Category: ITAR

After over 15 years of maintaining the same fee structure for International Traffic in Arms Regulations (ITAR) registration, the U.S. State Department has proposed amendments to increase the fees required for Directorate of Defense Trade Controls (DDTC) enrollment. As a reminder, the export regulations require registration for those engaged in manufacturing, exporting, temporarily importing, or brokering of…

In September 2021, the announcement of the AUKUS pact between Australia, the United Kingdom, and the United States sent shockwaves through the international community. This trilateral security partnership, aimed at enhancing maritime security, emerging technologies, and defense capabilities in the Indo-Pacific region, has since captured global attention. In response to this significant development, the U.S….

Adding to a list of seemingly never-ending problems, the Boeing Company recently agreed to pay a $51 million civil penalty for violating U.S. export regulations, specifically the International Traffic in Arms Regulations (ITAR) and Arms Export Control Act (AECA).  The company also agreed to remedial compliance measures and entered into a Consent Agreement with the…

Deemed export laws are complicated.  They can be confusing for all people – even Elon Musk.  The serial entrepreneur and founder of SpaceX recently tweeted an (inaccurate) interpretation of U.S. export controls laws.  This stems from the Department of Justice suing SpaceX for alleged discriminatory hiring practices. Musk tweeted: US law requires at least a…

In the 2008 comedy Burn After Reading, Brad Pitt and Francis McDormand play two clueless gym employees who try (and fail) to make money selling government secrets.  And while bribery, espionage and money laundering sound like all the good plot points for any spy comedy, you don’t expect to find them in the real world…

On July 26th, U.S. government agencies published a “tri-seal note” describing the Voluntary Self-Disclosure (VSD) policies applicable to export controls.  This is the second joint document issued by three key U.S. regulators – the Department of Commerce, Bureau of Industry and Security (BIS), the Department of the Treasury, Office of Foreign Assets Control (OFAC), and…

Do you think export control laws take precedence over employment laws?  Think again. Recently, two settlement agreements between the Department of Justice (DOJ) and U.S. companies highlight the complicated scenarios faced by many HR departments today.  Let’s take a closer look at General Motors and American CyberSystems Inc. More importantly, let’s find out what can…

Export compliance can sometimes feel like a jigsaw puzzle that keeps adding pieces faster than you can find out where they go.  In recent years, these regulations continue to change and become more complex.  (Just count the pages in the Federal Register notices.  They keep piling up!)  Now more than ever, it’s crucial to understand…

In the Chinese zodiac, 2023 is the Year of the Rabbit.  The rabbit symbolizes many different attributes, including cautiousness and self-protection.  During a recent gathering of trade compliance professionals, I heard someone mention that 2023 is “the year of export enforcement.”  I must say that I agree.  These two types of “years” seem to fit…

“We don’t export anything.” This is something we hear all the time.  Sometimes, it’s followed by: “Well, we do ship stuff to Canada.  Does that count?”  (Pro Tip:  Yes, it counts.)  But other times, our clients really don’t put something in a box and send it to a foreign country.  Yet, they still need help….