Stagg P.C. Publishes Client Alert: DDTC Issues Overly Expansive Interpretation of the ITAR for Defense Services (and Presumably Technical Data)

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Law firm publishes important client alert concerning an interpretation by the State Department of the International Traffic in Arms Regulations.

The law firm of Stagg P.C. has published a client alert regarding an expansive interpretation of the International Traffic in Arms Regulations (ITAR) concerning defense services by the Directorate of Defense Trade Controls (DDTC).

The client alert notes that “DDTC has maintained a consistent public position for over thirty years that it narrowly construes the ITAR’s controls for defense services.” The client note further provides that “it has been revealed that DDTC has a new and overly expansive interpretation of defense services that disregards its long-held narrow construction.”

“This is a very important issue, especially in light of DDTC’s long-standing and public position as to the ITAR’s controls over defense services and technical data,” said Christopher Stagg who authored the client alert.

Mr. Stagg was with DDTC from August 2010 to September 2013 where he was a senior member of the policy and commodity jurisdiction sections. He was also a key member of revising the ITAR and U.S. Munitions List under Export Control Reform, including to the new definition of defense services.

“It may impact a number of companies that provide services to civilian aircraft or to certain military aircraft that have recently moved to the Department of Commerce’s authority under Export Control Reform,” Stagg added.

A copy of the client alert can be obtained from the firm’s website at

About Stagg P.C.

Stagg P.C. is a law firm with significant experience in the areas of U.S. export control laws under the International Traffic in Arms Regulations and the Export Administration Regulations. The firm was founded by a former key regulator and senior advisor at the Directorate of Defense Trade Controls within the U.S. Department of State who was deeply involved in Export Control Reform, the commodity jurisdiction process, and national security investigations. The firm has offices in Washington, D.C. and New York.

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Christopher Stagg
Stagg P.C.
+1 (202) 765-2278
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