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The policies and processes dictated by the DDTC as they relate to the administration of the ITAR have begun to change. The changes that have occurred and are about to occur relate to the process in which Registrations, License Applications, Advisory Opinions, Commodity Jurisdictions and Voluntary Disclosures are submitted to DDTC.

Huawei Technologies and ZTE Corporation may both soon garner a new title – “Foreign Adversary”. The Federal Communication Commission (“FCC”) has taken the first action, announcing that it plans to vote in November to designate Huawei Technologies and ZTE Corporation as posing national security risks.

In a real baseball game, the players have the goal of staying at bat and not getting out, however, in the game of encryption, you are actually looking to get out. In particular, you want to determine if your item can “get out” of the Category 5 Part 2 controls.

The U.S. Department of Commerce announced sanctions against twenty-eight Chinese governmental and commercial organizations for engaging in or enabling activities contrary to the foreign policy interests of the United States, by adding these organizations to the Entity List. The entities that were listed have been connected to human rights abuses with respect to China’s suppression of rights of the Uighurs and other predominantly Muslim ethnic minorities.

Does your Compliance Manual still define Defense Articles as “specifically designed, developed, configured, adapted, or modified for a military application”? Does it still contain two different Destination Control Statements? Regulations and government policies change. Your manual must stay current with those changes.