Category: ITAR

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 our country’s special relationship with Canada, via the United...

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 exemption? Simply put, an exemption is a set of conditions which – if met – allow you to ship to your destination without the need to obtain an...

I’m something of a “news junkie.” If you’re like me, then you are constantly hearing about certain countries that can’t seem to keep themselves out of the news. You may even occasionally hear the name of a country that your company either does business with, or is contemplating as a customer. There are many ways...

‘Twas noon on a Friday, and at the warehouse, People were scurrying to get that last export out. Sales was yelling and customers mad, "Our shipment is late! Where is that iPad®?" Everyone was juggling, each with more than one hat, "Have all the parties been screened? Is there encryption on that?" Classification and screenings...

In my last blog article, we examined the Specially Designed Decision Tool. Today, we will explore the new “Catch and Release” concept when determining if a product meets the definition of “Specially Designed.” First, here is the definition in the current ITAR. [My Notes will be in brackets, boldface, and Italics. All underlines are my...

This is the first in a series of articles called Tools of the Trade, where we will highlight some of the most useful tools and resources for export compliance professionals. Keep checking back for future installments! Classification of items (products, software, technology, etc.) is at the heart of any compliance program. Never has this been...

This week, the Departments of Commerce and State revised export controls on most commercial, scientific and civil satellites, as well as their parts and components. This move is another key step forward in the Export Control Reform Initiative. For those of you who have been in trade compliance long enough, you will remember that this...

Yesterday, the Department of State, Directorate of Defense Trade Controls (DDTC) amended the International Traffic in Arms Regulations (ITAR) regarding defense trade policy with respect to the Central African Republic. This change is intended to reflect recent resolutions adopted by the United Nations (UN) Security Council. Effective immediately, the Central African Republic has been added...

Earlier this month, Esterline Technologies Corporation agreed to pay a $20 million civil penalty for alleged violations of the International Traffic in Arms Regulations (ITAR). According to the State Department’s charging letter, these violations span a number of years, and cover various subsidiaries and departments within the company. Although the charges against the company are...

As of January 1, 2014, all users of DDTC’s DTrade system are required to have the updated version of their digital certificate, which we originally reported on this blog in September. If you still have not upgraded to the SHA-256 certificate, it’s important to do so immediately to avoid delays in your export license processing....