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Old August 23, 2016, 11:23 AM   #51
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Join Date: October 20, 2007
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Originally Posted by Tinbucket
Where does the ITAR Registration Fee of 2250.00 end up: at the UN?
No, it's paid to the Department of State (DoS).
Originally Posted by 5whiskey
As I understand it is the manufacturing ffl fee that you pay to the federal government. That hasn't changed, just what is considered "manufacturing."... Asinine rule change to "comply with an arms treaty..."
Technically it's not a rule change and it has nothing to do with any treaty. It's mere "policy guidance."

The ambiguity regarding the significance of such guidance is much of the reason why people are so upset. A federal rule or regulation is subject to a deliberate vetting and comment process, so it's generally pretty clear what it means by the time it takes effect, and what will happen if one violates it. Not so with so-called policy guidance.

Lastly, ITAR has nothing to do with FFL licensing rules enforced by the ATF. They are separate and distinct. "Manufacturing" is much better defined under 68 GCA regulations enforced by the ATF. One of the underlying issues here is that many ITAR regulations are rather vague and therefore subject to broad interpretation by the DoS.
Originally Posted by JaxRolo
There is still a lot of debate about what is manufacturing.
I know most 07 FFLs do not pay the fee.
True. That said, this letter amounts to a loud proclamation of "I Dare Ya!" by the DoS.
"Smokey, this is not 'Nam. This is bowling. There are rules... MARK IT ZERO!!" - Walter Sobchak
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