Permanent vs. Temporary Imports: Where the ITAR Meets the ATF

Imports, ITAR, USML

As people become skilled at navigating the International Traffic in Arms Regulation (ITAR), they’re often surprised to learn that it not only places controls on exports, but that it also has something to say about temporary imports. In one of the more succinct...

They’re Here! Final Rules to Revise USML Cats. I-III Set to be Published

BIS, CCL, Commerce Dept, DDTC, Defense Trade Controls, EAR, ECCN Changes, ITAR, Press release, State Dept, USML

By: Johanna Reeves, Esq., jreeves@reevesdola.com; Reeves & Dola LLP.  www.ReevesDola.com After almost ten long years of fits and starts and Congressional holds, today the U.S. Departments of State and Commerce released their respective Final Rules to remove most...

Department of State Creates Definition of “Activities That Are Not Exports, Reexports, Retransfers, Or Temporary Imports”

DDTC, Defense Trade Controls, ITAR, State Dept, USML

The Department of State recently published an interim final rule requesting comments (must have been received by January 27, 2020) based on the idea of creating a definition of “activities that are not exports, reexports, retransfers, or temporary imports.” The...

Whether to Voluntarily Disclose Potential ITAR Violations and the Lesson from L3Harris

DDTC, Defense Trade Controls, Enforcement, ITAR, USML, Violations & Fines

By: Christopher B. Monahan, Esq., cmonahan@winston.com, 1-202-282-5778; and Adeoye O. Johnson, aojohnson@winston.com, 1-202-282-5293; both of Winston & Strawn LLP. Source:...

DDTC Posts FAQ Concerning the Manufacture of Integrated Circuits

DDTC, Defense Trade Controls, State Dept, USML

Question: We manufacture integrated circuits (ICs) that are unique for defense articles and include programmable elements. Are these ICs described by USML Category XI(c)(1)? How does Note 3 to USML Category XI(c)(1) apply when the programmable elements are...

State Department Revises Licensing Exemption for Transfers Made by or for a Department or Agency of the US Government

DDTC, Defense Trade Controls, Export License, ITAR, Licensing, Press release, State Dept, USML

On April 19, 2019, the Department of State released the final rule related to the International Traffic in Arms Regulations (ITAR) § 126.4. The ruling expands and clarifies under which circumstances transfers of defense articles and services by or for a Department...