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US DEPARTMENT OF STATE
DEFENSE TRADE NEWS
THE BULLETIN OF THE CENTER FOR DEFENSE TRADE
VOLUME 5, NUMBER 1, JANUARY 1994
BUREAU OF POLITICAL-MILITARY AFFAIRS

Defense Trade News (ISSN 1051-2845) is a quarterly 
publication (January, April, July, October) of the 
Bureau of Political-Military Affairs, U.S. 
Department of State.  Its purpose is to provide 
American industry, the public, and Congress with 
information on defense trade policy, licensing 
practices, and compliance issues.  Contents include 
official policy statements and other official 
documents.  Special features, articles, and other  
materials (such as maps, charts, graphs, tables, and 
photographs) provide additional information on 
current issues but should not necessarily be 
interpreted as official U.S. policy statements.  The 
Secretary of State has determined that the 
publication of this periodical is necessary in the 
transaction of public business required by law. 

Subscription and Address Changes:  DTC Registrants -
- Every firm registered with the Office of Defense 
Trade Controls as a manufacturer or exporter should 
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registered address in the name of the registrant in 
Block 14 of Form DSP-9.  To change mailing 
addresses, a registrant must  notify the Office of 
Defense Trade Controls in writing, citing its 
applicant code, and must amend Form DSP-9 (see ITAR 
122.4).  

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available to U.S. government agencies, foreign 
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interested parties.  To subscribe or to submit an 
address change, write to Editors, Defense Trade 
News, PM/DTC, SA-6, Room 200, Department of State, 
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companies may reproduce this entire edition 
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Corrections, Contributions, and Correspondence:  
Address to Editors, Defense Trade News, PM/DTC, SA-
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TABLE OF CONTENTS

     Policy
Non-Proliferation and Export Control Policy -- White 
House Unveils New Framework

The Export Control Agenda -- Under Secretary of 
State Davis Testifies

      Operations
Fine-Tuning the ITAR -- Questions and Answers on the 
Revised International Traffic in Arms Regulations

Don't Just Carp; Turn to SARP -- A New Licensing 
Appeal Mechanism at State 

DTSA's Role in the Export Review Process -- An 
Introduction to the Defense Technology Security 
Agency 

ELLIE Comes on Line -- DTC Introduces Electronic 
License Submission

State Tiger Team Unleashed -- Reorganizing for 
Efficiency at the Office of Defense Trade Controls

     Departments
Defense Trade Advisory Group Developments
Commodity Jurisdiction Determinations
Suspensions & Debarments 
Personnel Updates
Tips and Tidbits
Feedback Questionnaire
ELLIE User Application
Training Form


Editor's Note
Beginning this issue, we plan to broaden our 
coverage of policy issues handled by the Bureau of 
Political-Military Affairs--issues such as non-
proliferation, government-to-government defense 
relations, and technology transfer--which we believe 
to be of interest to the defense trade community.  
Accordingly, Defense Trade News now sports the 
subtitle Export Policy Bulletin.

Our goal is to help you to keep abreast of the 
broader framework of U.S. non-proliferation and 
export control policy, while continuing to provide 
detailed information to facilitate the defense trade 
process.

Finally, this issue introduces an expanded Feedback 
questionnaire, designed to provide more detailed 
analysis of your reaction to the magazine. We rely 
upon your input to make the publication better 
suited to your needs. Please take a few minutes to 
let us know how we can do better.  (###)

Defense Trade News On-Line
If you have a PC and a modem, you can have 24-hour 
electronic access to U.S. Government publications 
via the Federal Bulletin Board. Download Defense 
Trade News before your hardcopy reaches you.  Keep 
abreast of U.S. foreign policy with the Department 
of State Dispatch.  Track modifications to the 
International Traffic in Arms Regulations with the 
Federal Register.


Non-Proliferation and Export Control Policy
White House Unveils New Framework 

The following statement was released by the  White 
House, Office of the Press Secretary, Washington, 
DC, September 27, 1993. Reprinted from the U.S. 
Department of State Dispatch.

The President today established a framework for U.S. 
efforts to prevent the proliferation of weapons of 
mass destruction and the missiles that deliver them.  
He outlined three major principles to guide our non-
proliferation and export control policy.

--  Our national security requires us to accord 
higher priority to non-proliferation and to make it 
an integral element of our relations with other 
countries.

--  To strengthen U.S. economic growth, 
democratization abroad, and international stability, 
we actively seek expanded trade and technology 
exchange with nations, including former adversaries, 
that abide by global non-proliferation norms.

--  We need to build a new consensus--embracing the 
executive and legislative branches, industry and the 
public, and friends abroad--to promote effective 
non-proliferation efforts and integrate our non-
proliferation and economic goals.

The President reaffirmed U.S. support for a strong, 
effective non-proliferation regime that enjoys broad 
multilateral support and employs all of the means at 
our disposal to advance our objectives.  Key 
elements of the policy follow.


Fissile Material
The U.S. will undertake a comprehensive approach to 
the growing accumulation of fissile material from 
dismantled nuclear weapons and within civil nuclear 
programs.  Under this approach, the U.S. will:

--  Seek to eliminate where possible the 
accumulation of stockpiles of highly enriched 
uranium or plutonium and to ensure that, where these 
materials already exist, they are subject to the 
highest standards of safety, security, and 
international accountability;

--  Propose a multilateral convention  prohibiting 
the production of highly enriched uranium or 
plutonium for nuclear explosives purposes or outside 
of international safeguards;

--  Encourage more restrictive regional arrangements 
to constrain fissile material production in regions 
of instability and high proliferation risk;

--  Submit U.S. fissile material no longer needed 
for our deterrent to inspection by the International 
Atomic Energy Agency;

--  Pursue the purchase of highly  enriched uranium 
from the former Soviet Union and other countries and 
its conversion to peaceful use as reactor fuel;

--  Explore means to limit the stockpiling of 
plutonium from civil nuclear programs and seek to 
minimize the civil use of highly  enriched uranium; 
and

--  Initiate a comprehensive review of long-term 
options for plutonium disposition, taking into 
account technical, non-proliferation, environmental, 
budgetary, and economic considerations.  Russia and 
other nations with relevant interests and experience 
will be invited to participate in this study. 

The United States does not encourage the civil use 
of plutonium and, accordingly, does not itself 
engage in plutonium reprocessing for either nuclear 
power or nuclear explosive purposes.  The United 
States, however, will maintain its existing 
commitments regarding the use of plutonium in civil 
nuclear  programs in Western Europe and Japan.

Export Controls
To be truly effective, export controls should be 
applied uniformly by all suppliers.  The United 
States will harmonize domestic and multilateral 
controls to the greatest extent possible.  At the 
same time, the need to lead the international 
community or overriding national security or foreign 
policy interests may justify unilateral export 
controls in specific cases.  We will review our 
unilateral  dual-use export controls and policies 
and eliminate them unless such controls are  
essential to national security and foreign policy 
interests.

We will streamline the implementation of U.S. non-
proliferation export controls.  Our system must be 
more responsive and efficient and not inhibit 
legitimate exports that play a key role in American 
economic strength, while preventing exports that 
would make a material contribution to the 
proliferation of weapons of mass destruction and the 
missiles that deliver them.

Nuclear Proliferation
The U.S. will make every effort to secure the 
indefinite extension of the Non-Proliferation Treaty 
in 1995.  We will seek to ensure that the 
International Atomic Energy Agency has the resources 
needed to implement its vital safeguards 
responsibilities and will work to strengthen the 
IAEA's ability to detect clandestine nuclear 
activities.

Missile Proliferation
We will maintain our strong support for the Missile 
Technology Control Regime.  We will promote the 
principles of the MTCR Guidelines as a global 
missile non-proliferation norm and seek to use the 
MTCR as a mechanism for taking joint action to 
combat missile proliferation.  We will support 
prudent expansion of the MTCR's membership to 
include additional countries that subscribe to 
international non-proliferation standards, enforce 
effective export controls, and abandon offensive 
ballistic missile programs.  The United States will 
also promote regional  efforts to reduce the demand 
for missile capabilities.

The United States will continue to oppose missile 
programs of proliferation concern and will exercise 
particular restraint in missile-related cooperation.  
We will continue to retain a strong  presumption of 
denial against exports to any country of complete 
space launch vehicles or major components.

The United States will not support the development 
or acquisition of space launch  vehicles in 
countries outside the MTCR.

For MTCR member countries, we will not encourage new 
space launch vehicle programs which raise questions 
on both  non-proliferation and economic viability 
grounds.  The United States will, however, consider 
exports of MTCR-controlled items to MTCR member 
countries for peaceful space launch programs on a 
case-by-case basis.  We will review whether 
additional constraints or safeguards could reduce 
the risk of misuse of space launch technology.  We 
will seek adoption by all MTCR partners of policies 
as vigilant as our own.

Chemical and Biological Weapons
To help deter violations of the Biological Weapons 
Convention, we will promote new measures to provide 
increased transparency of activities and facilities 
that could have biological weapons applications.  We 
call on all nations--including our own--to ratify 
the Chemical Weapons Convention quickly so that it 
may enter into force by January 13, 1995.  We will 
work with others to support the international 
Organization for the Prohibition of Chemical Weapons 
created by the Convention.

Regional Non-Proliferation Initiatives
Non-proliferation will receive greater priority in 
our diplomacy and will be taken into account in our 
relations with countries around the world.  We will 
make special efforts to address the proliferation 
threat in regions of tension such as the Korean 
Peninsula, the Middle East, and South Asia, 
including efforts to address the underlying 
motivations for weapons acquistion and to promote 
regional confidence-building steps. 

In Korea, our goal remains a non-nuclear  peninsula. 
We will make every effort to secure North Korea's 
full compliance with its non-proliferation 
commitments and effective implementation of the 
North-South denuclearization agreement.

In parallel with our efforts to obtain a secure, 
just, and lasting peace in the Middle East, we will 
promote dialogue and confidence-building steps to 
create the basis for a Middle East free of weapons 
of mass destruction.  In the Persian Gulf, we will 
work with other suppliers to contain Iran's nuclear, 
missile, and CBW ambitions, while preventing 
reconstruction of Iraq's activities in these areas. 
In South Asia, we will encourage India and Pakistan 
to proceed with multilateral discussions of non-
proliferation and security issues, with the goal of 
capping and eventually rolling back their nuclear 
and missile capabilities.

In developing our overall approach to Latin America 
and South Africa, we will take account of the 
significant non-proliferation progress made in these 
regions in recent years.  We will intensify efforts 
to ensure that the former Soviet Union, Eastern 
Europe, and China do not contribute to the spread of 
weapons of mass destruction and missiles.

Military Planning and Doctrine
We will give proliferation a higher profile in our 
intelligence collection and analysis and defense 
planning and ensure that our own force structure and 
military planning address the potential threat from 
weapons of mass destruction and missiles around the 
world.

Conventional Arms Transfers
We will actively seek greater transparency in the 
area of conventional arms transfers and promote 
regional confidence-building measures to encourage 
restraint on such transfers to regions of 
instability.  The U.S. will undertake a 
comprehensive review of conventional arms transfer 
policy, taking into account national security, arms 
control, trade, budgetary, and economic 
competitiveness considerations. (###)


The Export Control Agenda
Under Secretary of State Davis Testifies

Under Secretary of State for International Security 
Affairs Lynn E. Davis testified before the House 
Committee on Foreign Affairs Subcommittee on Europe 
and the Middle East on November 10, 1993, addressing 
non-proliferation and export control issues.  An 
excerpt from Under Secretary Davis's opening 
statement follows.

Thank you very much. . . for the opportunity to 
appear before your committee to discuss an issue of 
great importance to the Clinton Administration. As 
you and your committee appreciate, non-proliferation 
is the arms control priority of the post-Cold War 
world.  The proliferation of dangerous weapons 
represents the most critical security threat we 
face. As a result, the Clinton Administration is 
placing a very high priority on non-proliferation.

Let me briefly describe the Clinton Administration's 
non-proliferation agenda, which spans the whole 
range of proliferation dangers and which we are 
pursuing with a global diplomatic effort.

Secretary Christopher recently returned from a 
visit, a trip to Russia, Kazakhstan, Ukraine, and 
Belarus. In addition to pledging U.S. support for 
democratic reform, Secretary Christopher focused on 
the nuclear danger and our goal to prevent the 
threats posed from the proliferation of weapons of 
mass destruction.

U.S. / N.I.S. Partnership
The United States and Russia, now as partners, are 
consulting very closely on the goals of negotiating 
as quickly as possible a Comprehensive Test Ban 
Treaty, achieving the indefinite extension of the 
Non-Proliferation Treaty, a global ban on the 
production of fissile material for the production of 
nuclear weapons, and the elimination of chemical 
weapons. In Moscow, we worked together to ensure a 
smooth entry into force of the Bilateral Missile 
Technology Control Regime Agreement.

Kazakhstan committed to accede to the NPT as a non-
nuclear weapons state by the end of this year.  In 
Ukraine, President Kravchuk reaffirmed the goal of a 
non-nuclear Ukraine and his personal commitment to 
ratify the START Treaty and to proceed to the NPT as 
a non-nuclear weapons state.  He made clear that the 
Lisbon protocol covers all nuclear weapons in the 
Ukraine, including the SS-24 missiles.

But much remains to be done. . . particularly on the 
3,000 former Soviet nuclear warheads that need to be 
eliminated from Ukraine, Kazakhstan, and Belarus.  
The U.S. is working actively to facilitate 
agreements to transfer all these nuclear warheads to 
Russia for dismantling and to provide compensation 
for the highly enriched uranium in them.

Through the Nunn-Lugar program, we will assist in 
the elimination of strategic offensive arms in all 
four states.  Such assistance is already flowing to 
Russia and Belarus and we aim to put the necessary 
agreements in place with Ukraine and Kazakhstan in 
the coming weeks.  To prevent these nations from 
becoming a source of dangerous arms and 
technologies, we are working with them to establish 
effective export control systems.

Our activities in the Newly Independent States 
demonstrate the many diverse elements which 
constitute the Clinton Administration's overall non-
proliferation policy.  Let me describe our overall 
goals with respect to our non-proliferation policy. 

The spread of nuclear weapons is clearly the 
greatest proliferation danger we face.  Our foremost 
goal is universal NPT membership. We are actively 
urging all NPT parties to join us in extending the 
Non-Proliferation Treaty indefinitely and 
unconditionally in 1995.  And I can report. . . that 
support is growing for these goals. 

Critical Initiatives
The Clinton Administration has announced two 
critical initiatives in support of our overall 
nuclear nonproliferation strategy:  to achieve a 
Comprehensive Nuclear Test Ban Treaty by 1996, and 
to put in place a global convention cutting off 
production of fissile material for nuclear weapons 
purposes.

I can report again momentum towards a CTBT is 
growing. Last summer, the Conference on Disarmament 
reached consensus on beginning formal negotiations 
in Geneva in January of 1994.

Since then, we have made good progress on drafting a 
specific CD negotiating mandate for the Conference 
on Disarmament.  And in addition, in New York at the 
General Assembly, for the first time. . . we will 
achieve a consensus resolution supporting test ban 
negotiations. So we see movement and momentum 
towards a Comprehensive Test Ban Treaty.

But we also need measures to strengthen the global 
nuclear non-proliferation regime with a regional 
focus.  And here let me describe to you briefly one 
particular area of concern and one particular set of 
policies that are very important to our 
Administration.  And this has to do with North 
Korea.

North Korea Concerns
President Clinton made clear that North Korea cannot 
be allowed to develop a nuclear bomb.  We are thus 
working very closely with the IAEA, with Japan, 
South Korea, and other interested parties to bring 
North Korea into compliance with all of its 
international obligations.  This is not an easy 
process but we remain committed to our goal of 
having North Korea comply with its safeguards 
obligations under the Non-Proliferation Treaty and 
implement the North-South Denuclearization 
Declaration.

Recent North Korean behavior has been disappointing.  
The U.S. has made clear its readiness to address 
legitimate North Korea concerns.  But unless the 
North Koreans take the necessary steps to persuade 
the world community that it is not pursuing a 
nuclear weapons option, we will have no choice but 
to end our bilateral dialogue with North Korea and 
pursue further steps in the United Nations Security 
Council.

Let me turn, then, briefly to. . . the progress we 
have made with respect to tightening export controls 
to prevent the spread of the materials necessary to 
produce chemical and biological weapons.

MTCR Successes
With respect to missile proliferation, the 
multilateral missile technology control regime will 
continue to be the primary tool of United States 
missile nonproliferation policy. It works and has 
enjoyed several recent successes which this 
committee has learned about through our past 
consultations.

In South Africa, Argentina, Hungary and in Russia we 
are achieving successes with respect to the flow of 
missiles and missile technology. We now intend to 
move the regime into the future, beyond a group of 
responsible suppliers that seeks to ensure that its 
own industries do not inadvertently contribute to 
missile proliferation, to a group that works 
actively together to deal with the missile 
proliferation problem worldwide.

We have also demonstrated that we are  prepared to 
pursue our non-proliferation goals vigorously even 
when such efforts involve sanctions and may risk 
frictions in critical bilateral relationships.

Again. . . to point out the breadth and range of the 
Clinton Administration's overall non-proliferation 
policies, we are in the process of reorienting 
export controls in the post-Cold War world to meet 
the new dangers and security concerns that we see in 
the world that we now live in.

Reorienting Export Controls
There is general agreement that the COCOM controls 
on trade with Russia and the other states of the 
former Warsaw Pact should be phased out, and a 
partnership offered to Russia and other Newly 
Independent States in a new regime.  The partnership 
will be based on clearly defined criteria concerning 
adherence to export controls and non-proliferation 
norms.  We and our allies are discussing now how 
best to structure a new regime in partnership with 
Russia and the other Newly Independent States to 
enhance transparency and coordination of controls on 
exports of arms and sensitive dual-use and military 
technologies. Our approach is multilateral, focused 
on new dangers, and particularly focused on the 
dangers  we see in Iran, Iraq, Libya, and North 
Korea. . . .

Let me conclude by a few observations with respect 
to how to think about our non-proliferation goals in 
the new world.

We very much appreciate the complex nature of the 
task of promoting non-proliferation. It is not 
simply stopping the flow of technologies, weapons, 
or hardware. Rather, it deals with the tough and 
interrelated issues of security, economics, jobs, 
and trade. It also cuts to the fundamental 
prerogative of states and that is their sovereignty.

Non-proliferation requires global engagement. 
Success will also require regional strategies 
tailored to the specific security concerns of 
individual countries. Diplomacy, backed up by 
American power, represents our primary tool in 
attaining our non-proliferation goals. At the same 
time, we will ensure that U.S. and allied forces are 
prepared to cope with possible threats if our non-
proliferation efforts were to fail.

American Leadership
Success will require American leadership. The 
Clinton Administration is poised to undertake that 
leadership around the world. We also recognize that 
we cannot shoulder all non-proliferation 
responsibilities alone. We  will require the help of 
others to succeed, first in controlling trade in 
dangerous arms and technologies which are available 
now around the world.

But let me conclude. . . that as important, if not 
more important, will be that the Administration and 
the Congress will work as a team. We share the same 
non-proliferation goals, and working together, in my 
view, we will be able to achieve these so the world 
knows that the United States stands firmly for these 
goals and that we are prepared to take the steps 
necessary to achieve those goals. (###)


OPERATIONS

Fine-Tuning the ITAR
Questions and Answers on the Revised International 
Traffic  in Arms Regulations

A revised version of the International Traffic in 
Arms Regulation (ITAR) entered into force on July 
22, 1993.  This article provides informal guidance 
and clarification of some of the changes in the new 
ITAR.  Only changes  printed in the Federal Register 
constitute official modifications to the ITAR. 

Exemptions and Registration.  While the new ITAR 
allows for many new exemptions and reduced 
paperwork, companies in the business of defense 
trade must still fulfill the requirements of 
registration.  All U.S. manufacturers of defense 
articles, as well as exporters of defense articles 
and persons furnishing defense services, are 
required to register with the Office of Defense 
Trade Controls.  This is true even if they will be 
exporting articles or services that, in the specific 
circumstances, are exempt from licensing 
requirements. 

Public Domain Exemptions (120.11 (5).  The public 
domain exemption for technical data does not apply 
to patents protected by secrecy orders.

Hierarchy (120.1 (b).  The revised ITAR provides 
that all authorities conferred upon the Director of 
the Office of Defense Trade Controls may be 
exercised at any time by the Under Secretary of 
State for International Security Affairs, the 
Assistant Secretary of State for Political-Military 
Affairs, and the Deputy Assistant Secretary of State 
for Export Controls.

Transfer or Disclosure to Embassies (120.13).  The 
new ITAR expressly provides that disclosure or 
transfer of any defense article to a foreign embassy 
in the U.S. is to be considered an export for the 
purposes of these regulations.

Satellites (120.17 (6).  Transfer of a U.S.-origin 
satellite  between foreign countries, or from the 
U.S. to a foreign country, requires a license. 
However, the launch of a satellite from the U.S. or 
from a foreign country (once the license for 
transfer has been approved) does not require a 
license.  Once in space, a satellite is still 
covered by the ITAR; the transfer of ownership, 
control, or use of a satellite in orbit from one 
country to another requires a license.

Free Trade Zones (120.18).  Any transfer of an item 
covered by the USML to a foreign country through a 
free trade zone requires a license or other written 
approval, whether or not the item originates in the 
U.S.

"NATO Plus" Exemption (123.9).  The ITAR, under 
certain circumstances,  grants an exemption from the 
general requirement for State Department retransfer 
authorization to transfers to the governments of 
NATO members, Japan and Australia of U.S.-origin 
components incorporated into a foreign defense 
article. This exemption does not apply to parties 
ineligible under 126.7(a)(2)-(7),  127.7(c), or 
128.  These parties must apply to DTC for specific 
exemption to legally retransfer defense items to any 
recipient, including the governments of NATO 
countries, Japan and Australia.

Empowered Official Defined (120.25).  The ITAR 
defines the criteria a company officer signing a 
license application or other written request for 
approval must meet to qualify as an "empowered 
official" for the purposes of registration. All 
these criteria must be met.  In submitting a license 
application, other request for approval or 
registration form, an empowered official does not 
need to demonstrate evidence of fulfillment of the 
criteria unless specifically requested.

Questions have  been raised as to whether an 
"empowered official" needs to have a "power of 
attorney." An employee need not hold a power of 
attorney for a company to be designated an empowered 
official for the purposes of the ITAR.

Records Maintenance (122.5). Companies must hold 
records of defense trade for 5 years from the 
expiration of the license or other approval, down 
from 6.

Intermediate Consignees (123.9 (c) (d).  DTC must 
be informed of all intermediate consignees, or any 
other consignees, involved in any export of defense 
articles.  Even when an exemption is claimed for a 
U.S.-origin defense article shipment, all companies 
at each stage of the shipment must be informed that 
the article is of U.S. origin and may not be 
retransferred except with the prior written approval 
of the Department of State.

Proscriptions (126.1).  In addition to those 
countries listed in 126 as proscribed, other 
countries may from time to time be subject to the 
denial, suspension, or revocation of licenses to 
export to them.  These decisions will be announced 
in the Federal Register.
ITAR Qs & As

Q:  Will licenses approved before July 22, 1993 now 
be valid for 4 years (new ITAR), instead of 3 years 
(old ITAR)?

A:  No.The provision concerning validity of export 
licenses is not retroactive to previously issued 
licenses.

Q:  Does the new ITAR extend the validity of  DSP-94 
licenses (for authority to export under the Foreign 
Military Sales program) from 2 years to 4 years?

A:  No. However, it is the intent of DTC to amend 
the ITAR to do so.

Q:  122.4 (c) (1) - (3) requires certain 
information to be provided to DTC when a new entity 
is formed in a merger or acquisition.  Is there a 
specific time period within which DTC must be 
notified?

A:  DTC must  be notified of any material changes in 
the registration statement, including any material 
changes in the information required by 122.4 (c) 
(1) (3), within 5 days of the event, as specified in 
122.4 (a) (2).

Q:  Is a registrant required to notify DTC in 
advance of any intended sale or transfer to a 
foreign person of ownership or control of the 
registrant or entity thereof?

A:  Yes, in accordance with 122.4 (b).  A 
registrant must notify DTC in writing at least 60 
days in advance of any such intended sale or 
transfer.  (###)

DTC invites questions and comments on the new ITAR 
and its implementation.  Please fax your thoughts, 
queries, and ideas to (703) 875-6647. (###)

To order a copy of the revised ITAR, call the 
Government Printing Office  at (202) 783-3238 from 
8:00 - 4:00 EST.  Cite stock number 069-001-000-58-
1. (###)


Don't Just Carp; Turn to SARP
A New Licensing Appeal Mechanism at State

The Office of Defense Trade Controls, on the 
recommendation of the Department of State's Defense 
Trade Advisory Group (DTAG), has implemented an 
informal appeal process for license applications for 
which it has made a preliminary determination of 
denial.  The process is known as the State Appeal 
Review Process, or SARP.  

An additional appeal mechanism.  The SARP will not 
replace the formal appeals process provided for in 
ITAR 126.7(d).  The goal is for the Director of DTC  
to augment the regulatory system by ensuring 
industry has the opportunity to understand the U.S. 
Government position on any case which DTC intends to 
deny.

Eligibility.  Cases eligible for review in the SARP 
include applications which DTC licensing officers 
recommend for denial either in the initial review 
process or following interagency referral.  Not all 
cases are eligible for the SARP.  

For example, any ineligible case include those for 
which there clearly exists published foreign policy 
or national security guidelines.  This would include 
publication of denial criteria in the regulations, 
Federal Register, DTN or any MTEC case where the USG 
has requested MTEC assurances and the foreign 
government has either not responded or refuses to 
provide the required assurances.

Grounds for denial.  In accordance with ITAR 126.7 
(a) (1), applications for export licenses will not 
be approved when such exports are deemed not to be 
in furtherance of world peace, national security, or 
the foreign policy of the United States.  Factors 
that may lead to a denial include human rights 
concerns, regulatory interpretation, technological 
sophistication, bona fides of the end use and end 
user, and concerns related to the Missile Technology 
Control Regime.

Step one--notification.  The SARP process will begin 
with DTC notifying the applicant by phone and fax of 
the intent to deny, explaining the rationale for the 
denial. DTC will request a written response as to 
whether the applicant wishes to implement a SARP 
review. If the applicant does not reply within 3 
working days of transmission of the notification, 
DTC will proceed with a formal written denial.  To 
reply, the applicant need only complete the bottom 
of DTC's fax notification form.

Step two--the ASID test.  If the applicant requests 
a SARP, the applicant has 7 working days, dating 
from DTC's notification, to submit a paper known as 
the "Applicant SARP Information Document (ASID)." 
The ASID should address and counter DTC's denial 
rationale; thus it must contain new information not 
included in the original application.  

The ASID paper, at this time,  has no format 
requirements.  However, if the Department of Defense 
has held a "Day in Court" review of the application, 
the applicant should attach a copy of the "White 
Paper" which was prepared for the Day in Court.

Step three--the meeting.  Within 2 working days of 
receiving the ASID, DTC will review it and decide 
whether the additional information presented 
warrants a follow-up meeting.  If so, DTC will 
coordinate with the applicant to establish a meeting 
date, time, and place.  DTC may invite other 
interested agencies to participate, in which case 
DTC will request that the applicant provide copies 
of the ASID directly to all U.S.G. personnel who  
will participate in the SARP.

Step four--decision.  DTC will not rule on the spot, 
but will notify the applicant in writing of its 
decision within 5 working days.  (###)


DTSA's Role in the Export Application Review Process
An Introduction to the Defense Technology Security 
Administration  

Approximately 25% of the arms export license 
applications submitted to the Office of Defense 
Trade Controls involve issues of national security 
that require Department of Defense (DOD) review.  
The Defense Technology Security Administration 
(DTSA), established in May 1985 by DOD Directive 
5105.51, is responsible for developing the DOD 
position on munitions license applications and 
Commodity Jurisdictions. Within DTSA, this function 
is delegated to the License Directorate (DTSA/LD).

Why DOD reviews applications. DOD reviews arms 
export license applications to assess their impact 
on U.S. national security. Among the factors in that 
evaluation:

--  Commodity sophistication 
    -  potential operational risk to U.S. troops 
    -  valid needs of the end user 
--  End use
    -  stated end use 
    -  possible alternate end uses 
--  End user
    -  ability to use the commodity 
    -  status; not debarred or suspended 
--  Security classification of commodity 
    -  accordance with National Disclosure Policy 
--  International agreements
    -  disclosure guidance 
--  Foreign availability
    -  capability to manufacture production  
quantities 
    -  exportability 
--  FMS-only proviso
    -  must be fully justified in accodance with 
existing DOD policy 
--  False impression
    -  if export of the end item cannot be approved, 
DTSA normally cannot approve technical marketing 
data or a hardware demonstration. 

Details, details, details.  Twice each week, DTSA 
picks up applications from DTC and records the 
pertinent details of each license application in a 
computer system.  There is a direct relationship 
between the accuracy and completeness of an 
application and the quality and timeliness of the 
DOD response.  The following items are critical to 
DOD in reviewing a case:

Commodity description.  A technical description of 
hardware and/or data must be attached to enable 
technical personnel to understand the item's 
functional capabilities.

End-use description.  A thorough description of the 
end-use must be provided to give reviewers a 
complete understanding of the transaction.

Precedent cases.  A history of previous cases, 
including denials, involving the identical commodity 
is important in obtaining a fair and accurate 
review.  Applicants should attach copies of any 
precedent applications and related State Department 
letters.

Foreign availability.  For an item with no precedent 
release history, applicants should attach any 
available documentation indicating an equivalent 
foreign item is in production, plus any available 
documentation indicating that the government of the 
foreign producer would permit export.  It may be 
advisable to consult with DTSA on this issue prior 
to submitting an application to State.

When DOD receives an application without supporting 
technical data, DTC is advised that the application 
will be Returned Without Action if DOD does not 
receive the data in 3 working days.  If technical 
data accompanying an application is insufficient, 
the applicant has 10 working days to provide the 
data.  If the applicant does not do so, the 
application is Returned Without Action to DTC.

How DOD reviews applications.  To save time, DTC 
provides copies of applications to pertinent DOD 
offices.  (Refer to chart on following page.)  
DTSA/LD reviews opinions received from these DOD 
entities and formulates a single DOD position.  A 
DOD office that disagrees with a DOD position 
proposed by DTSA/LD can request DOD's International 
Technology Transfer Coordinating Committee, chaired 
by an Assistant Secretary of Defense, to consider 
the issue. 

National Disclosure Policy.  The National Disclosure 
Policy (NDP) is a classified document that governs 
the release of U.S. classified military information 
to foreign governments and international 
organizations.  A request for exception to NDP may 
be sponsored by State, Defense, Army, Navy,  Air 
Force, or the Joint Chiefs of Staff.

How DOD views Commodity Jurisdiction determinations.  
Determination of whether an item or service is under 
the jurisdiction of the Department of State's U.S. 
Munitions List (USML) is provided by the Office of 
Defense Trade Controls, Department of State upon 
receipt of written request.  The determinations are 
based on interagency consultations, including 
technical evaluations from the Departments of 
Commerce and Defense and other cognizant agencies.

A Commodity Jurisdiction request should contain a 
complete technical description of the item, the 
reason it was developed, whether U.S. Government 
funds were used in its development, a description of 
any military and/or commercial usage, and any other 
facts the applicant deems appropriate.

Commodity Jurisdiction determination is based 
primarily on whether the item was specifically 
designed or modified for a military application.  A 
narrow exception to this policy exists for items 
which have commercial applications but also have 
significant military or intelligence applicability; 
see ITAR 120.3.  Use of an item by the U.S. 
military and the intended end use of an item 
proposed for export are not factors.  

Responsiveness. To respond to State Department 
referrals within 20 calendar days, DTSA has recently 
begun transmitting its positions to DTC via 
computer, saving up to 3 days of processing time.

Case status.  Exporters can download case status 
information from DTSA's computer by calling the 
Export License Status Advisor (ELISA) at (703) 697-
6109.  Case information remains in ELISA for three 
weeks after DOD closes a case.  ELISA maintenance 
assistance is available by calling (703) 697-7840.  
Case status information is also available by calling 
(703) 697-5336, Mondays and Wednesdays from 2:00 to 
4:00 pm and Fridays from 9:00 to 10:30 am. 

Objections.  When DOD intends to object to a 
transaction, DTSA contacts the designated applicant 
contact.  Objections based on established release 
policies or a determination by the cognizant service 
that it does not wish to sponsor the required 
exception to National Disclosure Policy are not 
usually subject to further discussion with DOD.  
Other types of DOD objection rationales may be 
questioned through "Day in Court" procedures.

For information on the Day in Court, contact DTSA's 
License Directorate at (703) 697-5336. 

Questions concerning this article should  be 
referred to Nancy Hindman, DTSA/LD, at (703) 614-
7761.(###)


License Directorate
Defense Technology Security Administration  (DTSA)
Suite 302, 400 Army Navy Drive, Arlington, VA   
22202


Position                   Name             Phone
Acting Director           Jim Woody  (703) 695-3554
   Policy Analyst         Nancy L. Hindman 614-7761
   Secretary              JoAnne L. Brown  695-3554
   Secretary              Cheryl Barnett   614-7398
   Admin Support    SMSGT Ricky B. Cooksey 697-5336

Chief, Munitions Branch   Janet L. Michel  697-3429
   Senior Analyst        Leonard H. Altman 693-1127
   Analyst               Julia Kortum      614-7756
   Export Control Specialist Mary Gressette 614-7399
   Analyst                Howard Gardiner   693-1126
   Export Control Specialist  Paula Harris  614-7399
   Analyst               MAJ Brien McNamara 693-1125
   Export Control Specialist  (vacant)      693-1129
   Senior Analyst         Jim Stofferahn    614-7754
   Analyst                Linda Randall     614-7753
   Export Control Specialist Paula Harris   614-7399
   Analyst          Natalie Pechanski-McRoy 697-5335
   Export Control Specialist  Janet Smith   693-1129
   Analyst               Susan Webster      614-7392
   Export Control Specialist Mary Gressette 614-7399
   Admin NCO        TSGT Joseph Brooks      614-7398
(###)


[EDITOR'S NOTE:  The chart on "DOD Review of License 
Applications" that appears in the hard copy version 
of this pubication cannot be duplicated in this 
electronic format]



ELLIE Comes On Line
Office of Defense Trade Controls Introduces 
Electronic License Submission

Following up the success of ROBB (DTC's Remote On-
Line Bulletin Board), the Office of Defense Trade 
Controls has inaugurated a pilot program to test the 
feasibility of electronic license submission.

The centerpiece of the system is the ELectronic 
LIcense Entry system, ELLIE, designed and 
implemented by DTC's in-house Computer Support Staff 
under Jim DePalma.  With ELLIE, applicants can fill 
out applications on the personal computers in their 
offices, dial up DTC's computer via modem, and 
submit the applications electronically. 

Easy application.  ELLIE users fill in the face of 
the application (DSP-5s only, at this stage) on the 
computer screen.  The system features continuation 
sheets, to continue an item on the form or to add an 
attachment (e.g., a list of freight forwarders).  A 
template feature  allows users to store repetitive 
data such as company name and address.  Companies 
with divisions at multiple locations could create a 
template for each, selecting the appropriate one for 
each application.

Error-resistant processing.  All information 
submitted via ELLIE is automatically entered into 
DTC's licensing data base eliminating data entry 
errors, further speeding the licensing process. 

Easy  tracking.  Licenses entered electronically 
show up in ROBB the following morning, referenced by 
license number and by a transaction number generated 
to facilitate cross-referencing with paper 
attachments.

Quick turnaround.  Building the efficiencies 
inherent in electronic licensing, our aim is that 
companies using ELLIE will receive approved licenses 
back much more quickly than with traditional 
methods.  During our test phase, a number of the 
most straightforward applications were processed 2 - 
3 days quicker. 

Outstanding issues.  Operational questions remain to 
be solved for ELLIE to achieve her full potential.  
For example, backup material for complex 
applications cannot be entered electronically on 
ELLIE's continuation sheets; it still must be 
submitted--by mail, courier, or fax--and a paper 
file married up to the information provided via 
ELLIE.

Now recruiting.  From an initial test group of five 
selected companies, the ELLIE project has grown to 
include more than forty.  User reaction has been 
overwhelmingly positive, and DTC is eager to expand 
the number of users as well as the system's 
features.  (###)

For more information, or to sign up for ELLIE, 
please call DTC's  Computer Support Staff at (703) 
875-6650 or use the rear application form on page 
28. 


State Tiger Team Unleashed
Reorganizing for Efficiency at the Office of Defense 
Trade Controls

If you have submitted a license application to the 
Office of Defense Trade Controls since December, 
1993, you may have gotten it back stamped with the 
phrase "TIGER TEAM." Those licenses are part of an 
organizational experiment underway at DTC--one 
aspect of a multi-pronged effort to improve 
productivity, increase job satisfaction within the 
office, and increase customer satisfaction with case 
processing.

Enhanced computerization.  A major thrust of the 
change is an emphasis on greater computerization at 
DTC. Two examples are the implementation of license 
application through "electronic data interface,"or 
EDI  (in which the applicant submits a license 
application electronically via the ELLIE system), 
and the expansion of electronic staffing of cases to 
other agencies and other State Department offices.

DTC  is already using electronic means to staff 
cases to the Department of Defense, and will expand 
electronic staffing to State Department offices 
early in 1994.  This will enable DTC to get cases 
staffed instantaneously and on a daily basis, and 
will combat the problem of paper files going astray 
as they travel between DTC and other offices and 
agencies.

Organizational change.  Perhaps the most intriguing 
element of the change at DTC involves use of a 
"Tiger Team" experiment to test the utility of 
"Total Quality Management" (TQM) theory in 
organizing the office as a whole and in approaching 
license processing.

Tigers in the vanguard.  The thrust of the TQM 
approach as applied to DTC is to combine licensing, 
compliance, and administrative specialists into 
largely self-managed work teams, improving inter-
functional coordination and cutting down on the 
transfer of cases among DTC divisions.

Licensing officer Ken Peoples has been appointed to 
head this team for a three-month trial period.  Dan 
Cook and Major Bob Kovac join the Team as licensing 
analysts (Bob also as the Team's "quality control" 
officer), Jim DePalma as computer and electronics 
expert, Danielle Mack as administrative assistant, 
and Eva Tyler as compliance analyst. 

Since December 6, license applications assigned to 
Peoples, Cook, or Kovac have been processed using 
this teaming approach, with a processing system 
which the team has designed itself.  Licenses which 
they process in this fashion are being marked "TIGER 
TEAM" when issued. 

Fewer hands, quicker handling.  The Tiger Team 
expects to reduce case processing time by minimizing 
the number of people handling each  case, maximizing 
the amount done to a case each time someone handles 
it (e.g., having licensing officers type in license 
provisos instead of passing cases off to secretaries 
for typing), and emphasizing use of electronics  
(ELLIE, electronic staffing). 

Towards paperless licensing.  The Team is also 
looking at several proposals to improve processing 
speed and reduce opportunities for human error--
e.g., eliminating manual processing of applications, 
computer-generating licenses at the end of the 
process.  If possible, the Team wants to use such an 
approach as part of the experiment.  Note that this 
will be possible only with cases submitted 
electronically (another reason for companies to sign 
onto the ELLIE pilot project).

You be the judge.  Eventually, the Tiger Team will 
seek industry reaction and comments from those 
customers affected by the process.  At the end of 
the 3-month trial period, a neutral observer will be 
called in to evaluate the Team's performance; 
customer satisfaction will be one of the criteria 
used in that evaluation.  In the meantime, 
applicants should not be surprised if they receive a 
call from Bob Kovac seeking feedback on a case the 
Tiger Team has handled.   

Investment in training.  Finally, training will be 
an important aspect not only of the Tiger Team 
project, but of the customer service and processing 
enhancements DTC seeks to implement in the near 
future. 

All DTC employees are scheduled to take a 2-day 
course in "customer service" at the State 
Department's National Foreign Affairs Training 
Center in January.  In addition, all DTC employees 
will receive basic training in TQM theory, and 
selected employees will receive advanced TQM 
training. 

This training is being scheduled so everyone will be 
given adequate "back-up" while out of the office on 
training, but  callers seeking a specific person in 
the office might be delayed.  Any delays or 
inconveniences will be short-lived and, we expect, 
minor--and worth it.  (###)

Questions on the Tiger Team project can be addressed 
to Ken Peoples at (703) 875-6619, Dan Cook at 875-
5674,  Bob Kovac at 875-5199, or Jim DePalma at 875-
7391.



Landmine Moratorium Extended Through 1996
On November 10, 1993, Congress extended for an 
additional three years the moratorium on exports of 
anti-personnel landmines established in the 1993 
Defense Authorization Act. The original one-year 
moratorium took effect on November 23, 1992, 
prohibiting the sale, transfer, or export under the 
Arms Export  Control Act of any anti-personnel land 
mine. In November 1992 the State Department 
announced via the Federal Register (57 FR 55614) the 
revocation or suspension of previously-issued 
licenses.  (###)



DEPARTMENTS

DTAG DEVELOPMENTS
The Defense Trade Advisory Group (DTAG) convened its 
semi-annual plenary session on October 6, 1993 at 
the Department of State.  Highlights from the 
session:

Reorganization at State
Assistant Secretary for Political-Military Affairs 
Robert L. Gallucci discussed how the Department of 
State has redirected its export control priorities 
to reflect President Clinton's emphasis on non-
proliferation and U.S. economic security. 

State export control functions have been centralized 
within the Bureau of Political-Military Affairs. The 
restructuring advances one of the Bureau's key 
goals--to prevent arms diversions and exports which 
fuel proliferation, while promoting transfers 
consistent with U.S. national security and foreign 
policy concerns. Assistant Secretary Gallucci 
concluded by reaffirming the Administration's 
commitment to facilitating legitimate U.S. defense 
exports.

New Priorities
In her keynote address, Under Secretary for 
International Security Affairs Lynn E. Davis 
commented on the Administration's proposed 
international affairs budget reforms.  Evolving 
relations between countries and new U.S. priorities 
require the Administration to re-examine the way it 
allocates scarce resources. 

Although it is proposed that the Economic Support 
Funds (ESF), Foreign Military Financing (FMF), and 
International Military Education and Training (IMET) 
programs will no longer exist, the activities they 
have sustained will continue. The administration 
will instead redraft the Foreign Assistance Act 
according to five policy objectives, and will link 
funding levels to the attainment of these goals:

   -  promoting economic prosperity and development;
   -  building democracy;
   -  promoting peace;
   -  providing emergency humanitarian assistance; 
and
   -  refining the bilateral and multilateral 
negotiating skills of U.S. diplomats.

Arms Transfer Policy
Dr. Davis remarked that the Administration is 
reviewing its conventional arms transfer policy.  
She confirmed the U.S. Government's commitment to 
actively support U.S. manufacturers' efforts to 
increase their exports, saying that State will take 
into account a proposed export's economic 
consequences and effect on the U.S. industrial base.  
Dr. Davis cautioned, however, that support for U.S. 
business must be balanced against other policy 
concerns, such as non-proliferation.

Whither COCOM?
Under Secretary Davis concluded by commenting on the 
future of COCOM.  An institution which formulates 
export controls based on the former East-West divide 
is not consistent with post-Cold War conditions. The 
Administration favors a new institution through 
which responsible supplier nations would address 
dual-use technologies on a world-wide basis, and 
restrain countries engaged in proliferation. The 
United States is participating in sensitive 
negotiations with its COCOM partners on how to 
reorient export controls. 

Working Group Reports
Policy Working Group suggestions for future projects 
include:  initiating a joint DTAG/DOD study on how 
increased U.S. arms exports can strengthen our 
industrial base; developing a foreign availability 
database on specific defense articles and 
technologies to assist the arms export licensing 
process; revising DTAG Chairman William Schneider's 
paper on arms transfer policy; and requesting State 
to organize a briefing on USML exports to and 
imports  from the former Soviet Union.  After 
further discussion, some of these suggestions may be 
incorporated into formal DTAG recommendations to the 
Department.

The Department has completed action on several 
Regulatory Working Group recommendations, including:  
upgrading DTC's Remote On-Line Bulletin Board; 
improving licensing forms; establishing a pilot 
project on the electronic submission of license 
applications; agreeing to establish a State Appeal 
Review Process; and identifying MTCR equipment in 
the ITAR.

The Technical Working Group  made no formal 
recommendations to the Department, but continues to 
examine jet engine hot sections, commercial aircraft 
prior to certification, software source code, and 
encryption.  It is working to develop criteria to 
determine whether specific technologies belong on 
the U.S. Munitions List or the Commodity Control 
List.

Taiwan Briefing
Officers from State's Taiwan Coordination staff and 
Office of Export Control Policy and the Department 
of Defense spoke in closed session on U.S. arms 
transfer policy toward Taiwan.  They noted that our 
policy has resulted in Taiwan being more secure, 
prosperous, and democratic than at any time during 
its history.  U.S. arms sales policy since the 1980s 
has fully met Taiwan's legitimate defensive needs 
while remaining consistent with our commitments 
under the August 1982 communique.  U.S. defense 
firms are in a good position vis-a-vis foreign 
competitors, as U.S. manufacturers have the highest-
quality, most interoperable, and lowest-priced 
equipment to offer. (###)


DTAG-related questions can be directed to Linda Lum 
of the DTAG Secretariat at (202) 647-4231.



Commodity Jurisdiction Determinations
The following chart lists selected recent Commodity 
Jurisdiction (CJ) determinations.  We have described 
the commodities in general terms to ensure the 
confidentiality of proprietary information related 
to individual cases.  Determinations apply only to 
the specific commodities reviewed.  If you believe 
one of your products is similar to one listed here 
as having been placed on the Commerce Department's 
Commerce Control List (CCL)  and wish to have your 
product reviewed, please submit a CJ request letter 
following the guidelines set forth in ITAR 120.4.  
Refer to Defense Trade News articles "Guidelines for 
Preparing CJ Requests" and "CJs for Mass Market 
Software" (Vol. 3, No. 4, Oct 1992) and "Class and 
Multiple CJ Requests" (Vol. 3, No. 1, Jan 1992), or 
call (703) 875-5655 for guidance.  


COMMODITY                            JURISDICTION
Accelerometers
   Specifically Designed or Modified
     for military use                   USML XII(d)
   Not Specifically Designed or 
     Modified for military use                  CCL
Acoustic Charge Transport Devices, Processors, 
   Modules and Development Stations      USML XI(d)
Actuators, Electric Motor Operated Valve, 
   Specifically Designed for Military Use USML VI(b)
Armor, Level IV 
   Aluminum Oxide Ceramic Inserts         USML X(a)
Aerial Targets Specifically 
   Designed for Military Gunnery Training USML IX(a)
Aerial Targets Associated Equipment       USML IX(b)
Aerial Targets Technical Assistance       USML IX(c)
Ammunition Demilitarization System        USML XXI
Antennas Specifically 
   Designed for Military Use              USML XI(d)
Artillery Fuze Part                       USML 
III(b)
Artillery Fuze Part Manufacturing Equipment
                                         USML III(d)
Batteries, Lithium                       USML XI(d)
Braided Textiles
   Specifically Designed, Modified, 
       or Configured for Military Use   USML XIII(d)
   Not Specifically Designed, Modified, or 
       Configured for Military Use          CCL **
Bullet Casting Machines 
   Automated                            USML III(d)
   Non-automated                        CCL 1B96G
Bullet Lubricant                        CCL 1C96G
Bullet Molds 
   Designed, Modified, or Configured for 
       Automated Bullet Casting Machines USML III(d)
   Not Designed, Modified, or Configured for 
Automated
       Bullet Casting Machines              CCL **
Camera, Military Thermal Imaging         USML XII(c)
Camera System, Infrared                 USML XII(c)
Collators 
   Specifically Designed, Modified, or 
       Configured for Bullet Manufacturing   
                                        USML III(d)
   Not Specifically Designed, Modified, or 
       Configured for Bullet Manufacturing
                                          CCL 1B96G
Compasses, Navigation, Specifically Designed 
   for Military Use                     USML XII(f)
Computers , Microcomputers, Monitors, and Keyboards
  That Are Ruggedize
   TEMPEST Models                        USML XI(b)
   Non-TEMPEST Models                        CCL **
Cones, Copper and Molybdenum, 
   Used in Research of Shaped Charge Liners  
                                         USML III(b)
Dies, Lubricating and Sizing            USML III(d)
Document Analyzer, Fraud Investigations   CCL 3A96G
Fire Detection Kit                         CCL **
Flight Loads Recording Systems, 
   Designed for Military Aircraft      USML VIII(j)
GPS Mission Planning Station              CCL 7A94F
GPS Receiver, Miniaturized Airborne       CCL 7A25B
Gyro, Vertical, Specifically Designed for 
   Commercial Use                         CCL 7A94F
Headsets, Specifically Modified for 
   Use with Armored Vehicles              USML X(a)
Intelligence Surveillance System          USML XI(b)
Image Intensifier Tube, Military, 
   Second Generation                      USML Xl(c)
Imaging Equipment, Thermal               USML XII(c)
Metal Matrix Composites Production Process    CCL **
Micro-peripheral Devices, Specifically Designed 
   for Commercial Spacecraft             USML XV(d)
Nuclear Thermal Rocket Engine            USML IV(d)
Oil Filtration Kit, Not Specifically Designed 
   for Military Engines                  CCL 9A94F
PBAN Polymer
Printer, Continuous                      CCL 6A96G
Processor, Single Board Signal           USML XI
Radar, Site Security Surveillance        CCL 6A96G
Radiation-Hardened Components 
   Designed for Military Systems         USML XI(a)
Radioactively-Contaminated Scrap Metals 
   (Depleted Uranium, Beryllium, etc.), 
   Non-Military Recycling, Manufacturing
   Technology for                        CCL **
Radio Controller and Data Modem Not 
   Specifically Designed for Military Application
                                          CCL **
Radio Frequency Target Generator          CCL 6A96G
Receiver, GPS                             CCL **
Receiver HF, Designed for Military Use    USML XI(b)
Receiver System, Wide-band, Not Designed, Modified,
   or Configured for Military Application    CCL **
Reflector Assembly for Communications Antenna
                                          CCL 5A96G
Schottky Rectifier Semiconductors Not Specifically
   Designed for Military Application       CCL 3A96G
Signature Reduction Material          USML XIII(e)
Silicon Carbon-Aluminum Alloy Metal Matrix 
Composites
   Production Process                     CCL **
Silicon Nitride Rolling Contact Bearing Materials,
   Generic                                  CCL **
Software, Electronic Catalog               CCL 5D13A
Software, Employing DES for Data Encryption
                                      USML XIII(b)
Software, Employing DES for Password Encryption
   Object Code                            CCL 5D13A
   Source Code                          USML XIII(b)
Software, Military Communications       USML XI(e)
Software, Simulation and Analytical Modeling
                                        CCL 4D96G
Steel Plate, Not Designed, Modified, or Configured 
   for Use as Armor for Defense Articles    CCL **
Suppressors, Data Line Transient, Not 
   Designed for Military Use              CCL 3A96G
Surge Protection Modules, High-Power
   Specifically Designed, Modified, or 
       Configured for Military Application 
                                          USML XI(d)
   Not Specifically Designed, Modified, or 
       Configured for  Military Application   CCL**
Switch, Automatic Bus Transfer             CCL 8A94F
Tachometer, DC                             CCL 2A96G
Tape Recorders, Remote Sensing Satellite  USML XV(d)
Technical Data Related to AZT               CCL **
Technical Data Related to Equipment Specifically
   Designed to Detect, Analyze, and Jam 
   Communications Signals                USML XI(e)
Technical Data Related to a Mortar        USML I(d)
Technical Data Related to Military Multilevel
    Database Systems                   USML XIII(k)
Telecommunications Switching System
    Limited Access Feature              CCL 5D13A
Television Receiver/Decoder System With No
   Digital Encryption Capability and With the 
   Digital Decryption Limited to Video and 
   Audio Functions                        CCL 5A95F
Test Set for Military Aviation Oxygen Mask
                                         USML X(d)
Vehicle, Remotely Operated, Specifically 
   Designed for Inspecting Nuclear and 
   Hydroelectric Power Plants          CCL 2A50B
Voice Transmitter                      CCL 5A80D
Zirconium
   Zirconium 93, 95, and 97 NRC, App F
   Zirconium Alloy Powder of 
       Particle Size 60 Micrometers or Less 
       Manufactured from Material With a 
       Zirconium Content of 99% or More   USML V(a)
   Zirconium Sponge Compacts              USML *
    Zirconium, Other Forms                CCL **

*    USML category is the same as the item for which 
this part or component was designed.

**  A specific Export Commodity Classification 
Number (ECCN) was not provided by the Department of 
Commerce.  For the ECCN number, please file a 
commodity classification request with the Bureau of 
Export Administration (BXA), Department of Commerce, 
P.O. Box 273, Washington, DC 20044	(###)



Suspensions & Debarments

Eliyahu Cohen, a.k.a. Eli Cohen

On September 26, 1993, Assistant Secretary Robert L. 
Gallucci, Bureau of Political-Military Affairs, 
suspended all existing licenses and other approvals 
(including all activities under manufacturing 
license and technical assistance  agreements), 
granted pursuant to 38 of the Arms Export Control 
Act (AECA), that authorized the export or transfer 
of defense articles or services by, for or to 
Eliyahu Cohen a.k.a. Eli Cohen,  Netanya, Israel;  
A.V.S. Armoured Vehicles Systems Inc. a.k.a. A.V.S. 
Inc., New York;  A.V.S. Armoured Vehicles Spares 
Ltd.  a.k.a. A.V.S. Ltd., Netanya, and any of their 
subsidiaries, associated companies or successor 
entities.

In addition, it shall be the policy of theDepartment 
of State to deny all export license applications and 
other requests for approval involving, directly or 
indirectly, Eliyahu Cohen a.k.a. Eli Cohen; A.V.S. 
Armoured Vehicles Systems, Inc. a.k.a. A.V.S., Inc.; 
A.V.S. Armoured Vehicles Spares Ltd. a.k.a. A.V.S. 
Ltd., and any of their subsidiaries, associated 
companies or successor entities. Also, these persons 
are precluded from using any exemptions from license 
or other approval included in the International 
Traffic in Arms Regulations (ITAR).

Notice of  this suspension  was published in the 
Federal Register (October 13, 1993, Vol. 58, Page 
53015, Public Notice 1887). (###)



PERSONNEL UPDATES

Out...
Marsha Finley (Major, USA), completed her 3-year 
tenure as Managing Editor of  Defense Trade News and 
retired from the Army in November 1993. 

Foreign Service Officer Charles A. Ray, formerly 
Special Assistant to the Director of DTC and 
Executive Editor of Defense Trade News, is now 
Deputy Chief of Mission at U.S. Embassy Freetown, 
Sierra Leone. 

Martin "Tex" Maier (Major, USAF) after completing a 
2-year tour as a DTC licensing officer,  moving to a 
similar position at USAF.

DTC licensing officer Sue Plant departed in November 
to join her husband who will be employed in the US 
Embassy in Bonn.

In...
Philip S. Kosnett joined DTC in July, 1993 as 
Special Assistant to the Director and Executive 
Editor of Defense Trade News.  A Foreign Service 
Officer, he has served in    Ankara, Turkey; Nagoya, 
Japan; and State's  Bureau of Intelligence and 
Research.

Christopher R. Elder  joined DTC's new Research and 
Analysis Branch in March, 1993 as a Compliance 
Specialist. He previously handled Commodity 
Jurisdictions in the  Arms Licensing Division. 

Robert Huffman also joined DTC 's Research and 
Analysis Branch  in March 1993 as a Compliance 
Specialist.  He has worked for DTC since October 
1991, when he started as a clerk in the Compliance 
Analysis Division.

The Office of Export Control Policy  (formerly the 
Office of Defense Trade Policy) welcomed a new 
director and four officers:

William P. Pope assumed direction of EXP in August, 
after a tour as Deputy Political Counselor at U.S. 
Embassy Pretoria, South Africa.  A member of the 
Senior Foreign Service, he has served in Paris;  
Belgrade; Zagreb; and Gaborone, Botswana.  In 
Washington, he has served in the Legislative 
Affairs, Near Eastern Affairs, African Affairs, and 
Intelligence and Research bureaus.  

Paul S. Aronsohn handles industry outreach and 
intergovernmental issues. Before coming to  State, 
he worked in the White House Communications Office. 
During the Clinton Administration transition he 
served as a liaison to the Commerce Department's 
Bureau of Export Administration.

John C. Clarkson is responsible for the Western 
Europe, NATO and United Nations Arms Register 
portfolios. A Foreign Service Officer,  he has 
completed tours in Helsinki, Finland; Damascus, 
Syria; and Kingston, Jamaica. He has also served in 
State's Bureau of Economic and Business Affairs.

Foreign Service Officer Julie L. Kavanagh covers 
East Asia and represents the Bureau of Political-
Military Affairs on the Committee on Foreign 
Investment in the U.S. She has served in Rio de 
Janeiro, Brazil and Montevideo, Uruguay.

Jeffry R. Olesen, also a Foreign Service Officer, is 
responsible for the Middle East and South Asia. He 
has served in Guadalajara, Mexico; Abu Dhabi, United 
Arab Emirates; and Lahore, Pakistan. (###)


TIPS AND TIDBITS

'NATO' Not Enough
The use of the word 'NATO' as the ultimate 
destination is not adequate identification for 
multiple countries on a license application. When 
completing Block 3 on the DSP-5, block 4 on the DSP-
73, or block 4 on the DSP-85, please list each 
country separately.

Are Your Suppliers Registered? 
Exporters should request manufacturers  from which 
they purchase defense articles to confirm that they 
are registered with the    Office of Defense Trade 
Controls.  Checking this before submitting an 
application can help to avoid processing delays.

Recognizing Carbonless Forms
Remember that  the newly revised DSP application 
forms are printed on carbonless paper.  Please do 
not insert carbon paper between the pages when 
completing the forms.  How to recognize the new 
forms:

    -- There is no short carbon interleaf at the 
top;  
    -- The numbers 11-92  appear under the word 
"Form" at the bottom left;
    -- An expiration date of 12-31-95 or 3-31- 96 
appears at the bottom right corner; and 
    -- The  ITAR 126.13 certification and 130 
statement are on the back of copy 1 of the form. 

New Forms - No More 126.13 and 130 Letters
It is not necessary to submit a separate 126.13 or 
130 letter with the new forms.  Simply have an 
empowered official sign the front of the form, and 
check the appropriate boxes on the back of copy 1.

Rounding Off Dollar Values
License applicants are encouraged to include only 
whole dollar values when completing  applications.  
Please round off cents to the nearest dollar.  For 
example, enter $100.45 as $100.  Round $100.50 up to 
$101. This will simplify processing and reduce the 
potential for processing errors. 

Did I Miss Defense Trade News Volume 4, Number 4?
We didn't publish one.  In 1993 we published two 
issues: "Volume 4, Numbers 1 & 2" dated  
January/April, and "Volume 4, Number 3" dated July.  
We plan four quarterly issues for 1994. (###)


FEEDBACK

Please circle or fill in your responses,  add any 
comments, and fax it to (703) 875-6647.
1. Your organization is a...
     1.  Manufacturer
     2.  Exporter
     3.  Consulting or law firm
     4.  Freight Forwarder
     5.  U.S. Embassy or Consulate
     6.  U.S. Customs element
     7.  U.S. DOD/Military element
     8.  Other U.S. Government element
     9.  Foreign government element
     10. Other (please explain in Comments) 
2. How many people will read this issue?
     1.  1 person
     2.  2-5 people 
     3.  6-10 people
     4.  11+ people 
3-14. Please rate the usefulness of each article  on 
a scale of 1 (worst) to 5 (best). Rate as "0" any 
articles you did not read.
     3.   White House Statement ___
     4.   The  Export Control Agenda___
     5.   Fine-Tuning the ITAR___
     6.   Don't Just Carp; Turn to SARP___
     7.   DTSA's Role___
     8.   ELLIE Comes on Line___
     9.   Tiger Team___
     10.  DTAG Developments___
     11.  Commodity Jurisdiction ___
     12.  Suspensions & Debarments___
     13.  Personnel Updates___
     14.  Tips & Tidbits___
15-26.  Please rate each article's readability 
(style and physical presentation) on a scale of 1 
(worst) to 5 (best); rate as "0" articles you did 
not read.
     15.  White House Statement___
     16.  The Export Control Agenda____
     17.  Fine-Tuning the ITAR___
     18.  Don't Just Carp; Turn to SARP___
     19.  DTSA's Role___
     20.  ELLIE Comes on Line___
     21.  Tiger Team___
     22.  DTAG Developments___
     23.  Commodity Jurisdiction___
     24.  Suspensions & Debarments___
     25.  Personnel Updates___
     26.  Tips & Tidbits___
27-29. Please circle the numbers of the three topics 
you would most like to see covered in the magazine.
     1.  Defense trade policy
     2.  Non-defense trade policy
     3.  Country-specific trade issues
     4.  Trade legislation
     5.  Licensing procedures
     6.  Regulatory and legal issues
     7.  Licensing case studies
     8.  Compliance case studies
     9.  Other (please explain in Comments)
30. This magazine is provided to DTC registrants and 
others free of charge.  If we were to change to a 
paid subscription basis (at  c. $20/year), how would 
your organization react?
     1.  We would pay for one subscription.
     2.  We would pay for more than one  
subscription.
     3.  We would not pay to subscribe.
     4.  Don't know.
Comments: 
____________________________________
____________________________________
____________________________________
We welcome lengthier comments, suggestions, and 
criticism.  (###)




Contacting the Office of Defense Trade Controls

Postal Address
Office of Defense Trade Controls
Bureau of Political-Military Affairs
PM/DTC, SA-6,  Room 200
U.S. Department of State
Washington, D.C.  20522-0602

Express Mail/Courier Delivery Address
Office of Defense Trade Controls 
Bureau of Political-Military Affairs
PM/DTC, Room 200
U.S. Department of State
1701 N. Fort Myer Drive (Nash St. Entrance)
Arlington, VA  22209-3113

Fax  Numbers
Director; Licensing Division; Defense Trade News: 
(703) 875-6647
Compliance Division;info on ROBB or ELLIE: (703) 
875-5663

General Telephone Numbers
General Information:  (703) 875-6644
Office Director & Deputies:  (703) 875-7050
Defense Trade News: (703) 875-5671
Licensing Division:(703) 875-6644 
Registration/Compliance:  (703) 875-6650
Commodity Jurisdiction:  (703) 875-5655

Status Inquiry Telephone Numbers
General Status Inquiries:  (703) 875-6652 
Congressional Case Status:  (703) 875-6641
Automated License Status System:  (703) 875-7374
Remote On-Line Bulletin Board:  (703) 875-6650



Contacting the Deputy Assistant Secretary for Export 
Controls
Deputy Assistant Secretary for Export Controls
Bureau of Political-Military Affairs
PM, Room 7325A 
U.S. Department of State
Washington, D.C.  20520-7325


Contacting the Office of Export Control Policy
Office of Export Control Policy
Bureau of Political-Military Affairs
PM/EXP, Room 2242
U.S. Department of State
Washington, D.C.  20520-2242
Telephone  (202) 647-4231
Fax  (202) 647-4232

(###)
END OF VOL 5, NO 1

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