DDTC Imposes Arms Embargo on Cambodia, BIS Applies Military End User/End Use Controls and Places Cambodia into Country Group D:5.
On Thursday, December 9th, 2021 DDTC and BIS published final notices in the Federal Register ramping up export controls on Cambodia in response to corruption, human rights abuses and the increasing Chinese presence in Cambodia’s defense industry. Effective December 9, 2021 DDTC has adopted a full arms embargo on Cambodia adding that country to the ITAR § 126.1 list of countries for which it is the policy of the United States to deny all licenses or other approvals to export and import defense articles and defense services. On the Commerce/EAR side of U.S. export control, in the December 9th final rule BIS added Cambodia to Country Group D:5 [Arms Embargoed Countries] and has added Cambodia to the list of countries subject to the Military End User/End Use Controls found in n § 744.21 of the EAR as well as the military intelligence end user/end use controls found in §744.22. This new ramping up of export controls, with very few exceptions eliminates ITAR transactions and greatly enhances upfront export compliance due diligence that is now required if and when exporting, re-exporting or transferring (in-country) commodities, software and/or technology to Cambodia that is subject to the EAR.
Contact TSI Global Consulting for further details on this new escalation of U.S. export controls on Cambodia and how it may impact your company’s business.