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Validity of Export Licenses, Agreements Extended for Items Transitioning from USML to CCL

Tuesday, October 13, 2015
Sandler, Travis & Rosenberg Trade Report

The State Department’s Directorate of Defense Trade Controls is extending the validity of export licenses or authorizations and various agreements for items transitioning from the U.S. Munitions List to the Commerce Control List as part of the Export Control Reform Initiative.

Licenses and Authorizations. A transition plan published Oct. 3, 2013, stated that a DDTC license or authorization will be effective for up to two years from the effective date of the revised USML category if all the items on the license or authorization have transferred to the export jurisdiction of the Department of Commerce. DDTC now states that licenses or authorizations that would otherwise expire at the conclusion of this two-year period will remain valid for 48 months from the date of issuance or as otherwise indicated on the license or authorization.

Agreements. Under the transition plan, approvals for technical assistance agreements, manufacturing license agreements, and warehouse and distribution agreements that are submitted prior to the effective date of the relevant revised USML category and contain transitioning and non-transitioning items will remain valid until expired (unless they require an amendment) or for two years from the effective date of the relevant final rule, whichever occurs first, unless otherwise revoked, suspended or terminated. DDTC is extending by one year the period of validity for agreements that would otherwise expire at the conclusion of this two-year period.

The transition plan also provides that approvals for agreements that are submitted prior to the effective date of the relevant revised USML category and contain solely transitioning items will remain valid for two years from the effective date of the relevant USML category unless revoked, suspended or terminated. The period of validity for agreements that would otherwise expire at the conclusion of this two-year period is being extended for one year as well.

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