Category: Export Control Reform Initiative

On December 26, 2019, DDTC issued an Interim Final Ruling which outlined changes to the ITAR and significantly, to ITAR Encryption Rules. My Blog, “When is an Export not an Export” (published on 12/30/2019), discussed in general terms the Interim Final Ruling  and the changes that would become effective on March 25, 2020. Now that the Final Rule is in place…

Effective on the 25th of March 2020, the ITAR will be amended based upon an Interim Final Ruling published by the Department of State on 26 December 2019. In an effort, under Export Control Reform, to further harmonize definitions found in the ITAR and the EAR, the State Department has amended definitions found in the…

The holidays are here, and many of us take this time of year to reflect on all that we have to be thankful for.  If your company is registered pursuant to §122.1 of the International Traffic in Arms Regulations (ITAR), you may well be thankful that the new DECCS Registration Form and Process haven’t been…

This is the second post in a series of blogs about the proposed changes to USML Categories I, II and III.  Please check back for further articles in this series.  For more information about these changes, and the movement of items from ITAR to EAR, check out Part 1 in our series and read the…

This is the first in a series of blogs about the proposed changes to USML Categories I, II and III.  Please check back for more updates soon.  For more information about these changes, and the movement of items from ITAR to EAR, read our post on the latest firearms Export Control Reform updates.   One…

Understanding China’s New Export Laws Lately, everyone is focused on changes to U.S. export control regulations and related trade initiatives (such as the new tariffs and FIRRMA/CFIUS). Export Control Reform will shortly see the transitions of items from USML Categories I, II and III from the ITAR to the EAR. Likewise, the reforms to CFIUS are simply awaiting…

In recent weeks, we’ve seen significant activity from both the legislative and executive branches that could change the way foreign investment occurs in U.S. companies. These changes could also affect the export control compliance requirements of many companies who are targets of foreign investors. Keep reading for a brief history of CFIUS reviews, and the…

In July 2016, the U.S. Department of State, Directorate of Defense Trade Controls (DDTC) announced that it had re-initiated its Company Visit Program for companies engaged in ITAR-controlled work. The stated objectives of this program are: Advance DDTC’s understanding of how different companies establish and maintain an overall defense trade control program to fit the…

Moving one step closer to the Single IT system goal of Export Control Reform, DDTC has acquired a new case management IT system to modernize its business processes. Additionally, DDTC has begun accepting comments related to the new DS-7788 (Application for Permanent Export, Temporary Export or Temporary Import of Defense Munitions, Defense Services and Related…

The clock is ticking! Exporters have just one month (until November 15, 2016) to change the language and use of their Destination Control Statements (DCS). As the U.S. Government moves forward with the harmonization of export regulations under Export Control Reform, the ITAR and the EAR will soon be aligned with respect to the content…