BIS Implements Mandatory Electronic Registration for SNAP-R

On February 9, 2011, the Bureau of Industry and Security (BIS) posted a final rule in the Federal Register that amends the Export Administration Regulations (EAR) implementing mandatory on-line registration process for obtaining an account to submit license applications and similar documents electronically through Simplified Network Application Processing (SNAP-R) system. 

The final rule sets forth the information that parties registering online are required to provide to BIS and other duties that registered parties have with respect to keeping information in their accounts current. In the past, BIS required filing entities to register for a SNAP-R account through a paper and facsimile process. 

The rule is effective March 11, 2011. Beginning on April 11, 2011, all new SNAP-R registrations must be made in accordance with this rule. 

The rule also provides that, beginning on June 10, 2011, SNAP-R accounts of filing entities that do not have account administrators will not be accessible until an existing individual user for that entity logs-on to SNAP-R and registers as account administrator. Beginning September 8, 2011, any accounts that do not have an account administrator will be inactivated. Filing entities will be able to register again but will have to go through entire registration process that applies to new entities.