Category: ITAR

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...

Updated 1/23/2020 Is Your Company's Understanding Of ITAR Procedures Flawed? Earlier this month, I was reading some articles online and found the following statement about a company and its ITAR requirements (bold emphasis mine): Export-controlled technical data has a unique set of rules designed to ensure that it is not inadvertently released or “exported” to...

Updated 1/14/2019 The ITAR Exemption Handbook Intro Many people focus on the need to obtain an ITAR license, without first considering whether or not an exemption may apply to their transaction. What is an ITAR exemption? Simply put, an exemption is a set of conditions which – if met – allow you to ship to...

Updated 1/09/2020 Navigating The Confusing Landscape Of Distribution Statements Have you ever been frustrated or stymied by those DoD Distribution Statements concerning Critical Technology, which appear to prohibit U.S. contractors from sharing the data with their partners in Canada? If so, you’re not alone! Well, there is a way to work within the framework of...

The Export Solutions blog provides timely and helpful information to anyone who is responsible for import/export compliance.  If you haven’t subscribed yet, join our growing community by subscribing now to stay current on all that’s happening in the world of trade compliance. As we say goodbye to 2019, let’s take a look at our top...

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...