DDTC Updates Guidance on Electronic DSP-61 and 73 Supporting Docs
The Directorate of Defense Trade Controls has updated its guidance on supporting documentation for DSP-73 (temporary export) and DSP-61 (temporary import) license applications, in order to remove paper transmittal letter instructions, as all license applications must now be submitted electronically via D-Trade2.
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(DDTC’s previously updated this guidance in April 2008. (See ITT’s Online Archives or 05/02/08 news 08050235, for BP summary.)
Block 23 Instructions Updated for Electronic DSP-73 Applications
DDTC has removed instructions on submitting transmittal letters with DSP-73 applications, and has added the following instructions for electronic applications:
“A DSP-73 license application must clearly identify the need for the temporary export and describe the role of each party to the transaction. This information can be provided in Block 23 or in a separate letter of explanation. Technical data and/or product brochures must be provided on the requested defense articles.”
Removal of Paper Instructions for DSP-61 Return to Country of Origin Apps
DDTC has removed instructions on submitting transmittal letters with DSP-61 applications for return to the country of origin, which now only states that for overhaul/repair and modification/upgrade transactions, the application must be supported by a request from the foreign owner of the defense articles for the requested transaction, and as necessary, explaining fully the modification/upgrade to be performed.
Block 21 Instructions for DSP-61 Third Country/Transship Requests
DDTC has also amended its instructions for DSP-61 Transit to a Third Country/Transshipment Requests as follows (new language underlined):
“For transshipment licenses involving non-U.S. origin defense articles, the documentation must represent the transaction between the two foreign entities to the transaction (e.g. purchase documentation should not be directed to the U.S. applicant) and must include the same information that a DSP-5 requires. The license applicant and the U.S. entity identified in Block 21 should only be acting as a freight forwarder. If not, the role of the U.S. parties must be explained in a transmittal letter. The applicant must be identified in Block 21 and their role described. Identification in Block 8 does not explain the applicant’s role in the transaction.”
Electronic Instructions for Replacement/Renewal DSP-73/DSP-61 Apps
DDTC has removed transmittal letter guidance and added instructions for DSP-73/DSP-61 replacement/renewal license applications as follows (new language underlined):
“The license application must specifically identify the need for the continued activity and the current disposition of the subject defense articles. This information can be provided in Block 23 or in a separate letter of explanation. The application submission must be accompanied by a complete copy of the precedent license. The renewal license application must be received 60 days prior to expiration to ensure sufficient time for review by DDTC.”
(See ITT’s Online Archives or 05/18/09 news, 09051825, for BP summary of DDTC’s announcement that the D-Trade2 application must be used to submit all new license submissions.
See ITT’s Online Archives or 09/29/09 news, 09092925, for BP summary of DDTC’s announcement that applicants must use D-Trade2 amendment forms to amend a DSP-5, 61, or 73.)