STEPTOE: OUTSIDE COUNSEL
On 15 October 2013, as part of the US government’s “Export Control Reform” (“ECR”) initiative, the Commerce Department’s Bureau of Industry and Security (“BIS”) and the State Department’s Directorate of Defense Trade Controls (“DDTC”) implemented the “specially designed” rule in the Export Administration Regulations (“EAR”) and the International Traffic in Arms Regulations (“ITAR”), respectively. This rule fundamentally altered the landscape for classifying products....
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