The Directorate of Defense Trade Controls (DDTC) recently updated and posted new guidance for U.S. persons abroad (USPAB) applications for the provision of defense services to foreign entities. Specifically, DDTC has posted on their webpage under Guidelines and Instructions a new Guidance document as well as a submission letter template and a sample §126.13 certification letter to be used for USPAB General Correspondence applications for authorization to provide defense services. It is important to note that USPAB authorization requests to provide defense services are submitted through the Defense Export Control and Compliance System (DECCS) using Form DS 6004. The foreign person applicant does not need to be ITAR registered and the application packet must include the following elements:
DS 6004 Application
Submission Letter
Resume
Detailed job description
ITAR § 126.13(a) certification
It is important to note that applications for the provision of defense services that are approved via a USPAB application do not authorize export, re-export or transfer of technical data subject to the ITAR and any such data requires separate authorization. USPAB Authorizations are approved by e-mail from the Department of State. For further information and/or assistance in preparing USPAB applications please contact TSI Global Consulting.
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