A material change is a change in information contained in the DS-2032 Statement of Registration (“DS-2032”). Examples of material changes include, but are not limited to, ineligibility changes, changes to name, address, or senior officers (e.g., Members of the Board of Directors, Senior Officers, Partners, and Owners); the establishment, acquisition or divestment of a U.S. or foreign parent, subsidiary, or affiliate; a merger; or, the addition or deletion of USML categories. Material changes where the 5-day reporting period coincides with an annual registration renewal may be submitted within a registration renewal and must be explicitly noted in the cover letter and highlighted for additions and strike through for deletions in the DS-2032.
Notification of Mergers, Acquisitions, or Divestures must be submitted to the Directorate of Defense Trade Controls (DDTC) separately from an annual registration renewal.
Pursuant to ITAR Section 122.4(c)(3) regarding currently approved and pending authorizations which are affected by material change notifications, please access The Office of Defense Trade Controls Licensing guidelines at http://www.pmddtc.state.gov/licensing/guidelines_instructions.html. Once on the website, select General Correspondence for Amendment of Existing ITAR Authorizations Due to Foreign Entity Name Change or General Correspondence for Amendment of Existing ITAR Authorizations Due to U.S. Entity Name/Address and/or Registration Code Changes.
Material Changes - 5-day Notification (Per ITAR §122.4(a))
All material change notifications must be reported to DDTC by the registrant within five days of the effective date.
Sale or Transfer to Foreign (i.e., non-U.S.) Person - 60-day Pre-Notification (per ITAR §122.4(b))
A registrant must notify DDTC 60 days in advance of an intended sale or transfer to a foreign person of ownership or control of the registrant or any entity thereof. Note: Committee on Foreign Investment in the United States (CFIUS) filings do not satisfy the ITAR 60-day pre-notification requirement.
Material changes must be sent by registered mail or overnight mail delivery. We highly recommend use of overnight mail for faster delivery. Faxes and e-mails will not satisfy the change notification requirement.