brokering registration and licensing 22 cfr 129 l.
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BROKERING REGISTRATION AND LICENSING (22 CFR 129). DTAG BROKERING WORKING GROUP May 3, 2005. WORKING GROUP. David Ashby Ginger Carney Giovanna Cinelli Rich Gogolkiewicz Mona Hazera David Isenberg Chuck Jameson (Chair) Joel Johnson Peter Jordan Dennis Kennelly John Liebman

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brokering registration and licensing 22 cfr 129

BROKERING REGISTRATION AND LICENSING(22 CFR 129)

DTAG BROKERING WORKING GROUP

May 3, 2005

working group
WORKING GROUP
  • David Ashby
  • Ginger Carney
  • Giovanna Cinelli
  • Rich Gogolkiewicz
  • Mona Hazera
  • David Isenberg
  • Chuck Jameson (Chair)
  • Joel Johnson
  • Peter Jordan
  • Dennis Kennelly
  • John Liebman
  • Joe Mariani
  • Ed O’Connor
  • Terry Otis
  • Suzanne Palmer
  • Mike Richey
  • Ken Williamson
slide3
BACKGROUND
  • Intent of Part 129.
  • Limited legislative history and statutory guidance.
  • Multiple interpretations
slide4
APRIL 25TH MEETING WITH DDTC OFFICIALS
  • Purpose:
    • To gain an understanding of DDTC’s regulatory objectives as part of fact gathering.
    • To set an agenda to begin a constructive dialogue aimed at achieving those objectives while minimizing potential collateral damage to legitimate U.S. defense export initiatives.
slide5
TOPICS OF DISCUSSION:
  • Intent of ITAR Part 129
  • Definition of “brokering activities”
  • Criteria for classifying an entity as a “broker”
  • Licensing brokering activities
  • DDTC’s process for adjudication and licensing
slide6
STATUS:
    • DTAG will provide to DDTC a list defining the spectrum of activities commonly performed by consultants, commissioned sales reps, etc. The list will range from routine business assistance activities to activities that are clearly brokering.
    • DDTC will examine whether entities registered as brokers and identified as such in export applications need to obtain separate authorizations from DDTC.
    • DTAG intends to continue working with DDTC on brokering issues, including process standardization and consistency of interpretation.