As of May 1, the State Department has made a temporary change in the Tier I, Tier II, and new registrant payment guidelines on the Directorate of Defense Trade Controls (“DDTC“) website to reflect certain reduced registration fees to mitigate the economic impact of the COVID-19 pandemic.

The DDTC is reducing fees for Tier I and Tier II registrants to $500 (reduced from $2,250 and $2,750, respectively) for registrations whose original expiration date is between May 31, 2020 and April 30, 2021. DDTC is also reducing registration fees to $500 (reduced from $2,250) for new applicants who submit their registration application between May 1, 2020 and April 30, 2021.  The fee structure for Tier III registrants remains unchanged.  

These reductions will apply through April 30, 2021, unless modified by a subsequent notification in the Federal Register. The reduction in these fees comes shortly after the DDTC issued measures, including some related to compliance and licensing, in response to the COVID-19 pandemic. Our blog post on those recent changes can be found here.  The DDTC estimates that these registration fee reductions will save regulated industry over $20 million over the coming year.

The authors acknowledge the assistance of Ryan Orange in the preparation of this blog post.

Author

Ms Stafford Powell advises on all aspects of outbound trade compliance, including compliance planning, risk assessments, licensing, regulatory interpretations, voluntary disclosures, enforcement actions, internal investigations and audits, mergers and acquisitions and other cross-border activities. She develops compliance training, codes of conduct, compliance procedures and policies. She has particular experience in the financial services, technology/IT services, travel/hospitality, telecommunications, and manufacturing sectors.

Author

Inessa is an associate in Baker McKenzie’s Washington, D.C. office, focused on international trade compliance. She advises clients on US export controls and international trade sanctions, including those targeting Cuba, Iran, North Korea, Syria, and Russia. Inessa also provides sanctions compliance advice in the context of cross-border transactions, including mergers and acquisitions, financings, and distribution agreements.