Our “EAR”... to the ITAR
Answers to your questions about U.S. export controls
from
ECS expert trainers and consultants.
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 […]
On February 2, 2022, the Department of State, Directorate of Defense Trade Controls (DDTC) issued a proposed rule (87 FR 5759) that would make multiple revisions to the International Traffic in Arms Regulations (ITAR). The most significant of these revisions would scale back the longstanding approach toward determining the nationality of foreign persons, to an […]
Cambodia Added to ITAR §126.1 Prohibited Destinations On December 9, 2021, the Department of State, Directorate of Defense Trade Controls (DDTC) issued a new rule (86 FR 70053) that adds Cambodia to the International Traffic in Arms Regulations (ITAR) § 126.1 list of prohibited destinations. After Russia and Ethiopia, this is the third country added […]
Since our last update, the Department of Commerce, Bureau of Industry and Security (BIS) has released a small flurry of new and proposed technology controls, continuing its review of emerging technologies required by ECRA and ongoing negotiations within the Wassenaar Arrangement. BIS Expands Controls on Cybersecurity Items, Creates New License Exception ACE On October 21, […]
Ethiopia Sanctions and 126.1 Following the announcement of sanctions targeting the conflict in Ethiopia on September 17, the Department of State, Directorate of Defense Trade Controls (DDTC) announced on its website that it intends to add Ethiopia to ITAR §126.1 and revise the entry for Eritrea. While the main effect of this change will be […]
DDTC Proposes Revised Definition of “Regular Employee” On May 27, 2021, the Department of State, Directorate of Defense Trade Controls (DDTC) issued a proposed rule (86 FR 28503) to revise the International Traffic in Arms Regulations (ITAR) §120.39 definition of “regular employee.” Following temporary measures adopted for the COVID-19 pandemic, the proposed amendment would permanently […]
Russia to Rejoin 126.1, Individuals and Entities Face Additional Sanctions On March 2, 2021, the U.S. Department of State announced a series of new sanctions related to “The Russian Federation’s Use of a Chemical Weapon in the Attempted Assassination of Russian Opposition Figure Aleksey Navalny in August 2020 and his Subsequent Imprisonment in January 2021.” […]
January saw a number of updates to export compliance regulations and policies to close out a number of Trump administration initiatives. On January 20, 2021, the Biden administration announced a regulatory freeze. How do these relate? Read on. Regulatory Freeze Let’s start with the regulatory freeze, since what everyone wants to know is whether new […]
In a flurry of activity in December, the Department of Commerce, Bureau of Industry and Security (BIS), updated licensing policies for countries near and far. The updates will have notable impacts on license exemption availability as described below. Hong Kong no Longer a Separate Destination On December 23, 2020, BIS issued a final rule (85 […]