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EMBARGOED!: The ITAR Episode (for the Real Trade Nerds)


In this episode, host Tim O'Toole and guest Scott Gearity, President of the Export Compliance Training Institute (ECTI), talk in-depth about the International Traffic in Arms Regulations (ITAR). They discuss the growing importance of the regulations related to the provision of defense services abroad by U.S. persons, the jurisdictional implications of importing of foreign made defense articles into the U.S., the growing compliance challenges of the deemed export rule, the recently revised Directorate of Defense Trade Controls (DDTC) compliance guidelines and risk matrices, the reorganization of the ITAR, the 10-year anniversary of export control reform (ECR), and the effect ECR has had on the Export Administration Regulations (EAR). 


  • Introduction
  • Defense services abroad
  • Subject to the ITAR from coming into the U.S.
  • Deemed export/SpaceX
  • ITAR Part 120 rewrite
  • DDTC revised compliance program guidance/risk matrix
  • 10-year anniversary of ECR
  • Complexity at the Bureau of Industry and Security (BIS)


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EMBARGOED! is not intended and cannot be relied on as legal advice; the content only reflects the thoughts and opinions of its hosts.

EMBARGOED! is intelligent talk about sanctions, export controls, and all things international trade for trade nerds and normal human beings alike. Each episode will feature deep thoughts and hot takes about the latest headline-grabbing developments in this area of the law, as well as some below-the-radar items to keep an eye on. Subscribe wherever you get your podcasts for new bi-weekly episodes so you don't miss out!