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ARTICLE · 26 JULY 2024

ITAR And EAR Proposed Rules Expand Controls On U.S. Person Services

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On July 25, 2024, the U.S. Departments of State and Commerce issued new proposed rules that, if implemented, would (1) increase the restrictions associated...

GlobalInternational Law
Jana del-Cerro
Jana del-Cerro
Jeremy Iloulian
Jeremy Iloulian
Aryn Gruneisen
Aryn Gruneisen
Chandler Leonard
Chandler Leonard
Rachel Schumacher
Rachel Schumacher
Dilan Wickrema
Dilan Wickrema
Dmitry Bergoltsev
Dmitry Bergoltsev

On July 25, 2024, the U.S. Departments of State and Commerce issued new proposed rules that, if implemented, would (1) increase the restrictions associated with U.S. persons providing services in support of non-U.S. military-related end users / uses; and (2) implement new controls associated with exports, reexports, and transfers of items subject to the EAR if they involve a broader swath of non-U.S. military-related parties.

Both departments are accepting comments until September 27, 2024. Quick summaries of the rules, and key points follow.

Proposed Revisions to the ITAR's Definition and Controls Related to Defense Services

The ITAR proposed amendments:

  • Create new U.S. Munitions List entries to broadly control U.S. person's creating, supporting, or improving (i) foreign government "intelligence activities", or (ii) a foreign government's organization, formation, or operation of military paramilitary operations or capabilities; irrespective of whether

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