ITAR Lawyer - Commodity Jurisdiction

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They have been cited as influential authority by industry leaders in advocating regulatory revisions to the Department of State and Department of Commerce.

Indeed, Stagg P.C.'s insights have led to revisions to the ITAR and EAR.

 


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Next Steps for Export Control Reform: Options for the Trump Administration

The last two administrations undertook specific measures to reform these controls. For instance, President Bush took more practical steps to reform the system by improving license processing times and moving to an electronic filing system. By contrast, President Obama took a more invasive approach that has substantially increased its complexity...


DDTC Issues Conflicting Guidance Concerning Firearms and Congressional Notification

A trade group recently requested that the Directorate of Defense Trade Controls clarify informal guidance and licensing provisos some of its members have received. In particular, the request pertains to Congressional notification requirements involving firearms under the Arms Export Control Act...


The ITAR’s “Directly Related” Qualifier – The Importance of Defining the Term

The Directorate of Defense Trade Controls (DDTC) issued a proposed rule in June to add and revise key definitions within the International Traffic in Arms Regulations (ITAR). This is commonly known as the harmonization rule. In this proposed rule, DDTC suggested a definition for the term "required" to be codified within new ITAR § 120.46...


DDTC's Arms Export Control Act Problem

The Directorate of Defense Trade Controls (DDTC) issued a proposed role on June 3, 2015 to revise how the International Traffic in Arms Regulations (ITAR) treats the placement of information into the public domain. Controversially, this proposed revision would require the prior approval of the U.S. Government before putting any information into the public domain that DDTC may consider to be subject to the ITAR...


Toolkit for Writing Public Comments on Export Control Reform

Stagg PC is releasing this complimentary toolkit for writing public comments on proposed rules involving Export Control Reform. This toolkit provides general drafting guidance and tips to assist organizations with preparing public comments in response to proposed rules for Export Control Reform under the International Traffic in Arms Regulations (ITAR) and Export Administration Regulations (EAR)...


Status Update on Export Control Reform

The government has been relatively quiet for nearly a year on issuing final or proposed rule-making in furtherance of Export Control Reform. This is about to change. The proposed revisions to Category XII of the U.S. Munitions List are expected soon. Also, a number of other proposed revisions to the International Traffic in Arms Regulations (ITAR) and Export Administration Regulations (EAR) are anticipated throughout 2015. This article summarizes the status of the remaining revisions under Export Control Reform....


Court Case Reveals Insights into the Commodity Jurisdiction Procedure

Export Control Reform and its focus on positive control criteria is here.  The government believes that a positive control list will make jurisdiction assessments more certain and require less use of the commodity jurisdiction (CJ) procedure.  However, what happens if an item is the subject of a CJ case and the government makes a determination that is inconsistent with the control criteria?  This is not a theoretical question.  A recent lawsuit and its underlying criminal prosecution involved this issue....


 
 
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