We are reviewing the new regulation that, in part, will require approved end-users, prior to making transfers to certain dual national and third-country national employees, to screen employees, make an affirmative decision to allow access, and maintain records of screening procedures to prevent diversion of ITAR-controlled technology for purposes other than those authorized by the applicable export license or other authorization.

The Final Rule is effective starting August 15, 2011.

A more detailed analysis to follow.