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DDTC Issues ITAR Guidance on 'See-Through Rule'

The State Department’s Directorate of Defense Trade Controls issued guidance Oct. 5 on the “see-through rule” -- a “colloquial phrase” that refers to the impact of controls under International Traffic in Arms Regulations. DDTC clarified the rule by stressing that…

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ITAR controls and requirements do not “disappear simply because the defense article is integrated into another item.” If an ITAR-controlled component is integrated into a “larger system or end-item,” the component does “not lose its identity.” DDTC said “the ITAR ‘sees through’ the larger system or end-item and continues to regulate that defense article.”