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ARTICLE · 10 JANUARY 2012

DDTC Proposes New Brokering Rule

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On December 19, 2011, the US Department of State’s Directorate of Defense Trade Controls ("DDTC") published a proposed rule to amend Part 129 of the International Traffic in Arms Regulations ("ITAR") relating to brokering and other select provisions.

United StatesInternational Law
Edward Krauland
Edward Krauland
Jack Hayes
Jack Hayes
Andrew Irwin
Andrew Irwin
David Lorello
David Lorello
Meredith Rathbone
Meredith Rathbone
Julia Ryan
Julia Ryan

On December 19, 2011, the US Department of State's Directorate of Defense Trade Controls ("DDTC") published a proposed rule to amend Part 129 of the International Traffic in Arms Regulations ("ITAR") relating to brokering and other select provisions.  The proposed rule would expand the scope of the activities that constitute brokering, and also would provide additional exemptions.  In addition, the proposed rule would amend brokering-related registration, prior approval, reporting, and recordkeeping provisions.  A summary of the detailed proposed rule follows.

Definitions of "Broker" and "Brokering Activities" in Proposed § 129.2

  • Broker: The proposed rule would amend the definition of a "broker" to mean "any person who engages in brokering activities."  The proposed language would not maintain the current elements in the definition that limit a broker to someone: i) "who acts as an agent for others"; and ii) "in return for a fee, commission, or

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