Restructured ITAR Streamlines Export Regulations

Restructured ITAR

The Directorate of Defense Trade Controls (DDTC) has restructured ITAR in an effort to streamline the regulations and clarify definitions.  While no substantive changes were made to the International Traffic in Arms Regulations (ITAR), revisions in definitions may effect those under the regulation’s purview.

Changes to Part 120 – Purpose and Definitions

Part 120 of the ITAR has received massive reorganization.  This section is now broken up into three parts; General Information, General Policies and Processes, and Definitions enumerated as subparts A through C.  Subpart A – General Information details purpose and legislative authority for the regulations.  Subpart B – General Policies and Processes provides an overview of general policies and processes within the regulations.  Subpart – C Definitions provides a centralized locations for terms used throughout the document.

Prior to this revision, definitions had been scattered throughout the regulations.  They are now arranged in Subpart – C in a logical order proceeding from larger conceptual items to those of lesser importance.  Subsequently those definitions have been removed from other sections.  Additionally, these terms have undergone clarification and been moderately reworded.  Examples of terms that have undergone revision include:

  • Defense Article
  • Defense Service
  • Technical Data
  • Public Domain
  • Compositional Terms
  • U.S. Person
  • Foreign Person
  • Regular Employee
  • Specially Designed
  • Export
  • Reexport

Missile Technology Control Regime

The Missile Technology Control Regime (MTCR) Annex which had previously been a part of the ITAR has now been removed in its entirety.  The content of this annex is now reflected with notations in the United States Munitions List (USML).  Articles enumerated in the USML that relate to MTCR controls are now annotated with (MT).  

CVG Strategy Export Compliance Services

Because the the DDTC has restructured ITAR, providers of military goods and services will have to make adjustments to their export compliance programs.  This will involve adjustments to program documents and assessing revised definitions to assure that compliance requirement are met and maintained.

CVG Strategy, LLC is recognized the world over as the premier provider of customized Export Compliance Consulting, Export Compliance Programs, and Training that address critical U.S. Government and Canadian laws and regulations, from Export Administration Regulations (EAR), to the International Traffic in Arms Regulations (ITAR), Office of Foreign Asset Controls (OFAC), Canadian Goods Program (CGP) and other regulatory agencies.

CVG Strategy ITAR and Export Compliance experts have managed manufacturing and distribution businesses and have worked for multi-national organizations.  CVG Strategy’s experts are not ex-government employees, they understand the needs and goals of small to medium-sized operations in managing compliance requirements.  They also have expertise in the implementation and maintenance of a wide variety of management system standards.

Kevin Gholston

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