Dec

21

Look Under Your Tree for a Gift From DDTC. Ho Ho Ho!


Posted by at 8:53 pm on December 21, 2015
Category: CBPDDTC

State Department by Josh [CC-BY-SA-2.0 (https://creativecommons.org/licenses/by-nd/2.0/)], via Flickr https://www.flickr.com/photos/ncindc/2838284991 [cropped]If you’ve had outbound goods seized because a certain big name shipping company filed your AES on a shipment before you lodged the license with Customs, raise your hand. I thought so. A bunch of you have had that happen.

And I see a number of you mumbling and grousing that this high-profile shipping company, after learning of the seizure, ran out of the room like a scalded dog, leaving you with the pleasure of paying off Customs an absurd amount to get your goods released (after, on average, 37.245 years). When your lawyers wrote the company, it sent back a note saying that under your contract with them, you had absolved them from all liability, even if they opened up your package, substituted weapons of mass destruction, exported them and you were later, as a result, criminally indicted and sentenced to  13 years in jail.

Well, Merry Christmas. Just days before Santa dispenses his gifts to all children (except U.S. children because of his continued insistence on providing gifts to Cuban children), the State Department has given you the biggest gift of all. Effective immediately, you no longer have to lodge DDTC export licenses. This is possibly the best news since Disney announced that J.J. Abrams would direct the latest installment in the Star Wars franchise.

The notice of the elimination of this requirement appears on the front page of the DDTC site today (and, apparently nowhere else, so that if DDTC changes it mind, it can delete the notice and take the gift back). This Christmas present was not entirely unexpected because, as the web notice states, DDTC, having finally discovered how computers work, has been sending licensing data daily to Customs thus effectively ending the need for exporters to hand off a dead tree copy of the license to the Pony Express for delivery to your closest Customs port.

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Copyright © 2015 Clif Burns. All Rights Reserved.
(No republication, syndication or use permitted without my consent.)


2 Comments:


Wow! This is great news. However, there is a small cottage industry of couriers who go back and forth between forwarders and customs offices that probably don’t appreciate this xmas gift.

Comment by Tom on December 22nd, 2015 @ 12:02 pm

First, the proper section for “temporary suspension or modification of any or all of the” ITAR is 22 CFR 126.2, not 126.3.

Second, by posting the notice on its web-page only and not in the Federal Register, DDTC is in open violation of 5 USC 552(a)(1).

Comment by Mike Deal on December 22nd, 2015 @ 2:25 pm