SUP-05Edition 1.0 · November 2026

Missing Licenses

Investigating the evidence gap — when the authorization behind your items cannot be found

A step-by-step method for non-US companies holding US-origin items whose historical authorization cannot be found — to reconstruct their regulatory provenance without inventing what is unknown, and to decide separately what can be done with them today.

A4 PDF · 20 pages · English · 4 templates · regulatory references checked November 2026

Buy the guide · €89Look inside

Prices excl. VAT · single user · revisions included for 12 months

Cover of Missing Licenses: Investigating the Evidence Gap

What this guide settles

  • Missing evidence does not prove missing authorization: four hypotheses — specific authorization, lawful route without a licence, credible indication it was not obtained, unresolved
  • Then is not now: historical jurisdiction and classification for the old transaction, current ones for today’s activity
  • Weigh each source for what it proves — invoice rules changed in 2013 and 2016; an empty search after the retention period is a weakness, not proof, and BIS or DDTC are not your archive
  • Reconstruct the evidence file, never the document; decide today’s activity on its own basis, with an interim control rather than presumed licence conditions

What you get

  • The guide: explanations, method, conditions and limits
  • Worked examples: four hypotheses, evidence source by source (with the history of ITAR invoice rules), record holders and retention periods, five historical conclusions, a composite case and ten pitfalls
  • Tools printed in the guide: four templates, including a then-and-now hypothesis matrix and a two-part conclusion and decision record, and a readiness check
  • Sources with section references and their verification date
  • Revisions included for 12 months

Printed tools: T1 · Evidence gap sheet · T2 · Evidence inventory and search log · T3 · Hypothesis matrix — then and now · T4 · Conclusion and decision record · Readiness check

Contents

  1. Before you start: scope and limits
  2. Why the gap matters
  3. The rule in one page
  4. Evidence, source by source
  5. The method in six steps
  6. Templates T1 to T4
  7. Ten pitfalls
  8. Case study: two batches, one request
  9. Readiness check

What it does not cover

  • Facts that point to a possible violation
  • A remediation campaign across many programmes
  • Items acquired through Foreign Military Sales

Assumed knowledge. How your items are classified, what a reexport and a retransfer are, and how to request information from suppliers.

Sample pages

Cover
Cover
The rule in one page: then and now
The rule in one page: then and now
Evidence, source by source — and how ITAR invoice rules changed
Evidence, source by source — and how ITAR invoice rules changed
Template T3: hypothesis matrix, then and now
Template T3: hypothesis matrix, then and now
Case study: two batches, one request
Case study: two batches, one request

Open an image for the full-size page.

Where it connects

SUP-07

Buying Through Distributors & Resellers

Missing Licenses reconstructs a past that left no evidence; Buying Through Distributors & Resellers decides which information to believe when it exists but arrives through relays.

SUP-04

Working Under a Supplier’s BIS License

Working Under a Supplier’s BIS License starts from licence evidence in hand; Missing Licenses starts when that evidence cannot be found.

ITAR-02

ITAR Reexports & Retransfers

Missing Licenses establishes what can be proved about how the items arrived; ITAR Reexports & Retransfers builds today’s request on that conclusion.

Part of a collection

Missing Licenses is one of the eight guides of Suppliers & Procurement (Manage Transactions), available together at €390 instead of €89 each.

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