Inter-Agency Process

Review Process

  Once an application enters the electronic submittal system at the Department of State (called D-Trade) it is then assigned to a licensing officer. That licensing officer reviews the application to ensure it is complete and contains all required documentation — if it is not complete the licensing officer Returns Without Action (RWA) the application and the applicant must start over, being sure to correct the previous errors. Your export expert should know what to do if an application is RWA'd. It is required that you reference the rejected application in the resubmittal, explaining that you have corrected the previous errors and providing the RWA number for the licensing officer to reference.

If the licensing officer determines that the application is complete, based on the purpose of the application, it is sent to multiple agency desks. An application may go to the human rights desk at State Department, or a branch of the U.S. Military. It will go for technical reviews and pass through Foreign Policy Analysts hands prior to being returned to the licensing officer. Each of these desks has the opportunity to add their comments and approval or disapproval to the application. These comments are in the form of Provisos — or special conditions levied upon an approval. When all of the internal agencies have reviewed and approved an application and included their comments, they are returned to the licensing officer who puts all the comments together and issues the authorization. Not all applications will be required to be cleared through multiple desks. The general rule of thumb is the more complex your application, the more sensitive the request or the value of your application will be deciding factors on what other agencies will want to review your application.