; (2) the Secretary determines, on a case-by-case basis, that the application of subsection (a) to any particular person would be impracticable and the applicant for issuance of a license under part I of subtitle B of title XVII of the John S. McCain National Defense Authorization Act for Fiscal Year 2019 commits in writing to submit to the Secretary of Commerce written records of any subsequent or pending sale or transfer that would have been required to be declared under subsection (a) absent a finding of impracticability that occurs within three years of the date of issuance of the requested license within 30 days of the instigation of any such subsequent or pending sale of transfer