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Clarification to Definition of Export/Transfer of Certain ITAR Controlled Items

News & Blog

DDTC has recently published a final rule defining what is not considered an export, retransfer, or temporary import of certain ITAR controlled items. The rule clarifies that the following are NOT considered controlled exports, retransfers, or temporary imports:

  1. Launching of Items into Space
  2. Transfer of technical data to a U.S. person in the U.S. from a person in the U.S.
  3. Retransfer of technical data within a foreign country from one U.S. person to another.
  4. Transfer of defense articles between or among the United States.
  5. Transfer of end-to-end encrypted technical data for access by authorized (i.e. U.S. persons, licensed recipients) recipients excluding Russian Federation and 126.1 sanctioned countries


The entire rule can be found at:


Please contact us if you have any questions.

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