Access Recording:

US PERSONS WORKING ABROAD FOR DEFENSE CONTRACTORS: DDTC’S NEW AUTHORIZATION PROCESS

OCCURRED ON THURSDAY | OCTOBER 8, 2020 | 2:00 PM ET

 

TOPICS INCLUDED:

  • US Persons Working Abroad for Defense Contractors:  DDTC’s New Authorization Process.  After years of inconsistent policies as to what ITAR authorization U.S. nationals should obtain before performing defense services for foreign employers, the U.S. Department of State’s Directorate of Defense Trade Controls (DDTC) posted a set of Frequently Asked Questions in early January detailing what it now says are its authorization requirements and process in such situations.  The new rules apply not just to individual Americans working abroad for unrelated foreign employers, but also U.S. companies which detail workers for assignments at foreign parents and subsidiaries.  Thus, this session is important not just for legal and compliance staffs, but also HR personnel.
  • All should attend to learn:
    • DDTC’s General Correspondence process for authorizing U.S. nationals performing defense services for foreign employers;
    • What steps a U.S. employee and its foreign employer should take if the employee has previously been performing defense services without authorization; and
    • Whether an authorized U.S. national employee’s work on a foreign defense article will “taint” that product with ITAR reexport/retransfer authorization requirements.

SPEAKERS: Gary Stanley, President| Global Legal Services