Our “EAR”... to the ITAR
Answers to your questions about U.S. export controls
from
ECS expert trainers and consultants.
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 […]
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: […]
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 […]
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: […]
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 […]
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 […]
Since our last post, there have been actions throughout the various export control agencies that may impact your business. Ranging from the new Conventional Arms Transfer Policy to tweaks to the USML and CCL to CFIUS country policies to new sanctions, we have the highlights below. White House: CAT Policy The White House released an […]
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 […]
ITAR Reorganization Begins With Definitions in Part 120 On March 23, 2022, the Department of State, Directorate of Defense Trade Controls (DDTC) issued an interim final rule (87 FR 16396) that will consolidate International Traffic in Arms Regulations (ITAR) definitions into ITAR Part 120. The long-awaited rule is effective September 6, 2022 and begins what […]
Blizzard of Sanctions Hits Russian Businesses: US Government Restrictions Continue to Expand Following the Russian invasion of Ukraine in February, we saw a near-daily ratcheting-up of sanctions intended to target the Putin regime, Russian oligarchs, and others identified as supporters. The highlights of this ever-changing effort are outlined below. Two Crucial Takeaways Continuous screening of […]