Review the terms and conditions of approval. Then review the Provisos that are returned with your application. You must comply with those Provisos. Occasionally an application will have so many Provisos that it is rendered almost useless, or there are Provisos that simply do not make sense or apply to the activity your organization requested for approval. Sometimes a Proviso may be a deal breaker for your contract, or something that your organization cannot possibly comply with. If that is the case your compliance professional will help you submit a Reclama or Proviso Reconsideration Request to the DTC. This Reclama will take as much time to process as an application — and you still might not get any relief. However, that is your only option.
Ultimately your organization must review the requirements of the ITAR (or EAR), understand your recordkeeping obligations, follow the terms and conditions of issue of your application and adhere to the Provisos word for word in order for your application to be considered valid. A failure to do any of the above will negate the approval and you will be in violation of the Arms Export Control Act — a place that is never good for any organization.
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