Inter-Agency Process

Processing Time

  In addition to reviews by multiple desks, applications can run into a host of other snags that cause delays in approval.

The Department of Trade Controls (DTC) is the branch of the State Department that reviews applications and frequently becomes bogged down in the bureaucracy of their own internal review processes and the shear number of applications that are submitted by the defense industry each year. DTC literally processes thousands of applications a year and each must go through the same vigorous review process.

Many times the staffing positions for licensing officers are not filled to capacity; the office has a high turn over rate. There may be administrative problems with the application, for instance the electronic licensing system may crash.

The U.S. may change Foreign Policy in-between the time your application was submitted and processed for approval. Sometimes the Provisos — or special conditions of an authorization are classified and it must work through the classified world regulations as well.

The U.S. Government may contact the Foreign Government in your application and ask for its own assurances on the request you are making. There may be inter-agency rivalries as to what levels of technology or services may be authorized; occasionally when these agencies disagree they have to go to the President of the United States to get resolution. Presidential resolution takes a long time to achieve and is not something an organization has any insight into, nor any influence to move it along faster.

Your application may require Congressional Notification or be held while a new policy is being put in place. The point is that your application is totally out of your hands once it is submitted and there is little that your organization can do to move it along faster. The temptation to contact your local Congressman or a lobbyist to help push your application at the Dept of State faster should be resisted. It may seem like a great idea to call special attention to your application and attempt to force State Department to work faster. This often blows up in an organization's face and becomes the source of long delays — on all applications as the licensing officers move your applications to the bottom of their stacks. Understand they are working as fast as they can — their job performance is tied to the metrics on how fast they get approvals completed — they are not dragging their feet because it affects their own personal bottom line.