17-0717 Monday “Daily Bugle”

17-0717 Monday “Daily Bugle”

Monday, 17 July 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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  1. DHS/CBP Corrects Proposed Rule Concerning Extension of Port Limits of Savannah, GA
  2. DHS/CBP Seeks Comments on Adjustment of Customs COBRA User Fees to Reflect Inflation
  1. Ex/Im Items Scheduled for Publication in Future Federal Register Editions
  2. Commerce/BIS: (No new postings.)
  3. State/DDTC: (No new postings.)
  4. EU Council Imposes Additional Sanctions Against Syria
  5. EU P2P Posts Summaries of Activities
  6. Singapore Customs Releases Circular Concerning Responsibility of Declaring Agents for Conditions Issued in Cargo Clearance Permits
  1. Defense News: “Swedish Bill Could Slow Weapons Sales to Nondemocratic Countries”
  2. ST&R Trade Report: “Import and Export Controls Imposed on Precursor Chemical”
  1. J.E. Bartlett: “Big Changes to the Foreign Trade Regulations Tomorrow — Including Some Big Mistakes”
  2. O. Torres & D. Kyle: “Whatcha Gonna Do When They Come For You? Export Control Agency Visits”
  3. Gary Stanley’s ECR Tip of the Day
  1. Monday List of Ex/Im Job Openings 
  1. Bartlett’s Unfamiliar Quotations 
  2. Are Your Copies of Regulations Up to Date? Latest Changes: ATF (15 Jan 2016), Customs (13 Jul 2017), DOD/NISPOM (18 May 2016), EAR (7 Jul 2017), FACR/OFAC (16 Jun 2017), FTR (19 Apr 2017), HTSUS (28 Jun 2017), ITAR (11 Jan 2017) 
  3. Weekly Highlights of the Daily Bugle Top Stories 



DHS/CBP Corrects Proposed Rule Concerning Extension of Port Limits of Savannah, Georgia

82 FR 32669: Extension of Port Limits of Savannah, GA
  In proposed rule document 2017-13983, beginning on page 30807, in the issue of Monday, July 3, 2017, make the following correction: 
  On page 30808, in the first column, the coordinates listed in line seven of “III. Proposed Port Limits of Savannah, Georgia”, “080[deg]04.998′ W.” should read “080[deg]54.998′ W.”

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DHS/CBP Seeks Comments on Adjustment of Customs COBRA User Fees to Reflect Inflation

82 FR 32661-32669: Procedures to Adjust Customs COBRA User Fees to Reflect Inflation
* AGENCY: U.S. Customs and Border Protection, Department of Homeland Security; Department of the Treasury.
* ACTION: Notice of proposed rulemaking.
* SUMMARY: This document proposes to amend the U.S. Customs and Border Protection (CBP) regulations to reflect that customs user fees and limitations established by the Consolidated Omnibus Budget Reconciliation Act (COBRA) will be adjusted for inflation in accordance with the Fixing America’s Surface Transportation Act (FAST Act).
* DATES: Comments must be received on or before August 16, 2017. … 
Explanation of Amendments
  Part 24
  Part 24 of Title 19 of the Code of Federal Regulations (CFR) sets forth the regulations regarding customs financial and accounting procedures. (19 CFR part 24). Section 24.22 describes the customs COBRA user fees and corresponding limitations for certain services (set forth in Table 1 below), which include the commercial vessel arrival fees, commercial truck arrival fees, railroad car arrival fees, private vessel arrival fees, private aircraft arrival fees, commercial aircraft passenger arrival fees, dutiable mail fees, customs broker permit user fees, barges and other bulk carriers arrival fees. (19 CFR 24.22). Section 24.23 describes the customs COBRA user fees and corresponding limitations for processing merchandise (set forth in Table 2 below). (19 CFR 24.23). CBP proposes to amend sections 24.22 and 24.23 to reflect the new requirements set forth in the FAST Act.
  Specifically, CBP proposes to add a new specific authority citation for section 24.22 and to amend the specific authority citation for section 24.23 to include the American Jobs Creation Act of 2004 (Pub. L. 108-357) and the FAST Act. In addition, CBP proposes to add an introductory paragraph to both sections explaining that the COBRA user fees and corresponding limitations are subject to adjustment annually to reflect the increase, if any, in the CPI-U pursuant to the FAST Act. The new introduction will also explain where to find the methodology that CBP will use to determine whether an adjustment to the fees and limitations is necessary as well as the means of notice and publication of any fee adjustments. CBP will announce the adjusted fee and limitation amounts by publishing a notice in the Federal Register annually for each fiscal year at least 30 days prior to the effective date of the new fees and limitations. The current amount for all customs COBRA user fees and corresponding limitations will be maintained on the CBP Website.
  Proposed Amendments to Sec.  24.22
  CBP proposes to amend paragraphs (b)(1)(i), (b)(1)(ii), (b)(2)(i), (b)(2)(ii), (c)(1), (c)(2), (c)(3), (d)(1), (d)(2), (d)(3), (e)(1), (e)(2), (f), (g)(1)(i), (g)(1)(ii), (g)(2), (g)(5)(v), (i)(7), (i)(8) and (h) of section 24.22 to explain that the specific fee amounts and annual fee limitations (set forth in Table 1 below) are subject to adjustment in accordance with the terms in a new paragraph (k). (19 CFR 24.22). The new paragraph (k) will set forth the methodology for determining whether and by what amount the customs COBRA user fees should be adjusted pursuant to the FAST Act. …
  CBP also proposes to amend paragraph (c) to clarify that there are two distinct fees that the current regulations describe as one fee. First, the CBP commercial truck arrival fee (currently $5.50) and second the Animal and Plant Health Inspection Service/Agricultural Quarantine Inspection (APHIS/AQI) fee (currently $7.55) that CBP collects on behalf of APHIS. (19 CFR 24.22(c)). Specifically, CBP proposes to revise the header and the text in paragraph (c)(1) to state that there are two fees and to state in paragraph (c)(2) that the annual limitation on the CBP portion of the commercial truck arrival fee is $100 once a prepayment in that amount is made. (19 CFR 24.22(c)).
  In addition, CBP proposes to make technical updates to paragraph (g) to reflect the elimination of the user fee exemption for passengers arriving from Canada, Mexico or one of the adjacent islands pursuant to the United States-Colombia Trade Promotion Agreement Implementation Act. (Colombia TPA, Pub. L. 112-42, October 21, 2011). Section 601 of the Colombia TPA amended 19 U.S.C. 58c(b)(1)(A)(i) to limit the fee exemption to passengers whose journey originated in a territory or possession of the United States, or originated in the United States and was limited to the territories and possessions of the United States. (19 U.S.C. 58c(b)(1)(A)(i)). CBP has been collecting the non-exempt user fees since the law became effective on November 5, 2011. CBP proposes corresponding updates to remove this exemption from the regulations found in paragraphs (g)(1)(i), (g)(1)(i)(A), (g)(1)(i)(B), (g)(1)(ii), (g)(1)(iii), the chart in paragraph (g)(2)(iv), and the collection procedures in paragraphs (g)(4)(ii)(A), (g)(4)(ii)(B), (g)(4)(ii)(C), (g)(4)(iii)(A), (g)(4)(iii)(B), and (g)(4)(iii)(C). (19 CFR 24.22(g)). CBP also proposes to remove the definition of “adjacent islands” from paragraph (g)(1)(iii) as references to adjacent islands have been removed from paragraph (g). (19 CFR 24.22(g)).
  Additionally, CBP proposes an amendment to paragraph (g)(2)(iii) to clarify that journeys between ports in the United States are not subject to the fee. (19 CFR 24.22(g)(2)(iii)).
  CBP also proposes to amend paragraph (h) of section 24.22 by changing the name of the fee from broker permit fee to broker permit user fee and specifying the fee amount of $138. (19 CFR 24.22(h)). Finally, CBP proposes to amend paragraph (h) by removing the cross-reference to section 111.96(c) and replacing it with a reference to new paragraph (k). (19 CFR 24.22(h) and 111.96(c).)
  A new paragraph (k) is added setting forth the methodology to determine whether adjustments of fee and limitation amounts are necessary, and if so, how to calculate the adjustments. CBP will determine annually whether an adjustment to the fees and limitations is necessary and a notice specifying the amount of the fees and limitations will be published in the Federal Register annually for each fiscal year at least 30 days prior to the effective date of the new fees and limitations.
  Steps for Adjusting Fees and Limitations
  CBP proposes to use the following methodology in determining whether adjustment of the fees and corresponding limitations is necessary and, if so, by how much the amounts would be adjusted.
  Step 1: Calculate the arithmetic average of the Consumer Price Index–All Urban Consumers, U.S. All items, 1982-84 = 100 (CPI-U) for the current year based on the most recent June-May period. This figure is referred to as (A).
  Step 2: Use the figure 236.009 which is the arithmetic average of the CPI-U for FY 2014. This figure is referred to as (B).
  Step 3: State the arithmetic average of CPI-U for the comparison year, which will be either (B) if the fees have never been adjusted in accordance with this paragraph (k), or the arithmetic average of the CPI-U for the last year in which fees were adjusted in accordance with this paragraph (k) (as set forth in the Federal Register notice that last adjusted the fee). This figure is referred to as (C).
  Step 4: Calculate the difference between the arithmetic averages of the CPI-U of the comparison year (C) and the current year (A). This difference is referred to as (D). (D) = (A)-(C).
  Step 5: Round the difference (D) to the nearest whole number. This figure is referred to as (E).
  Step 6: Calculate the percentage change in the arithmetic averages of the CPI-U of the comparison year (C) and the current year (A), which is referred to as (F). (F) = ((E) / (C)) x 100%.
  Step 7: If (F) is one (1) percent or more, proceed to the next step (8). If (F) is less than one (1) percent, no adjustment will be made.
  Step 8: Calculate the difference in the arithmetic average of the CPI-U between the current year (the most recent June through May period) and the base year (FY 2014). This difference is referred to as (G). (G) = (A)-(B).
  Step 9: Calculate the percentage change in the CPI-U from the base year to the current year. This figure is referred to as (J). (H) = ((G) / (B)) x 100%.
  Step 10: Increase the fees and limitations that are subject to the rules of this paragraph by (H), calculating fees to the second decimal.
  Proposed Amendments to Sec.  24.23
  In section 24.23, CBP proposes to amend paragraphs (b)(1)(i)(A), (b)(1)(i)(B), (b)(1)(ii), (b)(2)(i), (b)(2)(ii), (b)(2)(iii) and (b)(4) to add a reference to explain that the specific fee amounts and annual fee limitations (set forth in Table 2) are subject to adjustment in accordance with the terms in new paragraph (k) of section 24.22. (19 CFR 24.23(b).) Table 2 below indicates the customs COBRA user fees and corresponding limitations currently set forth in section 24.23. (19 CFR 24.23). CBP proposes to add this table to the regulations as Appendix B to part 24. …
  The Merchandise Processing Fee (MPF) is comprised of an ad valorem rate, a minimum fee amount, and a maximum fee amount. Adjusting the minimum and maximum fee amounts for the MPF pursuant to the FAST Act will reflect any increase in inflation. The value of the merchandise–to which the rate applies–will necessarily increase on its own along with inflation, obviating the need separately to adjust the rate specified in 19 CFR 24.23(b)(1)(i)(A).
  In addition, CBP proposes to amend paragraph (b)(4) to include the statutory minimum and maximum limitations on the fees for express consignment carrier facilities or centralized hubs. (19 CFR 24.23(b).) The statute provides for adjustment of this fee from an amount not less than $0.35 to an amount not more than $1 per individual airway bill or bill of lading. (19 U.S.C.58c(b)(9)(B)(i).) These fee limitations are also subject to adjustment pursuant to the FAST Act and therefore, must also be annually adjusted for inflation, if necessary. To include this second set of maximum and minimum fees, CBP proposes to split paragraph (b)(4) into three new paragraphs: (i) For general provisions, (ii) to describe the maximum and minimum fees, and (iii) for quarterly payment requirements. (19 CFR 24.23(b)). New paragraph (b)(4)(iii) will also reflect that two electronic payment methods, Fedwire and pay.gov, are available for submitting quarterly payments.
  The figure of $2,000 found at 19 U.S.C. 58c(b)(9)(A) is neither a fee nor a limitation on a fee, but a reference to the allowable value for informal entries authorized pursuant to 19 U.S.C. 1498, that are subject to the fee established by 19 U.S.C. 58c(b)(9). It is not subject to the adjustment for inflation under the FAST Act. (19 U.S.C. 1498 was amended in 1993, and the merchandise value limitation on informal entries authorized by 19 U.S.C. 1498 was raised from $2,000 to $2,500.)
  Part 111
  CBP proposes conforming amendments to Part 111. (19 CFR part 111.) Specifically, CBP proposes to remove the specific amount of the annual customs broker permit user fee ($138), found in paragraph (c) of section 111.19 and paragraph (c) of section 111.96, and add a reference to section 24.23(h) in section 111.96(c). (19 CFR 24.23(h), 111.19(c) and 111.96(c).) …
  Kevin K. McAleenan, Acting Commissioner, U.S. Customs and Border Protection.
  Approved: July 10, 2017.
Timothy E. Skud, Deputy Assistant Secretary of the Treasury.

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OGS_a13. Ex/Im Items Scheduled for Publication in Future Federal Register Editions
(Source: Federal Register

[No items of interest noted today.]
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EU Council Imposes Additional Sanctions Against Syria

On 17 July 2017, the Council of the EU added 16 persons to the list of those targeted by EU restrictive measures against the Syrian regime. The EU added these16 persons for their role in the development and use of chemical weapons against the civilian population, in line with the EU’s policy to fight the proliferation and use of chemical weapons. These persons include 8 high-ranking military officials and 8 scientists involved in chemical weapons proliferation and delivery. The EU had already imposed  restrictive measures on high ranking officials , most recently on 4 March 2017  for the use of chemical weapons.
Today’s decision brings to 255 persons the total number of persons targeted by a travel ban and an assets freeze for being responsible for the violent repression against the civilian population in Syria, benefiting from or supporting the regime, and/or being associated with such persons.
In addition, 67 entities are targeted by an assets freeze. More broadly, sanctions currently in place against Syria include an oil embargo, restrictions on certain investments, a freeze of the assets of the Syrian central bank held in the EU, export restrictions on equipment and technology that might be used for internal repression as well as on equipment and technology for the monitoring or interception of internet or telephone communications. These measures were last extended on 29 May 2017 and are in place until 1 June 2018.
The EU remains committed to finding a lasting political solution to the conflict in Syria under the existing UN-agreed framework. As stated in the EU strategy on Syria adopted in April 2017, the EU believes that there can be no military solution to the conflict and strongly supports the work of the UN Special Envoy and the intra-Syrian talks in Geneva. 
As the leading donor in the international response to the Syrian crisis with over €9.4 billion from the EU and member states collectively allocated in humanitarian and development assistance since the start of the conflict, the EU continues to support the delivery of humanitarian aid to all Syrians, including those who are under siege or in areas which are hard to reach. The EU response also includes support to international institutions which work to ensure accountability for violations of human rights and of international humanitarian law.
The EU will be ready to assist in the reconstruction of Syria only when a comprehensive, genuine and inclusive political transition, negotiated by the Syrian parties in the conflict on the basis of UN Security Council Resolution 2254 (2015) and the 2012 Geneva Communiqué, is firmly under way.
The legal acts adopted by the Council, including the names of the persons concerned, are published in the Official Journal of 18 July 2017.
  – Syria: Council response to the crisis (background information)
  – Factsheet: The EU and the crisis in Syria
  – Meeting Page

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EU P2P Posts Summaries of Activities

(Source: EU P2P)
The EU Partner-to-Partner (EU P2P) has published the following summaries of its activities in July:
  – 4-5 July 2017: Nay Pyi Taw, Myanmar/Burma: First Legal Workshop in Myanmar

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. Singapore Customs Releases Circular Concerning Responsibility of Declaring Agents for Conditions Issued in Cargo Clearance Permits

(Source: Singapore Customs)
Singapore Customs has released Circular No. 09/2017, “Advisory: Responsibility of Declaring Agents for Conditions issued in Cargo Clearance Permits.” The circular is available here

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Defense News: “Swedish Bill Could Slow Weapons Sales to Nondemocratic Countries”

Defense News, 14 July 2017.)  
Sweden’s Social Democratic government has received general support from opposition parties for a new legislative plan to curb weapons sales to so-called autocratic and nondemocratic nations.
The proposed legislation would have a direct impact on weapons sales to certain countries in the Middle East, Africa, Asia and South America. Military sales to countries applicable under the new proposal would be regulated according to tougher humans rights criteria.
The proposed legislation will amend Sweden’s existing Arms Export Controls Act. The strong degree of opposition party support for the legislative initiative means the new law could be introduced as early as 2018.
Countries that will be affected by the proposed legislation, like Oman, Saudi Arabia and the United Arab Emirates, all remain important customers for Sweden’s defense industry companies. 
Saab Group’s CEO, Håkan Buskhe, warned government and opposition leaders that an “overly intrusive” arms control law could increase the company’s domestic production costs, restrict the geographic scope for exports and might force it to relocate parts of its research and development operations abroad. 
Prime Minister Stefan Löfven’s administration has been under considerable pressure from opposition party leaders to tighten weapons sales and exports.
Opposition parties, led by the Centre, Moderate, Liberals and Green parties, had demanded weapons sales be further restricted to “dictatorship” states and countries where human rights are perceived to be under threat.
The legislative process has seen the government present a legislative bill containing a new, so-called democracy clause to the Riksdag’s (Sweden’s national parliament) Council on Legislation.
The Council on Legislation is tasked with examining the core proposals in the draft bill to ensure they do not conflict with Sweden’s constitution and legal obligations, both in terms of domestic and international law.
Moderate Party defense spokesman Hans Wallmark described the legislative bill as a “compromise” solution that will give Sweden’s defense companies greater certainty in doing business globally and exporting abroad.
  “Some parties, like the Christian Democrats, wanted to ban weapons sales to all dictator states. It was important that the bill also recognized the need to protect, and not weaken, Sweden’s defense industry. This Bill provides for such clarity and does not weaken our defense industry,” Wallmark said.

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ST&R Trade Report: “Import and Export Controls Imposed on Precursor Chemical”

The Drug Enforcement Administration has issued a final rule designating the chemical alpha-phenylacetoacetonitrile and its salts, optical isomers, and salts of optical isomers as a list I chemical under the Controlled Substances Act. Effective Aug. 14 this rule will subject importers, exporters, manufacturers, and distributors of any amount of APAAN to all of the regulatory controls (registration, records and reporting, inspection, etc.) and administrative, civil, and criminal actions applicable to the importing, exporting, manufacturing, and distribution of a list I chemical.
This rule does not establish a threshold for domestic and import transactions of APAAN; as a result, all such transactions regardless of size will be regulated. Chemical mixtures containing any amount of APAAN will also be regulated unless the DEA approves an application for exemption.
According to the DEA, APAAN meets the criteria for designation as a list I chemical because it is used in clandestine laboratories to illicitly manufacture the schedule II controlled substances phenylacetone (also known as phenyl-2-propanone or P2P), methamphetamine, and amphetamine.

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11. J.E. Bartlett: “Big Changes to the Foreign Trade Regulations Tomorrow — Including Some Big Mistakes”

Author:  Jim Bartlett, Law Office of James E. Bartlett III, PLLC, Washington, DC, and Partner, Full Circle Compliance, BV, Bruchem, Netherlands; 202-802-0646 or JEBartlett@JEBartlett.com.

The amendments to the Foreign Trade Regulations (FTR) made April 19, 2017, by 82 FR 18383-18393, take effect tomorrow, July 18th.  This is a major change of over 100 sections of the FTR, the regulation from the Bureau of the Census that requires statistical reporting of most exports from the United States under the Automated Export System and the filing of Electronic Export Information (EEI) reports.  Most of the changes are related to implementing the International Trade Data Systems (ITDS), the means by which the data collection of U.S. Government agencies will be incorporated into the design of the Automated Commercial Environment (ACE). 

The changes made in this Final Rule are as follows:
  – Amend the proposed rule to remove the definition and filing requirement for the used electronics indicator.
  – Section 30.1(c) is amended to revise the definition of “Carrier” to include a Non Vessel Operating Common Carrier (NVOCC) as an example of a carrier because the Automated Export System Trade Interface Requirements allows the Standard Carrier Alpha Code of a NVOCC to be reported.
  – Section 30.1(c), is amended to add the definition of “U.S. Postal Service customs declaration form” to identify the shipment document used for exports by mail.
  – Section 30.1(c), is amended to revise the definition of “Commercial loading document” to include the U.S. Postal Service customs declaration form as an example of a commercial loading document.
  – The note to Sec. 30.2(a)(1)(iv) is amended to add Country Group E:2 to ensure consistency with the Export Administration Regulations (EAR).
  – Section 30.2(c) is amended to clarify the application and certification process by dividing the section based on the filing method, AESDirect or methods other than AESDirect. As a result, the title was amended to read as “Application and Certification Process” as opposed to “Certification and Filing Requirements.”
  – Section 30.3(e)(2) is amended to add language requiring the authorized agent to provide the filer name in addition to the Internal Transaction Number (ITN) and date of export as proposed in the NPRM, when requested by the U.S. Principal Party in Interest in a routed transaction.
  – Section 30.4(b)(2)(v) is amended to read “mail” rather than “mail cargo” and the phrase “filing citation or exemption legend” will be revised to read “proof of filing citation, postdeparture filing citation, AES downtime filing citation, exemption or exclusion legend.”
  – Section 30.8(a) is amended to more accurately reflect U.S. Postal Service operations.
  – Section 30.16(d) is amended to add Country Group E:2 to ensure consistency with the EAR.
  – Section 30.28 is amended to add language removed from 30.28(c) to the opening paragraph.
  – Section 30.29(a)(2) is amended by clarifying that a license value is only required to be reported for shipments licensed by a U.S. Government agency.
  – Section 30.29(b)(2) is amended to replace the term “commercial document” with the defined term “commercial loading documents”.
  – Section 30.37(y) is amended to add Country Group E:2 to ensure consistency with the EAR.
  – Delete Appendices B, C, E and F because the Appendices were initially created to assist the trade in transitioning from the Foreign Trade Statistics Regulations (FTSR) to the FTR and are no longer necessary. As a result of deleting Appendices B, C, E, and F, Appendix D is redesignated as Appendix B.

Unfortunately, the FTR amendments going into effect tomorrow contain numerous errors. Census will probably correct them in an FTR Letter in a few days, then follow with an official Federal Register corrective notice. Among the errors are:
(1) Appendix B was deleted by the amendment, but FTR § 30.6(a)(18),
Export information code, states, “For the list of the codes see Appendix B.” The Export Information Codes, previously in Part II of Appendix B, no longer exist, yet § 30.6(a)(18) still directs the reader to Appendix B, which is now titled “Appendix B to Part 30-AES Filing Citation, Exemption and Exclusion Legends,” and contains no Export Information Codes.
(2) Appendix C was deleted by the amendment, but the FTR still references “Appendix C” in § 30.52.
(3) Appendix D was renamed as Appendix B, and there is no longer an Appendix D, but references to “Appendix D” remain in FTR § 30.1(c), § 30.4(c)(3), § 30.7(b), and § 30.8.
(4) The Federal Register editors in 2013 inserted an Editorial Note following section 30.1, explaining that they could not incorporate the Kimberly Process Certificate (KPC) amendment because of inaccurate amendatory instructions. Tomorrow’s new version leaves that 4 year-old error message in place.
Would you like a printed copy of the FTR?  Although GPO’s “e-CFR”
Internet edition will update the on-line edition of the FTR in a few days, the most usable version of the FTR is FCC’s version,
Bartlett’s Annotated FTR (“The BAFTR”), available for downloading today in Word format from
Full Circle Compliance.  Distributed as a Word file, you can read it on your laptop or print it out to 148 pages for your 3-ring binder. The BAFTR contains the full text of the regulation plus all FTR amendments, FTR Letters, Notices, a huge Index, and footnotes containing case annotations, practice tips, and Census/AES guidance.  The footnotes also point out the many errors in the official text.  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.

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12. O. Torres & D. Kyle: “Whatcha Gonna Do When They Come For You? Export Control Agency Visits”

Torres Law PLLC
* Authors: Olga Torres, Esq.; and Dick Kyle, Esq.. Both of Torres Law PLLC.  Contact information: 214-593-7120,
Many exporters are at least vaguely familiar with the “company visits” or “outreach visits” conducted by the export control agencies, but most have very little idea what these visits actually entail, how a company is selected for a visit, or the potential consequences of such a visit. Exporters, freight forwarders, non-exporting manufacturers of defense articles, and companies that share controlled technology with foreign persons, resulting in “deemed exports” should thoroughly prepare for these visits if they are ever “lucky enough” to be selected.
This article will constitute the first part of a two-part series and will introduce the reader to the types of visits conducted by the two major export control agencies: the Department of Commerce’s Bureau of Industry and Security (“BIS”) and the Department of State’s Directorate of Defense Trade Controls (“DDTC”). Additionally, this article will discuss some of the potential outcomes and consequences of these visits. In the forthcoming second part of the article, we will summarize our recommendations to prepare for and make the best of such a visit.
  DDTC Company Visit Program
The DDTC administers the International Traffic in Arms Regulations (“ITAR”) and maintains the U.S. Munitions List (“USML”) of controlled defense articles. Generally, the DDTC regulates exports of defense items, develops and enforces defense trade export control laws and regulations, and maintains registration requirements for manufacturers, exporters, and brokers of defense articles and defense services. DDTC also operates a Company Visit Program (“CVP”), which consists of visits by DDTC officials to entities registered with the DDTC, as well as other entities involved in ITAR-related activities.
In its current form, DDTC’s CVP supports two types of visits: CVP-Outreach, called “CVP-O” and CVP-Compliance (“CVP-C”). [FN/1] CVP-O is referred to by DDTC as an extension of DDTC’s outreach activities. According to DDTC, CVP-O visits are intended to be learning exercises for both the selected company and DDTC. During a CVP-O visit, a company has the opportunity to discuss the compliance challenges it faces with actual DDTC personnel. For their part, the DDTC team has the opportunity to see first-hand how members of industry are adapting to changes to the ITAR and other compliance changes. The CVP-O team can also provide suggestions for best practices and answer any questions the visited company may have. DDTC claims that CVP-O site visits are unrelated to any specific compliance matters and has stated that CVP-O visits are more educational in nature and are not conducted to evaluate compliance failures or violations.
DDTC also engages in CVP-C visits, which are conducted by the Office of Defense Trade Controls Compliance (“DTCC”) to verify company compliance. For example, if a company has entered into a consent agreement after the discovery of ITAR violations, the company should expect a CVP-C visit in the future. CVP-C visits may also occur in the context of the adjudication of a voluntary self-disclosure (“VSD”), directed disclosure, or other compliance matter. CVP-C visits will include a more in-depth look at a company’s compliance program and procedures.
Typically, DDTC aims to conduct between two and four CVP visits (of either type) per quarter. From May 2015 to April 2016, DDTC conducted fifteen CVP visits, and six of those were CVP-C visits pursuant to consent agreement monitoring. Six of the fifteen CVP visits were conducted in foreign countries. [FN/2] DDTC addresses how a company is selected for a CVP visit, but specific details are sparse. According to its website, DDTC “selects companies based on its CVP goals” and considers multiple factors when selecting a company. These factors include “proximity to other activities DDTC is participating in, registration status, volume of licensed activity, experience conducting ITAR activities, nature of business, type and sensitivity of technology, geographic location, monitoring of an existing consent agreement, and value to ongoing work within DDTC.” [FN/3]
  BIS Outreach Visits
BIS administers the Export Administration Regulations (“EAR”) and its Commerce Control List of sensitive “dual-use” goods and technology. Like DDTC, BIS also conducts on-site “outreach” visits. Unlike the ITAR, though, the EAR has no requirement for exporting or manufacturing entities to register with BIS. Thus, unlike DDTC-registered companies which by virtue of their registration are within the pool of companies that should be prepared for a CVP visit, the lack of an EAR registration requirement means that companies subject to BIS’ jurisdiction may not be explicitly aware of their potential to be selected for a visit from BIS. 
BIS conducts two different types of visits, but whereas both types of DDTC visits are administered within the same CVP framework, the two types of BIS visits are conducted by two completely separate divisions within BIS. The first, and far more common, type of visit is an “outreach visit” conducted by BIS’ Office of Export Enforcement (“OEE”). Technically speaking, the OEE creates a distinction between situations where a company requests OEE to come, called a “visit,” and where OEE arrives uninvited, called an “inquiry.” For simplicity’s sake, we’ll refer to all situations where OEE comes to a company as an “outreach visit.”
OEE outreach visits are conducted by OEE officers, the “guns and badges” branch of BIS, through the division’s Outreach Program. OEE has informed the public that companies that could be selected for visits include, but are not limited to, manufacturers, exporters, and freight forwarders. It is not entirely clear how OEE selects companies for outreach visits. However, exporters that have recently submitted an export license application without having previously applied for any licenses in the past have been targeted for outreach visits. In fiscal year 2016, OEE conducted more than 743 outreach visits to individuals and companies within the export community. [FN/4]
BIS’ Office of Exporter Services Export Management and Compliance Division (“EMCD”) has also begun to conduct company visits over the past couple of years. These visits are much less frequent than OEE outreach visits; only 40 on-site EMCD visits were conducted during fiscal year 2016. [FN/5] EMCD selects entities for a company visit based on filing errors found within the Automated Export System (“AES”). BIS explains that EMCD meets with these entities “to better understand the specific reasons that errors occurred, determine what export compliance procedures they [have] in place, and offer export counseling assistance.” [FN/6]
  Consequences of Visits
Typically, the only consequence of receiving a company visit from either DDTC or BIS is becoming more familiar with the agencies’ expectations for compliance. However, in some cases there certainly can be negative consequences. One area of concern is that it is unclear how either agency handles violations discovered during a visit. Per the DDTC website, if the DDTC visit team discovers a violation during their visit, DDTC will instruct the company to review the issue and submit a disclosure, if necessary. [FN/7] Importantly, DDTC does not specify whether the disclosure would be a VSD or a directed disclosure. The distinction is important because the submission of a VSD is considered a mitigating factor in the levying of any potential penalties, while a directed disclosure does not provide for any mitigation. BIS has provided no official guidance as to how it handles the discovery of violations during visits.
Additionally, in some cases BIS has imputed “knowledge” on a violating company based on evidence that the company participated in outreach visits in the past. For example, the charging documents in a recent $27 million settlement with an exporter detail several instances where BIS and other government agencies conducted outreach visits with the charged party. These visits were explicitly referenced to establish “knowledge” i.e., the exporter knew of its compliance obligations and violated the regulations anyway. [FN/8] Knowledge of the illegality of actions is an important piece of building an administrative case against an exporter, as well as providing an important component for recommending a case to the Department of Justice for criminal prosecution.
It is clear that, although potentially helpful and informative, visits by the export control agencies may not, and often are not, entirely positive experiences. With critical factors at stake like the mitigation of penalties or referral to the Department of Justice, visits from DDTC or BIS should be treated with the respect they deserve. The forthcoming second part of this article will discuss how to best prepare for a visit from one of the above referenced export control agencies and provide recommendations for navigating a visit with optimum results.
If you have been selected for a company visit by an export agency and wish to share your experience, or simply seek more information about these visits, we encourage you to contact us.
  [FN/1] On April 19, 2017, DDTC published recommendations for improvements to the CVP that were proposed by the Defense Trade Advisory Group (“DTAG”). The DTAG is made up of U.S. private sector defense exporters and defense trade specialists that act as a formal channel for consultation and coordination with DDTC on issues involving U.S. laws, policies, and regulations related to defense exports. At this point, it is unknown whether any of DTAG’s recommendations will be adopted by DDTC. The PowerPoint presentation providing the recommendations, called “Company Visit Program Guidelines,” is available at DDTC’s website
, under the heading for April 19, 2017.  Torres Law Managing Member, Olga Torres, is a member of DTAG.
  [FN/2] Defense Trade Controls Compliance Company Visit Program (CVP), DDTC, 10 (July 2016), available
  [FN/3] Company Visit Program (CVP), DDTC (Sept. 21, 2016), available
  [FN/4] Annual Report to Congress for Fiscal Year 2016, Department of Commerce, Bureau of Industry and Security, 16 (Oct. 7,2016), available
  [FN/5] Id. at 10.
  [FN/6] Id.
  [FN/7] Company Visit Program (CVP), DDTC (Sept. 21, 2016), available
  [FN/8] In the Matter Of Access USA Shipping, LLC, Settlement Agreement, Department of Commerce, Bureau of Industry and Security, 4 (Feb. 7, 2017), available

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13Gary Stanley’s ECR Tip of the Day

(Source: Defense and Export-Import Update; available by subscription from
* Author: Gary Stanley, Esq., Global Legal Services, PC, (202) 352-3059,
Established in 1990, the Blue Lantern program monitors the end-use of defense articles, technical data, services, and brokering activities exported through commercial channels and subject to Department of State licenses or other approvals under section 38 of the Arms Export Control Act (AECA) (22 U.S.C. 2778) and the International Traffic in Arms Regulations (ITAR) (22 CFR Parts 120-130). Blue Lantern end-use monitoring includes pre-license, post-license, and post-shipment checks to verify the bona fides of foreign consignees and end-users, confirm the legitimacy of proposed transactions, and provide reasonable assurance that 1) the recipient is complying with the requirements imposed by the United States Government with respect to use, transfers, and security of defense articles and defense services; and 2) such articles and services are being used for the purposes for which they are provided.

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MS_a114. Monday List of Ex/Im Job Openings

(Source: Editor)  
Published every Monday or first business day of the week. Please send openings in the following format to jobs@fullcirclecompliance.eu.
#” New listing this week:
* Abcam; Cambridge, United Kingdom;
Trade Compliance Coordinator; Requisition ID: CAM-012-996
* Acteon Group Ltd.; Norwich, Suffolk, or London, UK;
Head of Compliance; or email
Mike Pay
* Advanced Micro Devices (AMD); Austin TX; 
Import/Export Compliance Manager
; Requisition ID: 24061

Akin Gump Strauss Hauer & Feld LLP; Washington DC; 
International Trade and Customs Specialist
; Requisition ID: 147

* 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

* Ansell; Iselin NJ;
Senior Specialist NA Trade Compliance; Requisition ID: IRC6513
* Applied Materials; Alzenau, Germany;
Europe Trade Manager
; Requisition ID: (M3)-1701376

* Arthrex; Naples FL;
Senior Compliance Officer;

* ASML; Veldhoven, the Netherlands;
Senior Manager Trade & Customs;
Requisition ID: RC05619
* Babcock; Portsmouth, United Kingdom; 
Divisional Trade & Compliance Manager

* 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 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

Cubic Corporation; San Diego, CA; 
Senior Export Compliance Analyst

Requisition ID: 5982

* 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

* DRS Technologies; Dayton, OH;
Senior Trade Compliance Manager

* Eaton; Titchfield, United Kingdom;
Global Trade Manager (Trade Compliance); Requisition ID: 020681

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

* Esterline CMC Electronics; Montreal, Quebec, Canada;
Senior Manager Trade Compliance; Requisition ID: 9971BR

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

* 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 Atomics Aeronautical Systems, Inc.; San Diego CA; 

International Trade Compliance Analyst (ITC) / Export Import Specialist / Global Trade Administrator
; Requisition ID: 12252BR

General Dynamics Land Systems; Sterling Heights, MI; Site Lead/Compliance OfficerRequisition ID: 

General Dynamics Land Systems; Sterling Heights, MI; Compliance Officer


* George Washington University; Washington DC;
Research Compliance Officer, Export Control
; Requisition ID: PI97906765

* Givaudan; Bogor, Indonesia;
Compliance Manager
; Requisition ID: 68063
* Harris Corporation; Clifton NJ; 
Trade Compliance Analyst
; Requisition ID: ES20172404-18675
# Harsco; Columbia, SC; Import/Export Specialist

* Indiana Mills & Manufacturing, Inc.; Westfield, IN;
International Trade Compliance Manager

* 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
Livingston International; Western Region (TX, CA, OR, WA preferred)

Trade Ad

Livingston International; Western Region (TX, CA, OR, WA preferred);
Research Consultant

* 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

* ManTech International; Herndon VA; 
Director of Corporate Export Control
; Requisition ID: 90965BR

* 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
; Requsition ID: 16000DYY

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

* Meggitt PLC; Maidenhead, UK;
Trade Compliance Officer 
* Momentive Performance Materials, Inc.; Waterfield, NY;
Manager, Global Trade Compliance

* North Dakota State University; Fargo ND;
Director for Research Integrity Compliance; Requisition ID: 1700372

* Northrop Grumman; Falls Church VA; 
International Trade Compliance Analyst 3/4
; Patricia Vives, 
; Requisition ID: 17011893

* 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

* 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
; Requisition ID: 4301
* Raytheon; (El Segundo CA, McKinney TX, Dallas TX, Marlborough MA, or Washington D.C.);
Senior Manager of Global Trade Management
; Requisition ID: 98724BR

* Raytheon; Rosslyn, VA; 
Export Trade Compliance Specialist; Requisition ID: 97978BR

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

* Saab Defense and Security USA LLC; Syracuse NY;
Senior Import/Export Analyst
; Requisition ID: USA_00413

* Science and Engineering Services, LLC; Huntsville AL;
Export Compliance Specialist
bob.davis@ses-i.com; Requisition ID: 157
# Sierra Nevada Corporation; Arlington, VA; 
International Trade Compliance Analyst II; Req ID: R0003259

* SIRE: Noord-Brabant province, the Netherlands;
Trade Compliance Expert; Requisition ID: 33934

* Talbots; Hingham MA;
Sr Mgr Global Trade & Customs Compliance
; Requisition ID: 1077
* Talbots; Lakeville MA;
Dir., Global Logistics & Customs Com
; Requisition ID: 1085

* 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

* UBC; Monheim, Germany;
Manager Customs and Trade Compliance 
* Ultra Electronics; Greater London, United Kingdom;
International Trade and Export Compliance Specialist

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

* United Technologies Corporation, UTC Aerospace Systems; Burnsville MN;

ITC Tech Manager- SIS
; Requisition ID:38565BR

International Trade Compliance Analyst
; Requisition ID: 46876BR

United Technologies Corporation, UTC Aerospace Systems; Rockford IL;
Specialist, International Trade Compliance- Operations and Licensing
; Requisition ID: 50118BR

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

* University of North Carolina; Chapel Hill, NC;
Export Control Officer

* VAG; Mannheim, Germany;
Trade Compliance Manager (m/w)
; Contact: Mr. Florian Uhl, +49 621 749 – 1870

Vertiv (formerly Emerson Network Power); Columbus, OH,  
International Trade Management (ITM) Senior Specialist
; Req #1700001087

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

* Xilinx, Inc.; San Jose, CA, US;
Global Trade Compliance Program Manager; Requisition ID: 153811

* XPO Logistics; Greenwich CT;
Global Trade Compliance Analyst

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* Jesse Ventura (born James George Janos on 15 July 1951, is an American former professional wrestler, actor, political commentator, author, naval veteran, television host, and politician who served as the 38th Governor of Minnesota from 1999 to 2003. He was the first and only member of the Reform Party to win a major government position, but later joined the Independence Party of Minnesota.)
  – “Wrestling is ballet with violence.”
* Mary Baker Eddy (16 Jul 1821 – 3 Dec 1910, was the founder of Christian Science, a new religious movement in the United States in the latter half of the 19th century.
Eddy wrote the movement’s textbook, Science and Health with Key to the Scriptures, and founded the Church of Christ, Scientist in 1879.)
  – “Jealousy is the grave of affection.”
* Isaac Watts (17 Jul 1674 – 25 Nov 1748, was an English Christian minister, hymn writer, theologian, and logician. He was a prolific and popular hymn writer and is credited with some 750 hymns, including Joy to the World, O God, Our Help in Ages Past, and When I Survey the Wondrous Cross.)
  – “Learning to trust is one of life’s most difficult tasks.”
Monday is Pun Day. 
Today’s geography lesson:
Q. Do you know where Engagement, Ohio, is?”
A. Halfway between Dayton and Marion.
  – Mary Lou Gasser, Wooster, OH

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. 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: 13 Jul 2017: 82 FR 32232-32241: Electronic Information for Cargo Exported from the United States; Technical Amendments

  – 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 cancelled Supp. 1 to the NISPOM  (Summary here.)

: 15 CFR Subtit. B, Ch. VII, Pts. 730-774

  – Last Amendment: 7 July 2017: 
82 FR 31442-31449: Revisions to the Export Administration Regulations Based on the 
2016 Missile Technology Control Regime Plenary Agreements. 

: 31 CFR, Parts 500-599, Embargoes, Sanctions, Executive Orders
  – Last Amendment: 16 Jun 2017: 82 FR 27613-27614: Removal of Burmese Sanctions Regulations 
: 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 (18 July 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, Census/AES guidance, and to many errors contained in the official text. 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: 28 Jun 2017: Harmonized System Update 1704, containing 2,564 ABI records and 463 harmonized tariff records. 
  – HTS codes for AES are available
  – HTS codes that are not valid for AES are available
  – Last Amendment: 11 Jan 2017: 82 FR 3168-3170: 2017 Civil Monetary Penalties Inflationary Adjustment
  – The only available fully updated copy (latest edition: 10 Jun 2017) of the ITAR with all amendments is contained in Bartlett’s Annotated ITAR (“BITAR”), by James E. Bartlett III.  The BITAR contains all ITAR amendments to date, plus a large Index, over 800 footnotes containing amendment histories, 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., compiled by: Editor, James E. Bartlett III; Assistant Editors, Alexander P. Bosch and Vincent J.A. Goossen; and Events & Jobs Editor, John Bartlett. The Ex/Im Daily Update is 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.

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