On December 11, 2020, DDTC, as published in the Federal Register (85 FR 79836), announced the temporary suspension/modification/exception to help ease continued telework operations during the COVID-19 health emergency. On July 30, 2020, Export Solutions published a blog with information from DDTC concerning relief from several licensing requirements to help companies lessen the burdens the COVID-19 Pandemic on their day-to day operations.
Recognizing the uptick in public health concerns and that many companies will continue with ‘social distancing for the foreseeable future,’ DDTC issued the following extensions through June 30, 2021.
- Remote Work Allowances Continue for Another Six Months
- A temporary suspension, modification and exception to the requirement that a “regular employee”, for purposes of ITAR § 120.39(a)(2), work at the company’s facilities, to allow the individual to work at a remote work location so long as the individual is not located in Russia or a country listed in ITAR § 126.1.
- A temporary suspension, modification and exception to authorize regular employees of licensed entities who are working remotely in a country not currently authorized by a technical assistance agreement, manufacturing license agreement, or exemption to send, receive, or access any technical data authorized for export, reexport, or retransfer to their employer via a technical assistance agreement, manufacturing license agreement, or exemption so long as the “regular employee” is not located in Russia or a country listed in ITAR § 126.1.
Both extensions will give DDTC time to evaluate the possibility of making a major change to the ITAR, as well as give the compliance community the ability to provide their comments to such proposed changes.
Stay tuned to the Export Solutions Blogs for further updates to these particular license exceptions and any other changes that occur to the regulations because of COVID-19. If you need assistance navigating the regulations, please contact Export Solutions for a free consultation.
Beverly Demma is a Sr. Consultant for Export Solutions -- a full-service consulting firm specializing in U.S. import and export regulations.