The U.S. Department of State's Directorate of Defense Trade Controls (DDTC) posted updated Guidelines for Implementing New Dual National/Third-Country National Policy for Agreements. On its website, DDTC states:
The following guidance relates to the August 15, 2011 implementation of the new §126.18 rule on dual and third country nationals. The first document relates to the changes to agreements and will be incorporated into the new Guidelines as well. D-TCN AG Guidance Final.
The following notional implementation plan is a suggested approach, but is by no means the only way of complying with the rule and its core principle of preventing diversion of defense articles to unauthorized end-users and end-uses. Consistent with local national laws and programs for the control/protection of defense articles/technologies and consistent with the need for private entities to protect proprietary data, technology security plans should be designed with a comprehensive and individualized approach to securing sensitive data of all kinds with appropriate measures for physical security and personnel clearances. D-TCN Policy Implementation Final.
Additional guidance and clarification is provided in the attached Frequently Asked Questions relating to both of the above documents. D-TCN FAQs Final.