May

6

Bad Applicants! You’re All Getting Detention!!

Posted by at 11:32 pm on May 6, 2010
Category: DDTC

Bad, Bad, Bad!The Directorate of Defense Trade Controls (“DDTC”), the State Department agency responsible for licensing exports of defense articles, has issued new guidance to scold export license applicants for not using precise names legal names in license applications. Like confusing “that” for “which” and vice versa, minor name inaccuracies begin the legendary slide down the even more legendary slippery slope that winds up in terrorists being able to mail nuclear bombs from Des Moines to Pakistan by simply dropping the bombs in the corner mailbox with the correct postage.

An applicant must ensure the correct spelling is used when entering the legal business name(s) of any involved party. … Failure to adhere to these guidelines may result in a delay in review of a license application or a return without action (RWA).

Because if the intermediate consignee is listed as FeddEx rather than FedEx, DDTC’s licensing staff will be completely confused and will have no choice but to return the application or to delay it a few weeks while figuring out whether there really is a FeddEx or not.

Even more importantly we have the national security threat of names without middle initials.

When completing any online license application and an individual’s name is required, the middle name or initial should be provided.

For those who are inclined to scoff at this school-marmishness, let me point out the unstated goal behind this emphasis on disclosing middle initials. While most American’s have middle names, that is quite uncommon in the case of Arabic names, so the absence of a middle initial can be a good marker that a potential terrorist might be involved in an export application.

Seriously, the new guidance might have been more helpful if it dealt with the middle-named-challenged in the same way as these tips from DDTC on filling out DDTC’s Form DS-2032 for registration of manufacturers and brokers:

If no middle initial, enter “N/A.”

So if you’re wondering how to get permission for America’s first president, who had no middle name, to export a defense article, just list the applicant as “George N/A Washington.” I like the sound of that, don’t you? And it has the added advantage of keeping us all safer.

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Copyright © 2010 Clif Burns. All Rights Reserved.
(No republication, syndication or use permitted without my consent.)

2 Comments:

Good one relative to General Washington. We also have to remember that in his day, the pre-revolutionary government considered the colonial uprising to be “terrorist” inspired. Just think, had these rules been formulated in the eigthteenth century, George might not have been able to order supplies since the documentation would not have shown a middle initial. We could all still be drinking tea.

Comment by Doug Munro on May 7th, 2010 @ 9:20 am

I must confess I had a DSP-5 rejected. My sin was spelling out the word “corporation” in the name of our company. Per the help desk their software does not allow for anything other than an exact match to the name as it appears on the registration.

If indeed the idea is to use a middle initial or name because they’re uncommon in Arabic, and given corporation confuses the software, how are they going to account for the many different ways of spelling a name when it’s translated from Arabic?

In an earlier post you asked if we like D-Trade or SNAP-R better. I’ve got to vote for SNAP-R.

Comment by LDM on May 7th, 2010 @ 6:03 pm