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Defense Trade Information Collections Under Review

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

The State Department’s Directorate of Defense Trade Controls is soliciting through Nov. 13 comments on the proposed extension of the following information collections associated with the licensing of the export, temporary import and brokering of defense articles, defense services and related technical data in accordance with the International Traffic in Arms Regulations and the Arms Export Control Act.

Form DS-2032, Statement of Registration. Those who manufacture, export or temporarily import the above items, or engage in the brokering thereof, must register with DDTC.

Annual Brokering Report. U.S. and foreign persons required to register as a broker must provide annually a report to DDTC enumerating and describing brokering activities by quantity, type, U.S. dollar value, purchaser/recipient, and license number for approved activities and any exemptions utilized for other covered activities.

Brokering Prior Approval (License). U.S. and foreign persons who wish to engage in ITAR-controlled brokering activity of defense articles and defense services must first register with DDTC. Brokers must then submit a written request for approval to DDTC and receive DDTC's consent prior to engaging in such activities, unless exempted.

Request to Change End User, End Use and/or Destination of Hardware. This information collection is used to request DDTC approval prior to any sale, transfer, transshipment or disposal, whether permanent or temporary, of classified or unclassified defense articles to any end user, end use or destination other than as stated on a license or other approval.

Request for an Advisory Opinion. A request is submitted when an exporter wants an opinion from DDTC on whether it would likely grant a license or other approval for an export transaction involving defense articles and defense services.

Voluntary Disclosures. The ITAR encourage the voluntary disclosure of information to DDTC by persons who believe they may have violated any provision of the AECA, ITAR, or any order, license or other authorization issued under the AECA.

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