Tag Archives: export control

Lend Me Your EARs: CFIUS Makes Export Controls a Trigger for Mandatory Filings

Reid WhittenJulien BlanquartLisa MaysBy Reid Whitten, Julien Blanquart and Lisa Mays on Posted in CFIUS
On October 15, 2020, CFIUS will officially tie mandatory filings to U.S. export control regimes, including the Export Administration Regulations (EAR) and the International Traffic in Arms Regulations (ITAR).  While that change may draw a clearer line of what constitutes a mandatory filing, it also pulls your CFIUS review into the complex (and somewhat nerdy) … Continue Reading

CFIUS Proposes Rules to Implement FIRRMA

Reid WhittenBrian WeimerEamon TierneyBy Reid Whitten, Brian Weimer and Eamon Tierney on Posted in CFIUS
Key Takeaways: Technology Infrastructure and Data. CFIUS will focus its review on investments in critical Technology, critical Infrastructure, and sensitive personal Data (“TID Businesses”). Critical technologies is defined to include certain items subject to export controls along with emerging and foundational technologies under the Export Control Reform Act of 2018. CFIUS provides a very helpful … Continue Reading

Clear for More Takeoffs: Now is the Time to Have Your Voice Heard on New Satellite and Launch Regulations

Reid WhittenFatema MerchantBy Reid Whitten and Fatema Merchant on Posted in Export Control Reform (ECR), ITAR and Defense Exports
On March 8, the U.S. government signaled regulatory changes that may create new opportunities for international collaboration on satellite development, global sales of satellite and launch equipment, and even sharing launch technology. . . . and the Government wants you to weigh in.… Continue Reading

Layover in Tehran: United States Authorizes Carriers to Land Civil Aircraft in Iran

Reid WhittenJ. Scott MaberryBy Reid Whitten and J. Scott Maberry on Posted in Sanctions
On July 29, 2016, the U.S. Treasury Office of Foreign Assets Control (OFAC) cleared the runway for non-U.S. operators of civil aircraft to send flights into Iran. New  “General License J” authorizes many Boeing, Airbus, and other civil aircraft containing U.S.-origin materials to fly to Iran on “temporary sojourn.” The General License provides a great … Continue Reading

Export Control Settlements Highlight the Need to Pay Attention During “Outreach” Visits

By Sheppard Mullin on Posted in Export Administration Regulations (EAR) and Commercial Exports, Sanctions
By: Scott Maberry As illustrated by three recent export enforcement actions, when armed government enforcement agents come to your door with PowerPoint slides, pay close attention. On March 8, 2012, the U.S. Department of Commerce's Bureau of Industry and Security (BIS) and the U.S. Attorney's Office for the District of Wyoming announced settlements of three related cases involving illegal exports to Syria. The cases involved an increasingly common enforcement tool, the U.S. government "outreach" visit. … Continue Reading

State Department (Finally) Proposes Amendments to ITAR Brokering Provisions

By Sheppard Mullin on Posted in ITAR and Defense Exports
By: Thaddeus McBride and Cheryl Palmeri In a Federal Register Notice dated December 19, 2011, the U.S. Department of State announced proposed changes to 22 C.F.R. part 129 and related provisions of the International Traffic in Arms Regulations (ITAR) that regulate brokers and brokering activities.  State is accepting comments on the proposed rule until February 17, 2012.  The exporting community has been awaiting these amendments for several years, and while providing some clarification as to broker registration and approvals, the amendments are pretty modest. … Continue Reading
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