I had the most pleasant ITAR releated conversation with Steven, Steven delves deep into the intricacies of the Arms Export Control Act (AECA) and the modalities of arms sales, including Foreign Military Sales (FMS) and Direct Commercial Sales (DCS) processes.
Steven explores the objectives of the AECA and its integration with other US laws and regulations concerning arms transfers. Our expert shares insights into the challenges faced in understanding and complying with the AECA.
Next, we dissect the major differences between FMS and DCS processes, outlining the roles of key actors involved and situations where one process might be preferable over the other.
Moving on, we unravel the mechanics of ITAR licensing, focusing on its application to the DCS process. Steven demystifies the types of items subject to ITAR licensing, delves into the various types of licenses available, and discusses common pitfalls exporters should be wary of.
Finally, we address the requirements exporters must adhere to post-approval of an export license, including end-user and end-use verification procedures, compliance with recordkeeping, and reporting requirements. Our discussion also encompasses the consequences of non-compliance with export control regulations and strategies for mitigating them.