Client Alerts & Newsletters

Reform Initiative Becomes Reality

April 16, 2013

Today, the U.S. Departments of State and Commerce simultaneously published final rules to take effect in 180 days representing the initial step in completing the first phase of the Export Control Initiative: the creation of a brighter line between the U.S. Munitions List (USML) and the Commerce Control List (CCL). These rules include a uniform, but controversial, definition of "specially designed," a revised version of Category VIII (Aircraft & Related Articles) and the associated new Category XIX (Gas Turbine Engines & Associated Equipment), the unchanged Categories XVII (Classified Articles Not Otherwise Enumerated) and XXI (Defense Articles Not Otherwise Enumerated), and a licensing transition plan for those items moving from the USML to the CCL.

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

Alan W. H. Gourley
Partner – Washington, D.C.
Phone: +1.202.624.2561

Crowell & Moring LLP is an international law firm with offices in the United States, Europe, MENA, and Asia that represents clients in litigation and arbitration, regulatory and policy, and transactional and corporate matters. The firm is internationally recognized for its representation of Fortune 500 companies in high-stakes litigation and government-facing matters, as well as its ongoing commitment to pro bono service and diversity, equity, and inclusion.

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