On December 5, 2022, the Directorate of Defense Trade Controls (DDTC) issued its International Traffic in Arms Regulations (ITAR) Compliance Program Guidelines (ITAR Compliance Guidelines). The extensive guidelines – 63 pages in total – are similar in scope and content to compliance materials promulgated by the U.S. Department of the Treasury Office of Foreign Assets Control (OFAC) and the U.S. Department of Commerce’s Bureau of Industry and Security (BIS), rounding out regulatory guidance in the field.
Of note, DDTC highlights best practices when engaging in mergers, acquisitions, and divestitures (MAD, as defined in the guidelines, or M&A) transactions involving DDTC registrants and organizations that engage in ITAR-controlled activities.
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