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This overview discusses key insights from the August 2011 Export Control Conference hosted by Barbara Clements & Associates, focusing on the evolving landscape of trade compliance under the Directorate of Defense Trade Controls (DDTC). It highlights significant reforms, including the planned transition of 30,000 ITAR licenses to the Department of Commerce and the review of USML Category VII concerning military vehicles. Additionally, it outlines the roles of various government agencies involved in export control, including BIS and NRC, and addresses compliance considerations for businesses.
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DDTC & Reform Overview FISWG Export Control Conference August 4, 2011 Barbara Clements & Associates, Inc. Trade Compliance: Changing the Way You Do Business
Department of State • DDTC= Directorate of Defense Trade Controls • DTCL = Defense Trade Controls Licensing • DTCC = Defense Trade Controls Compliance • USML = United States Munitions List • XXI Categories, including Significant Military Equipment (SME) • Licensing and Agreements • ITAR = International Traffic in Arms Regulations Both Import and Export Requirements
Other Government Agencies • Bureau of Industry and Security (BIS) • Bureau of Alcohol, Tobacco, Firearms & Explosives (BATFE) • Nuclear Regulatory Commission (NRC) • Drug Enforcement Agency (DEA) • Food and Drug Administration (FDA) • Customs and Border Protection (CBP) • Foreign Trade Regulations (FTR) • Other considerations: • WEEE directive – Europe • REACH - Europe • RoHS directive - global requirement
Reform Review July 15, 2011 the export reform was announced: • USML Category VII (tanks & military vehicles) targeted for review; • 30,000 ITAR licenses to be moved to Commerce’s jurisdiction by end of 2011; • The remaining Categories to be reviewed by the end of 2012; and • All nuts, bolts, screws and other misc. Parts are being reviewed for transfer to Commerce’s jurisdiction (CCL).