Law360, New York (July 9, 2013, 5:50 PM EDT) -- The 2010 rule relating to "export-controlled items" set forth at Defense Federal Acquisition Regulation Supplement Subpart 204.73 and implemented in principal part by the clause set forth at 52.204-7008 was relatively straightforward, basically reminding U.S. Department of Defense contractors (1) that they were obligated to "comply with all applicable laws and regulations regarding export-controlled items" and (2) that those compliance obligations existed independent of the new DFARS rule and its implementing clause. In reality, while the clause had the capacity to transform an export violation into a breach of contract, with all of the attendant liabilities and risks that attend such breaches, it imposed no new substantive obligations on DOD contractors....