ITAR / USML Updates FAQs:
Q:
Other than prohibited countries under § 126.1, what's the general breadth of ITAR exports under ITAR § 126.4? Are there portions of the USML where ITAR § 126.4 would be unavailable?
A:
ITAR § 126.4 may be used for the transfer of any defense article or the furnishing of any defense service described on the United States Munitions List (“USML”). The plain text of the provision does not limit the scope of the exemption to certain portions of the USML. However, this section does not authorize any transfer that is otherwise prohibited by any other administrative provisions or by any statute or that is inconsistent with U.S. arms embargoes or United Nations Security Council Resolutions (see ITAR § 126.1).