Country exceptions to the policy of denial

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1. Denial with stated openings

Fifteen countries on the International Traffic in Arms Regulations (ITAR) list carry a qualified policy of denial, with each country’s terms set out in its own paragraph (22 CFR 126.1(d)(2)). Most paragraphs follow the same pattern. They state a policy of denial, then list cases where a license or approval may still be issued case by case. How countries reach the list, and the comprehensive list itself, is covered in the ITAR policy of denial.

2. Iraq and Afghanistan

For Iraq, the policy is to deny licenses and approvals for exports and imports of defense articles and services going to or coming from the country (22 CFR 126.1(f)). Two openings exist, and both are decided case by case. Licenses may be issued for non-lethal military equipment, or for lethal military equipment that the Government of Iraq or coalition forces need.

Afghanistan follows a similar pattern, with case-by-case licensing for the Government of Afghanistan or coalition forces (22 CFR 126.1(g)). The paragraph adds that individuals, groups and entities under arms embargoes because of links to the Taliban, Al-Qaida or their associates are named in lists kept by United Nations Security Council sanctions committees.

3. Protective gear for those working on the ground

Several paragraphs make room for protective equipment carried by people working in a conflict zone. For the Democratic Republic of the Congo, protective clothing such as flak jackets and helmets may be licensed. The items must be temporarily exported for personal use by United Nations staff, the media, or humanitarian and development workers (22 CFR 126.1(i)(3)). Libya, Somalia and South Sudan have matching provisions (22 CFR 126.1(k)(7), 22 CFR 126.1(m)(3) and 22 CFR 126.1(w)(3)). The Somalia paragraph is wider, and also names private security contractors among those who may take protective clothing in for personal use.

Libya goes further for weapons (22 CFR 126.1(k)(4)). Small arms, light weapons and related materiel may be licensed when temporarily exported for the sole use of United Nations staff, the media and humanitarian and development workers. The Security Council committee on Libya must be notified in advance, and the opening applies only if the committee makes no negative decision within five working days. Zimbabwe allows case-by-case licenses only for the temporary export of firearms and ammunition for personal use by individuals, not for resale or retransfer, including to the Government of Zimbabwe (22 CFR 126.1(s)).

4. Governments, missions and peacekeepers

Many paragraphs open a route for the national government and international missions. For the Democratic Republic of the Congo, licenses may cover the government and the United Nations stabilization mission or the African Union task force (22 CFR 126.1(i)). For Somalia, they may cover named national forces, United Nations and African Union missions, and forces of states with status of forces agreements that inform the Security Council committee (22 CFR 126.1(m)). The September 2026 changes clarified that last opening (91 FR 59059). The rule explains that supplies for European Union training and support, Turkey, the United Kingdom and the United States may be licensed case by case. It adds that the same applies to other United Nations member states with a status of forces agreement with Somalia that pre-notify the Security Council committee (91 FR 59060). The regulatory text covers forces with a status of forces agreement or memorandum of understanding with the Somali government, if they inform the committee about those agreements for information purposes only (22 CFR 126.1(m)(2)(iii)). Vessels carrying weapons for their own defense may also make temporary port visits, provided the items stay aboard (22 CFR 126.1(m)(5)).

Lebanon’s paragraph allows licenses for the United Nations force in Lebanon or as the Government of Lebanon authorizes (22 CFR 126.1(t)). Haiti’s covers the United Nations, authorized missions and security units under its government’s command, where items further peace and stability (22 CFR 126.1(j)). Sudan’s covers supplies for monitoring, verification and peace support operations (22 CFR 126.1(v)). South Sudan’s covers support to United Nations missions and to states protecting or evacuating their nationals, among other routes (22 CFR 126.1(w)).

5. Humanitarian and non-lethal items

Non-lethal equipment for humanitarian or protective use is a recurring opening. It appears for the Democratic Republic of the Congo, Libya, Somalia and South Sudan, among others (22 CFR 126.1(i)(4), 22 CFR 126.1(k)(5), 22 CFR 126.1(m)(4) and 22 CFR 126.1(w)(2)). Nicaragua’s paragraph allows only non-lethal equipment for humanitarian assistance, including natural disaster relief (22 CFR 126.1(p)). Sudan’s allows non-lethal equipment for humanitarian, human rights monitoring or protective uses (22 CFR 126.1(v)(2)).

6. Narrower and different policies

Some entries are limited in a different way. Eritrea’s policy of denial covers exports to its armed forces, police, intelligence and internal security services (22 CFR 126.1(h)). The Central African Republic’s covers armed groups and associated individuals operating in the country (22 CFR 126.1(u)). Russia’s covers exports destined for Russia, with case-by-case licensing for government space cooperation (22 CFR 126.1(l)).

Libya’s paragraph lists nine openings (22 CFR 126.1(k)). Besides the items above, it allows non-lethal equipment and defense services for security or disarmament assistance to the Libyan government. It also covers American government services to help reunify Libya’s military and security institutions, as notified in advance to the Security Council committee. Military aircraft and naval vessels temporarily brought in by the American government to deliver permitted items or assistance are covered, with defensive articles kept aboard or on non-Libyan personnel.

7. The burden stays on the applicant

These openings do not remove the need for authorization. Every sale, export, transfer and proposal involving a listed country still needs a license or written approval from the Directorate of Defense Trade Controls (22 CFR 126.1(e)(1)). Articles also may not be carried by ships or aircraft tied to a listed country or person (22 CFR 126.1(b)). For activities of the kind these paragraphs describe, licenses "may be issued, on a case-by-case basis" (22 CFR 126.1(i)). They are not automatic.

Key terms

Qualified policy of denial	A denial policy with stated cases where licenses may still be issued.
Case-by-case basis	Individual review of each license request within a stated opening.
Coalition forces	Forces for which Iraq and Afghanistan licenses may be issued.
Protective clothing	Flak jackets and helmets temporarily exported for personal use.
Security Council committee	The United Nations sanctions body that must be notified or approve in some cases.

Every statement above links to the document behind it. The full source list for this piece is on the sources page.

This page describes public United States government programs for general information. It is not legal, regulatory or procurement advice, and it does not address the facts of any particular case.

How Sentfore supports this

Protective equipment and support for missions often move into the places these rules describe. Sentfore works at the delivery end of defense programs in difficult environments, providing secure movement, protective security, facilities and life support. Requirements can be sent through the contact page.