Host Tim O'Toole and guests Melissa Burgess (Miller & Chevalier) and Johanna Reeves (Reeves & Dola, LLP) discuss changes to the ITAR that came into effect in 2024, proposed rules that could be finalized in 2025, and the enforcement outlook for the new year.

Roadmap:

• Updates: Addition of Nicaragua as a 126.1 country and new DDTC guidance for universities
• Deeper dives
  • Expansion of § 120.54: Activities that are not exports, reexports, retransfers, or temporary imports
  • AUKUS-related changes and new FAQs
  • Proposed rules: defense services
• Enforcement: DDTC and BIS approaches in recent years, what does the future look like in the wake of Jarkesy and Loper Bright?

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EMBARGOED! is not intended and cannot be relied on as legal advice; the content only reflects the thoughts and opinions of its hosts. EMBARGOED! is intelligent talk about sanctions, export controls, and all things international trade for trade nerds and normal human beings alike. Each episode will feature deep thoughts and hot takes about the latest headline-grabbing developments in this area of the law, as well as some below-the-radar items to keep an eye on. Subscribe wherever you get your podcasts for new episodes so you don't miss out!