The State Department’s Directorate of Defense Trade Controls released an update last week to its guidance for U.S. persons providing defense services abroad. The documents include an updated guidance for U.S. persons abroad (USPAB) authorization requests, a new sample certification letter for USPAB authorization requests, a new USPAB submission letter template and an updated set of frequently asked questions.
A revision to U.S. export regulations included in the fiscal year 2023 defense spending bill could lead to new end-use screening obligations for U.S. people and companies operating abroad, Akin Gump said in a Jan. 5 client alert. Although it remains unclear how and when the Bureau of Industry and Security will implement the change, the law firm said it could lead to new restrictions on activities that support foreign military, security or intelligence services even if the activity doesn’t involve technology subject to the Export Administration Regulations.