DDTC

News & Analysis as of

Company Fined $100,000 for Export Violation Involving H-1B Employee

Microwave Engineering Corp., a Massachusetts-based microwave components company, has agreed to pay a $100,000 penalty to the U.S. Department of State’s Directorate of Defense Trade Controls (DDTC) for allowing an H-1B...more

Contracting Globally - Part 2: International Traffic in Arms Regulations

There are two major regimes that govern exports from the United States. One is the Export Administration Regulations (“EAR”) administered by the U.S. Department of Commerce’s Bureau of Industry and Security and, second, the...more

BIS and State Department Issue Rules on Key Export Control Definitions and Cloud Computing

On June 3, 2016, the Department of Commerce’s Bureau of Industry and Security (BIS) and the Department of State’s Directorate of Defense Trade Controls (DDTC) issued new rules revising existing definitions and adding new ones...more

Export Control Reform Offers Revisions to Key Terms, and DDTC Increases Penalty Authority; More Work Remains (Part 1)

On June 3, 2016, the U.S. Department of State, Directorate of Defense Trade Controls (DDTC) and the Department of Commerce, Bureau of Industry and Security (BIS) issued changes to the International Traffic in Arms Regulations...more

US Terminates Arms Embargo Policy for Vietnam

On May 23, 2016, during President Obama’s visit to Ho Chi Minh City, the United States announced the termination its long-standing arms embargo policy for Vietnam. Exports of defense articles and defense services to Vietnam...more

DOJ Guidance on Navigating between a Rock – Export Controls – and a Hard Place – Employment Nondiscrimination

U.S. companies, particularly defense and other high-tech companies, have long faced challenges of how to comply with both the deemed export rule, which may require employment discrimination in very limited circumstances, and...more

ACE Deadline Reminder for Imports and Exports

On February 28, 2016, those involved with imports and exports are preparing to undergo a major transition. As of that date, all entries must be filed using the new Automated Commercial Environment (ACE) system. ACE not only...more

Key Export Compliance Issues For 2016

The following are a number of important strategic issues to be considered in the export compliance area for the new year. 1. Recent Country Amendments – New Obligations and New Opportunities. There have been export...more

"Insights Conversations: Developments in US Export Controls"

The U.S. export control system has undergone major reform in recent years, and companies have experienced both increased enforcement of export control laws and fines for violations, with more changes on the way. Skadden...more

Look Under Your Tree for a Gift From DDTC. Ho Ho Ho!

If you’ve had outbound goods seized because a certain big name shipping company filed your AES on a shipment before you lodged the license with Customs, raise your hand. I thought so. A bunch of you have had that happen....more

Lawyer Sues DDTC Over "Public Domain"

A New York City attorney is suing the U.S. State Department over a proposed change to the International Traffic in Arms Regulations (ITAR). The change pertains to how the regulations define “public domain,” and, if...more

"Key Takeaways: The Latest Developments in US Export Controls - Export Control Reform and Compliance Strategies"

On October 22, 2015, Skadden presented a webinar titled “The Latest Developments in U.S. Export Controls: Export Control Reform and Compliance Strategies.” Guest speakers were Benjamin Turkel, trade compliance counsel at...more

Export Control Reform Roundup – Overview of Recent Developments

In This Issue: - I. BIS and DDTC Publish Their Respective Proposed “Bookend” Controls on Toxicological Agents and Directed Energy Weapons - II. BIS and DDTC Publish Their Respective Proposed “Bookend” Definitions...more

Proposed ITAR Amendment Provides Important Benefit for Government Contractors

The Directorate of Defense Trade Controls (“DDTC”) has issued a proposed regulation under the International Traffic In Arms Regulations (“ITAR”) that will have a significant impact on government contracts firms. Under the...more

Proposed Change to Export Controls Would Allow Use of the Cloud for Encrypted Data

On June 3, 2015 the State Department’s Directorate of Defense Trade Controls (DDTC) and the Commerce Department’s Bureau of Industry and Security (BIS) published proposed regulations which would change the definition of the...more

State and Commerce Departments Publish Next Set of Proposed Export Control Reform Rules: Fire Control, Range Finder, Optical...

In This Issue: - Export Control Reform Initiative - DDTC Proposed Rule - BIS Proposed Rule - For More Information - Excerpt from Export Control Reform Initiative: By way of background, the Export...more

"Agencies Propose Expanding US Export Controls on Cameras, Night Vision Equipment and Sensing Technology"

On May 5, 2015, the U.S. Commerce Department’s Bureau of Industry and Security (BIS) and the U.S. State Department’s Directorate of Defense Trade Controls (DDTC) proposed extensive revisions to the current U.S. export...more

New DDTC Re-export Requirement – What You Need to Know

As of October 1, the State Department’s Directorate of Defense Trade Controls (DDTC) has added an additional requirement for foreign parties looking to re-export or re-transfer items that are under their jurisdiction by...more

You’re Only As Good as Your Source: Make Sure to Consult the Right Versions of the ITAR and EAR

These days when we’re in need of information on an unfamiliar topic our first thought is often to “Google it.” Usually, these initial searches generate plenty of useful results. But actually differentiating between the...more

"US Government Announces Reforms to Space and Satellite Systems Export Controls"

On May 13, 2014, the U.S. State Department’s Directorate of Defense Trade Controls (DDTC) and the U.S. Commerce Department’s Bureau of Industry and Security (BIS) issued interim final rules amending the U.S. export controls...more

No New Export Licenses For Items, Services, or Information Destined For Russia — Be Careful with Russian Nationals in the U.S.

The Commerce Department’s Bureau of Industry and Security (BIS) and the State Department’s Directorate of Defense Trade Controls (DDTC), the two offices in charge of issuing export licenses for controlled dual-use and defense...more

"US Government Halts Licensing for Key Exports to Russia in Response to Events in Ukraine"

In a further sign of the broadening of U.S. restrictions relating to Russia because of the situation in Ukraine, the United States has taken steps to limit trade with Russia in U.S.-origin goods and services that are...more

DDTC Ups the Ante on Data Gathering from ITAR-Registered Companies and Introduces Electronic Filing

Pursuant to the International Traffic in Arms Regulations (ITAR), the U.S. Department of State Directorate of Defense Trade Controls (DDTC) has issued a revised Statement of Registration (DS-2032) form and now allows it to be...more

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