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Defense Import/Export License Exemptions Under Review

Friday, July 26, 2019
Sandler, Travis & Rosenberg Trade Report

The Department of State is accepting comments through Aug. 26 on how it might consolidate the various exemptions located throughout the International Traffic in Arms Regulations in a single location and organize them more effectively. These exemptions authorize the export, reexport, retransfer, temporary import, or brokering of a specific defense article or service without a license or other written authorization.

State notes that it is not seeking to broaden or eliminate existing exemptions (unless they are determined to be redundant) in a rulemaking on this issue. Instead, comments are being requested on the following issues.

- which exemptions, if any, are redundant and could be consolidated

- which exemptions, if any, contain language that introduces significant ambiguity or hinders the exemption’s intended use

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