Industry News: Volume 2, Number 3


New Requirements for Commodity Jurisdiction Requests
The U.S. Department of State’s Directorate of Defense Trade Controls (State/DDTC) has posted a message on its website that effective immediately and until further notice, all commodity jurisdiction (CJ) requests must be mailed to DDTC.  Further, the requests must include eight complete copies of a fully-executed DS-4076 CJ Form and all supporting documentation.  Additional information may be found online at

Electronic Submission of Agreements
The U.S. Department of State’s Directorate of Defense Trade Controls (State/DDTC) has posted additional guidance on its website regarding the submission of Manufacturing License Agreement and Technical Assistance Agreement applications via D-Trade.  Additional information may be found online at:

ITT Debarment Lifted Two Months Early
The Directorate of Defense Trade Controls (“DDTC) published a notice in the Federal Register that effective February 4, 2010 the three-year statutory debarment of ITT Night Vision was terminated.  The debarment was scheduled to expire on March 26, 2010.  DDTC noted that “ITT Corporation has taken appropriate steps to address the causes of the violations and to mitigate any law enforcement concerns.”

The termination of the debarment means that a request for an exception to the debarment is no longer required when exporting ITT products from the United States.  A copy of the Federal Register notice may be found online at:

President Obama Hints at Export Reforms
On March 11, 2010, President Obama hinted at specific reforms to export controls.  A specific comment regarding dual nationals was of particular interest: “And second, we’re going to eliminate unnecessary obstacles for exporting products to companies with dual-national and third-country-national employees.  Currently, our exporters and foreign consumers of these goods have to comply with two different, conflicting set of standards.  They’re running on two tracks, when they could be running just on one.  So we’re moving towards harmonizing those standards.”

President Obama is referring to a conflict between the State Department and the Commerce Department on “deemed exports.”  Under the deemed export rules, exports of technology are deemed to be exports to the country of which the recipient is considered a national.

Under Commerce’s deemed export rules, an export to a foreigner with multiple citizenships or countries of permanent residencies is considered an export to the country of the most recently acquired citizenship or permanent residency.  Under State Department rules, the export is considered to be an export to each of the countries — with the most restrictive licensing policy applied.  Hopefully, the rules will be construed in favor of the more lenient Commerce Department rules.  Text of the President’s speech may be found online at:

Finns Propose Ban on Handguns
A Finnish government commission proposed a ban on semiautomatic handguns after two school shootings in recent years left 20 people dead.  The ban would require parliamentary approval.

Currently, Finland ranks among the world’s top five countries in civilian gun ownership, after the United States, Yemen, Switzerland and Serbia.  “We’ve had a very weapon-friendly culture,” commission chairman Pekka Sauri said.  “In carrying out the proposals we would, of course, pay compensation to anyone who turns in weapons.”  The Nordic nation of 5.3 million has 650,000 licensed gun owners.  Of some 250,000 handguns, more than 200,000 are semiautomatic, according to Sauri.

The commission also said that the minimum age of handgun ownership should be raised from 15 to 20 and that gun permits be made temporary and require at least two years proof of shooting practice.

U.S. Imports Up 31 Percent in 2009
The National Shooting Sport Foundation reports that U.S. imports of sporting arms and ammunition were up 31 percent in 2009 to $1.28 billion, compared to $974 million the previous year.  Imports of handguns were up 53 percent, while imports of ammunition increased 40 percent during 2009.  In the fourth quarter, imports of all sporting arms and ammunition increased 22.3 percent compared to the same period in 2008.

ATK Awarded Additional $41 Million to Deliver Non-Standard Ammunition (NSA) for Afghan Security Forces
Alliant Techsystems (NYSE: ATK) has received a $41 million contract modification to supply additional non-standard (non-NATO) ammunition to the Afghan Security Forces (ASF), under an existing three-year contract with the U.S. Army.

Under the contract awarded to ATK in 2009 by the U.S. Army Contracting Command in Rock Island, Ill., ATK provides supply chain management, quality assurance and logistical expertise in the delivery of non-standard small, medium and large caliber ammunition, as well as mortars and rockets, to Kabul for use by the Afghan security forces.