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Export Control Reform:  Why Less Licensing = More Complexity
 

Export Control Reform: Why Less Licensing = More Complexity

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Customers in highly regulated industries, such as those in aerospace and defense, industrial machinery and components, high tech, chemicals, and energy are often required to comply with complex export ...

Customers in highly regulated industries, such as those in aerospace and defense, industrial machinery and components, high tech, chemicals, and energy are often required to comply with complex export control regulations on technical data.

New rules implementing export control reforms become effective October 15, 2013. These reforms include the transfer of less sensitive military items currently controlled under the International Traffic in Arms Regulations (ITAR) to the more flexible Export Administration Regulations (EAR) that the Department of Commerce administers. This webinar will cover the key proposed updates and the timeline for implementation.

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    Export Control Reform:  Why Less Licensing = More Complexity Export Control Reform: Why Less Licensing = More Complexity Presentation Transcript

    • Export Control Reform: Why Less Licensing = More Complexity NextLabs Webinar ® G L O B A L L E G A L S E R V IC E S presented by Gary Stanley, Global Legal Services, PC, Washington, DC October 30, 2013
    • G L O B A L L E G A L S E R V IC E S U.S. Export Control Reform Is Here! “Before Reform” “After Reform” If U.S. suppliers didn’t understand U.S. export controls before, how will they master this much more complicated system? NextLabs Webinar – Export Control Reform 30 October 2013 2
    • G L O B A L L E G A L S E R V IC E S Timeline of Obama Export Reform Initiative  Jan. 2009 - Initiative arguably began as early as the day of President Obama’s first inauguration Secretary of Defense Robert Gates reportedly handed him a copy of the National Academy of Sciences’ Beyond “Fortress America” : National Security Controls on Science and Technology in a Globalized World  Aug. 2009 – Obama orders National Economic Council/National Security Council to conduct a broad-based interagency review of the current U.S. export control regime  Dec. 2009 – President Obama issues Presidential Study Directive (PSD8) setting a deadline of Jan. 29, 2010, to prepare "comprehensive" statutory and regulatory recommendations "to create a new U.S. export control system."  Aug. 31, 2010 – President Obama formally announces “4 Singles” approach to export control reform initiative NextLabs Webinar – Export Control Reform 30 October 2013 3
    • G L O B A L L E G A L S E R V IC E S Key Recent Developments  Initial Implementation – April 16, 2013 – Became Effective Oct. 15, 2013 New U.S. Munitions List Category VIII – Military aircraft & Category XIX – Gas Turbine Engines and Associated Equipment New Commerce Control List “600 Series” ECCNs 9A610 & 9A619, 9B610 & 9B619, 9C610 & 9C619, 9D610 & 9D619, and 9E610 & 9E619 New ITAR & EAR “catch and release” definitions of “specially designed” EAR §744.17 “China Catch-All” applied to all “600 series” items Multiple other implementing changes to ITAR & EAR – E.g., new Destination Control Statement requirements at ITAR § 123.9(b) and EAR § 758.6(b)  Other Forthcoming Changes: New ITAR Part 129 Brokering Regulations – Effective Oct. 25, 2013 Revised USML Categories VI, VII, XIII, & XX and corresponding “600 series” ECCNs – Effective Jan. 6, 2014  Other Proposed Changes USML Cat. IV, V, IX, X, XI, XV, & XVI and corresponding “600 series” ECCNs New Definition of “Defense Services”30 October 2013 Reg. 31444 (May 24, 2013) – 78 Fed. NextLabs Webinar – Export Control Reform 4
    • G L O B A L L E G A L S E R V IC E S Thank You for viewing a preview of our webinar Export Control Reform: Why Less Licensing = More Complexity To request a free copy of the full webinar, Click HERE. NextLabs Webinar – Export Control Reform 30 October 2013 5
    • G L O B A L L E G A L S E R V IC E S Thank You for viewing a preview of our webinar Export Control Reform: Why Less Licensing = More Complexity To request a free copy of the full webinar, Click HERE. NextLabs Webinar – Export Control Reform 30 October 2013 5