What is considered ITAR? Historically, the answer to that question has been very far-reaching and intentionally broad – encompassing a wide array of end items, sub-assemblies, components, materials and services. However, a recent proposed rule by the DDTC (and a concurrent rule from BIS), is proposing to change all that. If made final, this new…
Earlier this week, I was updating our list of common ITAR exemptions and noticed that several have been added in recent weeks or months. As with most exemptions, these are narrowly defined and you, as the exporter, must be careful to meet all criteria outlined in the ITAR before proceeding. Some of the recent ITAR…
Earlier this month, DDTC made final a new exemption for certain exports to the United Kingdom in §126.17 of the ITAR. This exemption is pursuant to the recent Defense Trade Cooperation Treaty between the United States and the United Kingdom. How much is this new exemption going to help your company’s ITAR compliance? And more…
Apparently, DDTC has encountered some glitches in its new process for online payment of ITAR registration fees. According to a recent notice on its website, DDTC states that a number of U.S. registrants have experienced difficulties transmitting ACH payments. Now the agency is offering an alternative method using FedWire. This brings the total number of…
DDTC’s proposed new rule on dual and third-country nationals (DN/TCN) becomes final August 15, 2011. We previously blogged about that new rule here, in case you missed it. In preparation for the implementation of these provisions, DDTC has published a variety of guidelines and answers to frequently asked questions about the new 126.18 exemption. Thankfully, these documents provide more…
The Bureau of Industry and Security (BIS) today announced the implementation of the latest license exception under the EAR – the Strategic Trade Authorization (STA) exception. In a nutshell, STA allows for the export, re-export and in-country transfer of a variety of items subject to the EAR – without a license – to 36 different…
You’ve heard of DTrade. You’ve been to SNAP-R. Now get ready to experience a whole new system for submitting export licenses online … USXPORTS. In recent meeting minutes published by the Defense Trade Advisory Group (DTAG), the Assistant Secretary for Political Military Affairs, Andrew Shapiro, announced the migration of all current export license processing systems to a single platform…