You Say Brokering, I Say Facilitation

Law360, New York (February 8, 2012, 1:37 PM EST) -- Words matter. More than that: “All words are pegs to hang ideas on.” So said the colorful 19th-century preacher and abolitionist Henry Ward Beecher. Given this immutable notion, the recent proposed revisions of the International Traffic in Arms Regulations by the U.S. Department of State’s Directorate of Defense Trade Controls are curious. Specifically, by removing and adding just a few key words to the brokering regulations, the DDTC may be dramatically expanding brokering requirements.

As we know, the purpose of ITAR Part 129 — Brokering is...
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