Category: ITAR

Business Has Changed, It’s Time For Trade Compliance To Change, Too As the business world adapts to face masks, Zoom calls and social distancing, the trade compliance community is also re-evaluating the way it does business. While a lot has changed in your business, one thing that is certain to change – and, in fact,…

No one wants to really talk about trade compliance or acknowledge if it is lacking or non-existent. Not only is trade compliance an overwhelming and complicated mix of regulations, it is also something that puts most people to sleep! Often times employees think someone else is handling import compliance, but nobody is fully dedicated to…

During tough economic times with layoffs, downsizing and budget cuts, companies look for ways to save money and deliver results more efficiently. Like other aspects of your business, you might be in a position where you need to find ways to cut costs while maintaining a high level of standards for your import and export…

Effective May 1, 2020, the Directorate of Defense Trade Controls announced a temporary reduction in fees due to the impact of the COVID-19 pandemic on the national economy and the Defense Industrial Base. The full notice can be found on the Federal Register. They key objectives of the measure are to: Temporarily reduce registration fees…

The Directorate of Defense Trade Controls (“DDTC”) announced on April 23, 2020 the following measures to lessen the burden that the COVID-19 pandemic is having on U.S. companies and the overseas supply chains in order to help the exporting/importing community. Below is a summary of those measures. The full notice can be found on the…

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…

Benjamin Franklin once stated that “Out of Adversity Comes Opportunity.” COVID-19 is the adversity- a tremendous difficulty. Companies forced to close their doors, employees laid off, lockdowns and stay-at-home orders could not be more adverse or difficult to our way of life; yet it is an unfortunate reality. Opportunities in Adversity So where are the…

On January 29,2020, Airbus SE of the Netherlands became another cog in the wheel of export enforcement. Airbus agreed to a settlement with DDTC of $10 million covering 75 violations of the Arms Export Control Act (AECA) and Part 130 of the ITAR for the time period 2011 through 2019. Outline of Violations The violations…

The transition of Defense Articles from the ITAR (USML Categories I, II, and III) to the Export Administration Regulations (EAR) is here. The Final Rule published by Department of Commerce and the Final Rule published by Department of State will be effective on March 8, 2020. Are you ready? The regulatory language has been circulated…

Updated 1/23/2020 Choosing An ITAR Consultant For Your Business Let’s face it:  the world is rife with export “experts.”  One way to handle this is to ignore the problem and pretend that ITAR compliance doesn’t matter. If you want to take this approach, it’s certainly your choice. Another option is to ask questions that will…