Annulment, Revocation, Limitation, Suspension, and Modification of a License

A license may be annulled by the Ministry, based on the decision of the Commission, if it was obtained under false pretenses, misleading representation, or concealment of material facts. In such cases, the license is null and void and any activity conducted under it is illegal.

A license may be revoked by the Ministry, based on the decision of the Commission, if:

  • It is requested by the license holder.
  • New facts emerge which, had they been known or existed at the time of the application, would have resulted in a denial.
  • A substantive change to the information in the license occurs.
  • The license holder fails to comply with the obligations, terms, or conditions of the license.
  • The license holder violates the Law for the Trade of Strategic Goods, its sub-legal acts, or other state security-related legal provisions.
  • The license holder fails to comply with a request from the Ministry for additional information about the license.
  • The license is destroyed or lost.
  • A natural person who is the license holder dies.
  • A legal person who is the license holder is dissolved or otherwise is no longer in existence.
  • The Commission becomes aware of any other national security-related reasons.

A license may be limited by the Ministry based on a decision of the Commission pursuant to the license holder’s request, if the license holder fails to comply with a request from the Ministry for additional information about the license, or the Commission becomes aware of any national security-related reasons.

 

The Ministry will suspend the validity of a license until the following circumstances can be ascertained:

  • The new facts which, had they been known or existed at the time of the application, would have resulted in a denial.
  • The license holder fails to comply with request of the Ministry for additional information about the license.
  • The Commission becomes aware of any other national security-related reasons.

In such cases, the Ministry will immediately notify Customs and other relevant government institutions of the annulment, revocation, limitation, or suspension of a license.

You may not appeal the Commission’s decision to annul or revoke a license, but administrative contest can be initiated with the competent court.

A license may be modified by the Ministry, based on the decision of the Commission, in the case of extension of the validity period, a change in the destination or end-user, or for other reasons.

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