United States Revokes ITAR Licenses and Accelerates Venezuelan Arms Embargo

August 21, 2006

Effective August 17, 2006, the United States revoked all licenses and approvals authorizing the export of or other transfers of defense articles or services to Venezuela and will no longer authorize the export of such articles or services to Venezuela. The revocation extends to the deletion of Venezuela from any manufacturing license or technical assistance agreement involving Venezuela, including any agreement that has Venezuela as a sales territory. Additionally, all exemptions from licensing as provided for in the International Traffic in Arms Regulations with regard to Venezuela were also revoked with the exception of the license exemptions used in connection with certain temporary exports of firearms and ammunition for personal use. 

This appears to be an acceleration of the arms embargo announced by the United States Department of State on May 15, 2006, due to Venezuela’s deemed failure to cooperate with U.S. counterterrorism efforts. According to that announcement, licenses were to be available until October 1, 2006, though proposed sales of defense articles to Venezuela until that date were to be scrutinized on a case-by-case basis. This change may be in response to a break down in bilateral cooperation in anti-narcotic and anti-terrorism actions and Venezuelan President Chavez’s heated rhetoric against broader U.S. counterterrorism and political interests.

Gibson Dunn & Crutcher’s International Trade Regulation and Compliance Practice Group is monitoring these developments and others and is prepared to address any questions regarding export control laws and sanctions for other countries.   For further information, please contact Judith A. Lee (202-887-3591) or Jim Slear (202-955-8578) in the firm’s Washington, D.C. office.

© 2006 Gibson, Dunn & Crutcher LLP

The enclosed materials have been prepared for general informational purposes only and are not intended as legal advice.