Comments on: DDTC Chief: “D-Trade is De-Lovely” http://www.exportlawblog.com/archives/23 Latest News on DDTC, BIS, OFAC, and other export law matters Sun, 12 Oct 2008 00:23:45 +0000 http://wordpress.org/?v=2.5.1 By: Paul Lauper Ellison, Esq. http://www.exportlawblog.com/archives/23#comment-18 Paul Lauper Ellison, Esq. Mon, 02 Oct 2006 21:33:57 +0000 http://www.exportlawblog.com/archives/23#comment-18 Just as important as your criticism of the DDTC's D-Trade "happy talk" is that fact that the D-Trade problems will get significantly worse and soon. D-Trade will be "mandatory" on October 12. DDTC will shut down the manageable ELLIE and ROBB licensing systems. While this does leave two routes, D-Trade and paper-based forms, the paper-based is not an option because it will become even slower process. At a D-Trade training meeting, the Licensing Officer threatened that the paper-based forms would wait for administrative staff to entered them by hand. An additional burden will be placed on D-Trade when Agreements are added to the system. "Turk" insisted that Agreements capabilities would be added to D-Trade "by the first of the year." While this seems unreasonable, considering that they will still be dealing with the problems created by the October 12th mandate, it is possible that the "heedlessly forge ahead" mentality will still hold sway at DDTC. Maybe, just maybe, these things will make it bad enough that DDTC will begin asking themselves questions, questions that industry has been answering with shouts. Just as important as your criticism of the DDTC’s D-Trade “happy talk” is that fact that the D-Trade problems will get significantly worse and soon. D-Trade will be “mandatory” on October 12. DDTC will shut down the manageable ELLIE and ROBB licensing systems. While this does leave two routes, D-Trade and paper-based forms, the paper-based is not an option because it will become even slower process. At a D-Trade training meeting, the Licensing Officer threatened that the paper-based forms would wait for administrative staff to entered them by hand.

An additional burden will be placed on D-Trade when Agreements are added to the system. “Turk” insisted that Agreements capabilities would be added to D-Trade “by the first of the year.” While this seems unreasonable, considering that they will still be dealing with the problems created by the October 12th mandate, it is possible that the “heedlessly forge ahead” mentality will still hold sway at DDTC.

Maybe, just maybe, these things will make it bad enough that DDTC will begin asking themselves questions, questions that industry has been answering with shouts.

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