Conference Session

Session 3: Export Control

Collection

2017 Public Policy Colloquium

Authors

Kevin Wolf

“technology” or “software,” a comparable authorization is required to transfer access information if done with “knowledge” that such transfer would result in the release of such “technology” or “software” without a required authorization See § 772.1 for new definition of “access information” DDTC did not address this in its interim final or final rule since it did not adopt other revisions in its proposed rule 23EAR § 734.20: Activities that Are Not Deemed Reexports Codifies prior BIS website guidance and reflects §§ 124.16 and 126.18 of the ITAR ● Note: DDTC moved old § 124.16 to § 126.18(d) in the interim final rule Release not a deemed reexport if