Real-World Implementation of the New Export Control Definitions and DCS Rules
Teradyne, Inc., 600 Riverpark Drive, North Reading, MA
Wiggin and Dana Partner Tahlia Townsend will join two additional speakers and discuss the recently published final rules affecting key definitions and terms under the Export Administration Regulations (EAR) and the International Traffic in Arms Regulations (ITAR).
The Bureau of Industry and Security (BIS) and the Directorate of Defense Trade Controls (DDTC) have recently published two sets of landmark companion final rules affecting key definitions and terms under the Export Administration Regulations (EAR) and the International Traffic in Arms Regulations (ITAR), respectively. The first set of rules, which took effect on September 1, refined and harmonized several fundamental definitions while also clarifying the application of EAR controls over the electronic transfer and storage of technology and software. Some of the key definitions harmonized under both the EAR and ITAR include "export," "reexport," "release" and "transfer," with several additional definitions revised under the EAR. The second set of rules, which will take effect on November 15, revised and harmonized the Destination Control Statement (DCS) under both the EAR and the ITAR. These deceptively complex rules not only impact the DCS verbiage, but they also specify when the DCS must be used and introduce new requirements for provision of certain export control licensing and classification information on the Commercial Invoice.
The speakers will discuss the specifics of these new rules, including key definitions, requirements, and applications. You will also hear from two export compliance practitioners who will discuss how they are assessing and adapting their export operational procedures and business practices to ensure compliance with the new rules while minimizing disruption. Speakers include: Brian Amero, Director of Global Compliance and Ethics — Teradyne, Inc.; Dirk Petersen, Vice President, Contracts & Trade Compliance — AMETEK Aerospace and Defense; Tahlia Townsend, Partner — Wiggin and Dana LLP.