On June 20, 2016 the Directorate of Defense Trade Controls (DDTC) published a rather vague Federal Register announcement seeking public comment on the proposed modernization of its export licensing system in which the current “form based” system for filing DSP-5, DSP-6, DSP-61, DSP-62, DSP-71 and the DSP-73 is expected to be replaced by an “intuitive” online system. In addition, via a separate FR announcement issued on the same day (June 20th) DDTC announced public comment on a new form based filing method for submitting voluntary disclosures in lieu of the current hard copy letter format that is currently in use. The new form that is expected to replace the DSP-5, DSP-6, DSP-61, DSP-62 and DSP-71 and DSP-73 will be referred to as a DSP-7788 whereas the form for submission of voluntary disclosures is being referred to be DDTC as the soon-to-be new DS-7787. At this time the test roll out by DDTC of this new system has been anything but smooth. In fact, on the DDTC website license filers are supposed to be able to preview this new proposed application and make comment on it. However, either the link is broken or DDTC has yet to upload the new proposed applications despite that fact that the link has now been live for seven days! In a separate webinar presented on May 20, 2016 (which unfortunately has not been archived on the DDTC website) DDTC did announce that the new applications will be filed through a web based system that WILL be replacing D-Trade. Hopefully, the new applications and more transparency on this new web based system will be posted on the DDTC site over the coming days so that industry can properly comment on the proposed change. The 60 day public comment period for both the proposed DS-7787 and DS-7788 runs through August 19, 2017.  At a minimum it does appear as if by Fall of 2016 the DSP-5 and other form based applications used by DDTC are going to be replaced by some form of online application. An FAQ page issued by DDTC can be accessed HERE. For more details stay tuned!

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