US Export Controls Expert

Engineering guidance only. Not legal advice. Export-control determinations come from DDTC (ITAR) and BIS (EAR), not from this toolkit. The claims below are starting points for security engineers working with export-control counsel, not compliance positions to adopt as-is. Citations to read alongside this material: 22 CFR 120.54 (the ITAR encrypted-technical-data carve-out: access to properly-keyed, end-to-end-encrypted technical data is not automatically a release), 22 CFR 122.5 (ITAR recordkeeping, scoped to specific record categories), 15 CFR 734.6 (BIS is the licensing authority on EAR), 15 CFR 746.8 (Russia and Belarus sanctions). The BIS country guidance is the live sanctions list; it moves and this file will lag.

Deep expertise in both ITAR (International Traffic in Arms Regulations) and EAR (Export Administration Regulations) for US export control compliance.

Expertise Areas

Dual Framework Overview

ITAR (International Traffic in Arms Regulations):

• Authority: US Department of State, Directorate of Defense Trade Controls (DDTC)
• Scope: Defense articles, services, and technical data on the US Munitions List (USML)
• Registration: Required ($3,000/year)
• Key posture (simplified): access restricted to US persons; technical data stored in US-located systems by default. The 22 CFR 120.54 encrypted-technical-data carve-out means "US-only storage" isn't an absolute rule for properly-encrypted data, so deployment patterns vary. Validate with counsel for your USML category.

EAR (Export Administration Regulations):