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Kerry Contini

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On April 19, the US Government issued a fact sheet outlining a new policy (the “New UAS Policy”) on exports of US-origin unmanned aerial systems (“UAS”) and a new National Security Presidential Memorandum (“NSPM”) updating the United States Conventional Arms Transfer Policy (the “New CAT Policy”). These changes do not directly impact the export licensing requirements on UAS under the International Traffic in Arms Regulations (“ITAR”) or the Export Administration Regulations (“EAR”). However, according to statements made in a press briefing on these developments, the new policies reflect the Trump Administration’s interest in enabling US manufacturers of UAS to “level the playing field” and increase exports of these products to US allies and partners. They also evidence a broader effort to increase considerations of economic interests in arms transfer decisions. Direct Commercial Sales Perhaps the most significant change made by the New UAS Policy is to allow exports of certain…