Part 130 of the International Traffic in Arms Regulations (ITAR) which relates to reporting of political contributions, fees and commissions.

Under the proposed rule, the primary changes would be to:

  1. Increase the monetary thresholds that trigger Part 130 reporting obligations,
  2. Consolidate reporting into a single annual submission, and
  3. Implement an electronic submission form for Part 130 reporting.

Part 130 thresholds were last adjusted in 1993 and apply to defense articles and defense services valued at $500,000 or more and sold commercially to or for the use of the armed forces of a foreign country or international organization.  Under the proposed changes, that dollar value would increase to $1 million.  Thresholds for reportable amounts would similarly increase.

Comments on the proposed changes will be accepted through August 14 ,2026

DDTC Updates Agreements Guidelines

On June 26, 2026, DDTC released Revision 5.2 of the Guidelines for Preparing Agreements.  The changes are largely administrative, including updates to reflect the § 126.7 AUKUS exemption and to clarify identification of systems and platforms should include variants thereof.  A summary of changes is included on page 2 of the updated Guidelines.  The guidelines were last updated in 2022.

Ethiopia to be Removed from ITAR §126.1

On May 11, 2026, DDTC announced that the U.S. has terminated the arms embargo on Ethiopia and that DDTC has removed the policy of denial and will review license applications for ITAR-controlled activities involving Ethiopia on a case-by-case basis. Ethiopia was added to the ITAR § 126.1 in 2021.

The Federal Register Notice removing Ethiopia from the list of countries in § 126.1 has not yet been published. Licenses may be submitted for Ethiopia, but other ITAR restrictions related to § 126.1 countries remain in effect.

Syria Removed from Antiterrorism Non-Cooperation List

On May 19, 2026, the Department of State published a notice (91 FR 29247) updating the list of countries that are not cooperating fully with U.S. antiterrorism efforts.

Those countries are Cuba, Democratic People’s Republic of Korea, Iran, and Venezuela.  Of note, this removes Syria from the list.

Syria remains on the ITAR 126.1 prohibited destination list and Country Group E:1 (terrorist supporting countries) under the Export Administration Regulations.  It is also subject to country-specific license requirements under EAR § 746.9.

OFAC Publishes Guidance on Sham Transactions and Sanctions Evasion

On March 31, 2026, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) published a sanctions advisory on sham transactions and sanctions evasion.  The advisory provides examples and red flags for transactions that may be intended to evade U.S. sanctions.

OFAC Guide Published

On June 1, 2026, OFAC published the “Introduction to the Office of Foreign Assets Control.”   This document provides useful background on OFAC, its mission, and compliance considerations.