DDTC Issues Dual/3rd Country National Transfer Policy Guidance, FAQ

The Directorate of Defense Trade Controls has issued two new guidances, "Guidelines for Implementing New Dual National/Third-Country National Policy for Agreements" and "Implementation Considerations: Dual/Third National Rule," regarding the August 15, 2011 implementation of the new 22 CFR 126.18 rule, which establishes screening requirements to exempt from approval requirements, under certain conditions, intra-company, intra-government, and intra-organization transfers of defense articles to dual country or third-country national employees. The agreement guidance is available here. The implementation guidance is available here. DDTC has also issued a Frequently Asked Questions document, available here.