Export Reform Implementation Steps Detailed

摘要

The Obama administration in December released draft regulations to implement portions of its ongoing export control reform overhaul, providing key details for the approach it announced earlier in the year. The newly proposed regulations flesh out the plan for aligning military as well as dual-use lists into three tiers, in part by defining key terms such as "critical," "substantial," and "significant." (See ACT, October 2010.) Those terms are used to indicate the types of advantages gained by controlling items in particular tiers.