THE JOURNAL OF EXPORT CONTROLS AND SANCTIONS

Issue 55, November 2016

Understanding U.S. re-export rules:  the ITAR and OFAC sanctions

In the second of a two-part article exploring U.S. re-export rules, Kevin DiBartolo describes the impact of the International Traffic in Arms Regulations (‘ITAR’) and the regulations administered..

In the second of a two-part article exploring U.S. re-export rules, Kevin DiBartolo describes the impact of the International Traffic in Arms Regulations (‘ITAR’) and the regulations administered by the U.S. Treasury’s Office of Foreign Assets Control (‘OFAC’).   For companies outside the United States, perhaps the most anxiety-inducing aspect of U.S. export control and sanctions laws is their broad extraterritorial reach. Unlike those of most countries, U.S. export controls and sanctions laws continue to apply to U.S.-origin products after those items have left the United States. In many cases, these rules also apply to non-U.S.-items that incorporate some threshold...

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