The View From Above: How Export Control Reform Will Impact Aviation

Jonathan M. Epstein is a Partner in our Washington, D.C. office

As part of their efforts to reform export controls, the Department of State and the Department of Commerce are planning to move certain military aircraft, aircraft engines, and specially designed aircraft parts and components off of the U.S. Munitions List ('USML') under the International Traffic In Arms ('ITAR') list, and place such items under the licensing jurisdiction of the Department of Commerce. It is not unlikely that these reforms, proposed in late 2011, will be implemented some time in 2013. These reforms will reduce the type of military aircraft parts and components that require a licence to export to certain countries.