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ARTICLE · 13 JUNE 2016

Commerce And State Departments Revise Technology Export Definitions

Hughes Hubbard & Reed LLP
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On Friday June 3, 2016 the U.S. Departments of Commerce and State released their latest rulemakings in the Export Control Reform Initiative...

United StatesIntellectual Property
F. Amanda DeBusk
F. Amanda DeBusk
Melissa Duffy
Melissa Duffy
Alan Kashdan
Alan Kashdan
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On Friday June 3, 2016 the U.S. Departments of Commerce and State released their latest rulemakings in the Export Control Reform Initiative - this time, revising the definitions of "export" and several other terms relating to technology transfers.1 These rules are the long-awaited follow-on to proposed rules issued by each agency exactly one year ago on June 3, 2015. The Commerce Department's Bureau of Industry and Security ("BIS") published a final rule to complete the process, and the State Department's Directorate of Defense Trade Controls ("DDTC") published an interim final rule with another request for comments due July 5, 2016. (BIS still welcomes public comments on its final rule on a continuing basis.) Both rules will become effective on September 1, 2016.

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