Venable’s International Trade and Customs Practice Group is publishing a four-part series of Client Alerts to highlight the changes surrounding the ECR (Export Control Reform). Below is Part 1 of the series.
On August 26, 2013, the U.S. State Department’s Directorate of Defense Trade Controls (DDTC) published an Interim Final Rule that makes significant changes to the current definitions of "broker" and "brokering activities" in Part 129 of the International Traffic in Arms Regulations (ITAR). The much-anticipated Interim Rule will go into effect on October 25, 2013.
The ITAR’s brokering provisions implement the Arms Export Control Act’s requirement that persons engaged in the business of brokering arms be registered with the State Department. As currently written, the brokering provisions are generally considered ambiguous because they fail to precisely define those activities that constitute "brokering activities." As such, questions as to what triggered the requirements of the ITAR brokering provisions, including requirements for registration, reporting, and obtaining "prior approval," were pervasive under the old rules.
Please see full alert below for more information.
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