;

16-1219 Monday “The Daily Bugle”

16-1219 Monday “Daily Bugle”

Monday, 19 December 2016

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

[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: “Tips on How to Resolve AES Fatal Errors” 
  4. State/DDTC Announces New Forms and Batch Common Schema 
  1. ST&R Trade Report: “Flagging for Reconciliation More Difficult Under CBP Change” 
  1. A. Arnold: “What Jeff Sessions as Attorney General Will Mean for the Iran Deal” 
  2. T.R. McBride & C.A. Palmeri: “Happy (End of the) Holiday: OFAC Signals Potential Iran Sanctions Snapback” 
  1. Monday List of Ex/Im Job Openings: 121 Jobs Posted 
  1. Bartlett’s Unfamiliar Quotations 
  2. Are Your Copies of Regulations Up to Date? Latest Changes: ATF (15 Jan 2016), Customs (12 Dec 2016), DOD/NISPOM (18 May 2016), EAR (16 Dec 2016), FACR/OFAC (4 Nov 2016), FTR (15 May 2015), HTSUS (30 Aug 2016), ITAR (5 Dec 2016) 

EXIMEX/IM ITEMS FROM TODAY’S FEDERAL REGISTER

EXIM_a1

[No items of interest noted today.]

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

OGSOTHER GOVERNMENT SOURCES

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


* Commerce; United States Patent and Trademark Office; NOTICES; Agency Information Collection Activities; Proposals, Submissions, and Approvals: Secrecy and License to Export [Publication Date: 20 December 2016.]

* U.S. Customs and Border Protection; RULES; Regulatory Implementation of the Centers of Excellence and Expertise [Publication Date: 20 December 2016.]

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

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

OGS_a63. Commerce/Census: “Tips on How to Resolve AES Fatal Errors”

(Source: census@subscriptions.census.gov, 19 Dec 2016)
 
When a shipment is filed to the AES, a system response message is generated and indicates whether the shipment has been accepted or rejected. If the shipment is accepted, the AES filer receives an Internal Transaction Number (ITN) as confirmation. However, if the shipment is rejected, a Fatal Error notification is received.
 
To help you resolve AES Fatal Errors, here are some tips on how to correct the most frequent errors that were generated in AES for this month.
 
Fatal Error Response Code: 123
 
  – Narrative: Conveyance Name Missing
  – Reason: The Conveyance Name/ Carrier Name is missing when the Mode of Transportation reported is one that requires the Conveyance Name/ Carrier Name to be reported.
  – Resolution: The Conveyance Name / Carrier Name must be reported for Vessel, Air, Rail, and Truck shipments. For Vessel shipments, report the name of the vessel. For Air, Rail, and Truck shipments, report the name of the carrier. Verify the Mode of Transportation Code and Conveyance Name/ Carrier Name, correct the shipment and resubmit.
 
Fatal Error Response Code: 626
 
  – Narrative: 1st UOM Code Missing
  – Reason: The Schedule B/HTS Number reported requires a Unit of Measure (1) and Unit of Measure (1) is missing.
  – Resolution: The Schedule B/HTS Number reported requires the Units for 1st Quantity to be reported. Verify the Unit of Measure for the 1st Quantity, correct the shipment and resubmit.
 
For a complete list of Fatal Error Response Codes, their reasons, and resolutions, see Appendix A – Commodity Filing Response Messages.
 
It is important that AES filers correct Fatal Errors as soon as they are received in order to comply with the Foreign Trade Regulations. These errors must be corrected prior to export for shipments filed predeparture and as soon as possible for shipments filed postdeparture, but not later than five calendar days after departure.
 
For further information or questions, contact the U.S. Census Bureau’s Data Collection Branch.
 
  – Telephone: (800) 549-0595, select option 1 for AES.
  – Email: askaes@census.gov
  – Online: www.census.gov/trade

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

 
In support of Federal Register Notices 81 FR 8312681 FR 870340 and 81 FR 49531 licensing forms DSP-5, -61, -73, and -85, and the batch Common Schema have been upgraded to accommodate the additions and revisions to USML Categories VIII, XII, XIII, XIV, XV, XVIII, and XIX.  Beginning January 3, 2017, DTrade users must use version 9.3 for the DSP-5, DSP-61 and DSP-73 forms, version 3.2 for the DSP-85, and version 7.6 for the Common Schema to submit license applications.
 
Earlier versions of these forms and schema will automatically be rejected by the system beginning on January 3, 2017
 
The DTrade application will be unavailable to industry from 6:00PM December 30, 2016 until 7:00AM January 3, 2017 for scheduled system maintenance.

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

NWSNEWS

NWS_a15
. ST&R Trade Report: “Flagging for Reconciliation More Difficult Under CBP Change”

 
U.S. Customs and Border Protection recently announced a change to the process for blanket flagging underlying entries for reconciliation as part of the Jan. 14 transition of the reconciliation test to the Automated Commercial Environment. CBP said this change will streamline the process, but some importers are disputing that characterization. This article clarifies information about this change reported in a Dec. 16 article in the Sandler, Travis & Rosenberg Trade Report.
 
Currently, an importer requests that CBP input and apply a blanket flag for specified issues to all underlying entries filed for that importer. Effective Jan. 14, however, CBP is eliminating this option and instead requiring importers (or their customs brokers) to flag each applicable entry themselves as it is transmitted to ACE. This appears to be consistent with CBP’s previous announcement that blanket flagging would no longer be allowed once reconciliation moved to ACE.
 
Tom Gould, senior director, customs and international trade, for ST&R, said this change will make the process of reconciliation flagging more cumbersome and more prone to errors for importers who used the Automated Commercial System blanket flagging option in the past. For example, Gould noted, if an importer utilizes the services of multiple brokers, each broker will now have to flag each entry it files on behalf of that importer.

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

COMMCOMMENTARY

COMM_a16. A. Arnold: “What Jeff Sessions as Attorney General Will Mean for the Iran Deal”
(Source: Bulletin of the Atomic Scientists) [Excerpt.]
 
* Author: Aaron Arnold, Associate, Project on Managing the Atom, Harvard University, aaron_arnold@hks.harvard.edu
 
Already, President-elect Donald Trump’s pick for the next US attorney general, Jeff Sessions (R-AL), has caused quite a stir over his domestic policy positions, not to mention his checkered past of making racially charged and divisive statements. Few pundits, however, have discussed what Jeff Sessions’ appointment could mean for the Iran Deal-the agreement negotiated last fall, which provides sanctions relief to Iran in exchange for limits on its nuclear program. As the country’s new top cop, Sessions will have sweeping authority to shape the Justice Department’s policies and priorities-some of which have the potential to affect relations with Iran, if indirectly.  . . . .
* * * * * * * * * * * * * * * * * * * *

COMM_a27. T.R. McBride & C.A. Palmeri: “Happy (End of the) Holiday: OFAC Signals Potential Iran Sanctions Snapback”
 
* Authors: Thaddeus R. McBride, Esq., tmcbride@bassberry.com, 202-827-2959; and Cheryl A. Palmeri, cpalmeri@bassberry.com, 202-827-2967. Both of Bass, Berry & Sims PLC.
 
In what may be a harbinger of things to come, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) has issued new guidance regarding what may occur if the United States re-implements economic sanctions against Iran that were scaled back following the July 2015 nuclear deal (the Joint Comprehensive Plan of Action or JCPOA). That guidance, in the form of two amended Frequently Asked Questions (M.4 and M.5, available here), makes clear that:
 
  – the United States will not retroactively impose sanctions for legitimate activity undertaken prior to any sanctions snapback;
  – continuation of previously legitimate activities following snapback could be penalized; and
  – the U.S. government intends to provide a 180-day period to wind down Iran business that was consistent with the lifting of U.S. sanctions under the JCPOA.
 
This guidance is notable for a number of reasons. First, it seems to commit OFAC to a wind-down period, even though the Trump administration might never honor that commitment.
 
Second, OFAC seemingly is giving credence to the possibility that the JCPOA could fail, and the United States could re-impose sanctions against Iran that were lifted as a result of that agreement. As we indicated last month, Donald Trump has threatened to abolish the JCPOA, and there are various paths by which he could do so. OFAC’s guidance appears to contemplate that reality.
 
The guidance also may constitute a reaction to the recent announcement, by Iranian President Rouhani, that Iran will build a nuclear-powered marine propeller that could be used for nuclear submarines. That announcement was itself reportedly a response to the United States’ extension of the Iran Sanctions Act this week. (President Obama declined to sign the bill, but allowed it to become law anyway.)
 
Given these developments, and more drama that is sure to come, the U.S.-Iran relationship bears close watching. Businesses that have capitalized on or are contemplating opportunities in Iran may want to sit tight for the time being.

In this charged political climate, it is difficult to predict what sanctions restrictions will be in place in the weeks and months ahead. Such unpredictability means it is nearly impossible to make the calculated business decisions that are essential to long-term success in a market like Iran. It is a strange day when a U.S. regulator cannot say with confidence what is forthcoming, and issues guidance that could be ignored or rescinded within weeks of its issuance.
* * * * * * * * * * * * * * * * * * * *

MSEX/IM MOVERS & SHAKERS

MS_a18
. Monday List of Ex/Im Job Openings: 121 Jobs Posted

(Source: Editor)  


 
Published every Monday or first business day of the week.  Send openings in the following format to
apbosch@fullcirclecompliance.eu
.
 
COMPANY; LOCATION; POSITION TITLE (WEBLINK); CONTACT INFO; REQ ID

#” New listing this week:

 

# Aerospace Industries Association; Arlington VA;
International Affairs Director
;
Remy.Nathan@aia-aerospace.org

* Amazon; London, UK;
Senior Trade Compliance Program Manager (M/F)
; Requisition ID: 429019

* Amazon; Seattle WA;
Compliance Investigator
; Requisition ID: 432564

* Amazon; Seattle WA;
Sanctions Compliance Specialist
; Requisition ID: 467576

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

* Amazon; Seattle WA;
Prime Air Trade Compliance Program Manager; Requisition ID: 395658

* Amazon; Singapore;
Sr. Trade Compliance Manager
; Requisition ID: 441734
* Amazon; Tokyo, Japan;
JP Export Compliance Manager
; Requisition ID: 464733


* AstraZeneca; Wilmington DE;
Sr. Import Analyst
; Requisition ID: R-001528

* Avigilon; Plano, TX;
Global Trade Compliance Manager
; Requisition ID: 2016-2551


* Bayer; Leverkusen, Germany;
Head of Customs & International Trade Classification (m/f)
; Requisition ID: 0000180456


* Boeing; Bristol, UK;
Trade Control Specialist
; Requisition ID: 1600018482


* Boeing; Huntington Beach CA;
Trade Control Specialist
; Requisition ID: 1600019369

* Boeing; Neu-Isenburg, Germany;
Trade Specialist 4 m/f
; Requisition ID: 760960

* Ciena; Hanover MD;
Global Logistics Cost Leader
; Requisition ID: R005158

* Colony Brands, Inc.; Monroe WI;
Assistant Trade Compliance Manager
; Requisition ID: 16-0954

* Continental; Manila,
Philippines;
Head of Transportation and Foreign Trade Compliance
; Requisition ID: 42475BR


* Coriant; Naperville IL;
Sr Mgr of Global Trade Compliance
; Requisition ID: 11353

* Crane Aerospace and Electronics; Chandler AZ;
Sr. Export Compliance Analyst; Requisition ID: 4725

* Crane Currency; Nashua NH;
Import/Export & Logistics Manager
; Requisition ID: 2016-1459 

# Crane Aerospace and Electronics, West Caldwell NJ;
Export Compliance Manager
; Requisition ID: 5411

* Curtiss-Wright; Charlotte NC;
Principal Trade Compliance Analyst
;
michelle.stinziano@curtisswright.com

# Diageo; Norwalk CT;
Trade Compliance Excellence Manager
; Requisition ID: 54069BR

*
DRS Technologies; Dayton OH;
Senior Trade Compliance Specialist III
; Requisition ID: 61027

* DRS Technologies; Germantown MD;
Senior Trade Compliance Manager
;
Requisition ID: 54749

# ED & F Man; London, UK;
Trade Support Specialist

* Edgewell Personal Care; Milford CT; 
Export Compliance and Security Lead
; Requisition ID: NAM00808

* Esterline Technologies Corporation; Bellevue WA;
Audit Manager – Compliance
; Requisition ID: 8215BR

* Esterline Technologies Corporation; Bellevue WA;
Sr. Trade Compliance Manager – Sensors & Systems (Engineering)
; Requisition ID: 8791BR
* Esterline Technologies Corporation; Brea, CA;
Logistics Coordinator
; Requisition ID:
8887BR

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

* Esterline Technologies Corporation; Buena Park, CA;
Manager, Shipping and Inventory Control
; Requisition ID:
9046BR

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

* Esterline Technologies Corporation; Tijuana, Mexico;
Import-Export Specialist
; Requisition ID: 8617BR

* Expeditors; Bangkok, Thailand; Regional Trade Compliance Manager – Indochina & Philippines
* Export Solutions Inc.; Melbourne FL; 
Trade Compliance Specialist II

info@exportsolutionsinc.com

* Facebook; Menlo Park CA;
Head of Global Trade Compliance Operations

* FD Associates; Senior Export Compliance Associate,
jobs@fdassociates.net

* FLIR Systems; Arlington VA;
Director of Defense Trade Licensing & Compliance

* FLIR; Arlington VA;
Sr. Defense Trade Licensing & Compliance Analyst
; Requisition ID: 7924
* FLIR; Billerica MA; 
Sr. Defense Trade Licensing & Compliance Analyst
;
Requisition ID: 8008
* General Electric (Global Operations); Wash DC;
Administrator, International Trade Compliance
; Requisition ID: 2786498

* General Dynamics; South Wales, UK;
Senior Trade Compliance Officer
; Requisition ID: 6079

* HARMAN; Novi MI;
Senior Export Compliance Specialist; Requisition ID: 94688

* HARMAN; Novi MI;
Senior Import Compliance Specialist; Requisition ID: 94686

* Hewlett Packard Enterprise; Amstelveen, The Netherlands;
Customs and Compliance Manager
; Requisition ID: 1585140

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

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

* Intel; Santa Clara CA;
Export Compliance Specialist
; Requisition ID: JR0005160

* Lam Research Corporation; Fremont CA:
Foreign Trade Analyst 6
; Requisition ID: 12079BR

* Leica Biosystems; Nußloch, Germany;
Trade Compliance Manager (Import-Export)
; Requisition ID: COR000633

* Linde; Stewartsville NJ;
Compliance Administrator; Requisition ID: 916130

* Lumber Liquidators; Toano VA;
Compliance Auditor
; Requisition ID: 913

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

* Lutron; Coopersburg PA; Trade Compliance Coordinator; Requisition ID: 2834

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

* Meggitt PLC; Los Angeles CA;
Export Control/Trade Compliance Administrator
; Requisition ID: 22591

* Meggit PLC; Los Angeles CA;
Trade Compliance Officer

* Meggitt Control Systems; North Hollywood CA;
Trade Compliance Officer
;
jenn.avritt@meggitt.com
; Requisition ID: 23720

* Meggitt Advanced Composites Limited; Shepshed, UK;
Trade Compliance Officer
; Requisition ID: 22122

* Merck KGaA; South West England, UK;
Trade Compliance Specialist
; Requisition ID: 153405

* Microsoft; Redmond WA;
Trade Director, Regulatory Compliance & Standards
;
rybeli@microsoft.com
; Requisition ID: 973167

* Moog; East Aurora NY;
Export Compliance Manager
;
anihill@moog.com
; Requisition ID: 161913
* North Dakota State University; Fargo, ND;
Research Integrity and Compliance Administrator-Export Control
; Requisition ID: 1600266

* Northrop Grumman T
echnology Services Sector, Advanced Defense Services (ADS) Division
; International Posting (Saudi Arabia);
Manager International Trade Compliance 1
(Saudi Arabia)
; Requisition ID: 16003577

# Northrop Grumman Corporation; Annapolis Junction MD;
International Trade Compliance Analyst
; Requisition ID: 16028623

* Northrop Grumman Corporation; Falls Church VA;
International Trade Compliance Analyst 3/4
; Requisition ID: 16026961

# Northrop Grumman Corporation; Falls Church VA;
International Trade Compliance Analyst 3/4
; Requisition ID: 16027133
# Northrop Grumman Corporation; Herndon VA;
International Trade Compliance Analyst 4
; Requisition ID: 16027421
# Northrop Grumman Corporation; Linthicum MD;
International Trade Compliance Analyst 1
; Requisition ID: 16028160

* Northrop Grumman Corporation; Linthicum MD;
International Trade Compliance Analyst 3
; Requisition ID: 16013233


# Northrop Grumman Corporation; Melbourne FL;
International Trade Compliance Analyst 4 – E2C/D Production
; Requisition ID: 16027880
# Northrop Grumman Corporation; San Diego CA;
International Trade Compliance Analyst 2
; Requisition ID: 16028561
# NXP Semiconductors; Nijmegen, The Netherlands;
Export Control Officer, Requirements Manager
; R-10001504

* Pall Corporation; Portsmouth, UK;
Trade Compliance Specialist
; Requisition ID: SHA000201 

* Parexel; Buenos Aires, Argentina;
Trade Compliance Specialist
; Requisition ID: pare-10055899

* PerkinElmer; Waltham MA;
International Trade Compliance Associate, Informatics


* Raytheon; Arlington VA;
Export Licensing Manager I
; Requisition ID: 88665BR
*Raytheon; Arlington VA;
Export Licensing Manager I
; Requisition ID: 87321BR

* Raytheon; Cambridge MA;
Export Compliance Agreement Owner
; Requisition ID: 87607BR

* Raytheon; El Segundo CA;
Import Control & Compliance Administration
; Requisition ID: 87699BR

* Raytheon; Fullerton CA;
Global Trade Compliance Manager
; Requisition ID: 85521BR

* Raytheon; Indianapolis IN;
Principal SC Compliance Specialist
; Requisition ID: 84932BR

* Smith and Wesson; Springfield MA;
International Sales Administrator
; Requisition ID: SCB-1223


* State Department; Wash DC;
Supervisory Compliance Specialist; Requisition ID: HRSC/T/PM-2017-0003


* Tenneco; Edenkoben, Germany;
Global Trade Compliance Manager (m/w)
; Requisition ID: 176871-846

* Tesla Motors; Fremont CA;
International Tax Lead/Senior International Tax Counsel; Requisition ID: 35593

* Tesla Motors; Fremont CA;
Global Trade Compliance Manager
; Requisition ID: 40738 

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

* Tesla Motors; Fremont CA;
Group Manager – Logistics Sourcing; Requisition ID: 38574

# Tesla Motors; Sparks NV;
Logistics Analyst
; Requisition ID: 43692

* Textron Systems; Wilmington MA;
Principal Export Compliance Analyst
; Requisition ID: 242857


* Thales; Piscataway NJ;
Manager, Trade Compliance
; Requisition ID: R0012077

* Thales; Piscataway NJ;
Trade Compliance Specialist/Facility Security Officer; Requisition ID: R0012102

* ThermoFisher Scientific; Madison WI;
Import/Export Compliance Coordinator
; Requisition ID: 41440BR

* ThermoFisher Scientific; Matamoros, Mexico;
Import/Export Supervisor
; Requisition ID: 39750BR

* ThermoFisher Scientific; Shanghai, China;
Compliance Director, Greater China
; Requisition ID: 38520BR

* ThermoFisher Scientific; Shanghai, China;
Trade Compliance Specialist
; Requisition ID: 42144BR
* ThermoFisher Scientific; Shanghai, China;
Trade Compliance Specialist – CMC
; Requisition ID: 42143BR

* Toyota; Dallas TX;
Export Control Analyst
; Requisition ID: TMS003DS

* Tractor Supply Company; Brentwood TN;
Customs Process Manager
;
nknott@tractorsupply.com
; Requisition ID: 16-986

* Troy Corporation; Florham Park NJ;
Global Trade and Compliance Manager
; Requisition ID: 306


* United States Pharmacopeia; Rockville MD OR Frederick MD;
Trade Compliance Specialist
;
Meaghan Ireland –
mci@usp.org
;
Requisition ID: 709-679


* United Technologies Corporation, UTC Aerospace Systems; Charlotte NC;
International Trade Compliance Auditor; Requisition ID:
34285BR
* United Technologies Corporation, UTC Aerospace Systems; Charlotte NC;
* United Technologies Corporation, UTC Aerospace Systems; Charlotte NC;
* United Technologies Corporation, UTC Aerospace Systems; Charlotte NC;
Program Manager, Customs; Requisition ID:
31331BR


* United Technologies Corporation, UTC Aerospace Systems; Charlotte NC;
Specialist, ITC IT Systems
; Requisition ID: 33792BR
* United Technologies Corporation, UTC Aerospace Systems; Charlotte NC;
Sr Mgr, Intl Trade Compl
; Requisition ID: 30525BR


* United Technologies Corporation, UTC Aerospace Systems; Windsor Locks CT;
ITC Investigator; Requisition ID: 28069BR

* XPO Logistics; Greenwich CT;
Global Trade Compliance Analyst

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

ENEDITOR’S NOTES

(Source: Editor) 

 
*
Edith Piaf (19 Dec 1915 – 10 Oct 1963; born Édith Giovanna Gassion, was a French cabaret singer, songwriter and actress who became widely regarded as France’s national chanteuse, as well as being one of France’s greatest international stars.)

  – “I want to make people cry even when they don’t understand my words.”

 

*
Ty Cobb (Tyrus Raymond “Ty” Cobb, 18 Dec 1886 – 17 Jul 1961, nicknamed The Georgia Peach, was an American Major League Baseball outfielder. Cobb spent 22 seasons with the Detroit Tigers, the last six as the team’s player-manager.)

  – “The crowd makes the ballgame.

 

*
John Greenleaf Whittier (17 Dec 1807 – 7 Sep 1892, was an American Quaker poet and advocate of the abolition of slavery in the United States.)

  – “Of all sad words of tongue and pen, the saddest are these, ‘It might have been’.”

 

Monday is pun day:

 

Q: Why do the French eat only one egg for breakfast?

A: Because in France, one egg is an oeuf.

 

Q. Why do the French drink so much wine?

A. Because in France, the water is l’eau. 

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

EN_a310
. 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: 12 Dec 2016: 81 FR 890375-89381: Electronic Notice of Liquidation 

* 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: 16 Dec 2016: 81 FR 90983-90987: Implementation of the February 2016 Australia Group (AG) Intersessional Decisions and the June 2016 AG Plenary Understandings 

  
*
FOREIGN ASSETS CONTROL REGULATIONS (OFAC FACR)
: 31 CFR, Parts 500-599, Embargoes, Sanctions, Executive Orders
  – Last Amendment: 4 Nov 2016: 81 FR 76861-76863: Amendments to OFAC Regulations To Remove the Former Liberian Regime of Charles Taylor Sanctions Regulations and References to Fax-on-Demand Service 
 
*
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.
 
*
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: 30 Aug 2016; Harmonized System Update (HSU) 1612, containing 4,692 ABI records and 935 harmonized tariff records.  
  – HTS codes for AES are available
here
.
  – HTS codes that are not valid for AES are available
here.
 
INTERNATIONAL TRAFFIC IN ARMS REGULATIONS (ITAR): 22 C.F.R. Ch. I, Subch. M, Pts. 120-130.
  – Latest Amendment: 5 Dec 2016 (effective 5 Dec 2016): 81 FR 87427-87430: Corrections & Additions to ITAR Parts 120, 121, 122, 124, 126 and 127
  – The only available fully updated copy (latest edition 9 Dec 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 on 31 December 2016, plus a large Index, over 750 footnotes containing case annotations, practice tips, DDTC guidance, and explanations of errors in the official ITAR text.  Subscribers receive updated copies of the BITAR in Word by email, usually revised within 24 hours after every ITAR amendment.  The BITAR is available by annual subscription from the Full Circle Compliance website.  BAFTR subscribers receive a 25% discount on subscriptions to the BITAR, please contact us to receive your discount code.  

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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 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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