In our blog shop, most of the news we scan is the nerdy minutia of regulatory nuance. But the other day, we found big news, a real scoop. The ITAR will be rewritten to remove guns and ammunition from its control. Yes, you read that correctly, a plan has been proposed within the State Department … Continue Reading
Every time there is a new round of reforms under the President’s Export Control Reform initiative, we hear the same advice: Controls on certain items are eliminated or reduced (which creates new opportunities for manufacturers and exporters); but The new rules bring new complexities, so be careful. Attorneys in the export control space correspondingly inundate … Continue Reading
Glancing through the fictional but fascinating Hitchhiker’s Guide to the Galaxy (Rsch. Ford Prefect; Pub. Megadodo Publications), one might recognize that the assertions therein are a bit confusing. Similarly, one might become confused when reviewing another, less whimsical, guide to the galaxy: the revised United States Munitions List Category XV – Spacecraft and Related Articles. … Continue Reading
Here is a summary of export data for the first year after the initial implementation of ECR: There have been over 61,000 shipments of 600 series items since October 2013. The 600 series exports are valued at approximately $2.1 billion. The top 600 series ECCNs exported are:… Continue Reading
The Year Mark Apparently, it is now fashionable among my peers to host elaborate parties in honor of the first birthdays of their children. I have attended a number of these fêtes, and been impressed to just what lengths the parents will go to celebrate twelve months of growth and achievement for a Guest of … Continue Reading
In the country pubs of Ireland, it has long been the practice of the barkeep to “stand the third round” for good customers, meaning to offer the third drink for free. The practice makes sense both as customer appreciation and as an inducement for those fine customers to continue their revelries right where they are. … Continue Reading
Background If you manufacture or export Auxiliary Military Equipment controlled under Category XIII of the U.S. Munitions List, you may rightly consider the category number unlucky. The current scope of Category XIII controls is broad and can be difficult to interpret. The category includes SCUBA gear and might be read to cover materials for an … Continue Reading
By: Matthew Riemer
On August 26, 2013, in yet another move geared toward streamlining the U.S. export control regulatory landscape, the U.S. Department of State’s Directorate of Defense Trade Controls (DDTC) published its long-awaited interim final rule on arms brokers and brokering activities. The revamped International Traffic in Arms Regulation (ITAR) Part 129 directly addresses industry concerns regarding the scope and applicability of the current brokering requirements. Although the rule comes nearly two years after the most recent proposed brokering rule, the new rule significantly narrows the universe of persons and activities that are subject to the ITAR’s brokering regulations.… Continue Reading
By: Reid Whitten
First they came by air, now by sea and by land.
On July 8, 2013, the U.S. Department of State published its final rule revising controls on naval vessels and military vehicles contained in the International Traffic in Arms Regulations (ITAR). The changes will take effect on January 6, 2014 and will revise United States Munitions List Category VI (Surface Vessels and Special Naval Equipment), Category VII (Ground Vehicles), andCategory XX, (now named Submersible Vessels and Related Articles). The final rule also makes changes to Category XII(Materials and Miscellaneous Articles) which are noteworthy and will be covered separately in an upcoming episode of this series.
This article covers highlights of the regulatory changes for naval vessels and military vehicles, notes the pattern of the Export Control Reform revisions, and comments on how these changes may be important to you and your business.… Continue Reading
By: Reid Whitten The first major wave of the much-discussed U.S. Export Control Reform measures will break on October 15, 2013 as the first round of rule changes take effect. While many in the affected industries expect that the October changes will be a welcome relief from certain burdensome regulations, many are concerned, confused, and … Continue Reading
By: Reid Whitten
In Episode I: The Basics we noted that U.S. Export Control Reform may be causing confusion and consternation among those who will have to take the first theoretical rule changes and apply them in real and practical situations. Among the first test subjects are those who oversee ITAR compliance for manufacturers and exporters of aircraft and aircraft parts. While these brave souls will be the front line of the ECR implementers, those in the ranks behind (looking at you, Military Vehicles and Naval Vessels) will do well to learn from their experience.… Continue Reading