State Department - ITAR license amendment guidance 

August 5: The U.S. State Department's Directorate of Defense Trade Control (DDTC) posted guidance concerning submissions of “General Correspondence requests” for the amendment of existing International Traffic in Arms Regulations (ITAR) authorizations due to U.S. entity name / address and / or registration code changes.

According to the DDTC guidance [PDF 57 KB], a registrant must notify the DDTC of all material changes to its registration file. Material changes include: (1) restructuring, (2) mergers and acquisitions, (3) registration code consolidations, and (4) combinations thereof. Licenses affected by these changes must be identified to the DDTC via a spreadsheet / matrix attached to a General Correspondence letter.

A General Correspondence request must be submitted within 60 days after the Office of Defense Trade Controls Compliance approval or acknowledgement of the change.

All requests for the transfer of licenses and agreements must include the following documentation:

  • A letter identifying the requested changes
  • A §126.13 certification letter
  • A copy of the DTCC’s letter acknowledging the requested change(s), if issued
  • A matrix / spreadsheet containing the authorizations to be transferred

For more information, contact a professional with KPMG’s Trade & Customs practice:

Douglas Zuvich

(312) 665-1022

Andrew Siciliano

(631) 425-6057

John L. McLoughlin

(267) 256-2614

Todd R. Smith

(949) 885-5617

Luis A. Abad

(212) 954-3094

Amie Ahanchian

(202) 533-3247

Or your local KPMG Trade & Customs professional.

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