State Modifies Proscribed Country Rules on Afghanistan and Zimbabwe

Two Office of Defense Trade Control (ODTC) Federal Register notices in July modify slightly the rules as they apply to 126.5 proscribed countries Afghanistan and Zimbabwe  (If you have trouble remember which countries, use the mnemonic device “proscribed countries A to Z.)”   The first amends the ITAR to lift a policy of license denial for defense exports destined for the Afghan Interim Authority (AIA) and the International Security Assistance Force (ISAF).  The former is Karzia’s Government and the latter is the US and our allies.  As the Notice does not address use of exemptions, one would have to presume that the general proscribed country rule barring use of most ITAR exemptions still applies, even if intended for the AIA and ISAF.  The Zimbabwe Notice, in contrast, now allows for the use of the 123.17 temporary exports of firearms exemption, but does not change the overall denial licensing policy for Zimbabwe.