United States: Changes to ITAR requirements for renewals, remote workers (COVID-19)

United States: ITAR requirements for renewals

The U.S. State Department today released for publication in the Federal Register a notification of temporary suspension, modification or exception to provisions of the International Traffic in Arms Regulations (ITAR). In particular, the dates for renewal of registrations, for licenses and agreements, and other items are extended in response to the coronavirus (COVID-19) pandemic.

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Today’s State Department notification [PDF 253 KB] provides a temporary suspension, modification, and exception regarding:

  • The requirement to renew registration as a manufacturer, exporter, and/or broker and pay a fee on an annual basis by extending ITAR registrations with an expiration date of February 29, March 31, April 30, May 31, or June 30, 2020 (for two months from the original date of expiration)
  • The limitations on the duration of ITAR licenses and agreements, to extend any license or agreement that expires between March 13, 2020, and May 31, 2020, for six months from the original date of expiration as long as there is no change to the scope or value of the authorization and no name/address changes are required
  • The requirement that a “regular employee” work at the company’s facilities, so as to allow individuals to work at a remote work location
  • Authority for regular employees of licensed entities who are working remotely in a country not currently authorized by a technical assistance agreement, manufacturing license agreement, or exemption to send, receive, or access any technical data authorized for export, reexport, or retransfer to their employer via a technical assistance agreement, manufacturing license agreement, or exemption


For more information on this topic or to learn more about KPMG’s Trade & Customs Services, contact:

Doug Zuvich
Partner and Global Practice Leader
T: 312-665-1022
E: dzuvich@kpmg.com

John L. McLoughlin
Principal and East Coast Leader
T: 267-256-2614
E: jlmcloughlin@kpmg.com

Andy Siciliano
Partner and National Practice Leader
T: 631-425-6057
E: asiciliano@kpmg.com

Steve Brotherton
Principal and Global Export and Sanctions Leader
T: 415-963-7861
E: sbrotherton@kpmg.com

Luis (Lou) Abad
Principal, Washington National Tax
T: 212-954-3094
E: labad@kpmg.com

Irina Vaysfeld
Principal
T: 212-872-2973
E: ivaysfeld@kpmg.com

Amie Ahanchian
Principal
T: 202-533-3247
E: aahanchian@kpmg.com

Christopher Young
Principal
T: 312-665-3229
E: christopheryoung@kpmg.com

Gisele Belotto
Managing Director
T: 305-913-2779
E: gbelotto@kpmg.com

George Zaharatos
Principal
T: 404-222-3292
E: gzaharatos@kpmg.com

Andy Doornaert
Managing Director
T: 313-230-3080
E: adoornaert@kpmg.com

Jessica Libby
Managing Director
T: 612-305-5533
E: jlibby@kpmg.com

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