Author: Bruce Leeds

What the Heck is Drawback and How Do I Use It?

Early in my career I took a position as Import Manager at Hughes Aircraft Company, an aerospace company in California. Hughes had imported a small natural diamond window (the size of a penny), from the Netherlands for use in a spacecraft.

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Export Controls on Satellites – Changes to the Commerce Control List

By Bruce H. Leeds, Senior Counsel I previously wrote about changes to the US Munitions List (USML) in the International Traffic in Arms Regulations (ITAR) affecting export controls on satellites and spacecraft.  Those changes, which will become effective on Nov. 10, 2014, will result in the removal of many satellites, ground equipment, and components from

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Export Controls on Satellites – the Changes are (Almost) Done

By Bruce H. Leeds, Senior Counsel Originally all satellites, whether military, commercial, or remote-sensing were subject to controls under Cat. XV of the US Munitions List (USML) in the International Traffic in Arms Regulations (ITAR).  In the early 1990s most commercial satellites were moved to the Export Administration Regulations (EAR) of the Department of Commerce. 

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Using the Free Resources for Export Classification

By Bruce H. Leeds, Senior Counsel Let’s say you have been asked on short notice to classify for export control purposes a military aircraft component formerly subject to controls under the International Traffic in Arms Regulations (ITAR). The U.S. Munitions List category in which you would have previously classified it has been re-written through the

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Get Ready for Round Three of Export Control Reform

By Bruce Leeds, Senior Counsel July 1st not only marks the mid-point of the year, but is also the effective date of round three of Export Control Reform. The same process was used with round three as with rounds one and two.  Specific categories of the US Munitions List (USML) in the International Traffic in

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The Raytheon Case Illustrates the Other Half of Compliance

The Raytheon Company recently entered into a consent agreement with the Directorate of Defense Trade Controls (DDTC) of the Department of State settling allegations that it violated the Arms Export Control Act and the International Traffic in Arms Regulations (ITAR) by failing to properly manage license agreements and temporary export and import licenses. In the

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The Impact of Export Control Reform on an Electronics Subcontractor

Acme Electronics (Acme) is a medium-sized company in the U.S. that makes products (primarily circuit board assemblies and wiring harnesses) used in commercial and military aircraft. Acme occasionally sells these products to aircraft manufacturers, but most of its sales are to major U.S. and foreign subcontractors to aircraft manufacturers. Acme has a pretty straightforward process

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USML Cat. XI Rewrite – A Major Change to ITAR Controls

Category XI of the U.S. Munitions List (USML) controls a broad range of military electronics, placing them under the export controls enumerated in the International Traffic in Arms Regulations (ITAR). In a Federal Register notice dated Nov. 28, the Department of State announced a proposed rule that would dramatically change Category XI and move many

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