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Regular readers are familiar with this blog’s occasional posts on press releases where companies boast that they have registered with the Department of Defense Trade Controls. These press releases describe certain imaginary attributes of this registration, usually that it is a certification by DDTC that the company has met the exacting standards of DDTC to be eligible to export defense articles.
Sharp-eyed reader Lisa Caplinger brought to my attention a yet more lavish variation on the registration game. Now it appears that at least one company is boasting on its website that it is “registered” with the Bureau of Industry and Security (“BIS”):
The Bureau of Industry and Security is charged with the development, implementation and interpretation of U.S. export control policy for dual-use commodities, software, and technology. Dual-use items subject to BIS regulatory jurisdiction have predominantly commercial uses, but also have military applications. CBOL is registered with BIS, which is a precondition for the issuance of any license or other approval for export.
So, all of you out there who have applied for and received licenses from BIS without registering with the agency, you’d better get those voluntary self disclosures in tout de suite.
For new readers, we are kidding about the voluntary disclosure. No registration is required with BIS, and so no voluntary disclosure is in order. Perhaps the company is referring here to the process of getting a company identification number and PIN to enable electronic filing on the SNAP-R system. Does this mean we will start seeing press releases from companies that have received their ID numbers from BIS for electronic filings?
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Copyright © 2010 Clif Burns. All Rights Reserved.
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