Record Keeping Requirements

Are there specific guidelines for record keeping of export transactions?

ITAR
  • Maintenance of Records by Registrants 22 CFR 122.5
  • Recordkeeping for Exemptions 22 CFR 123.26
EAR
  • Recordkeeping 15 CFR Part 762
FARC
  • 31 CFR 501 Subpart C – Reports
Nuclear Regulations
  • NRC:  U.S. address, records, and inspections 10 CFR 110.53
  • NNSA:  Not specified in 10 CFR 810

What records are required to be kept?

In general, any paperwork detailing:  internal export control assessments, including any documentation regarding the applicability of any licensing exemptions, license determinations, license submissions, post-license management, negotiations in connection with an export regardless of whether the export or re-export actually occurs. 

How long are records required to be kept?  

Five years from last activity or expiration date. 

How are records required to be stored?

Records must be kept in a manner in which facilitates the ability to retrieve the records for any purpose and to review the records during internal or U.S. Government audits. 

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