The Daily Bugle Weekly Highlights: Week 2 (6 Jan – 10 Jan 2020)

Every Monday we post the highlights out of last week’s FCC Export/Import Daily Update (“The Daily Bugle”). Send out every business day to approximately 7,500 readers of changes to defense and high-tech trade laws and regulations, The Daily Bugle is a free daily newsletter from Full Circle Compliance, edited by James E. Bartlett III, and Alexander Witt.

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Last week’s highlights of The Daily Bugle included in this edition are:

1. Commerce/BIS Amends EAR by Adding AI Software Export Restrictions

(Source: Federal Register, 6 Jan 2020.) [Excerpts.]

85 FR 459-462: Addition of Software Specially Designed to Automate the Analysis of Geospatial Imagery to the Export Control Classification Number 0Y521 Series

* AGENCY: Bureau of Industry and Security, Commerce.

* ACTION: Interim final rule with request for comments.

* SUMMARY: In this interim final rule, the Bureau of Industry and Security (BIS) amends the Export Administration Regulations (EAR) to make certain items subject to the EAR and to impose a license requirement for the export and reexport of those items to all destinations, except Canada. Specifically, this rule classifies software specially designed to automate the analysis of geospatial imagery, as specified, under the Export Control Classification Number (ECCN) 0Y521 series, specifically under ECCN 0D521. BIS adds this item to the 0Y521 series of ECCNs upon a determination by the Department of Commerce, with the concurrence of the Departments of Defense and State, and other agencies as appropriate, that the items warrant control for export because the items may provide a significant military or intelligence advantage to the United States or because foreign policy reasons justify control, pursuant to the ECCN 0Y521 series procedures.

* DATES: This rule is effective January 6, 2020. Comments must be received by March 6, 2020.

* ADDRESSES: You may submit comments by any of the following methods: Federal rulemaking portal: The ID number for this rule is BIS-2019-0031. All comments (including any personally identifying information) will be made available for public inspection and copying. Address: By mail or delivery to Regulatory Policy Division, Bureau of Industry and Security, U.S. Department of Commerce, Room 2099B, 14th Street and Pennsylvania Avenue NW, Washington, DC 20230. Refer to RIN 0694-AH89.

* FOR FURTHER INFORMATION CONTACT: Aaron Amundson, Director, Information Technology Division, Office of National Security and Technology Transfer Controls, at email or by phone at (202) 482-5299. …


2. State/DDTC Issues New FAQs on Defense Services U.S. Persons Abroad

(Source: State/DDTC, 6 Jan 2020.)

Please see the Frequently Asked Questions published today for guidance on the subject of U.S. persons providing defense services abroad. The guidance addresses questions regarding registration and authorization requirements, as well as the process for obtaining authorization. The guidance is based on existing content in the ITAR, rather than the 2015 proposed rule that was not adopted.


3. Treasury/OFAC Issues Amended Venezuela-related General License 6A

(Source: Treasury/OFAC, 7 Jan 2020.)

​The Department of the Treasury’s Office of Foreign Assets Control (OFAC) is issuing amended Venezuela-related General License 6A, “Authorizing Certain Activities Necessary to the Wind Down of Operations or Existing Contracts with Globovision Tele C.A. or Globovision Tele CA, Corp.”


4. EU Amends Restrictive Measures Concerning Mali

(Source: Official Journal of the European Union, 8 Jan 2020.)


* Council Implementing Regulation (EU) 2020/8 of 7 January 2020 implementing Article 12(1) of Regulation (EU) 2017/1770 concerning restrictive measures in view of the situation in Mali


* Council Implementing Decision (CFSP) 2020/9 of 7 January 2020 implementing Decision (CFSP) 2017/1775 concerning restrictive measures in view of the situation in Mali


5. UK ECJU Updates List of Controlled Military and Dual-Use Items

(Source: UK ECJU, 8 Jan 2020.)

The UK Export Control Joint Unit (ECJU) within the Department of International Trade (TID) has published the following update on its website:

Consolidated list of strategic military and dual-use items that require export authorizatio

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