For our trip we took in June/July our local CBP would no longer let us put them on a 4457. We did do the 5320.20. Never heard of the DSP-73. No one wanted to see anything other than a 4457 and gun serial numbers.
DSP-73 is the form that gets filed with the US State Departments Directorate of Defense Trade Controls to apply for a temporary export of an ITAR (International Traffic in Arms Regulations) controlled item..
Technically a DSP-73 should have always been required based on the fact that suppressors are on the US Munitions List (the "list" that tells us all of the material items that the US Govt prohibits the export of without a license).. but prior to now theyve never really enforced it or even made it publicly known that a temporary export license was required..
One of the issues is that the US Govt has been undergoing a major overhaul and reform of export controls that literally dates back to Obama's first term.. they originally said they would have the reforms completed in 4 years.. its now been 21 years and they still arent completely finished.. they have moved a LOT of stuff off the DDTC controlled USML and over to Customs EAR and DEAR (Export Administration Regulations and Defense Export Administration Regulations) Bureau of Industrial Security controlled lists.. and have moved a lot of stuff from Customs BIS over to DOS DDTC.. theyve dumped a few things from both lists.. added a few things.. and changed several of the processes and procedures related to import and export of controlled items along the way...
Basically creating a 21 year long mess in an attempt to clean up what was already a shit show and a mess of our import/export regulatory environment..
The problem is now you have to watch things like a hawk.. because everything has been in a perpetual state of change for a couple of decades.. and making a mistake on a major export can straight up bankrupt a business and/or find several people wearing orange jump suits at Club Fed..
A violation of DDTC USML export can incur a penalty of up to $1.2M per violation (understand that a single export of say 25 firearms is NOT a single violation... its 25 individual violations).. and up to 20 years in prison.. as well as forfeiture of the goods, revocation of future export privileges, etc.. (DDTC does not play around)...
Thats not to say they will hit you with max penalties every time.. but.. thats also not to say they go light.. Just last year DDTC hammered RTX Corporation with a $200M settlement (they were going for much more than that initially)..
Airbus got hit with $3.9B in penalties in 2020 for ITAR violations and corruption issues..
Boeing paid $51M in 2024 for ITAR violations (exporting parts for F15's and other military aircraft with permission of the US Govt to do so, but without having the proper paperwork filed with DOS DDTC to conduct the export)..
etc..etc..
Granted an individual traveling with a single suppressor isnt Boeing or Airbus... and you'd be looking at only a single violation most likely rather than dozens or hundreds... BUT...
Even a single $100K fine, loss of a suppressor, and a year or two at the Federal Pen in Colorado probably wouldnt be too appealing to most people..
In a nutshell... THANK YOU
@kdenn for the update... people need to know that the DSP73 is now an official requirement.. its not hard to complete and submit.. but.. the pain associated with not doing it if you get caught is severe..
