Wednesday, October 1, 2008

New: Mandatory SNAP-R Filing

The Bureau of Industry and Security (BIS) issued a final rule requiring all export and reexport license applications, classification requests, encryption review requests, license exception notifications, and related documents be submitted via its automated Simplified Network Application Process (SNAP-R). Exemptions to the rule include Special Comprehensive Licenses (SCL) and certain situations authorized by BIS. Currently, members of the public submit these applications, requests and notifications to BIS in one of three ways: via SNAP–R, via BIS’s Electronic License Application Information Network (ELAIN), or via the paper BIS Multipurpose Application Form BIS 748–P. With the improvements made to SNAP-R, filers have the ability to include documents related to the request in the form of PDF files as “attachments” to the submission. BIS believes that exclusive use of SNAP–R will improve efficiency for all parties by reducing processing times and simplifying compliance with and administration of export controls.

This new rule takes effect for all of the above submissions on October 20, 2008. Additional information on the new filing requirements and criteria under which BIS will authorize paper submission can be found in the Federal Register, August 21, 2008.

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