Following Commerce/BIS, State/DDTC Proposes AUKUS Exemption! 

On May 1, 2024, the Department of State, Directorate of Defense Trade Controls (DDTC) issued a proposed rule (89 FR 35028) to create a new license exception to support the AUKUS (Australia, the United Kingdom, and the United States) Trilateral Security Partnership. The proposed exemption includes four main elements: Creates “an exemption to the requirement […]

BIS Announces AUKUS Exemption, DDTC Proposes Fee Increase

BIS Announces AUKUS Exemption On April 19, 2024, the Department of Commerce, Bureau of Industry and Security (BIS) issued an interim final (89 FR 28594) making to the Export Administration Regulations (EAR) to support the AUKUS (Australia, the United Kingdom, and the United States) Trilateral Security Partnership.  In order to streamline defense trade among the […]

New Export Restrictions for Nicaragua: § 126.1 Prohibited Destination and EAR Military End User Rule Now Apply!

Nicaragua Added to ITAR §126.1 Prohibited Destinations On March 15, 2024, the Department of State, Directorate of Defense Trade Controls (DDTC) issued a new rule (89 FR 18796) that adds Nicaragua to the International Traffic in Arms Regulations (ITAR) § 126.1 list of prohibited destinations. The primary rationales of the new listing are based on […]

Export Regulatory and Policy Update Roundup: Winter 2024

Since our last update, more U.S. Government actions have taken place that may affect your business’s export compliance efforts.  Ranging from a five-agency “know your cargo” advisory to revisions of the Commerce Control List (CCL) and inflation adjustments for export-related penalties, we have the highlights below. Multi-Agency Actions Know Your Cargo Advisory Department of State: […]

Export Regulatory and Policy Update Roundup: Fall 2023

Since our last update, more export control actions have taken place that may affect your business.  Ranging from country-specific business advisories to a new ITAR Consent Agreement to major changes to BIS semiconductor controls, we have the highlights below. Multi-Agency Actions Advisory to Industry on Iran Ballistic Missile Procurement Departments of Justice, Commerce, State and […]

State Department Compliance Guidelines Part 2 of 2: Training, Risk Assessment, Audits & Compliance Monitoring, and the ITAR Compliance Manual

In our last newsletter, we reviewed the first four elements of the U.S. Department of State’s Directorate of Defense Trade Controls December 2022 Compliance Program Guidelines.  These Guidelines are intended to provide an overview of an effective ITAR Compliance Program (ICP) and an introduction to defense trade controls. The Guidelines are divided into eight sections: […]

Export Regulatory and Policy Update Roundup: Summer 2023

Since our last post, U.S. export control agencies have continued take actions that may impact your business.  Ranging from the huge multi-agency settlement agreement raising supply chain issues to tweaks to the USML to updated guidance and reports, we have the highlights below. Multi-Agency Actions 3D Systems Corporation Multi-Agency Settlement New consent agreement and settlements […]

State Department Compliance Guidelines Part 1 of 2: Management Commitment, ITAR Activities, Recordkeeping, & Violations

In December 2022, the U.S. Department of State’s Directorate of Defense Trade Controls issued updated Compliance Program Guidelines. These Guidelines are an overview of an effective ITAR Compliance Program (ICP) and an introduction to defense trade controls. The Guidelines are divided into eight sections: Management Commitment DDTC Registration, Jurisdiction & Classification, Authorizations, & Other ITAR […]

DDTC General Licenses for Australia, Canada & the UK, NATO Expansion, and More!

DDTC Publishes First Long Awaited Open General Licenses On July 20, 2022, the Department of State, Directorate of Defense Trade Controls (DDTC) issued a Federal Register Notice (87 FR 43366) establishing two open general licenses. Open General License No.1 and Open General License No. 2 authorize the retransfer and reexport of unclassified defense articles “the […]