Category: Export Control Reform Initiative

This is the third 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 and Part 2 in our series...

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...

On May 24, 2018, the Departments of State and Commerce published proposed revisions to U.S. Munitions List (USML) Categories I, II, and III in the Federal Register. These three categories would be the last USML categories to be revised under the Export Control Reform Initiative – a process that began more than nine years ago...

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 the President’s signature, and the...

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...

Effective October 14, 2016, BIS has amended the Export Administration Regulations to allow for electronic submission of reporting requests U.S. persons receive to take action in furtherance or in support of an unsanctioned foreign boycott. Prior to this, reports were only permitted to be submitted by mail using BIS 621-P or BIS 6051-P. These can...

Traditionally Export Related Voluntary Disclosures/Voluntary Self-Disclosures have been filed with DDTC, BIS, OFAC or occasionally the Bureau of Census. Each of these agencies encourages companies and individuals to file the Disclosures and they provide an incentive in that the filing can be considered as a mitigating factor to the violation(s) committed. The number of agencies...

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...