ITAR for Facility Security Officers
ITAR for Government Contractors - New Developments for 2018
The Department of Commerce’s Bureau of Industry and Security (BIS) recently issued an interim final rule implementing licensing requirements for these emerging technology products for export to all foreign countries. See the...more
On April 15, the U.S. Department of the Treasury published a proposed rule that would enhance certain Committee on Foreign Investment in the United States (CFIUS or the Committee) procedures and increase CFIUS penalty and...more
On May 1, 2024, the U.S. State Department published a proposed rule to reduce International Traffic and Arms Regulations (ITAR) licensing requirements for the transfer of defense articles or services between the United...more
On April 25, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) announced in a press release that it will publish an interim final rule (IFR) in the Federal Register on April 30, 2024, updating the...more
On March 14, 2024, the U.S. Departments of Commerce and State announced rules restricting a range of exports to Nicaragua, citing the Nicaraguan government’s “campaign of repression and blatant human rights abuses.”...more
On February 23, 2024, the Biden Administration announced new sanctions targeting a number of different sectors of the Russian economy, Russian government officials and financial institutions, entities suspected of sanctions...more
In a relatively rare move for four (4) Cabinet-level Departments, the U.S. Departments of Commerce, Justice, State and Treasury issued an advisory notice on June 9, 2023, aimed specifically at reminding industry of their...more
On May 19, 2023, the Biden administration announced another major round of U.S. sanctions and export controls against Russia and Belarus in response to the ongoing war in Ukraine, in coordination with the G7 Leaders’ Summit...more
The U.S. Department of State (State Department) and U.S. Department of Commerce (Commerce Department), have recently previewed, proposed or finalized changes to relevant trade controls. These new regulatory updates include...more
This update includes the U.S. Department of the Treasury’s Office of Foreign Assets Control’s (OFAC) recent actions regarding the Russian seaborne oil price cap policy aimed at maintaining the supply of Russian oil to the...more
Most companies that employ non-U.S. persons in the United States are familiar with visa requirements, including completing U.S. Citizenship and Immigration Services Form I-129 – Petition for a Nonimmigrant Worker. However,...more
On January 23, 2020, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) and the U.S. Department of State issued two final rules, available here and here. The final rules outlined the removal of...more
On December 14, 2020, the U.S. Department of State initiated a series of sanctions pursuant to Section 231 of the Countering America’s Adversaries Through Sanctions Act (CAATSA) that target the Turkish Presidency of Defense...more
The U.S. Department of State announced that Sudan’s designation as a “State Sponsor of Terrorism” has been officially rescinded effective December 14, 2020. In October, the President notified Congress that Sudan’s designation...more
On December 14, 2020, the State Department officially rescinded Sudan’s State Sponsors of Terrorism (SST) designation, because Congress did not issue a joint resolution of disapproval. Originally on October 26, 2020,...more
The Committee on Foreign Investment in the United States (CFIUS) is now following new rules on mandatory filings for certain foreign investments in critical technology companies. As a refresher, CFIUS is the US Government’s...more
On June 30, 2020 at 11:00 PM Hong Kong time, the Law of the People’s Republic of China on Safeguarding National Security in the Hong Kong Special Administrative Region (HK National Security Law) took effect....more
On June 29, 2020, the U.S. Departments of State and Commerce announced stricter controls on exports to Hong Kong, withdrawing Hong Kong’s preferential treatment as an autonomous territory. The regulatory changes follow...more
On June 29, 2020, the US Secretary of State and the US Secretary of Commerce announced changes to US export controls in response to recent actions by China involving Hong Kong. These regulatory changes are likely not the last...more
The State Department has adopted an important new ITAR amendment confirming that if controlled technical data is encrypted using end-to-end encryption, the transfer of such data outside the U.S. is not considered an export...more
This is the sixth in our start-of-year series examining important trends in white collar law and investigations in the coming year. Our previous entry discussed enforcement by the Massachusetts Attorney General’s Office in...more
As part of its years-long project to update and revise the International Traffic in Arms Regulations (ITAR) and better align them with the Export Control Regulations, the Department of State (DoS) recently amended the ITAR...more
The good news is that, for the most part, State resisted the temptation to do something just a little different in the ITAR regulation, so the joint Commerce-State solution works. The chart below provides a quick side-by-side...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
Companies involved in Small Business Innovation Research (“SBIR”) and Small Business Technology Transfer (“STTR”) contracts often are subject to requirements under the International Traffic In Arms Regulations (“ITAR”) and...more