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Does the seller identified in Block 19 have to be the applicant of the license request?
Per the guidance originally published on September 10, 2005, the purchase order must be addressed and directed to the registered U.S. party selling the defense articles and submitting the export license application. This requirement ensures the applicant is in a contractual position to fulfill all responsibilities of registered parties under the ITAR, including being knowledgeable of all elements of the transaction. This requirement is not applicable to submissions by foreign embassies who are issued authorizations on a case-by-case basis as a matter of exception.
Directorate of Defense Trade Controls (DDTC), U.S. State Department
http://www.pmddtc.state.gov/
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