Good news on ITAR

Botts said:
I read that Commerce is going to start allowing aliens to use AES. In which case we might be able to AES submit ourselves.

I read it on a summary of comments re: Form 6 NIA. Apparently a Form 6NIA is no longer enough to get your guns back into Canada, you may to file with AES to get an export permit for your temporarily imported guns.

See comment 78: https://www.federalregister.gov/doc...es-the-president-determines-no-longer-warrant
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The hope/goal is they would make it easier to file AES. There are ongoing conversations already regarding what requires AES filing and what does not, and further clarity will come in the weeks ahead.

Regarding the need to file AES when leaving the USA after bringing a firearm in temporarily with an ATF 6NIA -- it is my understanding that they erroneously left some language in the analysis portion of the rules suggesting this, but did not implement this within the actual regulatory changes.
 
15567 said:
Would like to confirm if it is now possible to pay the seller directly and no longer necessary for IRUNGUNS to buy on your behalf?
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You would have to ask/confirm with IRUNGUNS if that's who you're using, as this is Prophet River's forum ;)

BUT, as an exporter I can tell you that thus far the Commerce Department has suggested that the policy that the Exporter be the same party as the Seller of the goods will, in most cases, continue to be required. It is hoped that this will be fully clarified in the next month or two, with an official opinion in writing from them.
 
BDVW said:
You would have to ask/confirm with IRUNGUNS if that's who you're using, as this is Prophet River's forum ;)

BUT, as an exporter I can tell you that thus far the Commerce Department has suggested that the policy that the Exporter be the same party as the Seller of the goods will, in most cases, continue to be required. It is hoped that this will be fully clarified in the next month or two, with an official opinion in writing from them.
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I read the IRUNGUNS export directives and it no longer states must be purchased by IRUNGUNS but arrange payment with the seller. If this has indeed changed than Prophet River's requirements will be the same.
 
Some of this back-and-forth on AES filing and seller/exporter roles reminds me how easy it is to miss key updates. If anyone’s dealing with US export rules regularly, even as a small shop or individual, this ITAR audit checklist covers what to keep in check to stay compliant. Especially helpful now with all the policy shifts and grey areas still being “clarified.”
 
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