DECCS Is Coming: What You Need To Know (IRB No. 579)

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The US Department of State, as part of its system modernization effort, is continuing its roll out of the Defense Export Control and Compliance System (DECCS) next month.  DECCS is set to become the central online platform for submitting license applications, requests, and other materials to the Directorate of Defense Trade Controls (DDTC), and the DECCS applications for registration and licensing are expected to go live in January.  DECCS will fully replace DTRADE, DDTC’s current licensing system, by summer 2020, after which time DTRADE will be inaccessible. 

Specifically, DECCS users will be able to submit Commodity Jurisdiction and Advisory Opinion requests, registration forms, license applications, and other communications with DDTC, including voluntary disclosures.  Certain of these capabilities are already functional in DECCS, while others will be added after the early 2020 deployment.  Importantly, registration with DDTC is not required in order to enroll and maintain a DECCS account, and foreign parties may enroll in DECCS for purposes of submitting materials to DDTC, such as retransfer applications.  The State Department is in the process of migrating data from DTRADE, meaning your organization’s historic DTRADE information should be available in DECCS once you enroll.

DECCS will also offer increased functionality in terms of managing and scaling user access.  Organizations will need to appoint at least one (but preferably more than one) DECCS corporate administrator who will act as the main user in DECCS.  The corporate administrator will be able to manage other users’ access and create user groups for purposes of license management or other DECCS system applications (similar to your current DTRADE Super Users).

The State Department has indicated that multiple training opportunities and materials will be made available for DECCS, including pre-and post-deployment webinars, standalone training videos, and user guides.  In addition to engaging with training materials, we recommend industry take the following steps now in order to prepare for the full DECCS deployment in the new year:

  • Renew security certificates that will expire between now and the end of January to ensure continuity when DECCS deploys and during the continual DTRADE transition. Renewed certificates will be available in DECCS.  Given the processing time associated with obtaining a new security certificate, users may experience a delay in the ability to submit license applications if they wait to renew until after the DECCS transition and allow existing certificates to expire.  DTRADE will cease to be available sometime next summer.
  • Identify the key stakeholders in your organization to determine who is positioned to serve as the corporate administrator(s) in DECCS and what other individuals will need DECCS access. Review your list of current DTRADE Super Users and other users and make updates as needed, particularly in light of the expanded scope and capabilities of DECCS.  Ensure an adequate number of Empowered Officials will have DECCS access.  Decide whether to create user groups and how to structure such groups.
  • Take note of your registration and license renewal schedule to avoid any lapses.

Although certain applications will not be live until January, you may consider volunteering to be an industry tester for these DECCS functions; this may be helpful in terms of familiarizing your personnel with the system and alerting DDTC to any system issues prior to the January deployment.  If your organization is interested in assisting with the final stages of DECCS testing before the full deployment, you may contact the DDTC IT Project Team at PM_DDTCProjectTeam@state.gov.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations. Attorney Advertising.

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