Broker Registration Renewal and Reporting
Once a broker has been registered, there are numerous additional requirements in order to maintain their status as a registered broker.
Material Changes Must Be Reported
When there have been changes to the circumstances such that the registration is materially affected (the details of brokering activity have changed) then the DDTC will have to be notified of the changes in order for a broker’s registration status to be maintained.
If it’s a US broker, then notice must be given within 5 days of the material change in circumstances. If it’s a foreign broker, then notice must be given within 60 days of the material change in circumstances.
“Material” changes typically include, but are not limited to, changes in eligibility status (due to citizenship changes, employment status changes, etc.), name, location info, hierarchical changes in firm structure, changes in the defense articles exported and services rendered, and more.
Annual Reporting is Required
Registered brokers are required to provide an annual brokering activity report to the DDTC. The annual report must include detailed information on brokering activities (such as the dollar value, quantity, category, type, and more).
An annual report is due even if the broker has not been engaged in brokering activities during the previous year.
Annual Registration is Required
In addition to annual reporting, brokers are required to annually renew their registration by filing a statement of registration between 30-60 days before expiration date. Both the renewal registration and the annual brokering activity report are due in the same month. Failure to file a statement of registration (to renew) will result in the suspension of registration status.
Under the ITAR, brokers must follow strict guidelines to ensure that they can engage in brokering activity for defense articles and services. Depending on the circumstances, a broker will have to register and obtain approval from the DDTC, or may qualify for an exemption.
Posted on October 7th, 2016 by admin
Filed under: ITAR