International Traffic Arms Regulations

News & Analysis as of

Apocalypse Soon? Permanent Disqualification From Department of Defense Contracts May Result From Voluntary Disclosures of Export...

Etymology, particularly the Greek or Latin roots of words, aids our understanding in much the same way as root cause analysis does. The Greek word for disclosure is ap???????, transliterated to apokálypsi, or “apocalypse.”...more

CFIUS’ Global Reach – Users of U.S. Controlled Technology Beware

The U.S. government, and we mean the pre-Trump administration at that, has blocked an acquisition of a foreign company by another foreign company. The concern is that the target company has a U.S. presence and has access to...more

3D Printing of Manufactured Goods: An Updated Analysis

(NEW YORK) December 15, 2016 – Reed Smith LLP today released “3D Printing of Manufactured Goods: An Updated Analysis,” a comprehensive new white paper that provides in-house counsel and industry leaders with an in-depth look...more

Companies Face New Process in Disclosures of Potential Export Violations

Companies opting to file voluntary disclosures of potential export violations with the State Department’s Directorate of Defense Trade Controls (DDTC) will soon be required to utilize a new process for submitting their...more

Chinese Investment in the United States – Prospects for the Trump Presidency

An important thing for people interested in U.S.-China commercial and financial relations to consider in connection with Donald Trump’s victory in the presidential election on November 8, 2016 is that no one can know with...more

November 15, 2016 Implementation Date for BIS and DDTC Harmonized Destination Control Statements

As part of the President's Export Control Reform (E CR) initiative, the Department of Commerce, Bureau of Industry and Security (BIS) and the Department of State, Directorate of Defense Trade Controls (DDTC) issued a final...more

Export Documentation Requirements Change Following EAR/ITAR Amendments

Export control documentation requirements are changing effective November 15, 2016. Specifically, the Department of Commerce’s Bureau of Industry and Security, and the Department of State’s Directorate of Defense Trade...more

Weekly Update Newsletter - November 2016

DEPARTMENT OF DEFENSE - Withholding of Unclassified Technical Data and Technology from Public Disclosure - The Department of Defense (“DOD”) Office of the Under Secretary of Defense for Acquisition, Technology, and...more

DOJ Publishes Guidance Encouraging Voluntary Self-Disclosures, Full Cooperation and Timely and Appropriate Remediation

On Oct. 2, 2016, the U.S. Department of Justice (DOJ), National Security Division (NSD) published Guidance setting forth its policy of encouraging business organizations to voluntarily self-disclose criminal violations of...more

Company Eliminated from Army Contract Competition Due to ITAR Compliance Program Description

The U.S. Government Accountability Office (GAO) denied on Aug. 11, 2016, a government contract protest by Microwave Monolithics Inc. See GAO case number B-413088. The case is noteworthy because of the reason for denial. The...more

State Department Relaunches Company Visit Program to Assess ITAR Compliance

The Directorate of Defense Trade Controls (“DDTC”) within the State Department has relaunched its “Company Visit Program.” Under the Company Visit Program, DDTC officials come to your office to review your company’s...more

SEC Rules for Resource Extraction Issuers Could Lead to Increased FCPA Scrutiny, Disclosures

New rules issued by the U.S. Securities and Exchange Commission (SEC) that require resource extraction issuers to disclose payments made to U.S. and foreign governments for the commercial development of oil, natural gas or...more

Government Contracts Legislative and Regulatory Update - August 2016

We are pleased to offer you the inaugural issue of our newsletter, "Government Contracts Legislative and Regulatory Update." Our aim is to keep you up-to-date on legislative and regulatory ?changes relevant to government...more

Redefining U.S. Export Controls: Takeaways from Key Changes Effective September 1st

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

Redefining U.S. Export Controls: Takeaways from Key Changes Effective September 1st

On September 1, 2016 new rules previously published by the U.S. Department of Commerce, Bureau of Industry and Security (BIS)1 and the U.S. Department of State, Directorate of Defense Trade Controls (DDTC)2 will become...more

Final Rules Affecting Definitions of Export and Fundamental Research Take Effect

Amended definitions under the Export Administration Regulations (EAR) and the International Traffic in Arms Regulations (ITAR) became effective today, Sept. 1, 2016. Although there are no significant changes to the scope or...more

BIS and DDTC Harmonize Destination Control Statements, Make Other Clarifying Changes

On Aug. 17, 2016, as part of the President’s Export Control Reform (ECR) initiative, the Department of Commerce, Bureau of Industry and Security (BIS) and the Department of State, Directorate of Defense Trade Controls (DDTC)...more

How to Avoid Discrimination in Hiring, While Complying with Export Laws

Imagine your company has employed a research scientist to support your technology programs. The scientist is a citizen of the People’s Republic of China and holds an H-1B visa, but is not authorized to view certain...more

Compliance Conundrum -- Unauthorized Exports v. Discrimination: Find a Win in a Lose-Lose Scenario

Imagine your company has employed a research scientist to support your technology programs. The scientist is a citizen of the People’s Republic of China and holds an H-1B visa, but is not authorized to view certain...more

New Guidance on ITAR Registration in the Firearms Industry

The State Department has issued new policy guidance regarding the requirement for gunsmiths and others involved in the firearms industry to register with the State Department under Part 122 of the International Traffic In...more

Export Regulation Revisions: Harmonization of Destination Control Statements

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

Trade & Manufacturing - News of Note - August 2016

ITC Votes to Extend Antidumping Duties on Imports of Porcelain-on-Steel Cooking Ware from China for Five More Years - On July 12, the International Trade Commission (ITC) voted 5-0 to extend the U.S. antidumping duty...more

The Real Export Compliance Challenges of Simulation Software

Simulation software plays a vital role within industry by virtualising the natural trial and error of research and development, as well as reducing the expensive hands-on training time necessary to achieve mastery over...more

BIS And DDTC Revise Controls on Export of Toxicological Agents and Directed Energy Weapons

On July 28, 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 final rules implementing revisions to U.S. export controls...more

ITAR For Government Contractors: Revised For Recent Amendments

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

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