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Posted by Clif Burns at 8:43 pm on September 8, 2010
Category: Export Reform
One of the stated goals of export control reform is to unify the export licensing systems used by the Treasury, Commerce and State Departments. Each system — except, of course, for Treasury’s dead-tree system — has it advocates with some rooting for D-Trade, the system used by State, and others rooting for SNAP-R, the Commerce System, to prevail in this war of the Titans. In fact, the winning licensing system will not be any of these but is instead an electronic licensing system that likely is completely unfamiliar to 99.9 percent of exporters.
In the recently posted minutes of the July plenary session of the Defense Trade Advisory Group, Brian Nilsson, a member of the White House’s export control reform task force from the National Security Council, revealed the winner to the audience at DTAG. It is … (drum roll, please) … USXPORTS. Say what? USXwhat?
USXPORTS is a system developed by the DoD in 2003 to assist DOD’s internal processing of its review of export license requests at State and Commerce. Part of the goal of USXport was to enable DoD to receive electronic export application forms from State and Commerce, rather than requiring them to roll up paper copies and shoot them through pneumatic tubes to the Pentagon.
Forgive me for being cynical, but this doesn’t strike me as good news. If I were to select a government agency to develop a user-friendly electronic licensing interface, the Pentagon would be at the very bottom of my list. “User-friendly” and “Pentagon” go together about as well as “military” and “music” or “military” and “justice.” Expect something ugly, confusing, clunky and bureaucratic that requires a user to memorize military acronyms, numeric codes, and service jargon. Get used to the 24-hour clock and the military alphabet now before it is too late.
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9 Comments:
“Military music” as a pejorative almost always evokes a chuckle (except from the musicisians, of course). Like “military intelligence”, it’s just as cliched a knee-slapper. But “military justice” as illustrative of “something ugly, confusing, clunky and bureaucratic”? Perhaps your insult to the hundreds of hard-working service judge advocates and the commanders they serve under was unintentional. It was certainly undeserved.
The comment was intended to be directed at the Uniform Code of Military Justice, not at any of the individuals involved in administering its provisions.
Actually, I have a soft spot for Sousa et al. Maybe it’s because I’ve been to countless Evening Parades at 8th and I. When I see the Marine Band do its slow march to the “York’scher” I get one of those patented Chris Matthews leg tingles. On point, it’s interesting that the apparent winner was the one system with which industry has no practical experience…. All those D-Trade and SNAP-R classes I took (well, had my licensing folks take)…all for naught…?
Re Treasury and dead trees: OFAC has begun the initial rollout of its transfer to online licensing. I could be wrong, but I believe the links for TSRA-related licensing and non-family related Cuba travel licenses are new?
http://www.ustreas.gov/offices/enforcement/ofac/abarrs/index.shtml
@EF. Those links are quite new. I guess OFAC wasn’t joking when it said at the BIS Update that they were about to roll these out. Interestingly, you don’t need to sign up to use the system, as you do with BIS and DDTC.
A little bit of history concerning USXports. The Congress appropriated $33 million to DoD in the late 1990s to develop an electronic system that would be used by all agencies involved in the export licensing and replace the proprietary systems in existence at that time. The early interagency involved robust discussion about what the new system should contain. Every aspect of the individual licensing processes at the time were reviewed and suggestions solicited to make the licensing process more efficient. Interagency involvement subsequently broke down when it was understood that Commerce, State, and Energy in particular would have to use USXports instead of their individual electronic systems. As OC Chairman at that time, I was a participant in those interagency meetings on designing the new system, and there was no hint of a “miltarization” of the electronic system. Outside computer experts were hired as consultants and were also involved in these discussions which included concepts of risk assessment programs to assist in license review, along with other innovative programs that would allow virtual interagency meetings on a daily basis. All agencies were encouraged to participate in the design of the system, but ultimately significant interagency resistance to migrating to the new system developed with the result that only DoD/DTSA now uses USXports. It can only be hoped that this time around there will be one single modern electronc system so that all reviewing agencies have access to all information contained in the applications along with access to all archival material.
My impression has been that applicants will use the D-Trade system, and that the government users will use USXports. I could be wrong about that, but its probably worth checking into.
To be fair, it’s not as though the current system is light on acronyms. Once I saw MCSC IPO recommend that DTSA tell DDTC to RWA a TAA for USML VII stuff. OMG, what a mess.
I have had occasion to work with the DOD reviewing officers and I have to say their system seemed less clunky than the DOS and DOC. Their knowledge and review time was certainly quicker.
