DDTC Updates Guidance, FAQs for US Persons Providing Defense Services Abroad

The State Department’s Directorate of Defense Trade Controls this week updated its guidance and frequently asked questions for U.S. persons providing defense services abroad.

The updates clarify what qualifies as a defense service recipient, include more information on the scope for an approval to provide defense services, outline what type of information must be submitted by employees working for a foreign entity involved in space launches, give “additional guidance in identifying” the U.S. Munitions List defense service subcategories, and more. A summary of the updates is on the first page of the guidance.

DDTC also issued a new FAQ to clarify that defense services furnished to any foreign third parties, even when done for a foreign employer, are considered defense services and require U.S. authorization. This applies “regardless of whether that service is to be furnished within or outside the United States,” the FAQ said.

The agency last updated this guidance in 2023, in part to provide more “comprehensive” information for submissions of requests to authorize exports of defense services (see 2301060022).