DDTC Losing Patience with Low Quality Applications

DDTC is losing patience with the increasing volume of “low quality” applications that they have been receiving. In the past, they may have corrected minor mistakes, but they assure companies that they will not be doing that from this point. Examples of mistakes that they have been seeing with increasing frequency include:

• “The country name on a license application does not match the country on the supporting documentation.
• No purchase order attached to a license application.
• The value on the license application is not the same as the value on the purchase order.
• Technical Assistance Agreement requests to change the terms of other companies’ TAAs.
• Submission of agreements and agreement amendments without submission of an original empowered official certification letter.
• Proposing to provide defense services to a foreign government without a TAA.
• Submission of agreements and agreement amendments without the required Part 130 statement.
• Continually making late applications and evoking (without adequate justification) national security reasons for immediate case adjudication.
• Submitting multiple TAAs and licenses when one TAA would do.
• Poorly documented commodity jurisdiction requests.
• Incomplete and deficient registration requests.”

(taken from Federal Register Vol. 71, Number 234)

In a message from the DDTC Managing Director, he warns that making mistakes like these demonstrates an “inadequate” understanding of export control regulations and a potentially at-risk export compliance program. Mistakes are being made across the spectrum —by large companies and small ones.

(I didn’t realize that DDTC’s delays in processing applications is all the fault of the applicants. Live and learn. —John Black)