ITAR Brokering Registration Regulations and Compliance

Under the International Traffic in Arms Regulations (ITAR) implemented and enforced by the Directorate of Defense Trade Controls (DDTC) of the Department of State, “brokers” of defense articles and defense services are required to register with and obtain the approval of the DDTC prior to engaging in the business of brokering.


If you are not a broker of covered munitions or defense services, then you are not required to register as a broker or obtain approval.  For a current list of covered munitions and defense services, use the United States Munitions List as a reference (section 121.1 of the ITAR).


So, who qualifies as a broker, and is therefore subject to the registration and compliance requirements of the ITAR?


According to sections 129.2(a) and 129.2(b) of the ITAR, a “broker” is any person who engages in the business of brokering activities, which involves actions taken on behalf of another to facilitate the manufacture, export, permanent import, transfer, re-export, or re-transfer of a US or foreign defense article or defense service.  This definition covers a wide variety of activities, from financing, insurance, and transportation of covered articles and services, to promotion, negotiation, and general assistance with the contract.

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