Several years ago, the head of the State Department’s Director of Defense Trade Controls (DDTC) explained that, when a company engaged in substantial exporting makes no voluntary disclosures of export control violations, something is wrong. He reasoned that every company is made up of human beings—and human beings make mistakes, so every company doing lots
Helping individuals, companies, and organizations understand key legal and practical considerations for promoting compliance and making better business decisions in these types of federal, state, and local government contracting matters MORE
International, Battlefield and Contingency Contracting
New Changes to the ITAR Focus on Unclassified Technical Data And the release of “Access Information”
By Eric Whytsell on
As part of its years-long project to update and revise the International Traffic in Arms Regulations (ITAR) and better align them with the Export Control Regulations, the Department of State (DoS) recently amended the ITAR with an interim rule to address another group of amendments first proposed in June of 2015. The new rule defines…
Managing Your Supply Chain Just Got Trickier: Interim FAR Rule Prohibiting Contracting for Telecommunications and Video Surveillance Goes Into Effect
By Susan Ebner on
Continuing threats to the supply chain pose increasing risks to our national security. The new interim Federal Acquisition Regulation (FAR) rule published on August 13, 2019, seeks to address certain of these threats by imposing new representation and reporting requirements on contractors and their subcontractors (herein “contractors”) in the new FAR 52.204-24 Representation Regarding Certain…