Latest Updates from DDTC on Registration, Licensing and Management

The Directorate of Defense Trade Controls (“DDTC”) announced on July 29, 2020 the following changes to the measures announced on April 23, 2020 to lessen the burden that the COVID-19 pandemic is having on U.S. companies and the overseas supply chains. These changes were based on recommendations from industry and DDTC review of the public comments. The official notice may be found on the DDTC website. Here is a summary of those changes:

Compliance/Registration

• Extension of Registration Expiration Dates Discontinued:

• • Effective July 29, 2020, the 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 is discontinued based on the timelines stated in the May 01, 2020 Federal Register Notice, (Federal Register Notice 85 FR 25287).

• Return of Full Registration Fees

• • While DDTC granted a one-time temporary reduction in registration fees for manufacturers, exporters and brokers for the 2020 renewal period, the reduction will not be extended and will be reset to the stated amounts indicated in §122 and §129 of the ITAR.

Licensing

• Extension of License Timeframes will terminate

• • The six-month extension period granted on March 13, 2020, a temporary suspension, modification, and exception to the limitations on the duration of ITAR licenses to extend any license that expires between March 13, 2020 and May 31, 2020 for six (6) months from the original date of expiration will terminate based on the timeline stated in the May 01, 2020 Federal Register Notice, (see above link).

• Remote Work Allowances Continued

• • DDTC is approving the continuation of supporting remote work, as outlined on the March 13, 2020 directive, that a regular employee for purposes of ITAR § 120.39(a)(2), working at the company’s facilities, is allowed 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 December 31, 2020, unless otherwise extended in writing.
  • Effective July 29, 2020, DDTC is continuing the 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 December 31, 2020, unless otherwise extended in writing.

If you have questions related to ITAR licensing, registration, or compliance, please contact Export Solutions for a free consultation.