ITAR for Facility Security Officers
ITAR for Government Contractors - New Developments for 2018
On August 30, 2024, the U.S. Department of State’s Directorate of Defense Trade Controls (“DDTC”) announced the settlement of a record $200 million administrative enforcement action with RTX Corporation—a multinational...more
On December 21, 2023, the Department of Defense (DoD) issued a memorandum (Memo) providing guidance and clarification on the security and cyber incident management requirements applicable for the use of external Cloud Service...more
According to the National Center for Science and Engineering Statistics (“NCSES”), a key driver in the scientific and technological accomplishments of U.S. research universities is the volume of federal support for research...more
On October 28, 2022, on the eve of the mid-term elections, a bill was introduced in the House that, unless you are an export control/compliance nerd, most would not have given it any thought. This bill, H.R. 9241, called the...more
On September 15, President Biden issued the first ever executive order (E.O.) regarding the Committee on Foreign Investment in the United States (CFIUS). While the E.O. does not change the law or regulations related to CFIUS...more
Matthew Axelrod, the Assistant Secretary of Commerce for Export Enforcement with the Department of Commerce, recently made two important statements on how the Department will enforce trade controls and address violations....more
The Assistant Secretary for Export Enforcement Matthew S. Axelrod announced last week at the National Association of College and University Attorneys (NACUA) 2022 Annual Conference a new “Academic Outreach Initiative” by the...more
The Canadian Institute’s 11th Annual Forum on U.S. Export & Re-Export Compliance for Canadian Operations will take place in Toronto on January 25–27! IN-PERSON and LIVESTREAM options available. Over the last decade, this...more
On 23 December 2020, BIS created a new Military End User List, naming more than 100 Chinese and Russian companies subject to the enhanced licensing requirements of section 744.21 of the EAR....more
On December 23, 2020, the U.S. Department of Commerce Bureau of Industry and Security (BIS) issued the anticipated list of designated military end users (MEU List) under Section §744.21 (MEU Rule) of the Export Administration...more
For a whole decade, ACI’s U.S. Export & Reexport Compliance for Canadian Operations conference continues to stand apart as the only practical, comprehensive event of its kind for the export compliance community in Canada. ...more
In his last days, President Trump takes a swipe against companies identified by the Department of Defense (DoD) as Communist Chinese military companies by prohibiting US persons from investments. On November 12, 2020,...more
While the pandemic has slowed down many things this year, it did not impede progress by the Department of Commerce’s Bureau of Industry and Security (“BIS”) in publishing various regulatory changes aimed at addressing...more
The US Department of Commerce, Bureau of Industry and Security (BIS) issued a final rule amending the license review policy for items on the Commerce Control List that are controlled for national security (NS) reasons and are...more
Our International Trade & Regulatory Group investigates the connection between the Department of Commerce’s tightening of export control restrictions and the Department of Defense’s public release (for the first time) of 20...more
The title of this article is based on a line in an old song, “Everybody’s Crying Mercy,” by Mose Allison. As modified, the couplet captures the cognitive dissonance that many are feeling as a result of the federal...more
On December 20, 2019, President Trump signed into law the National Defense Authorization Act for Fiscal Year 2020 (“NDAA 2020”), which includes numerous sanctions-related provisions. The law includes the previously introduced...more
On November 19, 2018, the Bureau of Industry and Security, U.S. Department of Commerce (BIS) published an advance notice of proposed rulemaking (ANPRM) soliciting comments on the criteria to be used to identify emerging...more
ANTICORRUPTION DEVELOPMENTS - Petrobras Settles with U.S. Authorities Over Alleged FCPA Violations - On September 27, 2018, the U.S. Department of Justice (DOJ) and the Securities and Exchange Commission (SEC)...more
On August 13, 2018, President Donald Trump signed into law the John S. McCain National Defense Authorization Act (NDAA) for fiscal year 2019. A key focus of legislation contained in the NDAA is to protect U.S. technological...more
ANTICORRUPTION DEVELOPMENTS - $34 Million SEC Settlement for Legg Mason - On August 27, 2018, the Securities and Exchange Commission (SEC) announced that Legg Mason Inc. will pay more than $34 million to settle an...more
On March 14, 2018, the House Committee on Foreign Affairs held a hearing titled “Modernizing Export Controls: Protecting Cutting Edge Technology and U.S. National Security” to examine the proposed Export Control Reform Act...more
ITAR is an important area of regulation for government contractors. This includes firms in the defense, technical services, information technology, cyber-security, military training and DOD-funded R&D fields. These...more
Under DFARS Clause 252.204-7012, certain government contractors that store, process or transmit technical information that is controlled under the International Traffic In Arms Regulations (“ITAR”) or the Export...more
Based on certain State Department findings, effective October 12, 2017, long-standing U.S. sanctions on the Republic of Sudan administered by OFAC under the Sudan Sanctions Regulations will be terminated, and U.S. persons...more