How to Comply with Reporting Requirements of Itar Re: Political Contributions

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Per 22 CFR 130, my company would need to report political contributions, fees, and commissions as required under 130.5 and 130.6 since the value of the license exceeds $500,000.00. Reporting requirement will include (1) the gift of US-made goods to the purchasing manager valued at $1,100.00 and (2) the finder's fee paid to the third party in the destination country of $2,000.00. In each case, the reporting requirement threshold is $1,000.00. Payment of the Value Added Tax would not be reportable, even if it amounts to more than $1,000.00 per 130.6(b). To the extent my company had a vendor that supplied end-items or major components as described in §121.8 valued at $500,000.00 or more, my company would need to request from the vendor and include in its report to DDTC a full disclosure by the vendor of all political contributions or fees or commission paid, by vendor with respect to such sale. Per §130.12, a vendor is required to provide the information unless it believes that furnishing information to an applicant or supplier in a requested statement would unreasonably risk injury to the vendor's commercial interests. In such a case, the vendor may furnish in lieu of the statement an abbreviated statement disclosing only the aggregate amount of all political contributions and the aggregate amount of all fees or commissions which have been paid, or offered or agreed to be paid, or offered or agreed to be paid, by the vendor with respect to the sale. Any abbreviated statement furnished to an applicant or supplier under this paragraph must be accompanied by a certification that the requested information has been reported by the vendor directly to the Directorate of Defense Trade Controls. The vendor must simultaneously report fully to the Directorate of Defense Trade Controls all information which the vendor would otherwise have been required to report to the applicant or supplier under this section. Each such report must clearly identify the sale with respect...
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