;

16-0826 Friday “The Daily Bugle”

16-0826 Friday “Daily Bugle”

Friday, 26 August 2016

TOPThe 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 here for free subscription. Contact us for advertising inquiries and rates.

  1. DHS/CBP Amends Regulations, Seeks Comments on Administrative Exemption on Value Increased for Certain Articles 
  1. Ex/Im Items Scheduled for Publication in Future Federal Register Editions 
  2. Commerce/Census: “Who is the USPPI? It could be YOU!” 
  3. Commerce/BIS: (No new postings.) 
  4. DoD/DSCA Posts SAMM and Policy Memoranda, Week 21-27 Aug 
  5. State/DDTC: (No new postings.) 
  1. Defense News: “US Seeking Global Armed Drone Export Rules”
  2. Expeditors News: “CBP Reminds Trade of Protest in ACE Date”
  3. ST&R Trade Report: “Dates and Deadlines: Protests, ACE, Medical Devices, Export Regulations, AGOA”
  1. Gary Stanley’s ECR Tip of the Day 
  1. Friday List of Approaching Events 
  1. Bartlett’s Unfamiliar Quotations 
  2. Are Your Copies of Regulations Up to Date? Latest Changes: ATF (15 Jan 2016), Customs (26 Aug 2016), DOD/NISPOM (18 May 2016), EAR (23 Aug 2016), FACR/OFAC (18 May 2016), FTR (15 May 2015), HTSUS (1 Jul 2016), ITAR (17 Aug 2016)

EXIMEX/IM ITEMS FROM TODAY’S FEDERAL REGISTER

EXIM_a1

1
. DHS/CBP Amends Regulations, Seeks Comments on Administrative Exemption on Value Increased for Certain Articles

(Source: Federal Register) [Excerpts.]
 
81 FR 58831-58834: Administrative Exemption on Value Increased for Certain Articles
* AGENCY: U.S. Customs and Border Protection; Department of the Treasury.
* ACTION: Interim final rule; solicitation of comments.
* SUMMARY: This document amends the U.S. Customs and Border Protection regulations to implement section 901 of the Trade Facilitation and Trade Enforcement Act of 2015 by raising from $200 to $800 the value of certain articles that may be imported by one person on one day free of duty and tax. This document also makes clarifying and conforming amendments to the regulations.
* DATES:
   Effective date: This interim final rule is effective on August 26, 2016.
   Comment date: Written comments must be submitted on or before September 26, 2016.
* ADDRESSES: You may submit comments, identified by docket number USCBP-2016-0057, by one of the following methods: …
* FOR FURTHER INFORMATION CONTACT: Randy Mitchell, Director, Commercial Operation, Revenue and Entry, Trade Policy and Programs, Office of Trade, U.S. Customs and Border Protection, (202) 863-6532.
* SUPPLEMENTARY INFORMATION: …
   CBP implements the administrative exemption provided for in 19 U.S.C. 1321 in its regulations at 19 CFR 10.151 and 10.153. The administrative exemption amount is also referenced in various other sections in the CBP regulations: Sec. Sec. 128.21(a)(4)(ii); 128.24(d) and (e); 143.21(l)(1); 143.23(j); 143.26; and 145.31. In all of the previously listed sections that currently provide that the 19 U.S.C. 1321(a)(2)(C) administrative exemption amount is $200, CBP is amending the regulations to reflect that the new amount is $800.
   This rule also amends the scope of alcohol and tobacco products covered by the limitation in paragraph (e) of section 10.153, to conform to other past statutory changes. Perfume is removed from the list of products excluded from the administrative exemption because the excise tax on such products was eliminated in 1995 pursuant to section 136 of the Uruguay Round Agreements Act, Public Law 103-465. Paragraph (e) of section 10.153 is also amended pursuant to amendments to the Internal Revenue Code, Section 5701, which increased excise taxes for smokeless tobacco, pipe tobacco, roll-your-own tobacco, and cigarette tubes and papers. 26 U.S.C. 5701, as amended by the Children’s Health Insurance Program Reauthorization Act of 2009 (Pub. L. 111-3). …
 
R. Gil Kerlikowske, Commissioner, U.S. Customs and Border Protection.
   Approved: August 23, 2016.
Timothy E. Skud, Assistant Secretary of the Treasury.

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OGSOTHER GOVERNMENT SOURCES

OGS_a12. Ex/Im Items Scheduled for Publication in Future Federal Register Editions
(Source: Federal Register)

* Commerce; Industry and Security Bureau; NOTICES; Agency Information Collection Activities; Proposals, Submissions, and Approvals: Potential Market Impact of the Proposed Fiscal Year 2018 Annual Materials Plan [Publication Date: 29 August 2016.]

* State; NOTICES; Agency Information Collection Activities; Proposals, Submissions, and Approvals: Technology Security/Clearance Plans, Screening Records, and Non-Disclosure Agreements [Publication Date: 29 August 2016.]

* Treasury; Foreign Assets Control Office; NOTICES; Blocking or Unblocking of Persons and Properties [Publication Date: 29 August 2016.]

* U.S. Customs and Border Protection; PROPOSED RULES; Toxic Substance Control Act Chemical Substance Import Certification Process Revisions [Publication Date: 29 August 2016.]

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

(Source:
Global Reach Blog)

 
Questions about who the U.S. Principal Party in Interest (USPPI) is often come up when reporting exports. The USPPI is the person or legal entity in the United States that receives the primary benefit, monetary or otherwise, from an export transaction. The following parties can be the USPPI:
 
  – U.S. seller (wholesaler or distributor) of goods for export
  – U.S. manufacturer (if selling the goods for export)
  – U.S. order party (if directly negotiated between the U.S. seller and foreign buyer and received the order for the export of the goods)
  – U.S. customs broker (obtains clearance of goods through customs)
  – Foreign entity (if physically in the United States to purchase or obtain the goods)
 
Helpful tips to identify the USPPI 
 
  – The USPPI remains the same regardless of whether the transaction is standard or routed. For more information on the differences between standard and routed transactions, please see Clarification of Routed Transactions.
  – The exchange of funds does not need to occur for an entity to be the USPPI. For example, a U.S. company exporting goods at no cost (i.e., donations, replacement parts) to a subsidiary abroad would be the USPPI.
 
Identification scenarios
̶
 
Scenario 1:

Company A in the United States manufactures lamps. Once assembled, the lamps are sold to Company B in the United States. Company C in Canada places an order with Company B and authorizes Company B to export the lamps to the ultimate consignee in France. Who is the USPPI and why?

Company B is the USPPI because it received the primary benefit from the foreign buyer. The transaction between Companies A and B is a domestic transaction.
 
Scenario 2:
 
A representative from Company A in Mexico is in the United States buying electronics from Company B. After making the purchase, Company A’s representative authorizes Company C in the United States to file Electronic Export Information in the Automated Export System and move the electronics on Company A’s behalf. Company A’s representative returns to Mexico. Who is the USPPI and why? 

Company A’s representative is the USPPI because they were physically in the United States at the time the goods were purchased. 
 
Scenario 3:
 
Company A in the United States stores bamboo stalks in a warehouse on behalf of a Foreign Principal Party in Interest. While in the warehouse, Company A converts the bamboo stalks into fishing rods. Who is the USPPI and why?

Company A is the USPPI because it was responsible for converting the bamboo stalks into fishing rods, changing the classification.
 
I hope this information provides more clarity on who the USPPI is in an export transaction. For assistance, please call 800-549-0595, Option 3 to contact the Trade Regulations Branch of the U.S. Census Bureau.

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OGS_a56. State/DDTC: (No new postings.)

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NWSNEWS

 
The US State Department is asking countries to sign onto a set of international norms for the sale and use of armed unmanned systems, with top State officials holding meetings with delegates from various nations at this week’s Arms Trade Treaty conference in Geneva on the subject.
 
In recent weeks the department sent out a one page document, entitled “Proposed Joint Declaration of Principles for the Export and Subsequent Use of Armed or Strike-Enabled Unmanned Aerial Systems (UAS),” to a number of international allies.
 
Defense News obtained a copy of the Joint Declaration, and a State Department official, speaking on background, confirmed the authenticity of the document. However, the official stressed that it was a draft declaration and not the final language that could eventually be used.
 
A US delegation, led by Brian Nilsson, Deputy Assistant Secretary of State for Defense Trade Controls in the Bureau of Political-Military Affairs, travelled to Geneva this week with the express purpose of holding meetings with foreign delegations attending the conference and encouraging them to sign onto the Declaration.
 
The State official would not confirm if any countries have agreed to sign on, but there are indications that the US will seek to unveil a list of signatories around the time of a set of UN meetings starting Oct. 3.
 
The document lays out five key principals for international norms, including the “applicability of International law” and human rights when using armed drones; a dedication to following existing arms control laws when considering the sale of armed unmanned systems; that sales of armed drone exports take “into account the potential recipient country’s history regarding adherence to international obligations and commitments”; that countries who export unmanned strike systems follow “appropriate transparency measures” when required; and a resolution to continue to “ensure these capabilities are transferred and used responsibly by all States.”
 
That language is likely to fall well below what anti-drone advocates and the arms control community would like to see, but the State Department official, speaking on background given the nature of ongoing discussions, said the document represents only an “important first step” towards creating international standards for drone exports.
 
  “The Declaration is a political commitment by its signatories that stands on its own merits, but it is also intended to inform future, more fulsome international standards that could address factors beyond compliance with existing international law and transparency requirements ,” the official said.
 
Michael Horowitz, a former Pentagon official who is now an associate professor of political science at the University of Pennsylvania who has focused on drone export policies, says the language presented in the draft declaration is in line with the new drone export rules put in place by the US in February 2015.
 
  “This is an attempt by the Obama Administration to confront the inevitability of drone proliferation in a way that promotes the responsible use of drones by other countries,” Horowitz told Defense News.
 
In essence, the language put forth in the draft Declaration would put international producers of unmanned systems in line with the same rules and regulations US producers have followed since the release of those 2015 guidelines.
 
  “One of the best tools the US has to shape how countries use drones, ironically, is to export drones to them, given the ability of the US to leverage arms export rules to shape how countries use technology,” Horowitz added. “Especially if the US increasingly views drone proliferation as inevitable, the Obama administration likely views rules of the road as critical to ensure that the rest of the world uses drones responsibly.”
 
Indeed, the State official acknowledged that creating a global standard is very much a focus at Foggy Bottom.
 
  “As other nations begin to employ military UAS more regularly and as the nascent commercial UAS market emerges, the United States has a responsibility to ensure that sales, transfers, and subsequent use of all US-origin UAS are responsible and consistent with US national security and foreign policy interests, including economic security, as well as with U.S. values and international standards,” the official said.
 
The challenge facing the State department may be getting the major producers of armed unmanned systems to join onto such an agreement. After all, it’s one thing to get a country that does not plan to produce armed systems to sign on, but quite another to get a nation like China to agree on rules that could potentially restrict its defense industry growth.
 
A 2015 analysis by IHS Janes predicted the drone export market, including both armed and unarmed systems, would exceed $10 billion by 2024, with China, Russia, India, South Korea and Japan are predicted to reach $3.4 billion in sales during that period.
 
Meanwhile, a May 2016 report from analysis group Avascent found that Israel will continue to grow its defense sector at the expense of Western exporters, driven in large part by its unmanned systems sales.
 
Horowitz noted that getting countries to agree to export “in a responsible manner may actually help other exporters get customers, particularly if US exports do not increase.” But, he said, many countries will likely need time to come to that conclusion.
 
  “I would expect other countries to take some time to digest the US initiative, particularly if they worry that it might cut into their export markets,” Horowitz said. “US leadership will be critical in persuading other countries that such an initiative is in their interests as well as that of the United States.”

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NWS_a28. Expeditors News: “CBP Reminds Trade of Protest in ACE Date”
(Source: Expeditors News)
 
On August 25, 2016 U.S. Customs and Border Protection (CBP) released Cargo Systems Messaging Service (CSMS) #16-000744 as a reminder that protest filing in the ACE Secure Data Portal (ACE Portal) will begin on August 27, 2016.
 
CBP noted that once protests in the ACE Portal goes into effect the Document Image System (DIS) will no longer accept protest submissions. The ACE Protest page contains an Information Notice that details protest functionality as well as how to create an account. Additional guidance can be found on the published reference guide also on the ACE Protest page.
 
The full CSMS and link to the Protest page can be accessed here.

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NWS_a39. ST&R Trade Report: “Dates and Deadlines: Protests, ACE, Medical Devices, Export Regulations, AGOA”

(Source: ST&R Trade Report)
 
Following are highlights of regulatory effective dates and deadlines and federal agency meetings coming up in the next week.
 
  – Aug. 29: deadline for comments to USDA on cold treatment facilities to aid fruit imports
  – Aug. 29: effective date of mandatory ACE filing for electronic protests
  – Aug. 29: deadline for comments to Treasury Dept. on information collections on ACE, drawback, cigars
  – Aug. 30: deadline for comments to USDA on information collections on imported fruits and vegetables
  – Aug. 30: deadline for comments to USDA on proposal to allow imports of bone-in lamb meat from Uruguay
  – Aug. 30: deadline for comments to FDA on proposed rule to establish requirements for entry filing in ACE
  – Aug. 30: deadline for comments to ITC on potential IPR import restrictions on personal transporters
  – Aug. 31: effective date of USDA final rule revising imported peanut standards
  – Aug. 31: deadline for comments to ITC on potential IPR probe of breathing treatment systems
  – Sept. 1: effective date of BIS and DDTC final rules amending EAR and ITAR
  – Sept. 1: effective date of ITA rule to prevent manipulation of AD margins
  – Sept. 2: deadline for comments to USTR on eligibility for AGOA duty preferences
 
 – Sept. 2: deadline for comments to DOC on information collection on
direct investment abroad

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COMMCOMMENTARY

 
* Author: Gary Stanley, Esq., Global Legal Services, PC, (202) 352-3059,
gstanley@glstrade.com
 
ITAR § 130.3 defines the term “armed forces” as meaning “the army, navy, marine, air force, or coast guard, as well as the national guard and national police, of a foreign country. This term also includes any military unit or military personnel organized under or assigned to an international organization.”

 

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TrainingEX/IM TRAINING EVENTS & CONFERENCES

TE_a211
. Friday List of Approaching Events

(Sources: Event sponsors.) 
 
Published every Friday or last publication day of the week. Send events to
apbosch@fullcirclecompliance.eu
, composed in the below format:

* DATE: PLACE; “TITLE;” SPONSOR; WEBLINK; CONTACT (email and phone number)
 
Continuously Available Training:
* Executive Masters: “
International Trade Compliance
;” University of Liverpool;
exed@liverpool.ac.uk
;
+44 (0) 20 768 24614
* E-Seminars: “
US Export Controls” / “Defense Trade Controls
;” Export Compliance Training Institute;
danielle@learnexportcompliance.com 
* On-Line: “
Simplified Network Application Process Redesign (SNAP-R)
;” Commerce/BIS; 202-482-2227
* E-Seminars: “
Webinars On-Demand Library
;” Sandler, Travis & Rosenberg, P.A.
 
Training by Date:

* Sep 1: Webinar; “
Filing Protests in the New ACE Electronic Protest Module;”
Sandler, Travis & Rosenberg, P.A.;
Webinarorganizers@strtrade.com
* Sep 7: Wash DC; “ComDef 2016; IDEAA, Inc.

* Sep 7: Webinar; “
Navigating the Customs Regulations to Find the Information You Need
;”
Sandler, Travis & Rosenberg, P.A.;
Webinarorganizers@strtrade.com 

* Sep 9: Woodbridge VA; “
2016 Fall Golf Outing
;” Society for International Affairs

* Sep 12-15: Chicago, IL: “United States Export Control (EAR/OFAC/ITAR);” ECTI; jessica@learnexportcompliance.com; 540-433-3977

* Sep 12-14: Isle of Palms SC; “43rd South Carolina International Trade Conference;” South Carolina International Trade Conference

* Sep 12-13: Wash DC; “
WorldECR Export Controls and Sanctions Forum 2016
;” WorldECR;
Mark.Cusick@WorldECR.com 

* Sep 13-16: Dallas; “‘Partnering for Compliance™’ West Export/Import Control Training and Education Program;” Partnering for Compliance West; Ailish@PartneringForCompliance.org; 321-952-2978

* Sep 13-14: Silicon Valley CA; “
Complying with U.S. Export Controls
;”
Dept. of Commerce/Bureau of Industry and Security

* Sep 14-15: Annapolis; “
EAR/ITAR Boot Camp;” Export Compliance Solutions (ECS);
spalmer@exportcompliancesolutions.com; 866-238-4018

* Sep 14-16: Dallas TX; “
7th Annual ‘Partnering For Compliance™’ West Export/Import Control Program
;” Partnering For Compliance™
* Sep 14-15: Detroit MI; “
Export Compliance, International Documentation and Automated Commercial Environment
;” East Michigan District Export Council

* Sep 15: London; “Making Better License Applications;”
UK/BIS Export Control Organisation;
denise.carter@bis.gsi.gov.uk 

* Sep 15: Silicon Valley CA; “
Encryption Controls
;”
Dept. of Commerce/Bureau of Industry and Security

* Sep 19-22: Houston TX; “
Customs Broker Exam Boot Camp
;” Export-Import Law Institute;
info@bestcustomsbrokercourse.com
; 800-256-2013

* Sep 20: Oxford UK; “Intermediate Seminar;”
UK/BIS Export Control Organisation;
denise.carter@bis.gsi.gov.uk 

* Sep 20: Orlando FL; “
AES Compliance Seminar
;” Dept. of Commerce/Census
& M-Palm;
shawn@m-palm.com 

* Sep 20-21: Shanghai; “
2nd Advanced Conference on China Antitrust
;” American Conference Institute

* Sep 21: Buffalo NY; “
Essentials of U.S. Export Controls
;”
Dept. of Commerce/Bureau of Industry and Security

* Sep 21: Oxford UK; “Beginners Workshop;”
UK/BIS Export Control Organisation;
denise.carter@bis.gsi.gov.uk 

* Sep 21: Oxford UK; “Making Better Licence Applications;”
UK/BIS Export Control Organisation;
denise.carter@bis.gsi.gov.uk 
* Sep 21-24: San Antonio TX; “
Texas Customs Brokers Brokers & Forwarders Association Annual Conference
;” Texas Brokers and Forwarders Association
* Sep 21: Wash DC; “
In-House Industry Seminar
;” Dept. of State/DDTC;
DDTCeSeminars@state.gov 

* Sep 22: Buffalo NY; ”
How to Develop an Export Management and Compliance Program
;”
Dept. of Commerce/Bureau of Industry and Security

* Sep 27-29: London UK; “Annual Anti-Bribery and International Trade Conference;” Email Kate Bullard to Request an Invitation to this Event; Baker McKenzie

* Sep 28-29: Amsterdam NL: “Defence Expors 2016;” SMi

* Oct 3-6: Amsterdam NL: “United States Export Control (EAR/OFAC/ITAR) (for EU and other non-US Companies);” ECTI;jessica@learnexportcompliance.com; 540-433-3977

* Oct 5: Leeds UK; “Intermediate Seminar;”
UK/BIS Export Control Organisation;
denise.carter@bis.gsi.gov.uk 

* Oct 6: Leeds UK; “Beginners Workshop;”
UK/BIS Export Control Organisation;
denise.carter@bis.gsi.gov.uk 
* Oct 6: Leeds UK; “Control List Classification – Combined Dual Use and Military;”
UK/BIS Export Control Organisation;
denise.carter@bis.gsi.gov.uk 

* Oct 9-11: Grapevine TX: “DFW Fall Conference;” ICPA

* Oct 12: Laredo TX; “
AES Compliance Seminar
;” Dept. of Commerce/Census;
shawn@m-palm.com
* Oct 12-13: Miramar FL; “7th Maritime/Logistics Seminar;” ABS-Consulting; albert@abs-consulting.net; 954-218-5285.
* Oct 12-13: New Orleans; “
Critical Compliance: Jurisdiction/Classification, Auditing & Recordkeeping
;” Export Compliance Solutions (ECS);
spalmer@exportcompliancesolutions.com
; 866-238-4018

* Oct 13-14: London; “
WorldECR Export Controls and Sanctions Forum 2016
;” WorldECR;
Mark.Cusick@WorldECR.com 

* Oct 17-20: Huntsville AL; “
EAR/ITAR/OFAC Compliance
;” ECTI;
jessica@learnexportcompliance.com
; 540-433-3977

* Oct 18-19: New Orleans; “
ITAR/EAR Critical Compliance Jurisdiction/Classification Auditing/Recordkeeping
” Export Compliance Solutions;
spalmer@exportcompliancesolutions.com
; 866-238-4018

* Oct 18-19: San Francisco; “9th West Coast FCPA Enforcement & Compliance Conference;” American Conference Institute

* Oct 18-19: Washington, DC; “International Technology Transfers, Cloud Computing, and Deemed Exports;” American Conference Institute; americanconference.com/techtransfers OR 1-888-224-2480

* Oct 19: London; “Control List Classification – Dual Use;” UK/BIS Export Control Organisation; denise.carter@bis.gsi.gov.uk 

* Oct 19-20: Oslo Norway; “US Defense Contracting and DFARS Compliance;” C5

* Oct 20: London; “Making Better License Applications;”
UK/BIS Export Control Organisation;
denise.carter@bis.gsi.gov.uk 

* Oct 24-25: Arlington VA; “2016 Fall Conference;” Society for International Affairs; admin@siaed.org 

* Oct 25: Troy MI; “Incoterms;” East Michigan District Export Council

* Oct 31-Nov 2: Wash DC; “
Commerce/BIS Update 2016 Conference on Export Controls
;” U.S. Dept. of Commerce/Bureau of Industry and Security;
UpdateConference@bis.doc.gov
; 202-482-6031

* Oct 31-Nov 3: Wash DC; “US Export Controls Seminar;” ECTI; jessica@learnexportcompliance.com; 540-433-3977
* Nov 2: Chicago; “AES Compliance Seminar;” Dept. of Commerce/ Census & M-Palm; shawn@m-palm.com 

* Nov 3-4: Amsterdam International Trade & Compliance Conference;
Email Claudia Wehmeijer to Request an Invitation; Baker McKenzie

* Nov 6-7: Singapore; “
Singapore Conference
;” International Compliance Professionals Association;
wizard@icpainc.org 

* Nov 8: London; “Control List Classification – Military;”
UK/BIS Export Control Organisation;
denise.carter@bis.gsi.gov.uk 
* Nov 9: London; “Making Better License Applications;”
UK/BIS Export Control Organisation;
denise.carter@bis.gsi.gov.uk 


* Nov 10-11: Shanghai; “
ICPA China Conference
;” International Compliance Professionals Association;
wizard@icpainc.org 

* Nov 14-16: London; “Expert Industry and Regulatory Advice for Solutions to Export Controls’ Global Compliance Risks;” Informa Maritime

* Nov 14-17: Phoenix AZ; “
EAR/ITAR/OFAC Compliance
;” ECTI;
jessica@learnexportcompliance.com
; 540-433-3977

* Nov 15-16: Santa Clara, CA, and webinar; “Year-End Review of Import/Export Developments;” Baker & McKenzie; Register Here; or call Lillian Han415-576-3061lillian.han@bakermckenzie.com 

* Nov 16: Manchester UK; “Intermediate Seminar;”
UK/BIS Export Control Organisation;
denise.carter@bis.gsi.gov.uk 

* Nov 17: Manchester UK; “Beginners Workshop;”
UK/BIS Export Control Organisation;
denise.carter@bis.gsi.gov.uk 
* Nov 17: Manchester UK; “Making Better License Applications;”
UK/BIS Export Control Organisation;
denise.carter@bis.gsi.gov.uk 
* Nov 17: Manchester UK; “Control List Classification Combined Dual Use and Military;”
UK/BIS Export Control Organisation;
denise.carter@bis.gsi.gov.uk 

* Nov 24: London; “
Cyber Export Controls 2016
;”
UK/BIS Export Control Organisation;
denise.carter@bis.gsi.gov.uk 

* Nov 30: London; “Control List Classification – Dual Use;”

UK/BIS Export Control Organisation;
denise.carter@bis.gsi.gov.uk

* Nov 29-Dec 2: Washington, D.C.; “
33rd International Conference on the Foreign Corrupt Practices Act
“; American Conference Institute
* Dec 1: London; “Making Better License Applications;”
UK/BIS Export Control Organisation;
denise.carter@bis.gsi.gov.uk 
* Dec 5-8: Miami FL; “
EAR/ITAR/OFAC Compliance Seminar Series
;” ECTI;
jessica@learnexportcompliance.com
; 540-433-3977

* Dec 7: Boston; “
AES Compliance Seminar
;”
Dept. of Commerce/Census
& M-Palm;
shawn@m-palm.com  

* Dec 7: London; “Intermediate Seminar;”
UK/BIS Export Control Organisation;
denise.carter@bis.gsi.gov.uk 
* Dec 8: London; “Beginners Workshop;”
UK/BIS Export Control Organisation;
denise.carter@bis.gsi.gov.uk 
* Dec 8: London; “Making Better License Applications;”
UK/BIS Export Control Organisation;
denise.carter@bis.gsi.gov.uk 

* Dec 14: Wash DC; “In-House Industry Seminar;” Dept. of State/DDTC; DDTCInHouseSeminars@state.gov

* Jan 23-26: San Diego, CA; “
EAR/ITAR/OFAC Compliance Seminar Series
;” ECTI;
jessica@learnexportcompliance.com
; 540-433-3977

* Jun 12-15: San Francisco; “
United States Export Control (EAR/OFAC/ITAR) Seminar
;” ECTI;
jessica@learnexportcompliance.com
; 540-433-3977

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ENEDITOR’S NOTES

EN_a112. Bartlett’s Unfamiliar Quotations

(Source: Editor)

“Never a lip is curved with pain that can’t be kissed into smiles again.”

“Never a tear bedims the eye that time and patience will not dry.”

  – Bret Harte (Francis Bret Harte, 1836-1902, was an American short story writer and poet, best remembered for his short fiction featuring miners, gamblers, and other romantic figures of the California Gold Rush.)

 

Friday funnies:

 

“Knock knock…”

“Who’s there?”

“Control freak!  Now you say “control freak who?”

  – Michael Babcock, Great Falls, MT

 

This week’s Blonde joke:


A blonde makes a really stupid mistake and her husband says, “I just don’t understand how you can be so beautiful and still be so dumb.” She says, “It’s simple: God made me beautiful so you would be attracted to me, and God made me dumb so I would be attracted to you!”


  – Ev Zenzen, Rice, MN

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EN_a213. 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.
 
*
ATF ARMS IMPORT REGULATIONS
: 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
 
*
CUSTOMS REGULATIONS
: 19 CFR, Ch. 1, Pts. 0-199
  – Last Amendment:
26 Aug 2016: 81 FR 58831-58834: Administrative Exemption on Value Increased for Certain Articles

* DOD NATIONAL INDUSTRIAL SECURITY PROGRAM OPERATING MANUAL (NISPOM): DoD 5220.22-M
  – 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.)

* EXPORT ADMINISTRATION REGULATIONS (EAR): 15 CFR Subtit. B, Ch. VII, Pts. 730-774 
  – Last Amendment: 23 Aug 2016: 81 FR 57451-57456: Addition of Certain Persons to the Entity List 

  
*
FOREIGN ASSETS CONTROL REGULATIONS (OFAC FACR)
: 31 CFR, Parts 500-599, Embargoes, Sanctions, Executive Orders
  – Last Amendment: 18 May 2016: 81 FR 31169-31171: Burmese Sanctions Regulations  
 
*
FOREIGN TRADE REGULATIONS (FTR)
: 15 CFR Part 30
  – Last Amendment: 15 May 2015; 80 FR 27853-27854: Foreign Trade Regulations (FTR): Reinstatement of Exemptions Related to Temporary Exports, Carnets, and Shipments Under a Temporary Import Bond 
  – HTS codes that are not valid for AES are available
here.
  – The latest edition (9 Mar 2016) 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.  Please contact us to receive your discount code. 
 
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HARMONIZED TARIFF SCHEDULE OF THE UNITED STATES (HTS, HTSA or HTSUSA)
, 1 Jul 2016: 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: 5 Aug 2016; Harmonized System Update (HSU) 1610, containing 12,995 ABI records and 2,287 harmonized tariff records.  
  – HTS codes for AES are available
here
.
  – HTS codes that are not valid for AES are available
here.
 
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INTERNATIONAL TRAFFIC IN ARMS REGULATIONS (ITAR)
: 22 C.F.R. Ch. I, Subch. M, Pts. 120-130
  – Latest Amendment: 17 Aug 2016: 81 FR 54732-54737: Amendment to the International Traffic in Arms Regulations: Procedures for Obtaining State Department Authorization To Export Items Subject to the Export Administration Regulations; Revision to the Destination Control Statement; and Other Changes 
  – The only available fully updated copy (latest edition 17 Aug 2016) of the ITAR 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, and over 700 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 THE essential tool of the ITAR professional.  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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EPEDITORIAL POLICY

* 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 7,500 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.

* INTERNET ACCESS AND BACK ISSUES: The National Defense Industrial Association (“NDIA”) posts the Daily Update on line, and maintains back issues since August, 2009 here.

* 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 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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