This proposal would appear to make it very easy for DoD to decline approval of
purchase of ML/CCL items by individuals as individuals would have no way of
demonstrating that they have any of the safeguards in place which would be
required by the proposed rule change (financial ability to safeguard ML/CCL items,
etc.). I'd like to see treatment of individual purchasers addressed more thoroughly
by the proposed requirements. Will DoD be looking at individuals' credit reports?
While this might be cogent in protecting ML/CCL items from improper sale to
foreign entities, it should not be a deal-stopper; many of us buy items from DRMO
auctions because they are cheaper than buying the same items from commercial
suppliers. Individuals' credit issues, if they are to be evaluated, should not be a de
facto basis for DoD to deny individuals' applications for EUCs. Also, I'd like to see
some provision for appeal by individual purchasers if their application for an End
User Certificate is denied. Overall, however, with regard to business enterprises
who buy ML/CCL items for the express purpose of reselling them at a profit, the
proposed rule change is good - I think closer scrutiny of such businesses is called
for and overdue given the overall world situation.
Comment on FR Doc # E6-17848
This is comment on Proposed Rule
DLA Procedures for Eligible Purchasers of Munitions List/Commerce Control List Items
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