News

A frequently asked compliance question among government contracts firms is whether they are required to register under the International Traffic In Arms Regulations (“ITAR”). ITAR are the State Department controls that regulate defense products, technical data and services.  Under ITAR 22 CFR §122.1, parties that manufacture, export or temporarily import “defense articles” or furnish “defense services” are required to register with the Directorate of Defense Trade Controls (“DDTC”) within the State Department.  It is important to note that even parties that engage solely in domestic manufacturing of defense articles that do not engage in any exporting or importing are required to register.  Under §122.1, engaging in such activity “requires only one occasion of manufacturing or exporting, or temporarily importing, a defense article or furnishing a defense service” to trigger this registration requirement.  In addition, parties that engage in defense “brokering” (see below) and freight forwarders that perform services under the Foreign Military Sales program are also required to register under ITAR.… Read more

I often encounter misconceptions about the International Traffic in Arms Regulations (ITAR). Among the biggest sources of confusion is registering as a Manufacturer, Exporter or Broker under the ITAR. Let’s clear up the confusion and shed some light on the matter.… Read more