ITAR PRACTITIONER’S HANDBOOK

1 Current through 80 FR 37974, July 2, 2015 Includes: Codified International Traffic in Arms RegulationsCommerce Control List 600 SeriesSummary of ITAR and EAR ExemptionsPrimer for Export Controls Complianceand moreITAR PRACTITIONER S HANDBOOK 2015 Second Edition 2009-2014 Squire Patton Boggs i FOREWORD SCOPE AND USE OF THIS HANDBOOK This publication of the International Traffic in Arms Regulations (ITAR) is intended to be a convenient reference guide for the reader. The official versions of the regulations contained herein are set forth in the annual printings of Title 22 of the Code of Federal Regulations (CFR), as amended in the Federal Register (FR).

2 This publication was taken from the Electronic Code of Federal Regulations (e-CFR) published by the Government Printing Office. This publication contains changes to the ITAR through Federal Register Notice Volume 80, Number 127, July 2, 2015 (80 FR 30615), concerning corrections and updates to the United States Munitions List (USML) for Category XI. This publication also includes changes due to Export Control Reform (ECR). The first five rules of ECR have been incorporated and are effective at this time.

3 The tables of contents, Editorial Notes and appendices have been added to this publication for the reader s convenience and reference. This HANDBOOK includes an index of export controls acronyms, an index and summary of license exemptions provided for in the ITAR, a DDTC phone directory, DDTC license processing times table, a list of DTrade country codes, and a primer on the ITAR that covers: getting started with the ITAR Determining the export jurisdiction and classification for products and technology Export licensing under the ITAR Employment of foreign persons Technical collaboration with foreign persons Essential elements of compliance programs Penalties In addition, this publication contains an appendix with the new 600 series Groups A and E of the Export Administration Regulations (EAR).

4 The appendix gives a basic understanding of how the 600-Series hardware and technology have moved from the USML to the Commerce Control List (CCL) and is not intended to be a complete listing of all items that have moved over. This publication contains changes to the EAR 600-Series through Federal Register Notice Volume 80, Number 133, July 13, 2015 (80 FR 39950), concerning corrections and updates to the ECCN 3A611, 9A5154 and 9E515. REPRODUCTION OF THIS HANDBOOK This HANDBOOK may be reproduced in its entirety and distributed in its entirety within your organization or at your event.

5 You may not reproduce selected pages or excerpts from this HANDBOOK or excerpt any pages or text from the reproduction of the HANDBOOK . QUESTIONS CONCERNING THE ITAR OR THIS HANDBOOK Questions concerning the ITAR or this HANDBOOK may be directed to: George N. Grammas Squire Patton Boggs +1 202 626 6234 2009-2015 Squire Patton Boggs ii ACKNOWLEDGEMENTS This HANDBOOK is the result of efforts by the many of us at Squire Patton Boggs, but we particularly wish to acknowledge the extensive contributions of the following: Kevin A.

6 Hoppin Christopher H. Skinner * * * We hope you find this publication useful, George N. Grammas Chair, Global Import and Export Compliance Squire Patton Boggs WHY CHOOSE SQUIRE PATTON BOGGS Worldwide reach in a local context allows us to respond in real time to your global trade compliance needs with a single call to your local contact. Our integration allows us to operate internally as a global team, to ensure we understand the implications for your business in all the jurisdictions you do business.

7 Whether your organization is a multinational company or a small importer or exporter, our global solution means you benefit from: A local point of contact; Our exceptional depth of experience in successfully handling the full spectrum of international trade compliance and technology transfer matters, including some of the most challenging and politically sensitive legal issues that arise in the conduct of international trade and technology transfer; Our presence in the US, EU, China, the Middle East and almost every other region and country; Our knowledge of the local government regulations understanding of the complexities of administration and enforcement; and Our excellent network of contacts with the competent regulators.

8 DISCLAIMER AND LEGAL NOTICE THIS PUBLICATION IS PROVIDED TO READERS ON AN AS IS BASIS, WITHOUT ANY EXPRESS OR IMPLIED WARRANTIES OR ANY KIND, INCLUDING IMPLIED WARRANTIES OF MERCHANTABILITY AND FITNESS FOR A PARTICULAR PURPOSE. This publication is provided solely for the convenience of the reader and its contents should not be construed as legal advice. The reader is advised to consult with legal counsel before proceeding with respect to any specific issue. By using this publication, the reader accepts the risk that this publication may contain errors or omissions and that any of the regulations contained herein might not be the most current version of such regulation.

9 Squire Patton Boggs shall not be liable for any damages arising out of or incurred in connection with the use or inability to use, or any errors or omissions or superseded information in this publication (including, without limitation, any consequential, special, direct, indirect, incidental, punitive, or exemplary loss, damage or expense, or any loss of business, loss of profits, business interruption, or loss of business information). 2009-2015. SQUIRE PATTON BOGGS.

10 All rights reserved. No claim to original Government works. Table of Contents Page 2009-2014 Squire Patton Boggs i FOREWORD .. i SCOPE AND USE OF THIS HANDBOOK .. i REPRODUCTION OF THIS HANDBOOK .. i QUESTIONS CONCERNING THE ITAR OR THIS HANDBOOK .. i ACKNOWLEDGEMENTS .. ii WHY CHOOSE SQUIRE PATTON BOGGS .. ii DISCLAIMER AND LEGAL NOTICE .. ii TITLE 22 FOREIGN RELATIONS .. 1 CHAPTER I DEPARTMENT OF STATE .. 1 PART 120 PURPOSE AND DEFINITIONS .. 1 General authorities, receipt of licenses, and ineligibility.