ITAR for Facility Security Officers
ITAR for Government Contractors - New Developments for 2018
The Department of Commerce’s Bureau of Industry and Security (BIS) recently issued an interim final rule implementing licensing requirements for these emerging technology products for export to all foreign countries. See the...more
On April 15, the U.S. Department of the Treasury published a proposed rule that would enhance certain Committee on Foreign Investment in the United States (CFIUS or the Committee) procedures and increase CFIUS penalty and...more
On May 1, 2024, the U.S. State Department published a proposed rule to reduce International Traffic and Arms Regulations (ITAR) licensing requirements for the transfer of defense articles or services between the United...more
On April 25, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) announced in a press release that it will publish an interim final rule (IFR) in the Federal Register on April 30, 2024, updating the...more
On March 14, 2024, the U.S. Departments of Commerce and State announced rules restricting a range of exports to Nicaragua, citing the Nicaraguan government’s “campaign of repression and blatant human rights abuses.”...more
The U.S. Department of State (State Department) and U.S. Department of Commerce (Commerce Department), have recently previewed, proposed or finalized changes to relevant trade controls. These new regulatory updates include...more
Most companies that employ non-U.S. persons in the United States are familiar with visa requirements, including completing U.S. Citizenship and Immigration Services Form I-129 – Petition for a Nonimmigrant Worker. However,...more
On January 23, 2020, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) and the U.S. Department of State issued two final rules, available here and here. The final rules outlined the removal of...more
The Committee on Foreign Investment in the United States (CFIUS) is now following new rules on mandatory filings for certain foreign investments in critical technology companies. As a refresher, CFIUS is the US Government’s...more
On June 30, 2020 at 11:00 PM Hong Kong time, the Law of the People’s Republic of China on Safeguarding National Security in the Hong Kong Special Administrative Region (HK National Security Law) took effect....more
On June 29, 2020, the U.S. Departments of State and Commerce announced stricter controls on exports to Hong Kong, withdrawing Hong Kong’s preferential treatment as an autonomous territory. The regulatory changes follow...more
On June 29, 2020, the US Secretary of State and the US Secretary of Commerce announced changes to US export controls in response to recent actions by China involving Hong Kong. These regulatory changes are likely not the last...more
The State Department has adopted an important new ITAR amendment confirming that if controlled technical data is encrypted using end-to-end encryption, the transfer of such data outside the U.S. is not considered an export...more
As part of its years-long project to update and revise the International Traffic in Arms Regulations (ITAR) and better align them with the Export Control Regulations, the Department of State (DoS) recently amended the ITAR...more
The good news is that, for the most part, State resisted the temptation to do something just a little different in the ITAR regulation, so the joint Commerce-State solution works. The chart below provides a quick side-by-side...more
Companies involved in Small Business Innovation Research (“SBIR”) and Small Business Technology Transfer (“STTR”) contracts often are subject to requirements under the International Traffic In Arms Regulations (“ITAR”) and...more
When shipping defense articles or dual-use items overseas, it is important to identify the actual end-user. This task cannot simply be outsourced to a freight forwarder. ...more
In the first two parts of this series, we covered companies’ obligations under U.S. export control laws, such as the Export Administration Regulations (“EAR”) governed by the Department of Commerce, Bureau of Industry and...more
A State Department ITAR enforcement case announced last week involving a supplier of military spare parts sends a valuable message to small and mid-sized government contractors of every type. The case involves Bright Lights...more
Introduction. One of the most important areas of regulation for defense contractors is the International Traffic In Arms Regulations (ITAR). ITAR are the State Department controls that regulate the defense industry. Companies...more
A frequently asked compliance question among government contracts firms is whether they are required to register under the International Traffic In Arms Regulations (ITAR). ITAR are the State Department controls that...more
You are the general counsel or CEO of your company. Your compliance manager comes into your office and tells you that he/she may have discovered an export violation within the company. Or perhaps you have received a directed...more
On September 1, 2016 new rules previously published by the U.S. Department of Commerce, Bureau of Industry and Security (BIS) and the U.S. Department of State, Directorate of Defense Trade Controls (DDTC) will become...more
New rules synchronize Destination Control Statements for EAR and ITAR. On August 17, both the US Commerce Department’s Bureau of Industry and Security (BIS) and the US State Department’s Directorate of Defense Trade...more
One of the most important areas of regulation for defense contractors is the International Traffic In Arms Regulations (“ITAR”). ITAR are the State Department controls that regulate the defense industry. Companies regulated...more