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Material Changes and PM/DTC Registration

News & Blog

Wilmarth and Associates - Taking Notes

If there is a material change to information submitted as part of your State Department registration application (on your DS-2032), you are required to submit the proper notification to DDTC. Material changes include changes in subsidiaries/affiliates, changes in senior officers, or change in address of the company (note: this list is not exhaustive). DDTC must be notified of all material changes within 5 days of the effective change. The notice must be signed by the senior officer who signs the DS-2032 and mailed to DDTC.


If a State Department registered company/subsidiary is being sold to a foreign company or person, a 60 day pre-notification is required to be mailed to DDTC before the transfer takes place. This requirement is in addition to the voluntary CFIUS filing that companies are asked to make when they are acquired by a foreign company or person. (note: CFIUS filings may not be warranted for all transactions.)


If your company is no longer going to involved in the manufacture, export or brokering of ITAR items and you are going to let your registration expire, a 30 notice is required to be sent to DDTC.

This Blog is made available by Wilmarth & Associates for educational purposes as well as to give you general information and a general understanding of export law and compliance, not to provide specific legal advice. This blog is not legal advice and should not be treated as such. You must not rely on this blog as an alternative to legal advice from your attorney or other professional legal services provider. The information provided on this website is presented “as is” without any representations or warranties, express or implied.
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