16-1026 Wednesday “The Daily Bugle”

16-1026 Wednesday “Daily Bugle”

Wednesday, 26 October 2016

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

  1. Ex/Im Items Scheduled for Publication in Future Federal Register Editions 
  2. Commerce/BIS: (No new postings.) 
  3. Commerce/Census: “Annotating an Export Shipment: Filing Citations, Exemption and Exclusion Legends” 
  4. Justice: “Two Men Sentenced In Scam To Illegally Export Goods To Syria” 
  5. State/DDTC Posts IT Modernization Webinar: Commodity Jurisdiction, DECCS Release 1 
  6. EU Posts Comprehensive Change Note for Dual-Use Regulation, Summary 2016 
  1. ST&R Trade Report: “In the News: Customs, Import Licenses, PierPass, FTAs” 
  1. M. Shenk, G. Soussan & D. Terruso: “EU Releases Official Proposal to Update Dual-Use Export Control Regime, Including Broad Controls on Cybertechnology” 
  2. Steptoe & Johnson LLP: “Inside DDTC’s New Definitions Of Export, Re-Export, Retransfer” 
  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 (17 Oct 2016), FACR/OFAC (17 Oct 2016), FTR (15 May 2015), HTSUS (30 Aug 2016), ITAR (12 Oct 2016) 



[No items of interest noted today.]

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

* Commerce; International Trade Administration; NOTICES; Export Control Reform; Subsidy Programs Provided by Countries Exporting Softwood Lumber and Softwood Lumber Products to the United States [Publication Date: 27 October 2016.]  
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The U.S. Census Bureau often receives questions on how to annotate commercial documents for export shipments to minimize potential delays at the port of export. In a previous blog on Filing Citations and Exemption Legends, we provided an overview of filing citations and exemption legends. In this blog, I would like to expand upon the information previously provided. We will discuss the use of exclusion legends and give a snap shot of the different types of citations and legends that must be clearly stated on the commercial loading documents. 
Exclusion legends are used for shipments that fall outside the scope of the Foreign Trade Regulations (FTR). The types of shipments that are excluded from filing requirements are identified in Section 30.2(d) of the FTR.  It is important to remember that whether you are required to file the Electronic Export Information (EEI) or not, the correct annotation must be displayed on the commercial loading document or in a prominent location on the shipment package. Below is a snapshot describing the citations and legends that must be provided prior to exportation.    
Citations / Legends
Proof of Filing Citation
Parties to the transaction file the EEI and receive their Internal Transaction Number (ITN) before the exportation of the shipment.
Automated Export System (AES) ITN. Example: AES X20160523777777
Postdeparture Citation
Postdeparture approved U.S. Principal Party in Interest (USPPI) have the privilege of filing  EEI within five days after exportation rather than obtaining the ITN in advance.
USPPI Filed: AESPOST followed by the USPPI ID and followed by the DATE OF EXPORT. Example: AESPOST   123456789 05/23/2016 Agent Filed:   AESPOST followed by the USPPI ID FILER ID and followed by the DATE OF EXPORT. Example:   AESPOST  123456789  – 987654321   05/23/2016
AES Downtime Filing Citation
When the AES experiences a major failure, the AES Downtime Filing Citation is used in place of a proof of filing citation.  The downtime filing citation is not to be used when the filer’s system is down, experiencing delays or for shipments subject to the International Traffic in Arms Regulations.
followed by the FILER ID and followed by DATE OF EXPORT. Example:   AESDOWN 123456789 05/23/2016
Exemption Legends
These transactions are within the scope of the FTR, but certain details make them exempt from filing EEI in the AES. The exemptions are located in 30.36 – 30.40. Below are two of the most commonly used exemptions: Ø 30.36 Exemption for shipments destined to Canada. Ø 30.37(a) Exemption for shipments that are valued $2,500 or less per Schedule B.
followed by the corresponding   FTR Exemption. Example: NO EEI 30.37(a)
Exclusion Legends
These transactions are outside the scope of the FTR and shall be excluded from filing EEI in the AES. Exclusions: Ø 30.2(d)(1) Good transiting the U.S. under U.S. Customs and Border Protection bond from one foreign country to another.
followed by the corresponding FTR Exclusion. Example: NO EEI 30.2(d)(1)
Ø 30.2(d)(2) – Except Puerto Rico and the U.S. Virgin Islands, goods shipped from the U.S. territories and goods shipped between the U.S. and these territories do not require EEI filing. Ø 30.2(d)(3) Electronic transmissions and intangible transfers. Ø 30.2(d)(4) – Goods shipped to Guantanamo Bay Naval Base from the U.S., Puerto Rico, or the U.S. Virgin Islands and from Guantanamo Bay Naval Base to the U.S., Puerto Rico, or the U.S. Virgin Islands. Ø 30.2(d)(5) – Goods licensed by a federal agency where the country of ultimate destination is the U.S. or goods destined to international waters where the entity assuming control of the goods is a U.S. entity.
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OGS_a44. Justice: “Two Men Sentenced In Scam To Illegally Export Goods To Syria”
(Source: Justice) [Excerpts.]
The United States Attorney’s Office for the Middle District of Pennsylvania announced today that Harold Rinko, of Hallstead, Pennsylvania and Ahmad Feras Diri, of London, United Kingdom were sentenced by United States District Court Judge Malachy E. Mannion in Scranton for their involvement in a conspiracy to illegally export goods to Syria.
According to United States Attorney Bruce D. Brandler, Diri, of London, United Kingdom, was sentenced yesterday to a 37-month term of imprisonment, a $100 special assessment, and ordered to forfeit $45,698 to the government. Diri was arrested by the Metropolitan Police in London on March 14, 2013, and extradited to the United States on charges in the Middle District of Pennsylvania.
On October 13, 2016, Rinko was sentenced to a term of time served, 12 months of home confinement, a fine of $2,600, a term of supervised release of 2 years, and was ordered to forfeit $45,698 to the government.  
A third defendant, Moawea Deri, a citizen of Syria, remains a fugitive from justice.
Rinko operated an export business in Hallstead, Pennsylvania and conspired with Diri to ship items purchased by customers in Syria in violation of United States law. The three men conspired to export various items from the United States, through third party countries to customers in Syria. The conspirators prepared false invoices which undervalued and mislabeled the goods being purchased and also listed false information as to the identity and geographic location of the purchasers of the goods. The items would be shipped from the United States to Jordan, the United Arab Emirates, and the United Kingdom, and thereafter transshipped to Syria. One such item is described in communications between the conspirators as “it is a portable multi-gas scanner for the detection of chemical warfare agents. Nerve, blood and lung warfare agents are detected using a highly sensitive ion mobility spectrometer.” …
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OGS_a55. State/DDTC Posts IT Modernization Webinar: Commodity Jurisdiction, DECCS Release 1
(Source: State/DDTC)
The webinar presented October 14, 2016 regarding the upcoming deployment of Defense Export Control and Compliance System (DECCS) Release 1 is available for review. The webinar provided a brief overview of the status of the IT Modernization effort and a demonstration of the new Commodity Jurisdiction (CJ) (DS-4076) interface.
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OGS_a66. EU Posts Comprehensive Change Note for Dual-Use Regulation, Summary 2016
This document summarizes proposed amendments to Annexes I, II and IV of Council Regulation (EC) No. 428/2009 (as amended by Commission Delegated Regulation (EU) No […]/2016) to implement the changes in the control lists of the various international flora on non-proliferation.
The changes implemented are a result of the review of the Wassenaar Arrangement (WA) Dual Use Lists, Missile Technology Control Regime (MTCR) Technical Annexes and Australia Group Common Control Lists during the course of 2015.
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NWS_a17. ST&R Trade Report: “In the News: Customs, Import Licenses, PierPass, FTAs”


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COMM_a18. M. Shenk, G. Soussan & D. Terruso: “EU Releases Official Proposal to Update Dual-Use Export Control Regime, Including Broad Controls on Cybertechnology”
* Authors: Maury Shenk, Esq., mshenk@steptoe.com, +44-20-7367-8050; Guy Soussan, Esq., gsoussan@steptoe.com, +32-2-626-0535; and Daniella Terruso, Policy Advisory, dterruso@steptoe.com, +32-2-626-0598. All of Steptoe & Johnson LLP.
On September 28, 2015 the European Commission (the Commission) released its proposal to “modernize and strengthen” the European Union’s (EU) dual-use export control regime as laid out by Regulation (EC) No. 428/2009 (the Regulation). [FN/1] As Steptoe has previously advised, a version of the Commission’s proposal was leaked in July, prompting concern from industry and other stakeholders.  The official release of the proposal triggers the process toward adoption of a slew of amendments to the current dual-use export control regime, including, most significantly, broad controls on the export of cybertechnology. 
Controls on Cybertechnology
The Commission’s proposal endeavors to implement its “initiative to control exports of cyber-surveillance technologies” in three major ways.  First, the proposal amends the Regulation’s current definition of dual-use items to include cyber-surveillance technology that can be used to violate human rights or threaten the security of the EU.  The proposal also introduces a definition of cyber-surveillance technology for the first time:
“cyber-surveillance technology” shall mean items specifically designed to enable the covert intrusion into information and telecommunication systems with a view to monitoring, extracting, collecting and analyzing data and/or incapacitating or damaging the targeted system. This includes items related to the following technology and equipment:
(a) mobile telecommunication interception equipment

(b) intrusion software
(c) monitoring centers
(d) lawful interception systems and data retention systems
(e) digital forensics [FN/2]
Second, the proposal adds a new list-based control category (Category 10), for specified types of cyber-surveillance technology.  Category 10, “Other Items of Cyber-Surveillance Technology,” contains three subcategories (10A001, 10D001, 10E001). 
* Category 10A001 would control, for export to certain countries, “surveillance systems, equipment and components for ICT (Information and Communication Technology) for public networks,” defined to include the following:
(a) Monitoring Centers (Law Enforcement Monitoring Facilities) for Lawful Interception Systems (LI, for example according to ETSI ES 201 158, ETSI ES 201 671 or equivalent specifications or standards) and specially designed components therefor,
(b) Retention systems or devices for event data (Intercept Related Information IRI, for example, according to ETSI TS 102 656 or equivalent specifications or standards) and specially designed components therefor.
A technical note states that “event data includes signalling information, origin, and destination (e.g., phone numbers, IP or MAC addresses, etc.), date and time and geographical origin of Communication.”  There is a carve-out for systems or devices specially designed for any of the following stated purposes: billing, data collection functions within network elements (e.g., Exchange or HLR), quality of service of the network [QoS] or user satisfaction [QoE], or operation at telecommunications companies (service providers).
* Category 10D001 would control “software specially designed or modified for the development, production or use of the equipment, functions or features” controlled by 10A001, as well as “software specially designed or modified to provide characteristics, functions or features of equipment” controlled by 10A001. 
* Category 10E001 would control technology for the development, production or use of equipment, functions or features controlled by 10A001 or software controlled by 10D001.
Third, the proposal introduces a “catch-all control” intended to supplement the control categories above by imposing export licensing requirements on non-listed “cyber-surveillance technology” items under certain circumstances.  As noted above, the proposal includes a new definition of cyber-surveillance technology, which broadens the range of potentially controlled items far beyond just the items listed in Category 10 under 10A001, 10D001, and 10E001.  The definition covers items related to mobile telecommunications interception equipment, intrusion software, monitoring centers, lawful interception systems and data retention systems, and digital forensics.  These catch-all controls will result in a licensing requirement for such items if there is evidence to suggest that they are to be used for specific end-uses of concern, as highlighted by the updated Regulation (for weapons of mass destruction purposes, for certain military purposes by certain countries, as parts or components for controlled military items that have been exported without proper authorization, for use by persons complicit in or responsible for directing or committing serious violations of human rights or international humanitarian law in situations of armed conflict in the country of final destination, or for use in connection with acts of terrorism).  
The addition of a new category of controlled items stems from concerns within the EU regarding the use of certain types of cybertechnologies, such as intrusion software, by oppressive regimes and other malicious actors to violate human rights and compromise global security.  However, the proposed definition of such technology casts a potentially wide net, prompting concerns by some that the additional controls could hinder, rather than advance, cybersecurity.
Technical Assistance
The proposal introduces controls on the provision of technical assistance related to dual-use items.  Technical assistance is defined to cover technical support including repairs, development, manufacture, assembly, testing, maintenance, “or any other technical service.”  In addition, the controls could cover “instruction, advice, training, transmission of working knowledge or skills or consulting services, including verbal forms of assistance.” 
The controls on technical assistance would apply to any person or entity resident or established in the EU, any subsidiary of an EU company located outside of the EU, and non-EU nationals supplying technical assistance from within the EU.  The controls apply to any dual-use item in situations where such a person or entity supplying technical assistance has been informed by authorities that the item may be used in any of the end-use circumstances which trigger catch-all controls, as listed above.  In addition, suppliers of technical assistance have a responsibility to inform relevant authorities if they are aware that the dual-use items in question are to be used for any such purposes.
Expanded Brokering Controls
The proposal also increases the scope of EU brokering controls by updating the definition of “broker” and expanding the type of items subject to authorization.  If the proposed amendments to the Regulation go forward, subsidiaries of EU companies located outside of the EU, and non-EU nationals carrying out brokering services from within the EU, will become subject to brokering controls. 
Further, controls on brokering services of dual-use items would be amended in two ways.  First, the proposal would amend the current Regulation by requiring authorization for brokering services of any dual-use item (not just those explicitly listed in Annex 1), intended for certain end-uses.  This amendment would include any items falling within the definition of “cyber-surveillance technology” – even those not specifically listed in the newly proposed Category 10.  Second, the proposal lists three new circumstances to which those controls apply.  In addition to the currently controlled circumstances (i.e., use related to weapons of mass destruction, or as parts or components for controlled military items that have been exported without proper authorization), the proposal adds:

  (1) military end-use in certain destinations;
  (2) use by persons complicit in human rights violations; and
  (3) use in connection with terrorism as end-use circumstances subject to brokering controls.

Other Amendments
In addition to introducing a new category of controlled items related to cyber-surveillance technology, proposing controls on technical assistance, and expanding controls on brokering, the proposal outlines a series of other amendments to the Regulation which, according to the proposal, aim to improve and simplify export control procedures and administration.  Among the amendments are provisions relating to the following:
  – redefinition of key terms including “export,” “exporter” and “broker”
  – simplification of controls on intangible technology transfers (ITT)
  – strengthening of transit controls
  – enhanced provisions aiming to tackle illicit trade
  – additional licensing elements to improve consistency within the EU, including the introduction of a new authorization for large projects and new EU General Export Authorizations related to encryption, low value shipments, intra-company transmission of software and technology, and other dual-use items
  – expanded powers of the Commission to “modify destinations or items on EUGEAs” through delegated act
  – expansion of end-use circumstances triggering catch-all controls 
  – revision of intra-EU controls
  – increased cooperation between Member States regarding implementation and enforcement
  – improved transparency and outreach through the publication of guidance and annual reports
  – increased dialogue and cooperation with third countries
Internal Compliance Programs
While each of the amendments to the current Regulation may bring changed or increased responsibilities for exporters, there is one new administrative requirement that should be brought to particular attention.  As part of the Commission’s stated goal to increase licensing consistency within the EU Member States, the proposal introduces conditions for use of certain licenses.  In particular, use of a global license will now require an exporter to maintain an Internal Compliance Program.  The proposal defines a compliance program as follows:
“… effective, appropriate and proportionate means and procedures, including the development, implementation, and adherence to standardized operational compliance policies, procedures, standards of conduct, and safeguards, developed by exporters to ensure compliance with the provisions and with the terms and conditions of authorizations set out in this Regulation …”
In addition, the proposal notes that exporters have an “obligation to exercise due diligence” when exporting dual-use items.
Consultation Period
Publication of the draft Regulation marks the end of a lengthy consultation period, initiated in 2011.  During this period, stakeholders raised multiple concerns, including the competition for dual-use goods that they face from third countries without multilateral export control regimes or with markedly different regimes, and the burden of management and compliance programs.  Although the proposal is a Regulation, and so will be directly applicable across the EU 28 Member States if adopted, there are key implementing measures for Member States to put in place which have the potential to cause asymmetric implementation across the EU. [FN/3]
Next Steps
Now that the Commission’s proposal has been published, it must be examined by the Council and European Parliament.  All three must agree before the Regulation is adopted, and the legislative process could take at least a year.  The Regulation will apply on the ninetieth day following publication in the Official Journal.  However, this implementation is unlikely to occur before spring 2018.  The European Parliament’s Think Tank recently published a helpful summary containing an overview of the proposed changes and outlining its path to implementation, which can be found here
The Council has begun its work, meeting initially on a monthly basis.  The European Parliament has appointed an MEP rapporteur, Klaus Buchner (a member of the Ökologisch-Demokratische Partei, the German Green Party) to draft the Parliament’s position and coordinate views from other members.  In addition to the initial consultation period, the legislative process will provide opportunities for interested representatives to discuss the impact of the proposal on their sector(s), either in meetings or in writing, to all three institutions.
During the consultation period Member States and Members of the European Parliament (MEPs) repeatedly raised concerns about the export of cybertools and other IT and telecoms surveillance, particularly in the context of human rights violations.  There is clear support across the Commission, Council, and European Parliament to address this concern, but, as ever, the devil will be in the details of the finalized Regulation.
  [FN/1] See “Commission proposes to modernize and strengthen controls on exports of dual-use items,” European Commission, 28 September 2016
  [FN/2] The official proposal’s definition of cyber-surveillance technology has been pared down from the version leaked in July 2016.  The leaked proposal’s definition of cyber-surveillance technology included, in addition to those listed in the official version, items related to biometrics, location tracking devices, probes, and deep package inspection systems.
  [FN/3] The concern about asymmetric implementation may be partially addressed by the proposal to confer power on the Commission to adopt delegated acts.  The acts would address amendments to export sensitivity assessments under Union General Export Authorizations as well as “technological and commercial developments.”  This means that amendments to Section A of Annex I, Annex II, and Section B of Annex IV would neither require revision to the Regulation itself nor would they require national (and potentially different), implementing measures. 
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COMM_a29. Steptoe & Johnson LLP: “Inside DDTC’s New Definitions Of Export, Re-Export, Retransfer”
On September 8, 2016, the US Department of State’s Directorate of Defense Trade Controls published a final rule to amend the International Traffic in Arms Regulations.  This rule clarifies and finalizes changes from a June 3, 2016, interim final rule related to the definitions of “export,” “re-export” and “retransfer.”
The preamble of the final rule includes an important takeaway where DDTC confirms “that theoretical or potential access to technical data is not a release,” and that a release occurs only “if a foreign person does actually access technical data.”  Such an explicit acknowledgment represents a notable change in a long-standing interpretation of DDTC policy that theoretical access by a foreign person to ITAR-controlled technical data is to be treated as an export, re-export, or retransfer, and that it was up to the data owner to show that no release actually occurred.  This issue often arose with databases, file shares, or electronic transfer networks to which a foreign national might have password access, even if there was no evidence the foreign national actually obtained and reviewed ITAR-controlled technical data, or accessed the electronic system at all.  Now, it appears the DDTC accepts that an actual release of technical data to a foreign national must occur in order to qualify as an export, re-export, or retransfer.  Going forward, we hope the DDTC will only declare an apparent violation when there is affirmative evidence of actual access by an unauthorized foreign person.  For more information, please see our advisory.
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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: 26 Aug 2016: 81 FR 58831-58834: Administrative Exemption on Value Increased for Certain Articles 

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

  – Last Amendment: 17 Oct 2016: 81 FR 71365-71367: Cuba: Revisions to License Exceptions  

: 31 CFR, Parts 500-599, Embargoes, Sanctions, Executive Orders
  – Last Amendment: 17 Oct 2016: 81 FR 71372-71378: Cuban Assets Control Regulations 
: 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
  – 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.
, 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: 30 Aug 2016; Harmonized System Update (HSU) 1612, containing 4,692 ABI records and 935 harmonized tariff records.  
  – HTS codes for AES are available
  – HTS codes that are not valid for AES are available
INTERNATIONAL TRAFFIC IN ARMS REGULATIONS (ITAR): 22 C.F.R. Ch. I, Subch. M, Pts. 120-130 (Caution — The ITAR as posted on GPO’s eCFR website and linked on the DDTC often takes several weeks to update the latest amendments.)
  – Latest Amendment: 12 Oct 2016: 81 FR 70340-70357: Amendment to the International Traffic in Arms Regulations: Revision of U.S. Munitions List Category XII and associated sections.
  – The only available fully updated copy (latest edition 12 Oct 2016) 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, footnotes to amendments that will take effect on 15 November and 31 December, plus a large Index and over 750 footnotes containing case annotations, practice tips, DDTC guidance, and explanations of errors in the official ITAR text.  Subscribers receive updated copies of the BITAR in Word by email, usually revised within 24 hours after every ITAR amendment.  The BITAR is available by annual subscription from the Full Circle Compliance website.  BAFTR subscribers receive a 25% discount on subscriptions to the BITAR, please contact us to receive your discount code.

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* 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.

* 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.

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