Tag Archives: EAR

“The Song Remains the Same” – DFARS Removes and Replaces Restrictions on Export Controls

By David Gallacher  Earlier this month, we wrote about a new proposed rule from the Department of Energy imposing new and onerous requirements relating to compliance with the U.S. export control laws. DOE claimed that this proposed rule was modeled on a prior rule included in the Department of Defense Federal Acquisition Regulation Supplement (DFARS) … Continue Reading

What’s New Out There? A Regulatory Update (“Promising Improvements” Edition)

By Mark Jensen Each month, we try to review the Federal Register and post an update summarizing some of the more interesting developments. This month, two of the topics – a proposed rule from the Department of Energy relating to onerous export requirements, and a final rule from the Small Business Administration relating to increased … Continue Reading

2011 Year In Review: Export Controls and Promised Reforms

By: David S. Gallacher 2011 was a banner year for U.S. export control laws. The Obama administration has vowed to streamline and reform the bloated U.S. export control system – promising to build "higher walls" around a narrower universe of goods and technologies requiring export licenses. Following is a summary of ten of the key … Continue Reading

Early Steps Toward a Streamlined Export Control System: Proposed Changes to the ITAR and EAR

By: Curt Dombek & Reid Whitten On November 7, 2011, the U.S. State Department published a proposed rule amending the International Traffic in Arms Regulations (“ITAR”) by narrowing the categories of aircraft and related equipment controlled on the United States Munitions List (“USML”). Concurrently, the U.S. Department of Commerce, Bureau of Industry and Security (“BIS”) published a … Continue Reading

Proposed Rule Details Major Changes to U.S. Export Controls

By Curt Dombek, Thad McBride and Mark Jensen In a significant step in the reform of U.S. export controls, the Department of Commerce issued a proposed rule on Friday, July 15, 2011, that would fundamentally affect the overlap between, and operation of, the International Traffic in Arms Regulations (“ITAR”) administered by the U.S. Department of … Continue Reading

Technology Exports: Uncertainty Around Form I-129 Persists

By Thaddeus McBride, Mark L. Jensen and Corey Phelps Beginning on February 20, 2011, the U.S. Bureau of Citizenship and Immigration Services (“CIS”) assumed a role in the U.S. Government’s increasing regulation of technology exports. The new role for CIS relates to the transfer of controlled technology or source code, sometimes referred to as “deemed exports," … Continue Reading

The Department Of State Seeks To Narrow The ITAR Definition Of “Defense Service”

By John M. Hynes On April 13, 2011, the Department of State (the “Department”) issued proposed amendments to various sections of the International Traffic in Arms Regulations (“ITAR”) regarding the definition of “defense service.” See International Traffic in Arms Regulations: Defense Services, 76 Fed. Reg. 20590-93 (amending 22 C.F.R. Parts 120 and 124).  … Continue Reading
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