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Anticipated ITAR Developments in 2022


In this article, author Christopher Stagg discussed anticipated International Traffic in Arms Regulations (ITAR) regulatory developments that the U.S. Department of State's Directorate of Defense Trade Controls' (DDTC) will focus on in 2022. "DDTC is preparing an interim final rule that will make various unspecified revisions to the U.S. Munitions List (USML), along other associated parts of the ITAR, by removing certain items while also adding 'entries for critical and emerging technologies,'" Stagg wrote. In addition to USML revisions, regulatory revisions regarding personal protective equipment exemption, regular employee definition and expansion of ITAR section 120.54 are being made. "Although most of these potential regulatory changes will take time to develop, it is important that an organization review how it might be affected by them and prepare accordingly," Stagg wrote, adding that "being aware that DDTC is considering future rulemaking involving a regulatory provision that currently presents complications for a company may impact whether that company should interact with DDTC, wait for the public comment process to press its case, or seek other alternatives such as a legal opinion. An organization should carefully analyze its consequences and whether it lacks clarity, providing feedback to the government in the form of a public comment when the proposed or interim final rule is issued."