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Recently a client asked if they can accept a RWA from the DDTC as a CJ. In investigating the background the client had submitted a license application to the DDTC, the application was RWA’d as subject to the DoC (600 Series). The client wanted to utilize the RWA as a official notification to it’s customers that the parts were no longer on the USML.

Simply put RWAs are not CJs. While researching if any other companies had been using RWAs as CJs I found a fantastic article on the subject published by Jones Day and written by Giovanna M. Cinilli and Keneth J. Nunnenkamp: 

http://www.mondaq.com/unitedstates/x/293106/Terrorism+Homeland+Security+Defence/Unintended+Consequences+of+Export+Reform+Has+DDTC+Opened+an+Alternative+to+the+CJ