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ITAR Update

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Jean G. Schtokal
Foster Swift Business & Corporate Law Report
November 13, 2013

A big part of successfully engaging in importing and exporting is navigating through the complex regulations, especially for a company whose exports fall under the International Traffic in Arms Regulations (ITAR). Here is a quick update on a recent change.

The DS-2032 used by the Directorate of Defense Trade Controls (DDTC) for registration and renewal of registration has changed. These changes are in part related to significant ITAR regulation changes already in effect. If you don't know about the changes, be sure to contact knowledgeable legal counsel to determine how the changes affect your company and to receive training regarding these ITAR changes.

How can you tell if you are using the old Statement of Registration form? The old form has "Electronic Form Version Number: 3.0" in the top left of the form. Although that form says the expiration date is 9/30/14, all registrants must use the new form which is "Electronic Form Version Number: 4.0". According to the DDTC website, older versions of the form will not be accepted after the effective date of October 25. Also, you can now file the form electronically (via EFS). If you wish, you can still register or renew by registered or express mail until the end of this year. Electronic filing of the DS-2032 Statement of Registration will be mandatory starting January 1, 2014.

If you need assistance adjusting to the new form, please give us a call. The changes include, among other things: the new Category XIX for Gas Turbine Engines and Associated Equipment, additional Ultimate and Intermediate Parent Company information; certification language additions and other changes, and several changes to the Block 12 information on foreign ownership. The form will also likely catch more registrations that should be consolidated due to common ownership or control.

Please note license application forms have also been updated; this means the DSP forms you commonly use.

Contact Attorney Jean Schtokal at jschtokal@fosterswift.com or 517.371.8276 with any questions.