News & Noteworthy

Exceptions to Exemptions in Part 126: Considering UK, Australia and Canada

Posted by Bruce Webb on May 10, 2017 10:15:00 AM

CTP’s renowned expert, Bruce Webb, pens a semi-regular blog on the nuances of commodity classification. Visit our archive for past entries by Bruce and other CTP experts. 

I want to discuss recent experiences involving the ITAR exemptions for UK, Australia and Canada. Why these specific nations?  Because these country-specific ITAR exemptions are made possible through existing country-to-country agreements as well as treaties relating to defense trade. These arrangements allow for the export of specific defense articles and defense services which meet the strict requirements set forth for each but this is not a carte blanche to export freely. Each transaction must be reviewed to avoid misinterpretation.

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Topics: DDTC, Export Compliance, ITAR

The Future is DECCS

Posted by Chalinee Tinaves on Nov 16, 2016 12:42:54 PM

The folks at DDTC are beginning a slow roll out of their new electronic interface, DECCS, starting next week. DECCS, which stands for the Defense Export Control and Compliance System, is DDTC’s new modernized IT system. It is intended to eventually replace the current D-Trade, the Electronic Filing System (EFS), MARY and ELLIE systems. The first phase of the DECCS rollout will focus on the new Commodity Jurisdiction (CJ) application.

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Harmonizing the Destination Control Statement: What You Need to Know

Posted by Chalinee Tinaves on Aug 25, 2016 12:00:00 PM

On August 17, 2016, the Bureau of Industry and Security and the Department of State published final rules (here and here) to harmonize the Destination Control Statement (DCS) required under §758.6 of the Export Administration Regulations (EAR) and §123.9 under the International Traffic in Arms Regulations (ITAR) respectively. As part of Export Control Reform (ECR) efforts, the agencies have sought to harmonize regulatory provisions that are intended to achieve the same purpose. The DCS is one example of an area where interagency coordination should reduce the burden on exporters.

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Topics: DDTC, BIS, Export Compliance

Coming Soon . . . Definitive Definitions

Posted by Rick Phipps on Jun 8, 2015 1:23:28 PM

In coordinated announcements last week, BIS and DDTC proposed many new or altered definitions that attempt to harmonize comparable terms in the EAR and ITAR. The DDTC proposal includes, among many others, a new definition of “defense services.” For the legion of long suffering compliance practitioners who have struggled to reconcile the varying terminology, this is a long awaited aspect of ECR. The proposed rules can be found at:

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Topics: DDTC, Government, BIS, News & Noteworthy

DDTC Licensing Office Poised for Reorganization

Posted by Rick Phipps on Apr 17, 2015 2:14:11 PM

According to an Industry Notice posted on the U.S. Department of State’s Directorate of Defense Trade Controls (DDTC) website, effective Monday, April 20, 2015, the Office of Defense Trade Controls Licensing (DTCL) will undergo a reorganization. Export Control Reform (ECR) has caused a 36% drop in licensing volume and has created a disparity in the volume of cases among the current divisions. Since 2013, DTCL has also experienced some downsizing through attrition. The new organizational structure will be leaner and will appropriately balance personnel and commodity volume to reflect the post-ECR environment while enabling DTCL to work toward meeting the directorate’s strategic goals.

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Topics: DDTC, Government, News & Noteworthy