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Helping Us Help You: DDTC Modernizes ITAR Exemption for Contractor’s Supporting Government Agencies

Client Alert | 1 min read | 04.22.19

On April 19, 2019, nearly four years after the initial proposal, DDTC issued a final rule modifying § 126.4 of the International Traffic in Arms (ITAR) to clarify and expand the exemption authorizing exports in support of the US Government, including US foreign assistance and cooperative programs. Most significantly, the revised exemption acknowledges the government’s expanded use of contractor personnel in supporting USG missions often involving foreign parties. The exemption now expressly covers defense services and other exports by “persons or entities in a contractual relationship with the U.S. Government” where use of the defense article or performance of the defense service is within the scope of such contract and where any one of three specified conditions exist and assure government control and oversight of the transfer.

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Client Alert | 5 min read | 08.21.26

FTC Proposes Enforcement Policy Statement on Personalized Pricing: What Businesses Need to Know

On August 19, 2026, the Federal Trade Commission (FTC) announced a proposed Enforcement Policy Statement on personalized pricing — the practice of companies using consumers’ personal data to set individualized prices, discounts, coupons, or other incentives. The proposed statement, which is open for public comment for 30 days following publication in the Federal Register, marks a major step up in the FTC’s focus on data-driven pricing strategies and puts businesses across industries on notice that undisclosed or inadequately disclosed personalized pricing will not be tolerated. Importantly, while the proposed statement is not a binding legal requirement and does not create new legal obligations, it serves as an enforcement warning that the FTC is prepared to use its existing enforcement authority under Section 5 of the FTC Act (Section 5) and is also a potential harbinger of rulemaking. Businesses that engage in — or are considering — personalized pricing should carefully assess their disclosure practices and data collection procedures against the standards articulated in this statement....

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