Export Control Reform

Subscribe to Export Control Reform

On October 12, 2016, the State Department’s Directorate of Defense Trade Controls (DDTC) and the Commerce Department’s Bureau of Industry and Security (BIS) published companion final rules to amend Category XII of the United States Munitions List (USML) and move some less sensitive items to the Commerce Control List (CCL).  The final rules will become…

On October 31, 2016, the Department of Defense (DoD) published a proposed rule entitled, Withholding of Unclassified Technical Data and Technology from the Public Disclosure.  Public comments must be submitted by December 30, 2016.

The proposed rule establishes DoD policy, assigns responsibilities, and prescribes procedures for the circulation and withholding of certain unclassified technical…

On September 28, 2015 the European Commission (the Commission) unveiled a proposal to “modernize and strengthen” the European Union’s (EU) dual-use export control regime pursuant to Regulation (EC) No. 428/2009 (the Regulation).  As noted in our previous advisory, a version of the Commission’s proposal was leaked in July, causing concern from industry and other …

On September 8, 2016, the US Department of State’s Directorate of Defense Trade Controls published a final rule to amend the International Traffic in Arms Regulations.  This rule clarifies and finalizes changes from a June 3, 2016, interim final rule related to the definitions of “export,” “re-export” and “retransfer.”

The preamble of the final rule …

On September 20, the US Department of Commerce (DOC) published a final rule revising the Commerce Control List (CCL) and other sections of the Export Administration Regulations (EAR).  This rule implements revisions decided at the December 2015 Wassenaar Arrangement plenary meeting, but also includes additional updates to the EAR.  The final rule revises 58 Export…

The State Department’s Directorate of Defense Trade Controls (DDTC) recently published a final rule amending the International Traffic in Arms Regulations (ITAR) to finalize and clarify changes from a June 3, 2016 interim final rule related to the definitions of “export,” “reexport,” and “retransfer.”  For additional information on the interim final rule, see our previous …

The US Departments of State and Commerce published final rules revising the destination control statements required under the International Traffic in Arms Regulations (ITAR) and the Export Administration Regulations (EAR).  Destination control statements are required to alert recipients of ITAR or EAR-controlled items of associated US export control requirements.  The agencies’ Federal Register notices describe …

On June 3, 2016 the Department of Commerce issued a final rule, and the Department of State issued an interim final rule, making changes to key definitions in the Export Administration Regulations (EAR) and the International Traffic in Arms Regulations (ITAR). The rules update the definitions of “export,” “reexport,” “release,” and “retransfer” under both the…

On December 2, 2015, the Bureau of Industry and Security (BIS) of the US Department of Commerce issued a proposed rule expanding the requirements to report offsets in defense sales agreements. The proposed rule would require companies to report certain offsets in the sale of items controlled in “600 series” Export Control Classification Numbers (ECCNs) on the Commerce Control List (CCL), except for certain submersible and semi-submersible cargo transport vessels and related equipment, software, and technology controlled in ECCN 8A620.b, 8B620.b, 8D620.b, and 8E620.b.
…
Continue Reading BIS Expands Offset Reporting Requirements in Defense Sales to Include Sales of Items Controlled in “600 Series”

Join us on Tuesday, December 15 for this complimentary webinar discussing economic sanctions, export control, and related developments over the past year.  Featured panelists include Steptoe International Compliance Blog contributors Alex Baj, Jack Hayes, Stephen Heifetz, Andy Irwin, Anthony Rapa, Meredith Rathbone, and moderator Ed Krauland.

Date:   Tuesday, December 15, 2015
Time:   12:00 p.m. –…