By Beverly Demma, Export Solutions

The Directorate of Defense Trade Controls (“DDTC”) announced on April 23, 2020 the following measures to lessen the burden that the COVID-19 pandemic is having on U.S. companies and the overseas supply chains in order to help the exporting/importing community. Below is a summary of those measures. The full notice can be found on the DDTC website.

Compliance/Registration

  • Extension of ITAR registrations expiring on February 29, March 31, April 30, May 31 and June 30, 2020 for two months from the original date of expiration.
  • Additional 30 days granted for responses to its request-for-information letters related to voluntary and directed disclosure matters.
  • Consideration for extension for the submission of full voluntary disclosures on a case-by-case basis.
  • One-time temporary reduction in registration fees for certain categories of DDTC registrants.

Licensing

  • Various flexibility to be reviewed regarding extensions, temporary suspension, modification, and exception to the limitations on the duration of ITAR licenses.
  • Flexibility given for remote working needs.
  • New procedures for General Correspondence requests.
  • New procedures for final action letters for DSP-85s.
    Re-issuance of guidance for the expedited authorization of requests submitted in support of U.S. Operations (USOP).

Management

  • Acceptance of disclosures and related information pursuant to ITAR § 127.12 via email. DDTC is now also accepting electronic submissions of FMS Part 130 reports via email at DDTC-Part130Notices@state.gov.
  • Additional points of contacts are provided for Key Personnel on the About DDTC web page listing additional staffing and IT resources for its Response Team and Help Desk functions.

Export Solutions is happy to help you understand how these measures may be beneficial for your company. Contact us for a free consultation.

Beverly Demma is a Sr. Consultant for Export Solutions -- a full-service consulting firm specializing in U.S. import and export regulations.