DDTC publishes clarification on expedited registration requirement for Ukraine exports

The US Directorate of Defense Trade Controls (‘DDTC’) has published an FAQ relating to the export of ITAR goods to Ukraine:’

Q: ‘How can I expedite my registration application to export, reexport, or retransfer ITAR-controlled defense articles to Ukraine as quickly as possible?’

A: ‘Requirements to export, reexport, or retransfer defense articles described on the U.S. Munitions List (USML) to Ukraine remain the same as before Russia’s full-scale invasion.’ This includes the requirement to register with the Directorate of Defense Trade Controls (DDTC) as an exporter.’ DDTC is working closely with numerous stakeholders, including international partners, the defense industry, non-governmental organizations, and other U.S. government agencies to expedite the process as appropriate for Ukraine-related exports, reexports, and retransfers.

‘Registration takes 40-45 days on average, but DDTC’s Registration, Compliance, and Analysis Division is making every effort to prioritize and expedite registrations related to Ukraine.’ Applicants should clearly establish that their application is Ukraine-related by submitting a letter attached to the application indicating that the registration is related to Ukraine.’ Applicants should also include the word “UKRAINE” in the title of this attachment.’

It adds that would-be exporters should note that the DDTC is ‘working hard to prioritize submissions related to Ukraine [but] cannot guarantee any specific processing timeframe,’ and that, ‘Part of DDTC’s review involves considering whether the applicant has experience in defense trade and can appropriately protect U.S. origin defense articles from unauthorized diversion or misuse. This review can vary in terms of processing time, depending on the circumstances of the case.’