(C) MTCR: GERMANY ACCEPTS USG FEEDBACK ON RISK

C O N F I D E N T I A L BERLIN 001441 SIPDIS STATE FOR ISN/MTR (PAM DURHAM) AND EUR/CE E.O. 12958: DECL: 10/23/2033 TAGS: MTCRE PARM PREL KSCA TSPA ETTC FR AS GM SUBJECT: (C) MTCR: GERMANY ACCEPTS USG FEEDBACK ON RISK ASSESSMENT SEMINAR PROPOSAL REF: A. BERLIN 1422 ¶B. PETERSEN-DURHAM E-MAIL 10/22/2008 Classified By: Global Affairs Unit Chief Don L. Brown for reasons 1.4 (b) and (d). ¶1. (C) MFA Export Control Division Desk Officer Nancy Reck welcomed REF B USG feedback on the REF A German MTCR Export Control Seminar nonpaper. During an October 23 meeting, Reck thanked the USG for the timely response and said that the feedback was sufficient for the GoG to move the proposal onto Russia, Brazil, and South Africa. ¶2. (C) In response to the clarification requested in REF B on a bullet in the proposal, "review ideas on how to reduce the length of the licensing process and how to solve legal problems", Reck explained that the intention of the German Federal Office for Export Control (BAFA) is to openly discuss areas of potential improvement in export licensing that Germany finds particularly problematic. Reck said that export licenses in Germany normally take from three months to a year to be completely resolved and that the BAFA feels that this seminar would present a good opportunity for countries to share ideas on how to expedite the licensing process and improve overall efficiency. In regards to legal problems associated with export licensing, Reck said BAFA's aim is to discuss and to create awareness regarding the unique legal challenges German export authorities face and give a chance for other countries to voice their legal challenges. COMMENT -------------- ¶3. (C) Reck's responses to the REF B clarification request did not address risk assessment directly. Rather, her responses focused on improving the export licensing process within unique legal confines. Reck said that she believes BAFA's decision to include export licensing time and legal concerns as part of the seminar agenda does have an indirect risk assessment angle, although she could not give an exact reason how. Pollard