December 2016
Companies opting to file voluntary disclosures of potential export violations with the State Department’s Directorate of Defense Trade Controls (DDTC) will soon be required to utilize a new process for submitting their disclosures: filing new Forms DS-7787 and supporting documentation in the online Defense Export Control Compliance System (DECCS). This new process will be a sharp departure from the way in which companies have historically approached disclosures, in which they filed detailed, narrative submissions in hardcopy with the DDTC.  

On November 28th, the Department of State published a Federal Register notice soliciting comments from the public regarding the proposed rollout of the new Form DS-7787 for the submission of voluntary disclosures of violations of the Arms Export Control Act and International Traffic in Arms Regulations. Public comments may be submitted on or before December 28, 2016. See 81 Federal Register 85668 (November 28, 2016).

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