By John M. Hynes

On August 27, 2010, the Department of State amended section 125.4(b)(9) of the International Traffic in Arms Regulations (“ITAR”) to clarify an exemption to the license requirement related to the hand-carrying of technical data outside the United States.
 Continue Reading ITAR License Exemption Amended To Allow Hand-Carrying Of Technical Data Outside The United States

In comments released on March 12, 2010, the Administration announced that it will be shifting the current encryption review request process under 15 C.F.R. section 740.17 to an on-line system, with the objective of reducing review times from 30-60 days to 30 minutes. While industry will welcome the shortening of the review waiting period, the current regulations already allow many encryption exports to our largest trading partners, those listed in Part 740, Supplement 3, as well as exports to other countries of items described in section 740.17(b)(1)(ii), to occur during the waiting period. There is no indication that the change would add countries like China or India to Supplement 3. As described, it also would not alter the technical definition of encryption products requiring review or result in any expansion of the existing exception for "ancillary cryptography." Without more fundamental changes along these lines, the ultimate impact of the review request change will probably be minimal.
 Continue Reading Administration to Expedite Encryption Reviews and Amend ITAR Citizenship Definition