Standard Licensing

Other Licensing Hurdles

  There are several other factors that may affect your license processing times. If your equipment is considered Significant Military Equipment (SME) there will be extra scrutiny on whether or not the transaction will be allowed to occur.

Additional requirements involve the need for prior notification or prior approval to make a proposal. Some proposals of high dollar values that contain SME equipment require an authorization from the Department of State before you may even discuss the product with a foreign customer — you must obtain this approval (which generally takes 30 days) before any discussions begin. Failure to do so will result in a violation. Sometimes the State Department simply requests prior notification of the intent to make a proposal — again, this adds 30 days into the process. You cannot apply for a license application for certain hardware or services without first establishing the prior approval/notification. Your compliance professional will know when this must be done and when the requirement can be waived, however you must communicate your business intentions to them prior to actually moving forward to avoid committing a violation. We will review the requirements for 126.8 in the next few slides.

Finally high dollar sales of equipment or services to certain countries will require Congressional Notification. We will discuss the requirements of Congressional Notification in the next several slides.