On January 6, 2020 the Directorate of Defense Trade Controls (DDTC) published Frequently Asked Questions for guidance on the subject of US persons providing defense services abroad. The guidance addresses questions regarding registration and authorization requirements, as well as the process for obtaining authorization. The guidance is based on existing content in the ITAR, rather than the 2015 proposed rule that was not adopted.
Below is a list of the published FAQs:
- How does the current authorization process for U.S. persons furnishing defense services abroad relate to the 2015 proposed rule (80 FR 30001, May 26 2…
- What is the validity period for authorizations issued under ITAR § 126.9(b)?
- I am a U.S. citizen and I want to work for a foreign entity that works with defense articles. Does the ITAR regulate this activity even if the company…
- What is DDTC’s policy with respect to compliance with the European Union General Data Protection Regulation (GDPR)?…
- How should an ITAR § 126.9(b) request for authorization be submitted?
- Does a U.S. person working on a foreign-origin defense article render that foreign defense article subject to the ITAR by virtue of their involvement?…
- If I do need DDTC authorization to furnish a defense service to my foreign employer, what kind of authorization do I apply for?…
- Can authorizations under ITAR § 126.9(b) be submitted for multiple potential employees at one time?
- I am a U.S. person and I want to work for a foreign entity and furnish a defense service (as described under ITAR § 120.9(a)) – for example assisting …
- If the job description changes for the U.S. person who holds an ITAR § 126.9(b) authorization is a new authorization required?…
- What information should a U.S. person submit to DDTC for an ITAR § 126.9(b) authorization to furnish a defense service to a foreign employer?…
- Can a non-U.S. person who is a prospective employer submit an authorization request under ITAR § 126.9(b) on behalf of the prospective U.S. person emp…
- If I am a U.S. person providing a defense service to a foreign entity in a foreign country, do I need to register with DDTC?…
- Do the nationalities of my prospective foreign employer’s customers affect the requirements for registration and licensing?…