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ITAR Requirement Suspensions and Modifications are Focus of Comment Request

Wednesday, June 10, 2020
Sandler, Travis & Rosenberg Trade Report

The State Department is accepting comments through June 25 on the following temporary suspensions, modifications, and exceptions to International Traffic in Arms Regulations provisions issued in response to the COVID-19 pandemic.

- temporary suspension of requirement to renew registration as a manufacturer, exporter, and/or broker and pay a fee on an annual basis by extending ITAR registrations expiring on Feb. 29, March 31, April 30, May 31, and June 30 for two months from the original date of expiration

- extension of any ITAR license that expired between March 13 and May 31 for six months from the original date of expiration so long as there is no change to the scope or value of the authorization and no name or address changes are required

- authorization for regular company employees to work at a remote work location so long as they are not located in Russia or a country listed in ITAR § 126.1 (this provision will terminate July 31 unless otherwise extended in writing)

- authorization for regular employees of licensed entities who are working remotely in a country not currently authorized by a TAA, MLA, or exemption to send, receive, or access any technical data authorized for export, reexport, or retransfer to their employer via a TAA, MLA, or exemption so long as the employee is not located in Russia or a country listed in ITAR § 126.1 (this provision will terminate July 31 unless otherwise extended in writing)

State is limiting its consideration of comments to the following areas.

- the efficacy of these actions on the operating environments of regulated community members during the COVID-19 emergency

- whether the original expiration dates are sufficient or should be considered for extension (and why)

- any additional temporary suspensions, modifications, or exceptions that should be considered in response to specific difficulties in operating conditions that have arisen for the regulated community as a direct result of the crisis (and why)

For more information, please contact Kristine Pirnia.

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