BIS recently issued a proposed rule for a new “ICT” license exception that would allow approved parent companies and subsidiaries to export, reexport or transfer controlled items among themselves. The exemption would require prior approval and would not cover all controlled items. To qualify for ICT, companies would be required to implement an ICT control plan that would include physical and information security plans, personnel screening procedures, training programs, self-audits, and non-disclosure agreements, among other things. ICT authorizations would never expire, but could be deemed invalid because of changed circumstances, such as a change in control of a parent company.