The United States is in the middle of the largest change in its export control regime in over 25 years. This Export Control Reform is rewriting the ITAR and the US Munitions List and effective October 15th 2013 moved thousands of military aircraft parts and components from ITAR jurisdiction to the jurisdiction of the US Commerce Department under the Export Administration Regulations. Far from being a simple decontrol, this Reform will result in a wide array of different compliance obligations for US exporters and the EU companies that use US origin technology, parts and components in aerospace, defence and security programs. This program will explain the reality of the new Munitions List categories, what the move to the Commerce Department really means, how the transition rules work, how the changes will affect dual and third country nationals and how Technical Assistance Agreements will be affected.
The US Export Control Reform will have impact for EU businesses using US origin technology, parts and components. What are the EU implications of the US ECR for these businesses and will the changes require the European Commission to adjust and complete some provisions of the EU Dual Use Regulation or national governments to review their national export controls rules?
About the speakers:
Curtis Dombek, Partner, Sheppard Mullin Richter & Hampton
Curt Dombek is the Managing Partner of the Brussels office of Sheppard Mullin Richter & Hampton, an international firm of 650 lawyers based in California with offices across the United States, in China, South Korea and Europe. He earned his undergraduate and law degrees at Harvard and has advised clients for 30 years on cross-border transactions and regulations affecting aerospace and defence, telecommunications, security and computer industries. He was appointed in 2011 to the President’s Export Council Subcommittee on Export Administration and in 2012 to the Regulations and Procedures Technical Advisory Committee of the Commerce Department, where he is working on implementation of the US Export Control Reform.
Brian Mulier, Partner, Bird & Bird
Brian Mulier's expertise covers the full range of customs and trade related matters as well as the application of EU export controls, including dual-use and military products and technologies, and economic sanctions. Besides export controls and sanctions he has extensive experience in advising multi-national clients in relation to customs valuation and transfer pricing, rules of origin and customs efficient supply chain (re-)structuring, including sourcing strategies and optimising the use of free trade agreements.
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