Media note from the U.S. Department of State On August 10, 2022, the U.S. Department of State published a Federal Register notice of ten persons statutorily debarred for having been convicted of violating, or conspiring to violate, the Arms Export Control Act (22 U.S.C. 2751, et seq.). This action, pursuant to section 127.7(b) of the International…
In a keynote address at the Global Investigations Review Connect: New York conference on October 5, Principal Associate Deputy Attorney General John Carlin provided insights into future Department of Justice (“ DOJ ” or the “Department”) corporate enforcement. Of particular note, and which has been largely unnoticed, Carlin highlighted the Department’s heightened focus on sanctions and export…
In a keynote address at the Global Investigations Review Connect: New York conference on October 5, Principal Associate Deputy Attorney General John Carlin provided insights into future Department of Justice (“ DOJ ” or the “Department”) corporate enforcement. Of particular note, and which has been largely unnoticed, Carlin highlighted the Department’s heightened focus on sanctions and export…
ITAR or EAR A United States manufacturer of electronic test and measurement equipment and software mistakenly exported ITAR-controlled software under the EAR instead, resulting in a Consent Agreement and civil penalty of $6,600,000. In the following transcript George W. Thompson, International Trade Attorney discusses the consequences of this error and how it could have been…
Part 129 of the International Traffic in Arms Regulations (“ITAR”) requires certain persons engaged in “brokering activities” to register with and pay a fee to, the U.S. Department of State Directorate of Defense Trade Controls (“DDTC”). ITAR Part 129.2 broadly defines “broker” as any person engaging in “brokering activities” (discussed in greater detail below) fitting…
A federal grand jury in Los Angeles unsealed an indictment Thursday that accuses five defendants of conspiring to unlawfully export defense articles to Russia. Specifically, the defendants allegedly exported thermal imaging riflescopes and night-vision goggles without a license, in violation of the Arms Export Control Act. According to court documents, Elena Shifrin, 59, of Mundelein,…
Export Controls: Denied Parties With concerns about the unauthorized and/or inappropriate transfer of technology, products, and information to individuals or entities within or beyond US borders, the US Government established laws and regulations, known as export controls, to restrict such transfer. The government regulates the export of sensitive information, physical equipment, and software and technology to promote foreign policy objectives and promote…
Export Administration Regulations (EAR) If you work in the international trade industry or if you are considering it, the export administration regulations are something you need to know. These regulations apply to all goods being exported out of the United States. These goods must be regulated for the country’s security and the safety of the…
What is ITAR compliance? The International Traffic in Arms Regulations (ITAR) are, as the title indicates, rules governing trade in munitions. While that summary is accurate, it leaves many open questions. What are “munitions”? How is trade in munitions defined? Who is engaged in such trade, what authorizations are United States exporters and foreign re-sellers…