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ARTICLE · 09 AUGUST 2024

Significant New U.S. Person And Other Export Controls Proposed Regarding Military, Intelligence, And Security End Users

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The U.S. Department of Commerce's Bureau of Industry and Security (BIS) has published proposed amendments to the Export Administration Regulations (EAR) that would significantly...

GlobalInternational Law
  • The U.S. Department of Commerce's Bureau of Industry and Security (BIS) has published proposed amendments to the Export Administration Regulations (EAR) that would significantly expand the scope of the export controls over U.S. person activities and the shipment of otherwise uncontrolled items if military, military-support, intelligence or foreign-security end-users in or from many countries would be involved. The Directorate of Defense Trade Controls (DDTC) also published a proposed complementary revision to the ITAR's definition of "defense services." BIS also published proposed new item-based controls on facial recognition systems and related items.
  • Ensuring compliance with the proposed amendments to the EAR, if adopted, would require significant and, indeed, dramatic expansions of internal compliance programs, included additional and updated training, end-use and end-user certifications, and due diligence screening efforts involving suppliers, customers and

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