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Focus on Regulation

Export Control Reform Advances

The Obama administration has taken a major step in its export control reform initiative: the submittal of its first formal notification to Congress of proposed changes to the State Department’s U.S. Munitions List.  The notification, which was required under Section 38(f) of the Arms Export Control Act, relates to the movement of certain military aircraft, aircraft parts and gas turbine engines to the Commerce Department’s Commerce Control List. 

The submission kicks off a 30-day review period, after which the Administration plans to publish a Final Rule in the Federal Register to implement the changes.  The control list changes will become effective 180 days after publication of the Final Rule.  The Administration will then roll out a series of additional notices throughout 2013 to implement revisions to other USML categories.  In a related action, President Obama issued an Executive Order to implement certain administrative measures to facilitate the export control reforms.

The Administration’s comprehensive export control initiative will impact nearly all companies engaged in trading controlled U.S.-origin items.  Companies will need to review carefully the control list revisions to identify changes in export control status and applicable licensing requirements.