Tips on DS2032 Form Preparation
- Every block of the form must be completed.
- Physical address must be included throughout the form. Post office boxes may be listed for mailing purposes, but cannot be
substituted for the physical address.
- A brokering registration must be a separate registration and cannot be combined with a manufacturer or manufacturer/exporter.
A separate fee is required for each registration.
Block 7
- Full last and first names must be provided - no initals.
- If no middle initial, enter "N/A."
- List ALL senior offices and directors, owners, partners, members - excluding will result in an incomplete submission.
- Position (e.g. President, Chief Executive Officer, Chief Financial Officer, Owner) as reflected in the articles of incorporation,
partnership, joint venture or other legal structure.
- Foreign Directors and Owners, all citizenships must be specifically identified. If residing in the United States, provide
copy of permanent residency documentation and visa information, as applicable, as an attachment.
- Place of birth should include city, state, and country.
- Social Security number (if not provided, may take longer to review and require additional documentation.)
- Home Address must be a physical street address. A post office box mailing address, but it cannot be substituted for the physical address.
- Citizenship(s) must be entered and if U.S., enter "U.S." "Yes" is not an acceptable answer.
Block 8
- Review the USML categories that are applicable to the business
(See ITAR Section 121 (PDF, 7MB))
and enter all that apply. A USML category MUST be entered with a description of the articles and/or services, described in the
"Commodity/Services" column.
- If working as a subcontractor and the purchasing U.S. Government agency information is not known, enter "N/A."
Blocks 9 & 10
- List all wholly and partially owned U.S. or foreign subsidiaries (to include joint ventures). List only those that are in the business of manufactureing, exporting and/or brokering USML articles, technical data or services.
Block 11
- Determine whether the U.S. parent company is registered, if applicable. If the parent company is registered, separate registration is not necessary.
- If the U.S. parent is not registered, the registration should be submitted under the parent company as the ultimate operational,
legal entity in the US.
- If there is no parent, enter "N/A."
- When applicable, list the name of the parent and include the address.
Block 12
- If applicable, need full name and address of ultimate non-US foreign person (include company) along with telephone and
fax number.
- If a company is owned and/or controlled by foreign persons, then the associated transmittal letter must reflect this fact.
- Submission must include details on the degree/percentage of ownership and control by the foreign (non-U.S.) persons and reflect the
ultimate owner (e.g. U.S. company ABS is 100% owned by a foreign company XYZ which is 50% owned by Jon Smith, a UK citizen and 50%
owned by Jane Smith, a UK citizen).
- Control is presumed to exist where foreign persons own 25% or more of the outstanding voting security if no U.S. persons control
an equal or larger percentage. It also means that one or more foreign persons have the authority to establish or direct the general
polices or day to day operations of the firm.
(See ITAR Section 122.2(c) (PDF, 1.1MB)).
Block 14
- Ensure the DS-2032 and transmittal letter are signed by a senior officer listed in Block 7 of the DS-2032 who has been empowered
by the registrant and must be a U.S. person.
- Foreign broker senior officers, although not U.S. persons, must meet the same qualification of an empowered offical.