DDTC Posts New Ukraine-Related FAQs
The State Department’s Directorate of Defense Trade Controls recently posted two new frequently-asked-questions under its licensing and registration guidance pages.
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One FAQ addresses whether certain defense-related exports to Ukraine fall under State Department or Commerce Department jurisdiction. The agency said it most commonly receives questions about exports of night-vision equipment, firearms, ammunition, and body armor, all of which could fall under either agency’s jurisdiction, depending on the item’s specifications. The FAQ includes steps exporters should take to determine the jurisdiction.
Another FAQ addresses how exporters can expedite their registration application to export, reexport or transfer controlled items to Ukraine "as quickly as possible." DDTC said it’s working to expedite those applications, and said exporters should “clearly establish that their application is Ukraine-related by submitting a letter attached to the application indicating that the registration is related to Ukraine.” Exporters should also include the word “UKRAINE” in the title of the attachment.
DDTC said its average registration time is 40-45 days, but the agency can’t “guarantee any specific processing timeframe.” As part of the review, the agency considers whether the applicant has experience in defense trade and can “appropriately protect U.S. origin defense articles from unauthorized diversion or misuse,” DDTC said. “This review can vary in terms of processing time, depending on the circumstances of the case.”