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COMSTAC : EXPORT CONTROLS WORKING GROUP May 2010. Recent Developments. For Singles!. Single Control List Single Primary Coordination Agency Single IT System Single Licensing Agency. Phase I (Congress, what Congress?). Refine, Harmonize, Understand the Lists Streamline Licensing
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For Singles! • Single Control List • Single Primary Coordination Agency • Single IT System • Single Licensing Agency
Phase I(Congress, what Congress?) • Refine, Harmonize, Understand the Lists • Streamline Licensing • Synchronize and De-Conflict by Creating an ‘Enforcement Fusion Center’ • Establish a Single IT Point of Entry
Phase II(Congressional Notification Required) • Control List Restructuring into Identical Tiered Structures • Revise Licensing Accordingly • Enforcement- Expand Outreach and Compliance
Phase III(Congressional Legislation Required) • Control List- Merge the two lists into a single list • Licensing- Implement Single Licensing Agency • IT- Single IT System
Recommendation #1 The COMSTAC supports the White House’s ‘four singles’ approach, which would create a single coordinating agency, a single list, a single licensing agency, and a single IT system. Moreover, we would urge the substantive review of the single list contemplated by the current reform effort so that there is greater clarity and more focused analysis of what technologies should or should not be included Yes We Can!!
Recommendation #2 In the process of establishing a single list, the COMSTAC supports ensuring the list creates substantive reform by limiting or eliminating the licensing process for low-sensitivity items and services, and that a review process continues on an ongoing basis to keep pace with the evolution of technology and its commercial availability.
Recommendation #3 As the export control review process proceeds, the COMSTAC would like to express its desire to serve as an ongoing resource by providing its unique industry perspective relative to the commercial space sector.
Unconstitutional ITAR • Prior Restraint on Free Speech • Too broad, not sufficiently narrowly tailored for its purpose • Does not protect a significant governmental interest • No hard deadlines • No expeditious judicial review
