home Export Controls, Trade Security & Related ABA Ad Hoc Coalition Submits Comments to USG on Proposed Revisions of US Export Control Regulations

ABA Ad Hoc Coalition Submits Comments to USG on Proposed Revisions of US Export Control Regulations

The Ad Hoc Coalition for Effective Export Control Reform (“CEECR”) submitted, on August 3, the embedded document to the U.S. Department of Commerce,Bureau of Industry and Security (“BIS”) and the U.S. Department of State, Directorate of Defense Controls (“DDTC”) in response to proposed revisions to certain definitions in the Export Administration Regulations (EAR) and the International Traffic in Arms Regulations (ITAR).

More than 10 attorneys made up the CEECR (see Footnote 1) who specialize in expert controls and economic sanctions and are also members of the American Bar Association International Law Section Committee on Export Controls and Economic Sanctions (ECES). Special thanks to Geoffrey Goodale of Trade Law Advisors in Washington, DC who successfully managed the CEECR process that has resulted in a consensus document covering a broad range of issue areas that the CEECR hopes will be seriously considered by DDTC and BIS.

The submission states that while the it is clear from the Proposed Rules “that much thought went into the proposed definitions” released by the U.S. government as part of ongoing export control reform efforts, and that there is a “significant improvement over earlier versions,” it is the CEECR’s view that the “proposed definitions for certain terms under the EAR and ITAR could be further improved by making the changes or clarifications that are recommended below.”

Comments to Proposed Revisions to US Export Control Regulations

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