Rolling Out a New Export Control Regime During a Government Shutdown

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Venable’s International Trade and Customs Practice Group is publishing a five-part series of Client Alerts to highlight the changes surrounding the ECR (Export Control Reform). Below is Part IV of the series.

- Part I: State Department Publishes Long-Awaited Interim Final Rule Amending ITAR Brokering Provisions

- Part II: October 15th Export Control Reform Changes Are Around the Corner: Take Time Now to Understand the Impact on Your Existing Licenses & Authorizations

- Part III: License Exception Strategic Trade Authorization: Understanding How It May Work for You

- The first of the President’s Export Control Reform (ECR) initiatives takes effect today, October 15, 2013. As noted in Part II of this series, the Final Rules taking effect today are the first to transfer jurisdiction of certain less-sensitive military items – specifically aircraft and related materials and gas turbine engines – which are currently controlled on the U.S. Munitions List and governed by the State Department’s International Traffic in Arms Regulations (ITAR), to the Commerce Control List under the Commerce Department’s Export Administration Regulations (EAR). Today also marks the third week of the Federal Government shutdown. The Final Rules will still be effective as of today; however, because of the shutdown, it is unclear how the significant number of new licenses for “600 Series” items under the jurisdiction of the Department of Commerce Bureau of Industry and Security (BIS) will be handled.

Please see full alert below for more information.

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