Make a Comment on New Firearm Export Regulations of the U.S. Commerce Department!

How to make a comment:

  1. From your digital device copy the model comment below the following Background information.
  2. Go to the Public Comment page on: https://www.federalregister.gov/documents/2024/04/30/2024-08813/revision-of-firearms-license-requirements
  3. Paste the model comment below. Add your own comments if you want.
  4. Fill out the other information in the comment form, including your email address, whether you are commenting as an individual, organization, or anonymously, and click the button agreeing that the comment can be posted on the web, then click the Submit Comment button.

Background

On April 26, the U.S. Commerce Department published an “Interim Final Rule” on gun exports under its jurisdiction, and invited members of the public to submit comments until July 1st. While the new rule makes several positive changes, it doesn’t curb some of the worst parts of U.S. gun exports, including exports to human rights violators – from Mexico to Israel -, the export of destructive weapons such as assault rifles, nor does it put an upper limit on the number of weapons exported to any one country. 

Yet the gun industry and its allies in Congress are already attacking the rule for the selective limits it places on weapons exports. Your comment is critical to ensuring that policy-makers hear from people who want to prevent gun violence both within and beyond U.S. borders.

The United States exports more guns to more countries in the world than any other, and the flow of weapons is growing. Since Donald Trump moved oversight of gun exports from the State Department to the Commerce Department in 2020, the volume of pistol exports to Latin America has grown by 81%, while violence and the press of people seeking asylum has grown. 

The export rule lists non-binding criteria for all U.S. gun export licenses, but focuses primarily on weapons exports to non-governmental end users. The State and Commerce Departments analyzed the risk of theft and diversion of exported guns, but did not focus on risks of human rights abuses, which led them to address mostly exports to nongovernmental end users.

Model Comment – please adapt this comment, with your own name, city, and any additional comments you wish to make. 

To whom it concerns:

I am writing in response to the Interim Final Rule on firearm exports published by the Department of Commerce on April 26. I support provisions of the rule, but strongly urge the Department to strengthen it in several ways to prevent U.S. weapons from being used to further violence and human rights violations.

I support the following provisions of the Interim Final Rule:

  • Reduction of firearm export licenses from four years to one year. Longer licenses risk putting weapons exports on automatic pilot, with less attention to changing circumstances or the consequences of prior exports. 
  • A “presumption of denial” of licenses for export to non-governmental end users to certain countries. This will have positive effects in countries like Guatemala (where the United States has exported an alarming increase of weapons in recent years) and other Central American countries.
  • Subjecting all firearms exports to the Commerce Department’s procedures for crime control items, which will provide needed additional scrutiny in the license review process when the importing country has a record of human rights abuses or civil disorder.
  • Creating new export classifications to differentiate between semi-automatic and non-semi-automatic weapons to better enable the Department of Commerce to track exports and evaluate the risk of diversion of specific weapons.

However, the rule does not address a number of ways that U.S. weapons exports are contributing to violence around the world. I am especially concerned that the State Department’s guidance, which shapes the rule, analyzed the risk of theft and diversion of exported guns, but did not focus on risks of human rights abuses, which led the rule to address mostly exports to nongovernmental end users. I strongly urge you to strengthen the rule in the following ways:

  • The Commerce Department should adopt policy that draws clear and binding red lines against exporting weapons to military and police end users implicated in human rights abuses, collusion with criminal groups or other violence. This should include using criteria for firearms exports that are at least as restrictive as those for U.S. assistance to military and police forces, known as the Leahy Law. 
  • The “presumption of denial” of exports to non-governmental end users should be extended to countries where U.S. companies have exported enormous quantities of firearms used in devastating violence, including Israel, Thailand, the Philippines, and Mexico. 
  • The rule should specify consequences, including denying a license, when firearms export license applications and purchase orders for firearms do not specify the identity of the weapons’ end users. 
  • The rule should cap the volume of weapons to civilian buyers, to prevent these lethal exports with a long shelf life from increasing violence during years to come.
  • The rule should specify a presumption of denial of export licenses for especially dangerous weapons to non-governmental users, such as assault weapons and .50 caliber rifles. The President has rightfully called for prohibiting the sale of these weapons of war and mass shootings within the United States; our country should not be exporting them to other countries. 
  • The rule should explicitly commit the Commerce Department to annually publishing firearms export data, including the number of licenses and firearms, dollar value and license duration for each country, whether the end users are government forces, private companies or individuals, and for each export category of weapon.

These measures are important for ensuring the Rule meets the goals of reducing the use of U.S. exported weapons in violence and human rights violations around the world.

📢 On June 11th, 12th, and 13th, migrants, Indigenous people, Afro-descendants, and gun violence survivors are uniting in Washington, DC, to demand an end to violence and call for collaboration between 🇲🇽 and 🇺🇸 governments. We’re advocating for Peace and Human Rights to be at the forefront of our regional priorities. ✊🏽🌍 Follow us on social media and share our demands!

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An interview with Stop US Arms to Mexico Coordinator John Lindsay-Poland.

What role do guns from the United States play in the ongoing crisis of gun violence in Mexico?  Listen Here. 

According to the Department of Justice’s Bureau of Alcohol, Tobacco, Firearms and Explosives, approximately 70 percent of firearms found at crime scenes in Mexico can be traced back to the United States.

In December of last year, about 250,000 people crossed the southern border into the U.S., with the majority coming from Mexico. Survey data from the Kino Border Initiative, a large migrant shelter in Nogales, Mexico, indicates that violence, rather than economic factors, is the primary driver causing many families to leave Mexico.

Understanding the violence in Mexico is crucial to understanding the migrant crisis. Additionally, efforts are being made to stem the flow of guns into Mexico.

Ieva Jusionyte, an anthropologist and former paramedic, author of “Exit Wounds: How America’s Guns Fuel Violence across the Border,” discusses this issue alongside Angela Kocherga of KTEP in El Paso and John Lindsay-Poland of Stop US Arms to Mexico.

On May 5th, protests took place in cities across Mexico and the United States to demand an end to violence.

This past weekend, we reclaimed the narrative on May 5th.

People took to the streets in Mexico City, Guerrero, Tlaxcala, Querétaro, California, New York, and Florida to call for an end to violence in the Mexico-United States region ahead of the 2024 elections in both countries. More than a thousand people participated in this powerful display of binational solidarity.

You can watch a video of these events here.

The protesters, composed of groups searching for missing persons, community leaders, relatives of the disappeared, as well as Afro-descendant, migrant, and Indigenous groups, all part of the People’s Movement for Peace and Justice, denounced the proliferation of weapons, racism, and militarized policies.

In Mexico City, a contingent of nearly 300 people, led by the Fathers and Mothers of Ayotzinapa; Maria Herrera, a mother of four missing children; Kathleen Murray, an Afro-Colombian representative of the Black Co-Redes for Peace and Justice; and migrants living in the city marched from the Monument to the Revolution to the United States Embassy in Mexico.

In Chilpancingo, Guerrero, a hundred people took to the streets despite the threats and intimidation to affirm, “From Washington DC to Tapachula, we are losing the future.”

In Tetlanohcan, Tlaxcala, approximately 150 people gathered, with Indigenous and Afro-descendant leaders. Grisel Bello, a member of the PMPJ Indigenous and Native-American Platform, declared, “The public policies of the last two decades have not stopped the horror.”

In Cuajinicuilapa, leaders of the Black Co-Networks for Peace and Justice, in front of nearly a hundred people, denounced policies of death and militarization in both Mexico and the United States. “Our movement emerged to stop the torrent of violence against our bodies and to denounce the policies of death and militarization, as well as the governments that exercise it and the sectors of society in Mexico and the United States that promote hatred and weapons.”

In Union Square, New York, despite the rain, 50 migrants from the Transnational People’s Network called for a common front of citizens, actions, struggles, and movements to demand that political and economic power be exercised for Peace and Justice. Fani Luna, from the Transnational People’s Network, said, “In the face of historical marginalization and new forms and modalities of war, we victims have always stood up. We are the ones who are here today calling on the citizens of Mexico and the United States to unite and build from our struggles and build new movements; to demand that whoever intends to exercise political and economic power, do so for Peace and Justice. Today, a new movement has been born, where people from both nations demand peace in our regions.”

Other actions were held in San Francisco and Los Angeles, California, where Indigenous People, migrants and workers organized workshops and meetings around the impacts of violence in their communities.

In taking action across national borders and in building connections between the crises we all face, the People’s Movement for Peace and Justice continues to show that we cannot resolve the crisis of violence without working binationally and hand in hand with organizations and families of the disappeared, survivors of violence, of horrific immigration policies.

On May 5th, we showed that there is nothing more powerful than international solidarity.

Please join us for a special webcast in celebration of Black History Month: “No Justice, No Peace: The Pending Agenda for Peace and Justice for Afro Descendants in the Americas.” We will hear from some of the most influential Black solidarity organizers and Black leaders from Latin America, all members of the Black Co-Networks, a platform of the People’s Movement for Peace and Justice. In this special conversation, our speakers will reflect on the accomplishments and failures of governments in advancing justice and peace for Black communities across the Americas.

Yesterday, while millions across the United States and around the world watched the Superbowl, Israel’s Prime Minister Netanyahu unleashed death and slaughter in Rafah – where 1.4 million people – fully 85% of Gaza’s population – are sheltering, crammed into an area 150 kilometers squared, after being driven from their homes by bombs, shells, and ground troops. 

The official story that this attack was conducted to rescue hostages is a flimsy lie, much like all the other lies deployed to cover the nakedly genocidal actions of the Israeli state. Over 30,000 people, nearly half of whom are children, are already dead. The International Criminal Court of Justice has found it “plausible” that Israel is engaged in genocide.

And our own eyes and eye-witnesses have much more than “plausible” grounds to go on – pictures and videos of unimaginable violence, the dehumanized rhetoric from top Israeli officials, and the ugliness of IDF soldiers gleefully filming themselves as they bulldoze homes and murder civilians. 

This deliberate obliteration is not a “hostage rescue.” It is an illegal, immoral, and utterly reprehensible campaign of revenge. It must END NOW. 

Right now, across the country, emergency actions are being organized to demand an end to the Siege on Rafah. Please join us in the streets to make your voice heard. FIND LOCAL, BAY AREA, EVENTS HERE and NATIONAL ACTIONS HERE.

CEASEFIRE NOW!

Today, at the Hague, the International Court of Justice issued a ruling, declaring that there is plausible reason to believe that Israel’s conduct in Gaza meets the standard of genocide. The provisional recommendations call on Israel to cease any and all genocidal conduct, to preserve evidence, and to hold accountable those responsible.

Though Israel has vowed to defy the ruling, this move represents a significant step forward for the international movement to end the genocide and bring an immediate ceasefire. The near unanimous rulings underscore the strength of the evidence that South Africa brought to bear, and the urgency of an immediate resolution.

Mere hours after the ruling calling on Israel to cease all violence, the IDF shelled the Jabalia Refugee Camp in Northern Gaza.

Until there is a ceasefire, our resistance continues.

Around the world, millions strong, we’re using every means at our disposal to end the bloodshed. International boycotts have targeted the multinational corporations profiting from the occupation of Palestine. We’ve taken to the streets on every corner of the globe. We’ve occupied Senate buildings, disrupted fundraisers and speeches.

There is real momentum in the United States to end unconditional aid to Israel, to call attention to apartheid and occupation, and to demand a change to a status quo that insists upon counting Palestinian lives as less than fully human. Public opinion has shifted significantly, to the point where lawmakers see real liabilities in continuing unwavering support for Israel’s war crimes. The decades-long effort to call attention to the injustice of apartheid and ethnic cleansing of Palestine is closer than ever before to making the occupation untenable.

Today’s landmark ruling at the International Court of Justice underscores this point. The tide IS turning.

And yet. And yet. And yet. The Genocide continues. The senseless death and wholesale slaughter, the targeting of hospitals and refugee camps, the desecration even of the graves of Palestinians, continues. Each moment of delay for an immediate ceasefire is counted in precious human lives.

So we keep going. Whatever way you can, whenever you can, please join the effort to stop the slaughter and to demand an immediate ceasefire. If you haven’t yet done so, please write to US President Joe Biden.

If you are able, attend local “ceasefire now” actions. Here is a list of action in the Bay Area and here is a list of other actions happening around the country.

A crisis this urgent demands our unwavering attention. We won’t look away. We build on this momentum and continue the struggle until there is peace in Palestine.

CeasefireNow. 

Global Exchange’s Stop US Arms to Mexico program hosted an International Delegation to Investigate the Weapons Flow to Mexico last month. Experts and gun violence prevention advocates from five countries that supply weapons to Mexico came to meet with impacted communities and policymakers in Mexico in February 2023.

We are pleased to share Chairwoman of Newtown Action Alliance & Newtown Action Alliance Foundation, Po Murray’s update from the delegation.


Dear GVP Community:

I was honored to be invited by John Lindsey Poland from Stop U.S. Arms to Mexico, a project of Global Exchange(and Centro Cultural Universitario Tlatelolco, Mexican Commission for the Defense and Promotion of Human Rights, Center for Ecumenical Studies, and Global Thought Mx.) to join an international delegation from Austria, Belgium, Germany, Israel, Italy, and the U.S. (including Change the Ref cofounder Manuel Oliver whose son Joaquin was killed in Parkland, John Lowy who founded Global Action on Gun Violence, and Jordan Giger from Black Lives Matter South Bend), to travel to Mexico to embark on a journey to 1) meet with gun violence survivors, survivors of the disappeared, displaced journalists, Mexican Senators, Mexican government officials, U.S. ATF agents, officials from the U.S. Embassy, and the civic society leaders and advocates; and 2) to attend the Peace Summit.

In Mexico City, we met a mother who was completely heartbroken because her four sons had disappeared. In Guerrero, a state that has been on the U.S. State Department travel advisory list due to high levels of violence and kidnapping, we met many survivors of gun violence and disappeared citizens — including a wife whose husband went to a meeting and never made it home. Now, she has little to no income to feed her children and she has been threatened and silenced. We met numerous journalists who have been threatened, silenced, and displaced. We also met one of the mothers of the 43 male students who disappeared from the Ayotzinapa Rural Teachers’ College after being forcibly abducted in Iguala, Guerrero, Mexico in 2014.

We learned that Mexico has strong gun laws and only one gun store that is managed by the Mexican Army. We also learned that more than 110,000 Mexican citizens have disappeared since records have been kept. U.S. weapons are contributing to Mexico’s human rights crisis. Over 70-90% of crime guns from Mexico are from the United States with most of the trafficked weapons coming from Texas and Arizona. Watch THIS excellent Vice News video on how the Mexican drug cartel is smuggling thousands of U.S. weapons from the U.S. border into Mexico- — including Barrett .50 calibers that have been used to attempt to shoot down planes. These Barrett .50 calibers would be banned if the U.S. Congress passed the federal assault weapons ban legislation. President Biden is ready to sign the bill into law. 

In August 2021, the Mexican government filed a $10 billion lawsuit against eleven U.S. gun manufacturers, including Smith & Wesson, Colt and Beretta, accusing them of marketing and selling weapons of war favored by the drug cartel and contributing to Mexico’s bloodshed. In September 2022, a federal judge from Massachusetts dismissed the case. The Mexican government is currently appealing the lawsuit and filed another lawsuit against numerous gun shops and dealers in Arizona.

The guns manufactured and not very well regulated in the U.S. are killing our children and loved ones in the U.S. and in Mexico. The trafficked weapons arm the drug cartels that supply fentanyl to the U.S. citizens and many Mexican families are being displaced to the U.S. border due to violence and corruption.

President Biden and the U.S. Members of Congress must act to stop fueling the violence in Mexico!

The journey to Mexico was overwhelming since stopping the flow of illegal U.S. weapons will be the first step towards finding peace, safety, and prosperity for the people of Mexico whose basic human rights have been stripped. We promised the survivors that we would take their stories and deliver them to President Biden, the Members of U.S. Congress, and the U.S. citizens. I made a promise to the international delegation that I will work with them to stop the flow of U.S. weapons into Mexico.

In the coming weeks, the delegation will write and share a report with recommendations for the U.S. government. CAP will convene a follow-up conference in April.
We invite Latino, human rights, drug, immigration, and other advocacy groups to join our efforts. Please reach out to me if you are interested.
The delegation press release is HERE.
Po Murray
Chairwoman, Newtown Action Alliance & Newtown Action Alliance Foundation

North America’s problems cannot be solved without joint action by the people and communities of the three countries in the region. Grassroots organizations, communities that have suffered the impacts of violence, inequality, discrimination and racism from Canada, the United States and Mexico are coming together this week in Mexico City for the Peace Summit to build an agenda that reflects a common reality and charts a path of actions and solutions for the region.

The event calls for a social movement among historically marginalized communities most impacted by gun violence, immigration, and climate crises to catalyze a cross-border political agenda in anticipation of the 2024 presidential elections in both Mexico and the United States.

Speakers from Global Exchange, Black Lives Matter, March for Our Lives, CIELO, and others will facilitate two days of dialogue between a diverse coalition of more than 80 organizations and over 300 attendees to develop a unified action agenda around human rights, democracy, and peace. Participants are coming from communities who suffer disproportionately from policies around these issues, including victims of gun violence, migrants, Afro-descendant and Indigenous Peoples across the region.

We have been building momentum for the Peace Summit since 2022 by hosting several community forums across the U.S. and Mexico and by sending a letter signed by over 100 grassroots organizations to President Joe Biden, President Andrés Manuel López Obrador (AMLO), and Prime Minister Justin Trudeau urging action on gun violence, climate change, and immigration policies across the region.

We’ve long believed that community-led change and the civic power it generates are strengthened by people reaching out, building networks, cultivating relationships, and sharing knowledge strategically.

We hope you will join us online for the opening plenary tomorrow, Feb 23rd at 8am – 11am Pacific Time. Or visit our social media channels for updates.