Global Trade Compliance Atlas

105%

120 121 122 123 124 125 126 127 128 129 130

§ 122.5

Maintenance of records by registrants

ITAR · Part 122

Registrants must maintain records of manufacture, export, temporary import, and the furnishing of defense services for five years from expiration of the license or other approval, or from the date of the transaction if no license was required. Records must be available to DDTC, ICE, and CBP. Electronic records are fine if they are complete and retrievable. “We use a freight forwarder” is not a recordkeeping system.

Five years from expiration, not from shipment — a four-year license that ships in year four still has a long tail.
Exemption use requires the same quality of records as a licensed shipment, plus the exemption citation.

eCFR (primary) · § 122.5 LII (secondary, unofficial)

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In this atlas

§ 123.22 § 124.4 § 127.1 § 130.14 § 129.11