DDTC Calls for Comment on Advisory Opinion Process


The Directorate of Defense Trade Controls (DDTC), an arm of the Political-Military Affairs Bureau of the Department of State, has invited public comments from registered members engaged in manufacturing, brokering, exporting, or the temporary importation of defense hardware or defense technology data.

Individuals or firms may seek advisory opinions or guidance from the DDTC under Sections 120.22 and 129.9 of the International Traffic in Arms Regulations (ITAR) (22 CFR parts 120–130). This could include queries regarding the probability of the DDTC granting a license or approval for exporting specific defense articles or services to certain countries, or interpretations of regulatory requirements.

The DDTC also provides guidance on whether an activity constitutes brokering under part 129—Registration and Licensing of Brokers. Notably, the advisory opinions are not legally binding on the Department of State and may not be referenced in future departmental considerations, except for decisions relating to ITAR § 129.9(a).

These advisory opinion requests are submitted electronically via the Defense Export Control and Compliance System (DECCS) portal, where users can also retrieve responses. 

Comments Close 07/24/2023.  FR Notice [88 FR 33185]


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