Over at the “Export Control News and Alert” blog, Maarten Sengers, a principal at BSG Consulting, posted an item that is worth a read if you are in the export controls business (an item to store away for potential future review and comment):
A senior official from the Directorate of Defense Trade Controls (DDTC) hinted today that it may consider revisiting the definition of what constitutes a “dual” or “third country” national for purposes of International Traffic in Arms Regulations (ITAR) compliance.
Frank Ruggiero, the Acting Assistant Secretary for the Bureau of Political-Military Affairs noted at a Defense Technical Advisory Group meeting in Washington on April 7 that Commerce, State and the Foreign Military Sales (FMS) program all have different definitions on what constitutes a dual or third country nationals for purposes of export compliance, and that State would look into developing a harmonized interagency approach.
According to Mr. Ruggiero, ”many Governments tell us that from a human and civil rights perspective” they cannot meet the current dual national requirements without violating local laws.
Read the complete post, here.