Comments on: New Processing Time Exception Announced by DDTC http://www.exportlawblog.com/archives/1017 Latest News on DDTC, BIS, OFAC, and other export law matters Fri, 10 Feb 2012 10:06:23 +0000 hourly 1 http://wordpress.org/?v=3.0 By: Name Changed To... http://www.exportlawblog.com/archives/1017/comment-page-1#comment-92127 Name Changed To... Thu, 10 Dec 2009 00:02:36 +0000 http://www.exportlawblog.com/?p=1017#comment-92127 I'm aware of a license that was denied with the reason given (paraphrasing)that the DDTC doesn't license military items for use on commercial applications. They went on to advise the submitter to send in a CJ. At a conference, a DDTC official was asked about this semmingly reversal of previous policy. That official explained that some of the licensing officers were denying licenses based on that "policy". No apologies were given. As long as the individucal licensing officers can make it up as they go along I remain skeptical about any real reform. I’m aware of a license that was denied with the reason given (paraphrasing)that the DDTC doesn’t license military items for use on commercial applications. They went on to advise the submitter to send in a CJ.

At a conference, a DDTC official was asked about this semmingly reversal of previous policy. That official explained that some of the licensing officers were denying licenses based on that “policy”. No apologies were given.

As long as the individucal licensing officers can make it up as they go along I remain skeptical about any real reform.

]]> By: JOHN LIEBMAN http://www.exportlawblog.com/archives/1017/comment-page-1#comment-92117 JOHN LIEBMAN Tue, 08 Dec 2009 19:25:50 +0000 http://www.exportlawblog.com/?p=1017#comment-92117 My favorite anecdote about DTC time limits arose several years ago in a CJ context. When reminded by me of the 45-day time limit, the reviewer said, "If I have to give you an answer now, you may not like it, but if you give me 10 more days, you may be happier." I did, and was. These time limits are annoying since invariably they are exceptions that swallow the rules. My favorite anecdote about DTC time limits arose several years ago in a CJ context. When reminded by me of the 45-day time limit, the reviewer said, “If I have to give you an answer now, you may not like it, but if you give me 10 more days, you may be happier.”
I did, and was.

These time limits are annoying since invariably they are exceptions that swallow the rules.

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