Skip to content

Menu

LexBlog, Inc. logo
NetworkSub-MenuBrowse by SubjectBrowse by PublisherJoin the NetworkGet StartedSubscribeSupportContact
Search
Close

DDTC’s Definitions of Export, Reexport, and Retransfer: Important Compliance Considerations

By Steptoe International on September 14, 2016
Email this postTweet this postLike this postShare this post on LinkedIn

The State Department’s Directorate of Defense Trade Controls (DDTC) recently published a final rule amending the International Traffic in Arms Regulations (ITAR) to finalize and clarify changes from a June 3, 2016 interim final rule related to the definitions of “export,” “reexport,” and “retransfer.”  For additional information on the interim final rule, see our previous advisory. 

In the preamble, DDTC confirms “that theoretical or potential access to technical data is not a release,” and a release occurs only “if a foreign person does actually access technical data.”  That represents a significant change in DDTC policy and will be relevant for a future DDTC final rule on the treatment of controlled technical data in an encrypted, cloud-based environment. Click here to read more.

  • Posted in:
    Antitrust, Competition and Trade
  • Blog:
    International Compliance Blog
  • Organization:
    Steptoe LLP

Call us at 1-800-913-0988 or email sales@lexblog.com.

Facebook LinkedIn Twitter RSS
The Library at LexBlog
  • About LexBlog
  • The Field We Built
  • Library at LexBlog
  • Our Beliefs
  • Our Team
  • Contact LexBlog
  • Disclaimer
  • Editorial Policy
  • Terms of Service
  • Get Started
  • Publishing Solutions
  • Compass
  • Submit a Request
  • Support Center
  • System Status
Copyright © 2026, LexBlog, Inc. All Rights Reserved.
Law blog design & platform by LexBlog LexBlog Logo