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ARTICLE · 29 JUNE 2005

International Client Alert - June 2005

Powell Goldstein LLP
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A number of companies that regularly apply for licenses to export defense articles controlled by the International Traffic in Arms Regulations, promulgated under the U.S. Arms Export Control Act, have begun to report that license applications are being returned by the Department of State’s Directorate of Defense Trade Controls

United StatesInternational Law
Clif Burns
Clif Burns

DDTC Begins Returning License Applications Based On New Interpretation Of Part 129 

A number of companies that regularly apply for licenses to export defense articles controlled by the International Traffic in Arms Regulations ("ITAR"), promulgated under the U.S. Arms Export Control Act, have begun to report that license applications are being returned by the Department of State’s Directorate of Defense Trade Controls ("DDTC"). These applications are being returned because the DDTC suspects that an agent listed as a foreign consignee may be a broker who has not registered as required under Part 129. The DDTC has recently informally adopted an interpretation of Part 129 of the ITAR which, in most exporters’ views, widely expands the definition of brokers who are required to register with the DDTC. This new and more expansive definition has led to the increased returns of license applications.

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