ITAR for Facility Security Officers
ITAR for Government Contractors - New Developments for 2018
On July 24, 2024, the Commerce Department’s Bureau of Industry and Security (BIS) announced amendments to the U.S. Export Administration Regulations (EAR), expanding the reach of U.S. export jurisdiction over certain...more
The U.S. government’s primary export control regulator – the Bureau of Industry and Security (BIS) within the Commerce Department – issued a new rulemaking to remove barriers from U.S. companies’ participation in...more
On April 19, 2024, the Department of Commerce Bureau of Industry and Security (“BIS”) published an interim final rule (“Interim Rule”), amending the Export Administration Regulations (“EAR”) to enhance cooperation and...more
In an interim final rule published on April 19, 2024 (New Rule), the Department of Commerce, Bureau of Industry and Security (BIS) amended the Export Administration Regulations (EAR) to reduce licensing requirements on...more
On Tuesday, October 17, 2023, the U.S. Bureau of Industry and Security (BIS) released a package of three rules (the 2023 Rules) targeting the Chinese semiconductor industry. The rules update the substantial semiconductor...more
In recent years, the U.S. has pursued a whole-of-government approach to target Chinese technology and service providers in furtherance of foreign policy and national security objectives....more
Ongoing tensions between the United States and China have resulted in an expansion of U.S. export controls and trade sanctions against China. The Biden Administration’s October 2022 National Security Strategy (“2022 NSS”)...more
On October 7, 2022, the Biden Administration announced new restrictions on exports to China of advanced integrated circuits (“ICs”), computers and components containing advanced ICs, semiconductor manufacturing equipment, and...more
Based on consistent comments by the US Congress, think tanks, and the US-China Economic and Security Review Commission, several members of Congress proposed legislation to shift jurisdiction for export controls from Commerce...more
The Announcement On Friday, October 7, 2022, the U.S. Bureau of Industry and Security (BIS) released for public inspection (available ...) one hundred forty pages of regulations (which we’ll call “the Regulation” here) that...more
Regulatory compliance is critical for any business involved in the export of defense related commodities. Violations under the International Traffic in Arms Regulation (ITAR) or the Export Administration Regulations (EAR) can...more
Outsourcing the design and manufacturing of products, components and software to foreign contractors has become a significant part of manufacturing in the U.S. However, if the items involved are subject to U.S. export...more
When most people think of exports, they imagine the movement of merchandise across international borders. However, an export can happen without having to leave the United States, such as in your office breakroom, by storing...more
On September 28, the U.S. Commerce Department, Bureau of Industry and Security (BIS) announced that it has imposed a civil penalty fine and denial of export privileges against Vorago Technologies (Vorago) for the unauthorized...more
On August 3, 2021, the U.S. State Department Directorate of Defense Trade Controls (DDTC) issued an order laying out charges and imposing a monetary penalty of $6.6 million on Keysight Technologies, a U.S. technology and...more
On February 1, the U.S. Commerce Department, Bureau of Industry & Security (BIS), announced a settlement (available here) with Princeton University in connection with 37 alleged violations of the Export Administration...more
United States export control, sanctions, and foreign investment (CFIUS) regulations advance U.S. national security and foreign policy interests, but in very different ways. They are also quite complex. As a result, media...more
On June 29, 2020, the Commerce Department issued 32 Frequently Asked Questions (FAQs) concerning revision - effective as of the same date - to Part 744.21 of the Export Administration Regulations (EAR). As we discussed in a...more
In response to the announcement on Friday by the U.S. Department of Commerce of new export-related restrictions targeting Huawei Technologies Co., Ltd. and several of its non-U.S. affiliates (collectively, Huawei), Sen. Ben...more
The U.S. Department of Commerce's Bureau of Industry and Security (BIS) on April 28, 2020, published two final rules and one proposed rule that amend the Export Administration Regulations (EAR), with the goal of limiting the...more
On January 6, 2020 the Bureau of Industry and Security (“BIS”) within the Commerce Department adopted export licensing requirements on certain artificial intelligence software used to automate the analysis of geospatial...more
Key Points - On January 6, 2020, BIS published an interim final rule to add a new worldwide (minus Canada) unilateral export control on a type of geospatial imagery software specially designed for training Deep...more
This software now requires a BIS authorization to be exported or reexported to all countries except for Canada. Companies that develop or use artificial intelligence (AI) to solve geospatial problems or in geospatial...more
The US State Department is soliciting feedback on its draft “US Government Guidance for the Export of Hardware, Software, and Technology with Surveillance Capabilities and/or Parts/Know-How,” issued September 4, 2019 (Draft...more
The Directorate of Defense Trade Controls (“DDTC”) issued a long-awaited revision to the ITAR license exemption at ITAR §126.4 for transfers by or for agencies of the U.S. Government. The amendment clarifies and expands the...more