EAR License Exceptions Under Export Control Reform

As part of the transfer of items from the U.S. Munitions List (USML) to the Commerce Control List (CCL), the new rules published by the U.S. Department of Commerce’s Bureau of Industry and Security and the U.S. Department of State’s Directorate of Defense Trade Controls explain how transferred defense articles will be treated as dual-use goods. The new rules also attempt to ensure that USML articles that benefit from existing license exemptions in the International Traffic in Arms Regulations (ITAR) will receive similar treatment under the Export Administration Regulations (EAR) while also restricting the use of some existing EAR license exceptions for transferred articles.

Join us for a one-hour webinar to discuss shifting jurisdiction from the USML to the CCL. Our presenters will provide helpful guidance for companies that are facing a learning curve not only on commodity jurisdiction and reclassification determinations, but also on the transition from ITAR license exemptions to EAR license exceptions.

Topics will include: 

• The steps needed to determine whether license exceptions may be used
• EAR license exception treatment compared to ITAR license exemptions
• Which EAR license exceptions are available
• How the new rules change certain license exceptions
• Eligibility under different license exceptions
• Compliance practices under the new rules

moderator
Margaret Gatti

panelists
Marynell DeVaughn
Louis Rothberg

CLE credit
CLE credit in FL, IL, NJ, NY, PA, TX, and VA is currently pending approval.

For more information, please contact Edita Vatenaite at evatenaite@morganlewis.com or 202.739.5668.