Client Alerts & Newsletters

Helping Us Help You: DDTC Modernizes ITAR Exemption for Contractor’s Supporting Government Agencies

Apr.22.2019

On April 19, 2019, nearly four years after the initial proposal, DDTC issued a final rule modifying § 126.4 of the International Traffic in Arms (ITAR) to clarify and expand the exemption authorizing exports in support of the US Government, including US foreign assistance and cooperative programs. Most significantly, the revised exemption acknowledges the government’s expanded use of contractor personnel in supporting USG missions often involving foreign parties. The exemption now expressly covers defense services and other exports by “persons or entities in a contractual relationship with the U.S. Government” where use of the defense article or performance of the defense service is within the scope of such contract and where any one of three specified conditions exist and assure government control and oversight of the transfer.

For more information, please contact the professional(s) listed below, or your regular Crowell & Moring contact.

Maria Alejandra (Jana) del-Cerro
Partner – Washington, D.C.
Phone: +1 202.624.2843
Email: mdel-cerro@crowell.com

Alan W. H. Gourley
Partner – Washington, D.C.
Phone: +1 202.624.2561
Email: agourley@crowell.com

Adelicia R. Cliffe
Partner – Washington, D.C.
Phone: +1 202.624.2816
Email: acliffe@crowell.com

Crowell & Moring LLP is an international law firm with more than 500 lawyers representing clients in litigation and arbitration, regulatory, and transactional matters. The firm is internationally recognized for its representation of Fortune 500 companies in high-stakes litigation, as well as its ongoing commitment to pro bono service and diversity. The firm has offices in Washington, DC, New York, Los Angeles, San Francisco, Orange County, London, Brussels, and Shanghai.

View Desktop Site | Mobile Sitemap

Contact | Subscribe | Terms of Use | Privacy Statement | Alumni

© Crowell & Moring LLP 2020
Attorney advertising - prior results do not guarantee a similar outcome.