Bruce Leeds, Author at Braumiller Law Group

Revisions and updates to the International Traffic in Arms Regulations (ITAR)

Hot (or at least warm) Off the Press: Updates & Revisions to the ITAR

February 2, 2023

By Bruce Leeds, Senior Counsel, Braumiller Law Group

The Directorate of Defense Trade Controls (DDTC) is continuing its project to revise and update the International Traffic in Arms Regulations (ITAR). Some of the changes are editorial and some are substantive. If you are affected by the ITAR or think you might be, you will need to stay on top of the changes because some (or all) may affect you.

What Have They Done to the ITAR? – Revisions and Reorganization Underway

October 2, 2022

By: Bruce Leeds, Senior Counsel, Braumiller Law Group
Joe Compliance has an export control issue involving definition of some of the terms being used. Joe goes to the website of the Directorate of Defense Trade Controls (pmddtc.state.gov) and clicks on “Review the ITAR.” He opens Part 120 where the definitions are found.

DDTC is Open to Open General Licenses

August 9, 2022

By: Bruce Leeds, Senior Counsel, Braumiller Law Group

Some may be familiar with Open General Licenses (OGLs) used in the United Kingdom and some other countries. They allow export of dual-use, strategic and other controlled articles to specific destinations under certain conditions.

In the Middle of Changing the MID CBP Proposal for Global Business Identifier

December 6, 2021

By: Bruce Leeds, Senior Counsel, Braumiller Law Group

In a Federal Register Notice on Oct. 6, 2021, U.S. Customs and Border Protection published a 60-Day Notice and request for comments for a Global Business Identifier (GBI) Evaluative Proof of Concept (EPoC).

Continuing the Proposal for Customs Broker Continuing Education

October 5, 2021

By: Bruce Leeds, Senior of Counsel

On Oct. 28, 2020, U.S. Customs and Border Protection (CBP) published an Advance Notice of Proposed Rulemaking on continuing education for individually licensed customs brokers. After receiving comments and feedback from the trade, CBP published a Notice of Proposed Rulemaking (NPRM) on this proposal on Sept. 10, 2021.

The ITAR Australia and UK Exemptions – Better Read the Regulations Carefully

August 4, 2021

By: Bruce Leeds, Senior Counsel to Braumiller Law Group and George Alfonso, Of Counsel to Braumiller Law Group and President of Reigncore Lobbying

On behalf of our example, we’d like to introduce you to “Joe Compliance.” Imagine Joe Compliance is going through the International Traffic in Arms Regulations (ITAR) and notices license exemptions for Australia and the UK in Part 126.16 126.17.

Navigating the Export Controls on Semiconductors

June 6, 2021

By Bruce Leeds, Senior Counsel, Braumiller Law Group Determining what export controls apply to semiconductor devices can be a challenging task. Most controls on semiconductor

Exporting to Russia? Things Just Got (More) Difficult

April 6, 2021

By Bruce Leeds, Braumiller Law Group

Exporting to Russia is already a challenge. There are OFAC sanctions arising out of the Ukraine/Crimea situation, Military End User controls, and the usual export licensing requirements.

What’s Happening with Trade in 2021

February 1, 2021

By Bruce Leeds, Senior Counsel, Braumiller Law Group

A new year, a new administration, and new trade initiatives. Well…at least 2 out of 3. Let’s take a look at some import and Customs subjects, then turn to export controls.

Back to Class! Customs Proposal for Continuing Education for Customs Brokers

December 3, 2020

By Bruce H. Leeds, Senior of Counsel, Braumiller Law Group

In a Federal Register Advance Notice of Proposed Rulemaking, dated Oct. 28, 2020, U.S. Customs & Border Protection (CBP) proposed a program for continuing education for licensed individual customs brokers.

Export Controls on Campus A Learning Experience

October 8, 2020

By: Bruce H. Leeds Senior Counsel, Braumiller Law Group

Colleges and universities – Ivy covered buildings with students and faculty engaged in academic pursuits. Colleges and universities – Hotbeds of export control concerns. What?? The halls of academia have increasingly become involved with export control issues. There are several ways that universities are potentially affected …