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DSCA 02-06

Memo Status : Superseded Notes : Superseded by DSCA Policy Memo 02-40 and SAMM Rewrite of October 2003.
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DEFENSE SECURITY COOPERATION AGENCY
201 12th STREET SOUTH, STE 203
ARLINGTON, VA 22202-5408

2/6/2006

MEMORANDUM FOR :

DEPUTY UNDER SECRETARY OF DEFENSE,
TECHNOLOGY SECURITY POLICY AND
COUNTER PROLIFERATION

SUBJECT :

Interim Security Assistance Management Manual (SAMM) Change - Missile Technology Control Regime (MTCR) Review Policy for Explosives (DSCA Policy 02-06)

Thank you for your 15 March memorandum. Subsequent discussion has revealed that our organizations approach the problem of identifying MTCR controlled items differently. Unlike the procedure with which MTCR is implemented in export licensing, the FMS MTCR procedure requires the reviewer to examine every item to be exported for each case, without regard to whether the case end item is MTCR controlled. As a result, language which is sufficient for FMS MTCR procedures presents ambiguities when read from the standpoint of the normal licensing procedure.

To satisfy both concerns, I suggest the following change:

"2. The reviewer must report if the compounds listed in Item 4 of the MTCR Annex are to be exported in bulk as an input for a manufacturing process, or in any other manner or form that might support the creation of a propellant for a missile or a UAV. However, the reviewer is NOT to report Item 4 explosive compounds if they are molded or poured into a form that precludes their use as rocket propellant (e.g.: as a bursting, propelling or gas-generating charge in a shell, cartridge, squib or actuator). "

My action officer, Colonel Craig McLane, (703) 604 6625, will hold this change for 30 days to incorporate any further feedback from you. In the event there is none, this change will be published at the end of April.

Richard J. Millies
Acting Director