Background

Effective June 6 the Department of State has imposed statutory debarment under the International Traffic in Arms Regulations on 23 persons convicted of violating or conspiring to violate Section 38 of the Arms Export Control Act. As a result, these individuals are prohibited from participating directly or indirectly in activities regulated by the ITAR, including any brokering activities and any export from or temporary import into the U.S. of defense articles, technical data, or defense services in all situations covered by the ITAR.

Exceptions to this debarment determination may be made on a case-by-case basis. However, any such exception would be granted only after a full review of all circumstances, with particular attention to whether an exception is warranted by overriding U.S. foreign policy or national security interests, whether an exception would further law enforcement concerns that are consistent with U.S. foreign policy or national security interests, or whether other compelling circumstances exist that are consistent with U.S. foreign policy or national security interests and that do not conflict with law enforcement concerns. Even if exceptions are granted, the debarment will continue until subsequent reinstatement.

The period for debarment is generally three years from the date of conviction. Export privileges may be reinstated only at the request of the debarred person, which may be submitted no earlier than one year after the date of debarment.

For more information, please contact export compliance attorney Kristine Pirnia.

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