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They’re Here! Final Rules to Revise USML Cats. I-III Set to be Published

BIS, CCL, Commerce Dept, DDTC, Defense Trade Controls, EAR, ECCN Changes, ITAR, Press release, State Dept, USML

By: Johanna Reeves, Esq., jreeves@reevesdola.com; Reeves & Dola LLP.  www.ReevesDola.com After almost ten long years of fits and starts and Congressional holds, today the U.S. Departments of State and Commerce released their respective Final Rules to remove most...

New Interim Final Rule Creates End-to-End Encryption Carve-Out for ITAR Technical Data

DDTC, Defense Trade Controls, Encryption, ITAR, State Dept

By: Olga Torres and Derrick Kyle (Torres Law, LLP) The Department of State Directorate of Defense Trade Controls (“DDTC”) has published an interim final rule (“the Interim Final Rule”) seeking public comments and clarifying that certain transfers of encrypted...

ITAR Defense Controls Catches Up to Modern IT, Allowing Exporters to Use Encryption to Protect Defense Technology on the Cloud

Cloud Computing, DDTC, Defense Trade Controls, ITAR, State Dept

By: Kay C. Georgi, Marwa M. Hassoun, Regan K. Alberda, Sylvia G. Costelloe (202-857-6293, Arent Fox LLP) In a surprise holiday present, the State Department finally brought the International Traffic in Arms Regulations (ITAR) into the 21st century by releasing an...

DDTC Publishes FAQs on US Persons Abroad

DDTC, Defense Trade Controls, ITAR, State Dept

On January 6, 2020 the Directorate of Defense Trade Controls (DDTC) published Frequently Asked Questions for guidance on the subject of US persons providing defense services abroad. The guidance addresses questions regarding registration and authorization...

Department of State Creates Definition of “Activities That Are Not Exports, Reexports, Retransfers, Or Temporary Imports”

DDTC, Defense Trade Controls, ITAR, State Dept, USML

The Department of State recently published an interim final rule requesting comments (must have been received by January 27, 2020) based on the idea of creating a definition of “activities that are not exports, reexports, retransfers, or temporary imports.” The...

DDTC Announces Commodity Jurisdiction Form Live

DDTC, Defense Trade Controls, Export License, ITAR, Licensing, Press release, State Dept

The new collection format for Commodity Jurisdiction form DS-4076 is now available on the DDTC DECCS portal.  The changes address additional sources of jurisdiction considerations and refinements to the supporting information. All previous submissions to the...
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