Late last month, DDTC proposed an ITAR amendment to clarify the licensing and registration requirements for U.S. persons who provide defense services to a foreign-person employer. One of several proposed amendments, for example, clarifies that the ITAR’s registration requirement for persons who engage in the United States in the manufacture, export or temporary import of defense articles also applies to U.S. persons who perform defense services abroad. The State Department is accepting industry comments until July 27, 2015.

For additional detail on the proposed amendments, see the Federal Register notice.