The Department of State and the Department of Commerce have revised several provisions of the International Traffic in Arms Regulations (ITAR) and the Export Administration Regulations (EAR). Many of the changes are part of an ongoing effort to increase consistency between the terms used in the ITAR and the EAR.
On September 8, 2016, the Department of State made further revisions regarding the International Traffic in Arms (ITAR) in response to the public comments to the previously interim final rule. In the revision, the definition of “retransfer” was amended to clarify that a temporary transfer to a third party is also a “retransfer”.
Other revisions include exemptions pursuant to the Defense Trade Cooperation Treaty with Australia and United Kingdom and the definition of “applicant”.
Revisions made on September 8 took effect on the same day.
One set of revisions has been in effect since September 1, while the other will take effect in November. Below is a brief summary of the changes. Please feel free to contact me with questions.