We currently do not have GPCs set up for each country case, so if we purchased each country's requirement separately using the same GPC and identifying the country case code and line in each order would this be considered splitting requirements? We wouldn't be doing this to avoid required thresholds, but to look at the requirement for each country individually and not as a total. Thinking this would be the same as if we did have GPCs established for each country and placing the orders separately on those GPCs.
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From a DAU perspective, the approach you suggest, "... purchas[ing] each country's requirement separately using the same GPC and identifying the country case code and line in each order" would appear to provide sufficient documentation to 'split the requirements' between the set of FMS customer nations that are separately acquiring the same piece of equipment. The additional effort that would be required to establish a separate GPC for each customer country does not appear to be needed or justified since you would establish/document 'traceability' for each separate GPC purchase order you place on behalf of each FMS customer country to meet that country's FMS case requirements using the procedures described in the first sentence.