New D-Trade Software Security Feature to Require Use of DDTC-Approved Name Before Application/Amendment Will be Accepted by D-Trade, Etc.
The State Department's Directorate of Defense Trade Controls (DDTC) has posted a message to its Web site announcing that effective February 12, 2007 or shortly thereafter, all D-Trade users must use their DDTC-approved registrant/applicant name which corresponds to their DDTC registration record before an application or amendment will be accepted by the D-Trade system.
Sign up for a free preview to unlock the rest of this article
If your job depends on informed compliance, you need International Trade Today. Delivered every business day and available any time online, only International Trade Today helps you stay current on the increasingly complex international trade regulatory environment.
DDTC states that it will implement a new D-Trade software security feature that will check the D-Trade request against DDTC's registration records to confirm that the name submitted on the request matches DDTC's official records. If a match is not made, the D-Trade system will automatically reject the application or amendment and preclude its submission to DDTC.
DDTC states that the DDTC-approved name must be provided for all D-Trade submissions in the first line underneath "applicant type" in the block titled "Applicant's Name, Address, ZIP Code, Telephone Number" (block 5 for a DSP-5 or DSP-73, and block 8 for a DSP-61).
According to DDTC, applicants/registrants unaccustomed to using a standard name/spelling or who routinely use subsidiary names or "doing business as" on the first line of a D-Trade submission must instead use the DDTC-approved name identification.
Currently, DDTC-approved name is found in addressee line of DDTC registration letter. For current DDTC registrants, DDTC states that the DDTC-approved correct name is contained in the addressee line of the registration letter sent by the Office of Defense Trade Controls Compliance (Compliance & Registration Division) at the time of registration or renewal.
In future, DDTC-approved name will be in body of DDTC registration letter. In future registration letters, the DDTC-approved registrant name will be separately identified and called out in the body of the letter.
DDTC to conduct mass mailing to assist current registrants/applicants. To assist current registrants/applicants in meeting this new D-Trade requirement, the Compliance & Registration Division will conduct a mass mailing in January 2007 to all registrants, providing them with the DDTC-approved name.
DDTC will not provide DDTC-approved name over phone or in e-mail. DDTC states that D-Trade users who are unsure of their DDTC-approved name must contact their central export control office to obtain that information. According to DDTC, export control offices should make every effort to share their DDTC-approved name among appropriate employees (e.g., designated empowered officials and D-Trade users with authority to submit requests) in advance of February 12, 2007.
DDTC states that it will not provide this information over the phone or in e-mails to D-Trade users.
DDTC to Issue Additional Guidance on Other D-Trade Matters
According to DDTC, subsequent Web site notices will be posted shortly on the following related matters:
Warning to D-Trade users on controlling and assigning "super user" and "regular user" responsibility to individuals within the registered entity and third parties.
Implementation of new procedures in the Office of Defense Trade Controls Compliance (Compliance & Registration Division) to reject deficient registration submissions.
D-Trade software feature that automatically identifies an expired registration code on a license request and precludes that request from being submitted to DDTC.
DDTC notice (dated 01/16/07) available at http://www.pmddtc.state.gov/compliance_standard.htm.