Category: BIS

Recommendations for the Next Reform

The complexity of U.S. export control regulations is at an all-time high. If you had the ability to decide the next administration’s export control reform agenda, what would it be? PAST REFORMS U.S. export controls are principally administered by the State Department under the International Traffic in Arms Regulations […]

Farewell to Supplement No. 1

Over the years, export compliance professionals and other members of the public looked to Supplement No. 1 to Part 734, ‘‘Questions and Answers—Technology and Software Subject to the EAR” (“Supplement No. 1”) to determine how to use exclusions for the release of technology at open conferences, publications, educational […]

Second Proposed Category XII Rule is Better but Far From Good

There was significant industry opposition to the Administration’s first proposed revisions to U.S. Munitions List (USML) Category XII (Fire Control, Range Finder, Optical and Guidance and Control Equipment) of the State Department’s International Traffic in Arms Regulations (ITAR) and corresponding Commerce Control List (CCL) entries on the Commerce Department’s […]

ECR Seeks ITAR Control Over Commercial Optics

The President’s Export Control Reform (“ECR”) Task Force released proposed rules yesterday that seek to subject a vast array of commercial optics items and technology to restrictive export controls under the International Traffic in Arms Regulations (“ITAR”). [F/N 1] Many of the items and technology subject to the […]