State Department Seeks Comments on Arms Export Violation Reporting Form
Published Date: 4/7/2026
Notice
Summary
The Department of State wants your thoughts on a form that companies and people must fill out if they break rules about exporting defense stuff. This helps keep track of violations under the Arms Export Control Act. If you’re involved in exporting or brokering defense items, this affects you, and you’ve got until June 8, 2026, to share your comments—no extra fees, just your time!
Analyzed Economic Effects
3 provisions identified: 1 benefits, 1 costs, 1 mixed.
Failure to Report Risks DOJ Referral
If you do not report an ITAR violation, DDTC states that failure to report may be an adverse factor in deciding how to handle the violation and the activity may be referred to the Department of Justice for possible criminal prosecution. The notice adds that the Department of Justice is not required to give weight to the voluntary nature of a disclosure.
New Electronic DS-7787 Disclosure Form
If you are an individual or company that exported, temporarily imported, or brokered defense items and committed an ITAR violation, you may submit a voluntary disclosure using Form DS-7787 (OMB Control Number 1405-0179). The form will be submitted electronically, is estimated at an average of 10 hours per response, and the agency estimates 600 responses with a total estimated burden of 6,000 hours.
Voluntary Disclosure Can Reduce Penalties
If you voluntarily disclose an Arms Export Control Act or ITAR violation to the Directorate of Defense Trade Controls (DDTC), that disclosure may be considered a mitigating factor when DDTC decides whether to impose administrative penalties. Voluntary disclosures are encouraged and may influence the administrative disposition of violations.
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