Foreign Military Sales restrictions
Defense and government contractors operating in the Foreign Military Sales channel face layered export control obligations enforced primarily by the U.S. Department of State's Directorate of Defense Trade Controls and the U.S. Department of Defense, with the U.S. Department of Commerce's Bureau of Industry and Security holding concurrent jurisdiction on dual-use items routed through FMS programs. DDTC's rewrite of ITAR Part 126 and ongoing FMS policy holds tied to end-user conduct reviews have pushed compliance teams to audit Letter of Offer and Acceptance terms against current country-eligibility status before contracts advance to congressional notification. The gap between State Department case approvals and DoD program office timelines is where most FMS-related compliance failures surface.
Watch
- ITAR Part 126 rewrite: proposed changes to country exemptions and retransfer conditions
- Active FMS policy holds on specific allied-nation programs pending end-user review
- Congressional notification thresholds under the Arms Export Control Act Section 36(b)
- DDTC enforcement actions citing deficient empowered official oversight in FMS transactions
- BIS Entity List additions affecting subcontractors in FMS supply chains
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