Following merger, acquisition or divestiture, all material changes must be submitted to DDTC within five days after the effective date. DDTC strongly recommends that you make your 5-day MAD material changes directly in DECCS Registration and attach your 5-day MAD material change notification letter as part of the submission. Failure to submit 5-day MAD material changes directly in DECCS and attaching your 5-day MAD material change notification letter will cause significant delays in review and completion of your MAD material change request.
Registered entities involved in mergers, acquisitions or divestitures which result in a foreign (i.e., non-US) person owning or controlling a registrant “or any entity thereof” are required to notify DDTC 60-days in advance of any intended sale or transfer.
Non-MAD changes (address change, change in officers, new USML Category.) may not require the notification letter but must be submitted to DDTC through an amendment to your registration within 5-days of the change. If you attempt to make the change during renewal, the application may be Returned Without Action at which time you will be directed to make the change through an amendment and to submit the renewal once the amendment has been completed. This may delay the renewal and place any scheduled shipments against a license in jeopardy.
Please contact our office if you require assistance with MAD changes or amending your registration.
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.
