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Thompson Hine LLP, a full-service business law firm with approximately 400 lawyers in 11 offices, was ranked number 1 in the category “Most innovative North American law firms: New working models” by The Financial Times and was 1 of 7 firms shortlisted for The American Lawyer’s inaugural Legal Services Innovation Award. The firm has been recognized by the National Law Journal as a Legal Technology Trailblazer and featured by Bloomberg for its innovative service delivery models, which drive accuracy and predictability. The firm’s commitment to innovation is embodied in Thompson Hine SmartPaTHTM – a smarter way to work – predictable, efficient and aligned with client goals. For more information, please visit ThompsonHine.com and ThompsonHine.com/SmartPaTH.

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Key Notes:
<ul>
<li>Proposed rule would allow persons working under a long-term contract to be considered &ldquo;regular employees&rdquo; under the International Traffic in Arms Regulations (ITAR) even if they work remotely.</li>
<li>Remote work would be permitted so long as people were not working in Belarus, Burma, China, Cuba, Iran, North Korea, Russia, Syria or Venezuela, or any other country subject to a U.S. arms embargo.</li>
<li>Persons considered &ldquo;regular employees&rdquo; are exempt from various licensing requirements under the ITAR.</li>
<li>Public comments must be submitted on or before July 26, 2021.</li>
</ul>
At the onset of the COVID-19 pandemic, the State Department&rsquo;s Directorate of Defense Trade Controls (DDTC) announced a temporary suspension of and exception to the ITAR&rsquo;s requirement that regular employees or long-term contractual personnel must work on-site at a company&rsquo;s facilities, allowing individuals to telework during the public health emergency. On May 27, DDTC proposed a rule that would amend the ITAR&rsquo;s definition of &ldquo;regular employee&rdquo; to make this change permanent and include (1) persons working under long-term contracts and sufficiently subject to the employer&rsquo;s control, and (2) contractors not working under long-term contracts but who have active security clearances and are sufficiently under the employer&rsquo;s control.
View this full client update in <a href="https://www.thompsonhine.com/publications/ddtc-proposes-to-make-pandemic-related-telework-rules-permanent">HTML</a> or <a href="https://www.thompsonhine.com/uploads/1139/doc/International_Trade_Update_-_DDTC_Proposes_to_Make_Pandemic-Related_Telework_Rules_Permanent.pdf">PDF</a> format.

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International Trade

DDTC Proposes to Make Pandemic-Related Telework Rules Permanent