The title of this post comes by way of an e-mail I received from another lawyer in Vermont. I could not believe my eyes when I saw the question. This attorney honestly believed that exports to some countries were 100% exempt from the ITAR rules.
Let me get the record straight...if you are going to sell USML products internationally, no matter where it is going, you are going to need a license, unless one of the exemptions applies. Specific destinations are not exempt from ITAR restrictions. For all of you hoping otherwise I hate to burst your bubble.
The closest thing there is to a blanket country exception is found under ITAR Part 126.5 (the Canadian Exceptions), but those rules by no means give unfettered access to the Canadian market.
I love my job.
Wednesday, March 5, 2008
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