Alexa, Are You a U.S. Person?

DDTC, Denied & Restricted Parties, Dual/3rd Party Nationals, Information Technology, ITAR, USA Regulations

By:  Jim McShane, Sr. Consultant, Trade Compliance, Export Solutions. (Source: Export Solutions) “Hey Alexa, are you a U.S. Person?” Imagine this. A conference call with your foreign-based customer is about to begin. Today’s agenda includes technical...

Hiring U.S. Citizens Only for ITAR Compliance Can Violate the Immigration and Nationality Act

Defense Trade Controls, DOJ, Dual/3rd Party Nationals, ITAR

By: David Ring, attorney, dring@wiggin.com; and Najia S. Khalid, attorney, nkhalid@wiggin.com. Both of Wiggin and Dana.   The Department of Justice (DOJ), Civil Rights Division, announced on August 29, 2018, its civil settlement with the international law firm,...

Company Pays $100,000 for One Transfer of ITAR Technical Data to PRC Citizen Employee

China, Deemed Export, Dual/3rd Party Nationals, Violations & Fines

By: Danielle McClellan Microwave Engineering Corporation (Microwave) of Andover, MA has pled guilty to one charge of an unauthorized export of a defense article to a foreign person and will pay $100,000 to settle the matter. The company designs and manufactures...

State/DDTC Posts New Agreement Guidelines for US-Canada Exchange of Notes re ITAR 126.18 Dual/3rds Exemption

Canada, Dual/3rd Party Nationals

By: Holly Thorne Licensing: New agreement guidelines pursuant to the US-Canadian Exchange of Notes regarding ITAR section 126.18, Canada has provided appropriate implementation guidance. I. Background — Classification Requests Section 748.3(a) of the Export...

UK Establishes Baseline for Compliance Procedures for ITAR Foreign National Exemption for Foreign Parties

BIS, Dual/3rd Party Nationals, ITAR, UK

By: Holly Thorne UK BIS/ECO Posts Exchange of Diplomatic Notes Concerning New Dual/3rd National ITAR Exemption United States Department of State Bureau of Political-Military Affairs Directorate of Defense Trade Controls Washington, DC 11 August 2011 Mr. William Mark...

UK BIS/ECO Posts Q&A Matrix on Implementation of New Dual/3rd National ITAR Exemption

BIS, Dual/3rd Party Nationals, UK

By: Holly Thorne Introduction 1.            This Table sets out a number of questions put to and answered by the US Department of State (DoS) (Director of Policy, Directorate of Defense Trade Controls) by HM Government (HMG) and UK industry, concerning this rule...