Many emerging technologies implicate U.S. government military, intelligence or foreign policy concerns. Because of this, many of them are described in existing U.S. export control lists. For those not already described in the lists, the U.S. Government gets a second bite at the apple through the recently revised U.S. Munitions List (“USML”) Category XXI and the new 0Y521 Commerce Control List Export Control Classification Number (“ECCN”) series. The new controls are much broader and open ended than previous catchalls on emerging technologies, presenting unique compliance risks. They also reduce the certainty necessary to cost-benefit analyses of international investment and collaborations in emerging technologies. Legal assistance in assessing the these risks can address compliance risks and increase certainty in these areas.
DEFENSE TRADE LAW BLOG
A recent New York Times article reported that William Powell, the author of The Anarchist Cookbook, died last year at the age of 66. [FN 1] The article noted: “William Powell was a teenager, angry at the government and the Vietnam War, when he walked into the main branch of the New York Public Library in […]
The United States Court of Appeals for the District of Columbia Circuit recently dismissed a case filed against the State Department Directorate of Defense Trade Controls (“DDTC”) by the author’s law firm, finding that DDTC only intends to apply Arms Broker regulations, codified at Part 129 of the International Traffic in Arms Regulations (“ITAR”) [FN […]
The complexity of U.S. export control regulations is at an all-time high. If you had the ability to decide the next administration’s export control reform agenda, what would it be? PAST REFORMS U.S. export controls are principally administered by the State Department under the International Traffic in Arms Regulations (“ITAR”) and the Commerce Department under the […]