Regulation

Many questions about DDTC proposal to revise the definition of “Defense Services”

Issue 46
September 2024

Author
Jack R. HayesRyan Pereira
+ About author

Jack Hayes is a Partner at Steptoe LLP, focusing on US export controls and sanctions, including the ITAR. www.steptoe.com

Ryan Pereira is an Associate in the Washington, DC office of Steptoe. www.steptoe.com

STEPTOE: OUTSIDE COUNSEL
On 29 July 2024, the US State Department’s Directorate of Defense Trade Controls (“DDTC”) issued a proposed rule to amend the definition of “defense services” in the International Traffic in Arms Regulations (“ITAR”). The rule is not yet effective, and DDTC is accepting public comments until 15 October 2024. If promulgated, the rule would expand controls to cover certain intelligence assistance-related and defense consulting services. This rule also is a departure from a...

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