17-0515 Monday “The Daily Bugle”

17-0515 Monday “Daily Bugle”

Monday, 15 May 2017

The Daily Bugle is a free daily newsletter from Full Circle Compliance, containing changes to export/import regulations (ATF, Customs, NISPOM, EAR, FACR/OFAC, FTR/AES, HTSUS, and ITAR), plus news and events.  Subscribe 
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[No items of interest noted today.] 

  1. Ex/Im Items Scheduled for Publication in Future Federal Register Editions 
  2. Commerce/BIS: (No new postings.) 
  3. Justice: “Nanticoke Man Indicted for Export Violations and Unlawful Possession of Ammunition” 
  4. State/DDTC: (No new postings.) 
  5. EU Posts Decision Concerning Modification of Annex 3 to the WTO Agreement 
  6. EU INTA Publishes Draft Agenda and Meeting Documents of 3-4 May Meetings 
  1. Global Trade News: “Valuation: How Do You Find Your Data? Q&A Wrap-up” 
  2. Montana Public Radio: “Montana Senators Aiming to Help State’s Gun Manufacturers Access Global Markets” 
  3. Reuters: “Commerce’s Ross: China’s Plans Threaten U.S. Semiconductor Dominance” 
  4. ST&R Trade Report: “Civil Nuclear Trade Initiative to be Discussed at June 1 Meeting” 
  5. ST&R Trade Report: “Global Value Chains Complicate Policies to Support Domestic Manufacturing, Report Says”  
  1. M. Volkov: “MoneyGram CCO Pays Civil Penalty” 
  2. O. Torres: “Trump Administration Begins Crackdown on Trade Abuses 
  1. ECTI Presents BIS License App 748P: How to Prepare It and How to Ensure Best Possible Approval Time Webinar, 20 Jun 
  1. Monday List of Ex/Im Job Openings: 93 Jobs Posted 
  1. Bartlett’s Unfamiliar Quotations 
  2. Are Your Copies of Regulations Up to Date? Latest Changes: ATF (15 Jan 2016), Customs (27 Jan 2017), DOD/NISPOM (18 May 2016), EAR (18 Apr 2017), FACR/OFAC (10 Feb 2017), FTR (19 Apr 2017), HTSUS (7 Mar 2017), ITAR (11 Jan 2017) 
  3. Weekly Highlights of the Daily Bugle Top Stories 



[No items of interest noted today.]

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OGS_a11. Ex/Im Items Scheduled for Publication in Future Federal Register Editions
(Source: Federal Register

* President; EXECUTIVE ORDERS; Defense and National Security: Cybersecurity of Federal Networks and Critical Infrastructure; Strengthening Efforts (EO 13800) [Publication Date: 16 May 2017.]
* Treasury; NOTICES; Blocking or Unblocking of Persons and Properties [Publication Date: 16 May 2017.]
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Justice) [Excerpts.]
The United States Attorney’s Office for the Middle District of Pennsylvania announced today that Mark Komoroski, age 54, of Nanticoke, Pennsylvania, was indicted on May 10, 2017, for violating federal export laws and unlawfully possessing ammunition as a previously convicted felon. The indictment was unsealed on May 11, 2017, following Komoroski’s arrest and initial appearance before United States Magistrate Judge Karoline Mehalchick.
According to United States Attorney Bruce D. Brandler, the indictment alleges that in February and March of 2016, Komoroski attempted to export two riflescopes to an individual in Russia without first obtaining the export licenses required by federal law. The indictment also alleges that Komoroski, a previously convicted felon, possessed over 25,000 rounds of ammunition. …
A sentence following a finding of guilt is imposed by the Judge after consideration of the applicable federal sentencing statutes and the Federal Sentencing Guidelines.
The maximum penalty under federal law is 20 years of imprisonment for the export offenses, 10 years of imprisonment for the ammunition offense, a term of supervised release following imprisonment, and a fine. Under the Federal Sentencing Guidelines, the Judge is also required to consider and weigh a number of factors, including the nature, circumstances and seriousness of the offense; the history and characteristics of the defendant; and the need to punish the defendant, protect the public and provide for the defendant’s educational, vocational and medical needs. For these reasons, the statutory maximum penalty for the offense is not an accurate indicator of the potential sentence for a specific defendant.

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. State/DDTC: (No new postings.)

(Source: State/DDTC)

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. EU Posts Decision Concerning Modification of Annex 3 to the WTO Agreement

  – Council Decision (EU) 2017/817 of 11 May 2017 establishing the position to be taken on behalf of the European Union within the World Trade Organisation (WTO) on the modification of paragraph C(ii) of Annex 3 to the WTO Agreement as regards the frequency of WTO Trade Policy Reviews and of the rules of procedure of the Trade Policy Review Body.

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. EU INTA Publishes Draft Agenda and Meeting Documents of 3-4 May Meetings

(Source: EU INTA)
The EU’s International Trade Committee (INTA) has published the draft agenda and meeting documents of the last INTA Committee meeting on 3 and 4 May.
The draft agenda and meeting documents are available here.
Part of the meeting concerned the recast of the EU dual-use regulations.
The next meeting of the INTA Committee will take place on 30 May 2017 from 3.00 to 6.30 PM in Brussels.

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. Global Trade News: “Valuation: How Do You Find Your Data? Q&A Wrap-up”

Q: I would like to start flagging my entries to file value recon. How do I go about setting this up?
A:  The first step is to contact your surety company to add a recon rider to your existing bond. Once this is complete, contact your broker to begin the application process to begin flagging your entries for value recon. Once your entries are flagged, you have 21 months to reconcile. You can work with your broker who can file recon entries with Customs with the corrected values.
Q: I have tooling that has depreciated over the last 25 years and has $0.00 book value. Can I value this on my commercial invoice as $0.00?
A:  Yes, under GAAP, the value of merchandise can depreciate to a $0.00 book value.
Q: I received a CF 28 on a classification issue that has now led to me needing to file a Prior Disclosure on classification. I believe I also have valuation issues but I am not certain how many and the depth of the issue. Should I include valuation in my Prior Disclosure?
A:  If you believe you have valuation issues that need to be corrected with Customs, I would suggest doing a sample audit– the size of the audit would depend upon how much you import. This may typically be 10-30%. This sample audit should yield any potential errors you may have. Review of the audit findings would help you make the determination if a disclosure for valuation is also required. Anytime you have questionable data, it is best to disclose all issues to Customs. This gives you protection under the Prior Disclosure to avoid any penalties.
Q: ­Value declared on entry is the amount listed on the commercial invoice. Once the product is received, we noticed damages and received a credit from the supplier. Are we required to make a correction to value declared on entry? ­
A:  Yes, a correction would be required and would work in your favor for a duty refund if duty was paid on the merchandise.
Q: ­I am new person to Customs processes. What is the best way to start learning valuation?  Any books or trainings you could recommend?
A:  I would recommend starting with the review of Customs Regulations and the below links:
You can also attend training seminars offered by the following organizations:
  – ICPA
  – AIAG
  – AAEI
Q: ­What are Assists? In addition, how is it reported?
A:  Assists are defined (19 U.S.C. 1401a(h)) as:
  – Materials, components, parts and similar items incorporated in the imported merchandise.
  – Tools, dies, molds, and similar items used in the production of the imported merchandise.
  – Merchandise consumed in the production of the imported merchandise.
  – Engineering, development, artwork, design work, plans, and sketches that are undertaken elsewhere than in the United States and are necessary for the production of the imported merchandise. ­
 To be treated as an “assist” the article or design must be:

Supplied directly or indirectly by the buyer

  – Provided free of charge or at reduced cost, used in connection with the production or sale for export to the United States of the merchandise

Q:  How is an assist reported?
A: The total value may be reported as:
  – The first shipment, if the imported wishes to pay duty on the entire value at once
  – The number of units produced up to the time of the first shipment or
  – The entire anticipated production
Q: ­You are very positive on RECON: Are there any import program scenarios that you think RECON would not be the preferred method and PSC or PD would be more appropriate? ­
A:  Recon can be filed if you have large volumes of entries to correct and there are entries that are more current. If you need to make changes to many of your entries, then recon is the best, most efficient route. One must first already be flagging for value recon though to file. If you only have a small volume of entries to correct then filing, PSCs would be most efficient. Prior Disclosure is the best method for correcting past errors. Should you discover you have a large volume of errors to correct and, may be outside of the period allowed for filing PSCs, then a Prior Disclosure may be your best option.
Q: ­I believe you have to be on Reconciliation to file a recon entry, so if you find an error and you are not on Recon then you cannot use recon to fix it, correct? ­
A:  That is correct. You must first flag your entries for value recon to be eligible to file a correction through the value recon process.
Q: ­If company A has a subsidiary B in another country to where company An export parts for machines sold by company B.­ Do we need to declare to CBP a transfer of technology for the payment of duties from a subsidiary in another country if the technology was transferred by email?
A:  Yes, the value of that transfer of technology needs to be declared. I can further assist if you would like to send more details.  Please feel free to reach out to me at inquiries@copper-hill-inc.com
Q: ­When recon was not performed, how many years back should we go with the prior disclosure? ­
A:  You are required to go back five years from the date Customs approved your desire to file a Prior Disclosure. You must first submit a letter to Customs asking for approval to file a Prior Disclosure. Once approved, you must review and file a PD for the previous five years.
Q: ­Mold Cost – Follow-Up Question: If the mold depreciates over time, can you use the depreciated amount? ­Or does the mold have a different life expectancy? ­
A:  The mold would not have a different life expectancy. You may declare the depreciated amount.

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The United States is a big player in the global arms trade, and nationwide, Montana is pretty into the gun business, it has the highest number of licensed gun manufacturers per capita of any state.
But not very many Montana guns are sold overseas. Montana’s Senators Jon Tester and Steve Daines are trying to change that for people like Peter Noreen.
Noreen started and runs Noreen Firearms in Belgrade, which has 15 employees. Several men oversee SUV-sized machines that turn aluminum bricks into gun parts. In the adjacent room, an employee assembles the rifles. Peter’s wearing a faded, camo baseball hat, and when he smiles, his whole face lights up.

  “We’re one of the larger manufacturers in Montana,” says Noreen. “Last year we produced somewhere in the vicinity of 14,000 firearms.”
Of the more than 150 licensed gun manufacturers in Montana, only a handful make most of the guns produced in-state. Noreen exports a small percentage of guns. Most go to individuals, but he has some bigger customers, too. …

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U.S. Commerce Secretary Wilbur Ross sees the U.S. semiconductor industry as still dominant globally but said he is worried that it will be threatened by China’s planned investment binge to build up its own chipmaking industry.
Ross told Reuters in an interview this week that his agency is considering a national security review of semiconductors under a 1962 trade law because of their “huge defense implications” including their use in military hardware and proliferation in devices throughout the economy.
He has launched similar “Section 232” reviews of the U.S. steel and aluminum sectors, where a flood of imports especially from China has depressed prices, threatening the industries’ long-term health.
The probes could lead to broad import restrictions on the metals, and the Trump administration could potentially take similar actions based on the findings of a semiconductor investigation.

  “Semiconductors are one of our shining industries, but they have gone from substantial surplus to the beginnings of a deficit,” Ross told Reuters. “China has a $150 billion program to take that much further between now and 2025. That is scary.”
The 79-year-old billionaire investor was referring to China’s plans for massive state-directed investments in semiconductor manufacturing capacity under its “Made in China 2025” program, which aims to replace mostly imported semiconductors with domestic products.
Ross’ predecessor at Commerce, Penny Pritzker, warned last November about looming market distortions if China builds too much semiconductor capacity.
Ross added that while he understands Beijing’s logic in developing its domestic chip industry, “that’s going to be a struggle” from a U.S. trade standpoint.
U.S. semiconductor makers, meanwhile, have other ideas about how to secure their future. Their major trade group, the Semiconductor Industry Association (SIA), advocates open trade and increased access to international markets, which now buy 80 percent of U.S.-made semiconductors. U.S. chipmakers also depend on a complex global supply chain and have nearly half their production capacity located overseas.
  “So while we fully support efforts to ensure trade in semiconductors is fair and market-based, we do not believe a Section 232 investigation is the right tool to be applied to our industry” SIA President John Neuffer told Reuters.
One area where there appear to be some differences is how to define the industry’s trade balance.
Commerce Department trade data showed that “Semiconductors and related device manufacturing” had a trade deficit of $2.4 billion in 2016, with exports of $43.1 billion and imports of $45.6 billion.
But that category includes rapidly growing imports of non-semiconductor devices including solar cells and light-emitting diodes (LEDs) as well as some raw materials.
In a new submission late on Wednesday to Commerce for a study on trade deficits, SIA said that excluding the non-semiconductor products shows the sector had a $6.4 billion trade surplus last year, with exports of $41.3 billion and imports of $34.9 billion.

Neuffer said the industry was ready to work with the Trump administration to find ways to persuade China to allow its semiconductor industry to develop in a market-driven way and not discriminate against foreign firms.
He added the government could make the United States a more competitive environment for semiconductor output through tax reform that does not penalize overseas earnings, immigration reform that allows the industry to attract new talent, improvements to U.S. education and more spending on basic research.
  “The Chinese are determined to build a semiconductor industry,” Neuffer said. “I think the strongest pillar of any strategy going forward has to be our government helping to create an environment where we can pedal faster and stay as far ahead as possible.”
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The Civil Nuclear Trade Advisory Committee will hold an open meeting June 1 via conference call. Members of the public wishing to participate must register by May 26.
The CINTAC advises the government on the development and administration of programs to expand U.S. exports of civil nuclear goods and services in accordance with applicable U.S. laws and regulations. CINTAC’s recommendations include advice on how U.S. civil nuclear goods and services export policies, programs, and activities will affect the U.S. civil nuclear industry’s competitiveness and ability to participate in the international market. The June 1 meeting will include a discussion of activities related to the Department of Commerce’s Civil Nuclear Trade Initiative.
[Editor’s Note: The announcement for this meeting can be found here.]

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Changes in the structure of manufacturing make it difficult to design government policies that support manufacturing-related value added and employment in the U.S., according to a recent report from the Congressional Research Service. The report comes as the Trump administration has made revitalizing domestic manufacturing and increasing associated jobs a primary focus of trade policy.
Numerous provisions in federal law are intended to support U.S. manufacturing, the report states. These provisions typically define manufacturing as the process of physically transforming goods (e.g., molding, cutting, and assembly) and establish a variety of potential benefits, preferences, or penalties based on the country in which physical transformation occurs.
However, the report adds, these policies rest on two implicit premises that have been rendered questionable as a result of developments in the private sector. The first is that each manufactured product is either made in the U.S. or is an import, an assumption that fits uneasily with the global value chains now widely used to combine raw materials, components, services, and intellectual property from multiple countries into a single, finished manufactured good. The second is that physical transformation is the means by which manufacturing creates economic benefits, which ignores the fact that other related activities (e.g., research, design, software development) may account for a large proportion of the value of the finished good or the employment related to the good’s production.
Another problem, the report states, is that the physical transformation of manufactured goods is increasingly performed by workers not classified as manufacturing workers and a growing share of workers whose jobs are related to manufacturing appear to be employed in economic sectors not directly involved in physical transformation, incl0uding business services, software development, and after-sales service. These changes have made it more difficult to identify workers whose jobs are related to manufacturing. In addition, linkages between non-physical inputs and factory production may not be evident in government statistics.
The report concludes that the increasingly blurred lines between manufacturing and other types of economic activity may complicate policies like those being pursued by the Trump administration to support domestic manufacturing and employment.
In addition, the report states, such policies could harm other sectors. For example, an April 18 executive order directs federal agencies to ensure that federal grants and procurement maximize the use of manufactured goods produced in the U.S. To the extent that domestic content requirements like these raise the cost of goods procured under federally funded contracts, the report states, they reduce the volume of procurement for any given level of expenditure and thus adversely affect employment in non-manufacturing industries such as construction and freight transportation.
[Editor’s Note: The Congressional Research Service report mentioned in this item can be found here.]
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12. M. Volkov: “MoneyGram CCO Pays Civil Penalty”

(Source: Volkov Law Group Blog. Reprinted by permission.)
* Author: Michael Volkov, Esq., Volkov Law Group, mvolkov@volkovlaw.com, 240-505-1992.
Like any other profession, the compliance profession is not immune to bad apples. Lawyers know the law but have been criminally prosecuted for breaking the law. The same goes for compliance professionals.
If the compliance profession wants to build credibility, it has to adopt professional standards and it has to accept when a bad apple is appropriately punished. Instead of claiming that prosecuting Chief Compliance Officers (Cos) will cause the profession harm, CCOs have to acknowledge when a fellow compliance officer crosses the line.
Thomas Haider, the CCO at MoneyGram, was properly punished for his failures and his affirmative steps to obstruct MoneyGram’s compliance program. This was not even a close case.
Haider agreed to pay a $250k civil penalty and to a three-year bar from serving as a compliance officers at a money transmitter. The civil enforcement action was brought by the Department of Treasury’s Financial Crimes Enforcement Network (“FinCEN”), with the assistance of the US Attorney’s Office for the Southern District of New York.
MoneyGram is a money transfer service that allows customers to transfer money through a global network of agents and outlets. Haider was MoneyGram’s chief compliance officer, and had direct oversight responsibility for MoneyGram’s Fraud Department and AML Compliance Department.
In 2006 and 2007, MoneyGram’s Fraud Department proposed that MoneyGram implement a policy for terminating agents and outlets that presented a high risk of fraud. A proposed policy was given to Haider but he failed to act on it because of objections from MoneyGram’s Sales Department.
In 2007, MoneyGram’s Fraud Department proposed terminating a number of outlets in Canada based on the fact that the cited outlets were responsible for approximately 58 percent of all fraud occurring in Canada during a six-month period. Additionally, the cited outlets had specific characteristics that Haider and other members of the Fraud and Compliance Departments recognized were strong indicators that the outlets were involved in fraud. Subsequently, one operator of several outlets plead guilty to criminal fraud and admitted that his money outlets were heavily involved in fraud schemes.
Notwithstanding all of the evidence presented to Haider, he did not exercise his authority to terminate any of the agents because of opposition from the Sales Department.
In 2007, Haider deliberately structured MoneyGram’s AML program to restrict analysts’ access to critical information concerning aggregate fraud analyses, and specific analysis of individual outlets over set time periods. Haider restricted access to such information with the apparent intention to prevent analysts from generating information needed to support the filing of a SAR. As a result, even though there were a number of MoneyGram outlets that were identified as engaged in consumer fraud, MoneyGram did not file any SARs for these entities.
MoneyGram never audited any of these outlets, and in fact, the agents were permitted to open additional outlets.
In considering Haider’s conduct, it is important to remember that he was charged with civil violations – not with criminal violations. The government’s burden of proof is far lower than a criminal case – a preponderance of the evidence.
Considering these facts, it is hard, if not impossible, to sympathize with Haider’s settlement. He deliberately ignored or frustrated serious compliance issues, even stretching his conduct to deliberately obstruct enforcement of MoneyGram’s compliance program, and the legally-required filing of SARs for suspected fraud. Some might feel that Haider got off lightly; some may think he should not have been punished at all. However, it is hard to defend Haider’s conduct.
In this context, the compliance profession needs to remind itself that it has to be held accountable for criminal or civil violations, and more importantly, the profession needs to develop professional standards to govern its responsibilities and ethical requirements.

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* Authors: Olga Torres, Esq., Torres Law PLLC, info@torrestradelaw.com.
With the signing of two new executive orders, President Trump is taking the first steps in fulfilling two of his favorite campaign promises, both relating to trade: (1) no longer tolerating trade abuse that damages the American economy and (2) decreasing the national trade deficit. On March 31, President Trump, who has repeatedly stated that he is for free trade that is also fair, signed Presidential Executive Order on Establishing Enhanced Collection and Enforcement of Antidumping and Countervailing Duties (“AD/CVD”) and Violations of Trade and Customs Laws (“Trade Enforcement EO”) [FN/1] and Presidential Executive Order Regarding the Omnibus Report on Significant Trade Deficits (“Omnibus Report EO”). [FN/2]
Trade Enforcement EO
The Trade Enforcement EO acknowledges the harm caused by anti-dumping and countervailing duty evading importers and states: “Importers that unlawfully evade antidumping and countervailing duties expose United States employers to unfair competition and deprive the Federal Government of lawful revenue.” The executive order goes on to claim that $2.3 billion in AD/CV duties remain uncollected by the federal government.
The Trade Enforcement EO applies to “covered importers,” which are defined in the EO as any importer of articles subject to antidumping or countervailing duties for which one of the following is true:
  (1) U.S. Customs and Border Protection (“CBP”) has no record of previous imports by the importer;    
  (2) CBP has a record of the importer’s failure to fully pay antidumping or countervailing duties; or
  (3) CBP has a record of the importer’s failure to pay antidumping or countervailing duties in a timely manner.
By June 29, the Secretary of Homeland Security, John Kelly, is tasked with developing a plan that will require covered importers that pose a risk to the revenue of the U.S. to provide additional security for AD/CVD liability through bonds and “other legal measures.” The plan will also identify “other appropriate enforcement measures.”
The Trade Enforcement EO also requires Mr. Kelly to develop and implement a strategy and plan for combating violations of trade and customs laws for goods and for enabling prohibition and disposal of inadmissible merchandise. The EO has special provisions related to the protection of intellectual property (“IP”) rights, as well, and requires the taking of appropriate steps to ensure that CBP can share with IP rights holders: (1) any information necessary to determine whether there has been an IP rights infringement or violation; and (2) any information regarding merchandise voluntarily abandoned, as defined in 19 CFR 127.12, before seizure, if CBP reasonably believes that the successful importation of the merchandise would have violated U.S. trade laws.
Finally, the Trade Enforcement EO directs Attorney General Jeff Sessions to assign a high priority to prosecuting significant offenses related to violations of trade laws.
Omnibus Report EO
The Omnibus Report EO leads with data regarding the United States’ annual trade deficit, stating the deficit in goods exceeds $700 billion and the overall trade deficit exceeded $500 billion in 2016. The EO goes on to blame the deficit on “unfair and discriminatory trade practices of some [U.S.] trading partners.” To combat the unfair and discriminatory practices, the EO claims it is necessary for policy makers and trade negotiators to have access to “current and comprehensive information regarding unfair trade practices and the causes of the United States trade deficits.” Pursuant to this aim, the EO requires Secretary of Commerce Wilbur Ross and the United States Trade Representative (“USTR”) Robert Lighthizer, and other heads of departments and agencies as needed, to prepare an Omnibus Report (the “Report”) concerning the U.S. significant trade deficits. The EO provides for a quick turn-around of only 90 days to submit the report to President Trump. For each identified trade partner, the Report will:
  (a) assess the major causes of the trade deficit, including, as applicable, differential tariffs, non-tariff barriers, injurious dumping, injurious government subsidization, intellectual property theft, forced technology transfer, denial of worker rights and labor standards, and any other form of discrimination against the commerce of the United States or other factors contributing to the deficit;
  (b) assess whether the trading partner is, directly or indirectly, imposing unequal burdens on, or unfairly discriminating in fact against, the commerce of the United States by law, regulation, or practice and thereby placing the commerce of the United States at an unfair disadvantage;
  (c) assess the effects of the trade relationship on the production capacity and strength of the manufacturing and defense industrial bases of the United States;
  (d) assess the effects of the trade relationship on employment and wage growth in the United States; and
  (e) identify imports and trade practices that may be impairing the national security of the United States.
The actual information gathered for the Report will go a long way in determining how the new administration will proceed with regards to the U.S. trade deficit.
The Trade Enforcement EO demonstrates that the Trump Administration means business when it comes to importers that continue to circumvent U.S. trade and customs laws. By directing the Attorney General to prioritize violators of trade laws, the President has sent a clear signal to the importing community that abuse of AD/CVD and other laws will not be tolerated. The Omnibus Report EO only directs an information gathering exercise at this point, but the information gathered will serve as a cornerstone for the shaping of future trade policy.
  [FN/1] Presidential Executive Order on Establishing Enhanced Collection and Enforcement of Antidumping and Countervailing Duties and Violations of Trade and Customs Laws, Office of the Press Secretary, The White House (Mar. 31, 2017), available here.
  [FN/2] Presidential Executive Order Regarding the Omnibus Report on Significant Trade Deficits, Office of the Press Secretary, The White House (Mar. 31, 2017), available here.
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14. ECTI Presents BIS License App 748P: How to Prepare It and How to Ensure Best Possible Approval Time Webinar, 20 Jun

(Source: Danielle McClellan, danielle@learnexportcompliance.com)
* What: BIS License App 748P: How to Prepare It and How to Ensure Best Possible Approval Time
* When: June 20, 2017; 1:00 p.m. (EDT)
* Where: Webinar
* Sponsor: Export Compliance Training Institute (ECTI)
* ECTI Speaker: Felice Laird
* Register: Here or Danielle McClellan, 540-433-3977, danielle@learnexportcompliance.com.

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MS_a115. Monday List of Ex/Im Job Openings: 93 Jobs Posted

(Source: Editor)  
Published every Monday or first business day of the week.  Send openings in the following format to jobs@fullcirclecompliance.eu.
#” New listing this week:

* Aerojet Rocketdyne; Huntsville AL; 
Specialist, International Trade & Compliance
; Requisition ID: 11972
* The Aerospace Corporation; El Segundo CA; 
Export Control Staff III
; Requisition ID: 19321

* Amazon; Luxembourg, Luxembourg;
Trade Compliance Project Integration Manager (M/F)
; Requisition ID: 479077

* Amazon; Mexico City, Mexico;
Mexico Trade Compliance Program Manager
; Requisition ID: 520481
* Amazon; Mexico City, Mexico;
Senior Manager, Mexico Trade Compliance
; Requisition ID: 520460

* Amazon; Seattle WA;
NA Compliance Analyst
; Requisition ID: 256357

* Amazon; Seattle WA;
U.S. Export Compliance PM
; Requisition ID: 475927

* Amazon; Tokyo, Japan;
Trade Compliance Specialist
; Requisition ID: 481891

* Advanced Micro Devices (AMD); Austin TX;
Import/Export Compliance Manager; Requisition ID: 24061

* Ansell; Iselin NJ;
Senior Specialist NA Trade Compliance
; Requisition ID: IRC6513
* ASML; Veldhoven, the Netherlands;
Senior Manager Trade & Customs
; Requisition ID: RC05619

* Bemis Company; Neenah WI;
Director – Global Trade Compliance
; Requisition ID: REQ_13735
* Berry Plastics Corporation; Evansville IN;
International Trade Compliance Administrator
; Requisition ID: 4054

* Boeing; Sydney, Australia, and other locations;
Global Trade Control Manager; Requisition ID: 1700006067

# Boeing; Amsterdam, The Netherlands, and Brussels, Belgium;
Trade Control Specialist
; Requisition ID: 1700006121
# Brunswick Corporation; Lake Forest IL;
Trade Compliance Specialist
; Requisition ID: 23122

* Brunswick Corporation; Lake Forest IL;
Trade Compliance Auditor
; Becky Longrie, 847-735-4755,
; Requisition ID: 22999

* Cobham Advanced Electronic Solutions; Exeter, NH, Plainview, NY, Eatontown, NJ, or Lansdale, PA;
Export Compliance Manager
; Charles Trokey

* CSRA Inc.; Falls Church VA;
Global Trade & Compliance Principal
; Alan Strober 571-375-4890; Requisition ID: 17002RN

* Danaher; Wash DC (Other locations possible);
Global Trade Compliance Manager; Requisition ID: DAN000510

* DB Schenker (2 positions); Atlanta GA, and Long Beach CA;
Area Customs Director
; Requisition ID: 17P009

* DHL; Netherlands;
Manager Customs Compliance
; Requisition ID: req39070 

* Erickson Inc.; Portland OR;
Trade Compliance Manager
Joanna Rafiner-Jarboe
; Requisition 2017-2267

* Esterline Technologies Corporation; Brea CA;
Sr. Trade Compliance Manager;
Requisition ID: 7333BR

* Esterline Technologies Corporation; Paso Robles CA;
Trade Compliance Manager
; Requisition ID: 6148BR

* Expeditors; Sunnyvale CA;
Customs Compliance Specialist
* Export Solutions Inc.; Melbourne FL; Trade Compliance Specialist;

* FD Associates, Tysons Corner VA;
Senior Export Compliance Associate

* FlightSafety International; Oklahoma; Trade Compliance Advisor; Requisition ID 16480

FLIR; Billerica MA; 
Sr. Defense Trade Licensing & Compliance Analyst
; Requisition ID: 8008

Fluke: Everett WA; 
Trade Compliance Manager
; Requisition ID: FLU005544
* General Dynamics Information Technology; Falls Church VA;
Division Export Compliance Coordinator
; Requisition ID: 2017-21288

* Givaudan; Bogor, Indonesia;
Compliance Manager
; Requisition ID: 68063
* Harris Corporation; Clifton NJ; 
Trade Compliance Analyst

; Requisition ID: ES20172404-18675

* Ingersoll Rand; San Diego, CA; Latin America Trade Compliance Manager (Trilingual: English, Spanish, and Portuguese); Requisition ID: 1610632

* Intel; Santa Clara CA;
Global Export Compliance Specialist
; Requisition ID: JR0814909

* KPMG; Antwerp, Brussels;
Manager Global Trade & Customs – SAP GTS
; 122756BR

* Lam Research Corporation; Fremont CA;
Foreign Trade Intern 1

* Lam Research Corporation; Shanghai, China;
Foreign Trade Analyst 

* Lutron; Coopersburg PA;
Trade Manager-Export
; Requisition ID: 2926

* L-3 Technologies; Arlington VA;
Sr. Mgr. Corporate Customs Compliance
; Requisition ID: 087862

* L-3 Technologies, Platform Integration Division; Waco TX;
Import/Export Compliance Administrator 3
; Requisition ID 

* Lockheed Martin; Orlando FL;
International Trade Compliance Sr Staff / ITAR / EAR / Export Control Officer
; Requisition ID: 387435BR

* Mars – Wrigley; Chicago IL; 
Global Trade Compliance Analyst (Corporate Export)
; Requisition ID: 69452

* Maxim Integrated; Dallas TX;
Manager, Global Trade
; 3304BR

* Medtronic; Heerlen, The Netherlands;
Trade Compliance Analyst
; 16000DYY

* Medtronic; Wash DC;
Global Trade Lawyer
; Requisition ID: 170002ON

* Meggitt PLC; Maidenhead, UK;
Trade Compliance Officer 

* Meggit-USA, Inc.; Simi Valley CA;
Trade Compliance Administrator
; Requisition ID: 25172

* Northrop Grumman Corporation; Herndon VA;
International Trade Compliance Analyst 2
; Requisition ID: 17010105

* Northrop Grumman Corporation; Herndon VA;
International Trade Compliance Analyst 3/4; Requisition ID: 17001180

* Northrop Grumman Corporation; Linthicum MD;
International Trade Compliance Analyst 1
; 17003433
* Northrop Grumman Corporation; Linthicum MD;
International Trade Compliance Analyst 3
; 17005262

* Northrop Grumman Sperry Marine; New Malden, UK;
Trade Compliance Coordinator

* Panduit; Tinley Park IL;
Global Trade Compliance Agent
; Requisition ID: PAND-03297

* Parexel; Billerica MA;
Vice President, Chief Compliance Officer; Requisition ID: pare-00024091

* Plexus Corporation; Neenah Wi;
Manager – Export Compliance
; Requisition ID: 14645BR
* Plexus Corporation; Neenah Wi;
Manager – Import Compliance
; Requisition ID: 14593BR
* Premier Farnell Organisation; Leeds, UK;
Trade Compliance Specialist – Europe
; 4301

* Roanoke Insurance Group; Schaumburg IL;
Carnet Service Representative
; Requisition ID: 1019

* Raytheon; Andover MA and Woburn MA;
Manager of Export Import Control, Empowered Officials
; Requisition ID: 93622

* Raytheon; Arlington VA;
Export Licensing Manager I
; Requisition ID: 94113BR

* Raytheon Australia; Canberra, Australia;
Export/Import Operations Advisor; Requisition ID: 86438BR

* Raytheon; McKinney TX;
Counsel Global Trade Compliance
; Requisition ID: 94826BR

* Raytheon; Portsmouth RI;
Manager of Export Import Control, Empowered Official
; Requisition ID: 93628

* Raytheon; Woburn MA;
Supply Chain Compliance Manager; Requisition ID: 93734BR

* Raytheon Space & Airborne Systems; McKinney TX;
Sr Exp License & Compliance Adv;
; 310-334-7499; Requisition ID:

* Saab Defense and Security USA LLC; Syracuse NY;
Senior Import/Export Analyst
; Requisition ID: USA_00413
* SABIC; Houston TX;
Analyst Import/Export Compliance
; Requisition ID: 7792BR

* Talbots; Hingham MA;
Sr Mgr Global Trade & Customs Compliance
; Requisition ID: 1077

* Talbots; Lakeville MA;
Dir., Global Logistics & Customs Com
; Requisition ID: 1085

* Teledyne Microwave Solutions; Mountain View CA;

Trade Compliance Administrator 2
; Requisition ID: 2017-4111

* Tesla Motors; Fremont CA;
Global Supply Manager – Logistics
; Requisition ID: 38153

* Thales Defense and Security, Inc.; Clarksburg MD; Senior Manager Trade Compliance
; William.Denning@thalesdsi.com; Requisition ID: 2592

* ThermoFisher Scientific; Breda, the Netherlands;
Import/Export Specialist – EMEA CMD Commercial Offices
; Requisition ID: 44930BR

* ThermoFisher Scientific; Germering, Germany;
Specialist, Trade Compliance
; 47293BR
* ThermoFisher Scientific; Shanghai, China;
Trade Compliance Specialist
; Requisition ID: 37381BR
* ThermoFisher Scientific; Shanghai, China;
Trade Compliance Specialist
; Requisition ID: 48394BR
* ThermoFisher Scientific; Shanghai, China;
Trade Compliance Specialist
; Requisition ID: 44904BR

* United Technologies Corporation, UTC Aerospace Systems; Brea CA;
Sr. Anlst, Intl Trade Compl
; Requisition ID: 46798BR

* United Technologies Corporation, UTC Aerospace Systems; Chula Vista CA;

International Trade Compliance Intern
; Requisition ID:

* United Technologies Corporation, UTC Aerospace Systems; Chula Vista CT;
International Trade Compliance Analyst
; Requisition ID: 46876BR

* United Technologies Corporation, UTC Aerospace Systems; Santa Fe Springs CA;
Sr. Analyst, International Trade Compliance
; Requisition ID: 46184BR

* United Technologies Corporation, UTC Aerospace Systems; Troy OH;
Sr. Manager, Intl Trade Compliance
; Requisition ID: 44065BR 

* United Technologies Corporation, UTC Aerospace Systems; Westford MA;
Senior Analyst, International Trade Compliance
; Requisition ID: 31576BR

* United Technologies Corporation, UTC Aerospace Systems; Windsor Locks, CT; Investigations and Disclosures Specialist; Requisition ID: 46282BR

* United Technologies Corporation, UTC Aerospace Systems; Windsor Lock CT;
International Trade Compliance Site Lead
; Requisition ID: 47259BR

* Varex Imaging Corp; Salt Lake City UT; 
Senior Customs Compliance Analyst
; Requisition ID: 

* Vigilant; Unknown location in the U.S.;
BioTech/Pharmaceutical Global Trade Analyst

* XPO Logistics; Greenwich CT;
Global Trade Compliance Analyst

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* L. Frank Baum (Lyman Frank Baum, 15 May 1856 – 6 May 1919, was an American author chiefly known for his children’s books, particularly The Wonderful Wizard of Oz. He wrote thirteen novel sequels, nine other fantasy novels, and a host of other works (55 novels in total, plus four “lost works”, 83 short stories, over 200 poems, an unknown number of scripts, and many miscellaneous writings.)
  – “I can’t give you a brain, but I can give you a diploma.”
* B.C. Forbes (Bertie Charles Forbes, 14 May 1880 – 6 May 1954, was a Scottish-born American financial journalist and author. He founded Forbes magazine in 1917 and remained editor-in-chief until his death in New York City in 1954, though assisted in his later years by Bruce Charles Forbes (1916-1964) and Malcolm Stevenson Forbes (1919-1990), his two eldest sons.)
  – “Work is the meat of life, pleasure the dessert.”
Monday is pun day.
Q. Why did Einstein wear suspenders?
A. To be eligible for the No-Belt Prize!
  — Colleen Hill, San Francisco, CA

* * * * * * * * * * * * * * * * * * * *

. Are Your Copies of Regulations Up to Date?
(Source: Editor)

The official versions of the following regulations are published annually in the U.S. Code of Federal Regulations (C.F.R.), but are updated as amended in the Federal Register.  Changes to applicable regulations are listed below.
: 27 CFR Part 447-Importation of Arms, Ammunition, and Implements of War
  – Last Amendment: 15 Jan 2016: 81 FR 2657-2723: Machineguns, Destructive Devices and Certain Other Firearms; Background Checks for Responsible Persons of a Trust or Legal Entity With Respect To Making or Transferring a Firearm. 
: 19 CFR, Ch. 1, Pts. 0-199
  – Last Amendment: 27 Jan 2017: 82 FR 8589-8590: Delay of Effective Date for Importations of Certain Vehicles and Engines Subject to Federal Antipollution Emission Standards; and 82 FR 8590: Delay of Effective Date for Toxic Substance Control Act Chemical Substance Import Certification Process Revisions.

  – Last Amendment: 18 May 2016: Change 2: Implement an insider threat program; reporting requirements for Cleared Defense Contractors; alignment with Federal standards for classified information systems; incorporated and canceled Supp. 1 to the NISPOM  (Summary here.)

  – Last Amendment: 18 Apr 2017: 82 FR 18217-18220: Revision to an Entry on the Entity List)

: 31 CFR, Parts 500-599, Embargoes, Sanctions, Executive Orders
  – Last Amendment:
10 Feb 2017: 82 FR 10434-10440: Inflation Adjustment of Civil Monetary Penalties. 
: 15 CFR Part 30
  – Last Amendment: 19 Apr 2017: 82 FR 18383-18393: Foreign Trade Regulations: Clarification on Filing Requirements 
  – HTS codes that are not valid for AES are available
  – The latest edition (19 Apr 2017) of Bartlett’s Annotated FTR (“BAFTR”), by James E. Bartlett III, is available for downloading in Word format. The BAFTR contains all FTR amendments, FTR Letters and Notices, a large Index, and footnotes containing case annotations, practice tips, and Census/AES guidance.  Subscribers receive revised copies every time the FTR is amended. The BAFTR is available by annual subscription from the Full Circle Compliance website.  BITAR subscribers are entitled to a 25% discount on subscriptions to the BAFTR.
, 1 Jan 2017: 19 USC 1202 Annex. (“HTS” and “HTSA” are often seen as abbreviations for the Harmonized Tariff Schedule of the United States Annotated, shortened versions of “HTSUSA”.)
  – Last Amendment: 7 Mar 2017: Harmonized System Update 1702, containing 1,754 ABI records and 360 harmonized tariff records. 
  – HTS codes for AES are available
  – HTS codes that are not valid for AES are available
  – Latest Amendment: 11 Jan 2017: 82 FR 3168-3170: 2017 Civil Monetary Penalties Inflationary Adjustment
  – The only available fully updated copy (latest edition 8 Mar 2017) of the ITAR is Bartlett’s Annotated ITAR (“BITAR”), by James E. Bartlett III. The BITAR contains all ITAR amendments to date, plus a large Index, over 750 footnotes containing case annotations, practice tips, DDTC guidance, and explanations of errors in the official ITAR text.  Subscribers receive updated copies of the BITAR in Word by email, usually revised within 24 hours after every ITAR amendment.  The BITAR is available by annual subscription from the Full Circle Compliance website.  BAFTR subscribers receive a 25% discount on subscriptions to the BITAR, please contact us to receive your discount code.

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Review last week’s top Ex/Im stories in “Weekly Highlights of the Daily Bugle Top Stories” published

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* The Ex/Im Daily Update is a publication of FCC Advisory B.V., edited by James E. Bartlett III and Alexander Bosch, and emailed every business day to approximately 8,000 readers of changes to defense and high-tech trade laws and regulations. We check the following sources daily: Federal Register, Congressional Record, Commerce/AES, Commerce/BIS, DHS/CBP, DOJ/ATF, DoD/DSS, DoD/DTSA, State/DDTC, Treasury/OFAC, White House, and similar websites of Australia, Canada, U.K., and other countries and international organizations.  Due to space limitations, we do not post Arms Sales notifications, Denied Party listings, or Customs AD/CVD items.

* RIGHTS & RESTRICTIONS: This email contains no proprietary, classified, or export-controlled information. All items are obtained from public sources or are published with permission of private contributors, and may be freely circulated without further permission. Any further use of contributors’ material, however, must comply with applicable copyright laws.

* CAVEAT: The contents of this newsletter cannot be relied upon as legal or expert advice.  Consult your own legal counsel or compliance specialists before taking actions based upon news items or opinions from this or other unofficial sources.  If any U.S. federal tax issue is discussed in this communication, it was not intended or written by the author or sender for tax or legal advice, and cannot be used for the purpose of avoiding penalties under the Internal Revenue Code or promoting, marketing, or recommending to another party any transaction or tax-related matter.

* SUBSCRIPTIONS: Subscriptions are free.  Subscribe by completing the request form on the Full Circle Compliance website.

* TO UNSUBSCRIBE: Use the Safe Unsubscribe link below.

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