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Export Services on Hold During Shutdown but Enforcement Continues

Monday, January 14, 2019
Sandler, Travis & Rosenberg Trade Report

The ongoing federal government shutdown has halted a number of activities related to controlled exports, although enforcement actions are said to be continuing. Following is an update on the current status of these services.

Bureau of Industry and Security

- The SNAP-R system that allows users to electronically submit export and reexport license applications and commodity classification requests is inaccessible.

- Other services are significantly curtailed, including processing voluntary self-disclosures, except those in direct support of the U.S. military or humanitarian aid.

Directorate of Defense Trade Controls

- Services are significantly curtailed, including processing requests for licenses, advisory opinions, commodity jurisdiction requests, voluntary self-disclosures, and retransfers, except for those that provide direct support to the military, humanitarian aid, or other similar emergencies.

- All D-Trade electronic submissions will be rejected by the system and returned to the applicant.

Office of Foreign Assets Control

- Online licensing services are inaccessible.

- There are significant delays for pending license applications and voluntary disclosures.

For more information please contact Jared Hollett at (415) 490-1404.

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