Recommendations for Modernizing Export Controls on Munitions List Items
The United States currently faces unprecedented threats to its security both at home and abroad. In confronting these threats, we must be able to exploit the full advantage we derive from our economic strength and technological prowess. To that end, the U.S. export control system must be modernized so that it is better able to respond quickly and effectively to evolving security threats, and promote our nation’s continued economic and technological leadership. The Coalition for Security and Competitiveness, representing multiple industry and trade associations, is committed to working with the Executive Branch and Congress in a cooperative spirit to accomplish these important goals.
To modernize the system and make it more efficient, predictable and transparent, the Coalition has developed the following eleven recommendations on export controls for munitions list items.
- State strategic policy principles for defense and technology trade and cooperation
- Appoint a senior director at the NSC responsible for defense trade, export policy and technology cooperation
- Create a presidential advisory body on defense trade and security cooperation
- Re-program funds for the Directorate of Defense Trade Controls (DDTC) to add a sufficient number of officers for agreements, licenses and commodity jurisdiction evaluations
- Ensure accurate interpretation and consistent use of International Traffic in Arms Regulations (ITAR) that govern the commodity jurisdiction process
- Keep items, particularly FAA-certified equipment, on the Commerce Control List (CCL) until after a final commodity jurisdiction determination is made
- Implement more efficient, effective, and transparent licensing procedures and technology disclosure review processes
- Establish a quarterly interagency appeals process (at the political appointee level) for decisions on critical jurisdiction and licensing applications
- Provide industry "intent to deny" and "intent to Return Without Action" feedback before such decisions are finalized
- Accelerate implementation of a more robust electronic system for processing and tracking license applications, including licenses that require congressional notification
- Require license and agreement processing to follow reasonable and predictable metrics
A more detailed description of the Coalition's concerns and proposals for action is provided in the attached recommendations. Additional recommendations for modernizing export controls on dual-use items, as well as other information on the Coalition, can be found on www.securityandcompetitiveness.org.