DDTC ANNOUNCES NEW POLICIES AND CHANGES AFFECTING ITAR REGISTRATIONS, LICENSING, PART 130 REPORTING, AND DDTC MANAGEMENT

COVID 19 has impacted our daily lives. DDTC is no exception. Between the DECCS rollout and COVID 19 telework, DDTC is impacted and has responded with the following policies and changes intended to aid industry and ease the burden on exporters that may be hampered during this period to make filings in accordance with the ITAR timelines or existing export authorizations.

Registrations

  • Effective March 13, 2020, a temporary suspension of the requirement in ITAR Parts 122 and 129 to renew registration as a manufacturer, exporter, and/or broker and pay a fee on an annual basis by extending 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.
  • DDTC is also pursuing a one-time temporary reduction in registration fees for certain categories of DDTC registrants. More information on any change will be provided on DDTC's website. 

Voluntary disclosures

  • Voluntary Disclosures can be filed electronically to This email address is being protected from spambots. You need JavaScript enabled to view it.
  • DDTC Compliance is now granting an additional 30 days for responses to its request-for-information letters related to voluntary and directed disclosure matters. DDTC Compliance is also considering extensions for the submission of full voluntary disclosures on a case-by-case basis. Extension requests should be sent via email to This email address is being protected from spambots. You need JavaScript enabled to view it. on company letterhead in PDF format.

Licensing

Validity period of export licenses

  • Effective March 13, 2020, a temporary suspension, modification, and exception to the limitations on the duration of ITAR licenses contained in ITAR Parts 120-130, including but not necessarily limited to ITAR §§ 123.5(a) (temporary exports), 123.21(a) (duration of licenses), and 129.6(e) (validity of brokering approval), to extend any license that expires between March 13, 2020, and May 31, 2020, for six (6) months from the original date of expiration so long as there is no change to the scope or value of the authorization and no Name/Address changes are required. This six (6) month extension is warranted in light of the unique challenges applicants face in the current environment when attempting to coordinate with U.S. and foreign business partners regarding the scope of applications.

Note: this extension is automatic and requires no action by the license holder

Remote work by company and long term contract employees defined by ITAR 120.39

  • To support remote work in this extraordinary period, effective March 13, 2020, a temporary suspension, modification, and exception to the requirement that a regular employee, for purposes of ITAR § 120.39(a)(2), work at the company's facilities, to allow the individual to work at a remote work location, so long as the individual is not located in Russia or a country listed in ITAR § 126.1. This suspension, modification, and exception shall terminate on July 31, 2020, unless otherwise extended in writing.

Remote work by regular employees (ITAR 120.39) of foreign signatories to TAAs/MLAs or ITAR exemptions

  • Effective March 13, 2020, authorization for regular employees of licensed entities who are working remotely in a country not currently authorized by a TAA, MLA, or exemption to send, receive, or access any technical data authorized for export, reexport, or retransfer to their employer via a TAA, MLA, or exemption so long as the regular employee is not located in Russia or a country listed in ITAR § 126.1. This suspension, modification, and exception shall terminate on July 31, 2020, unless otherwise extended in writing.

Paper filings with DDTC, adjudication of filing will be emailed to the applicant

  • DDTC is implementing new procedures and will send to the contact listed on the application email scans of final action letters for General Correspondence requests submitted in writing. If email information was not provided, final actions will continue to be mailed back to the applicant.
  • DDTC is implementing new procedures and will send to the applicant email scans of unclassified final action letters for DSP-85s submitted in writing. If email information was not provided, final actions will continue to be mailed back to the applicant. The Defense Counterintelligence and Security Agency (DCSA) will continue to receive original sealed copies through the mail.

Note: Approvals for DSP-5, DSP-61, DSP-73, and TAAs/MLAs/WDAs in DECCS, DDTC's electronic portal and can be retrieved via DECCS 

Expedited requests for licensing in support of U.S Operations

  • DDTC is re-issuing guidance for the expedited authorization of requests submitted in support of U.S. Operations (USOP) at DTCL SOP - USOPS Guidance. Refer to the DDTC website

DDTC to file Congressional Notifications electronically

  • In coordination with Congress and DOD, DDTC has moved to electronic submissions of Congressional Notifications of proposed Direct Commercial Sales (DCS) and Foreign Military Sales (FMS) to the Congress.

Other

  • DDTC is leveraging updated staffing protocols to ensure streamlined interagency licensing reviews.

Part 130 Reporting

  • DDTC is accepting electronic submissions of FMS Part 130 reports via email at This email address is being protected from spambots. You need JavaScript enabled to view it..

Updated information repoints of contact

  • To facilitate timely responses to inquiries from the public and regulated industry, DDTC has added additional points of contact on the Key Personnel tab of the About DDTC page on the DDTC website, and additional staffing and IT resources have been added to its Response Team and Help Desk functions.