Meeting Basic Standards for Registration Requests

A Message from David Trimble, Director of Compliance

Last Updated: January 2, 2008

The Office of Defense Trade Controls Compliance conducted a review of registration requests and renewals received over the past 6 months. The results were striking!

Nearly 50% of registration requests did not meet the minimum standard for acceptance, let alone subsequent analysis and final action by the Compliance & Registration Division.

Most of these registration requests missed one or more the following basic criteria:

• Form DS-2032 - not properly completed or blocks on the form were either left blank or the information provided was wrong.
• Transmittal letter pursuant to ITAR §122.2(b) – not provided, not on company letterhead, not signed by an authorized senior official or did not fully address information on foreign ownership in ITAR §122.2(b)(2).
• Copy of certificate of incorporation or authorization to do business - not provided or the document copy did not meet one of the acceptable criterions.
• Check payment – incorrect dollar amount, not drawn on a U.S. financial institution (not required for foreign brokers), not a corporate account.

To help companies avoid these common problems in preparing and submitting registration requests, the Office has updated and expanded upon our “Helpful Hints” guide.

The Office previously worked with registrants to obtain corrected documentation. Such efforts, however, were a drain on limited personnel resources, added steps to the review, and created opportunities for further error with supplementary faxes and phone calls. Final action on registration requests was often delayed by weeks or even months. The end result was added confusion and frustration on the part of industry and government.

The Office has adopted a policy of rejecting registration requests that do not meet basic criteria for acceptance. Those requests (and the check payment) will be returned via certified mail with the reason(s) for rejection. You may view a standard incomplete letter. We encourage you to use it as a guide in completing your registration requests.