Extract to table

Under the ITAR, any person who intends to permanently export a defense article listed on the USML must obtain a license from DDTC, unless an exemption applies

The introduction of foreign ownership creates additional vectors for potential diversion, unauthorized retransfer, or deemed export of controlled technology — risks that DDTC must assess and, if appropriate, mitigate through additional license conditions

Interaction with DDTC Registration Requirements As addressed in detail in the companion DDTC Registration Transfer Analysis memorandum, VPI must file a change-of-ownership notification with DDTC under ITAR § 122

Accordingly, License 1 must be amended — or, given the pending renewal, the renewal application must be updated — to reflect HSAG's ownership of VPI through Halcyon US Holdings Inc

-owned, and the license must be amended to reflect the new ownership structure

4(a) notification must be filed at least 60 days before the anticipated closing date