;

17-0127 Friday “The Daily Bugle”

17-0127 Friday “Daily Bugle”

Friday, 27 January 2017

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 Posts Civil Monetary Penalty Adjustments for Inflation 
  2. DHS/CBP Postpones Effective Date for Importations of Certain Vehicles and Engines Subject to CAA Emission Standards 
  3. DHS/CBP Postpones Effective Date for TSCA Chemical Substance Import Certification Process Revisions
  4. DHS/CBP Extends Comment Period Regarding Regulatory Implementation of the Centers of Excellence and Expertise
  1. Ex/Im Items Scheduled for Publication in Future Federal Register Editions 
  2. Commerce/BIS: (No new postings.) 
  3. Commerce/Census Posts ACE Export Reports Update
  4. DHS/CBP Announces ACE Production Outage on Jan 28-29
  5. DHS/CBP Deactivates Several CBP El Paso Port Codes for Import Cargo
  6. State/DDTC: (No new postings.)
  7. EU Amends Restrictive Measures Concerning ISIL and Al-Qaida 
  1. ST&R Trade Report: “Dates and Deadlines: Classification, Textiles and Apparel, Importer Loans, Broker Fees”
  1. M. Gajewski Barnhill: “Despite Changes to Iran Sanctions in 2016, U.S. Reporting Requirements Related to Iran Activities Remain in Place”
  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 (20 Dec 2016), DOD/NISPOM (18 May 2016), EAR (23 Jan 2017), FACR/OFAC (17 Jan 2017), FTR (15 May 2015), HTSUS (1 Jan 2017), ITAR (11 Jan 2017)

EXIMEX/IM ITEMS FROM TODAY’S FEDERAL REGISTER

EXIM_a1
1
. DHS Posts Civil Monetary Penalty Adjustments for Inflation

(Source:
Federal Register) [Excerpts.]
 
82 FR 8571-8584: Civil Monetary Penalty Adjustments for Inflation
* AGENCY: Department of Homeland Security.
* ACTION: Final rule.
* SUMMARY: This Final Rule finalizes the Department of Homeland Security’s (DHS) Interim Final Rule that adjusted DHS civil monetary penalties for inflation. The Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015 (2015 Act) was signed into law on November 2, 2015. Using the formula in the 2015 Act and guidance from the Office of Management and Budget (OMB), DHS calculated adjusted penalties. On July 1, 2016, DHS published an Interim Final Rule setting forth the adjusted civil penalty amounts, effective for civil penalties assessed after August 1, 2016 whose associated violations occurred after November 2, 2015.
    Pursuant to the 2015 Act, all agencies must adjust civil monetary penalties annually and publish the adjustment in the Federal Register. Accordingly, this Final Rule adjusts DHS’s civil monetary penalties pursuant to the 2015 Act and OMB guidance. The new penalties will be effective for penalties assessed after January 27, 2017 whose associated violations occurred after November 2, 2015. DHS also announces that it will make its required annual adjustment of civil monetary penalties in future years by publication of a Final Rule notwithstanding the notice and comment provisions of the Administrative Procedure Act.
* DATES:
This rule is effective on January 27, 2017.
* FOR FURTHER INFORMATION CONTACT: Megan Westmoreland, Attorney-Advisor, Office of the General Counsel, U.S. Department of Homeland Security. Phone: 202-447-4384.
* SUPPLEMENTARY INFORMATION: …
 
    This rule adopts, as final, the civil monetary penalty adjustment methodology that DHS announced in the IFR. This Final Rule also makes the 2017 annual inflation adjustment pursuant to the 2015 Act and pursuant to guidance OMB issued to agencies on December 16, 2016. [FN/1] Where applicable, we have finalized conforming edits to regulatory text. The penalty amounts in this Final Rule will be effective for penalties assessed after January 27, 2017 where the associated violation occurred after November 2, 2015. Consistent with OMB guidance, the 2015 Act does not change previously assessed penalties that the agency is actively collecting or has collected. …
 
Sec.  280.53  Civil monetary penalties inflation adjustment. …
 
 Section 275(b) of the Act, Penalties for improper entry: From $75 minimum/$376 maximum to $76 minimum/$382 maximum, for each entry or attempted entry. …
 
Jeh Charles Johnson, Secretary.
 

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

EXIM_a02

2. DHS/CBP Postpones Effective Date for Importations of Certain Vehicles and Engines Subject to CAA Emission Standards
(Source:
Federal Register
) [Excerpts.]
 
82 FR 8589-8590: Delay of Effective Date for Importations of Certain Vehicles and
Engines Subject to Federal Antipollution Emission Standards
* AGENCIES: U.S. Customs and Border Protection, Department of Homeland Security; Department of the Treasury.
* ACTION: Final rule; delay of effective date.
* SUMMARY: On December 27, 2016, U.S. Customs and Border Protection (CBP) published a Final Rule in the Federal Register announcing amendments to CBP regulations relating to the importation into the United States of certain vehicles and engines under the Clean Air Act (CAA) in order to harmonize the documentation requirements applicable to different classes of vehicles and engines that are subject to the CAA’s emission standards. That document further amended the regulations to permit importers to file the required U.S. Environmental Protection Agency (EPA) Declaration Forms with CBP electronically, and amended non-substantive provisions to update regulatory citations and delete obsolete provisions. The changes announced in that Final Rule were to be effective January 26, 2017. This notice announces that the effective date of the Final Rule is delayed for 60 days from January 20, 2017.
* DATES: This regulation is effective January 25, 2017. The effective date of the rule amending 19 CFR part 12 published at 81 FR 94974, December 27, 2016 is delayed until March 21, 2017.
* FOR FURTHER INFORMATION CONTACT: For questions related to the filing of EPA forms with CBP, please contact William Scopa, Partner Government Agencies Interagency Collaboration Division, Office of Trade, Customs and Border Protection, at
William.R.Scopa@cbp.dhs.gov
. For questions related to EPA’s vehicle and engine imports program, please contact Holly Pugliese at
pugliese.holly@epa.gov
. …
 
Kevin K. McAleenan, Acting Commissioner, U.S. Customs and Border Protection.
   Approved: January 25, 2017.
Timothy E. Skud, Deputy Assistant Secretary of the Treasury.

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

EXIM_a33
. DHS/CBP Postpones Effective Date for TSCA Chemical Substance Import Certification Process Revisions

(Source:
Federal Register) [Excerpts.]
 
82 FR 8590: Delay of Effective Date for Toxic Substance Control Act Chemical Substance Import Certification Process Revisions
* AGENCY: U.S. Customs and Border Protection, Department of Homeland Security; Department of the Treasury.
* ACTION: Final rule;
delay of effective date.
* SUMMARY: On December 27, 2016, U.S. Customs and Border Protection (CBP) published a Final Rule in the Federal Register announcing amendments to CBP regulations regarding the requirement to file a Toxic Substances Control Act (TSCA) certification when importing into the customs territory of the United States chemicals in bulk form or as part of mixtures and articles containing a chemical or mixture. That document amended the regulations to establish an electronic option for importers to file the required U.S. Environmental Protection Agency (EPA) TSCA certifications, to clarify and add certain definitions, and to eliminate the paper-based blanket certification process. The changes announced in that Final Rule were to be effective January 26, 2017. This notice announces that the effective date of the Final Rule is delayed for 60 days from January 20, 2017.
* DATES: This regulation is effective January 25, 2017. The effective date of the rule amending 19 CFR parts 12 and 127 published at 81 FR 94980, December 27, 2016 is delayed until March 21, 2017.
* FOR FURTHER INFORMATION CONTACT: For questions related to the filing of EPA forms with CBP, please contact William Scopa, Partner Government Agencies Interagency Collaboration Division, Office of Trade, Customs and Border Protection, at
William.R.Scopa@cbp.dhs.gov. For EPA policy questions, please contact Harlan Weir, at
Weir.Harlan@epa.gov. …
 
Kevin K. McAleenan, Acting Commissioner, U.S. Customs and Border Protection.
    Approved: January 25, 2017.
Timothy E. Skud, Deputy Assistant Secretary of the Treasury.

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

EXIM_a44
. DHS/CBP Extends Comment Period Regarding Regulatory Implementation of the Centers of Excellence and Expertise

(Source:
Federal Register)
 
82 FR 8588-8589: Regulatory Implementation of the Centers of Excellence and Expertise
* AGENCIES: U.S. Customs and Border Protection, Department of Homeland Security.
* ACTION: Interim final rule; extension of comment period.
* SUMMARY: This document provides an additional 60 days for interested parties to submit comments on the interim final rule that amended the U.S. Customs and Border Protection (CBP) regulations establishing the Centers of Excellence and Expertise (“Centers”) as a permanent organizational component of the agency and transitioning certain additional trade functions to the Centers. The interim final rule was published in the Federal Register on December 20, 2016, with comments due on or before January 19, 2017. To have as much public participation as possible in the formulation of the final rule, CBP is extending the comment period to March 20, 2017.
* DATES: The comment period for the interim final rule published December 20, 2016, at 81 FR 92978, effective January 19, 2017, is extended. Comments must be received on or before March 20, 2017.
* ADDRESSES: You may submit comments, identified by docket number, by one of the following methods:
     Federal eRulemaking Portal:
http://www.regulations.gov. Follow the instructions for submitting comments via docket number USCBP-2016-0075.
     Mail: Trade and Commercial Regulations Branch, Regulations and Rulings, Office of Trade, Customs and Border Protection, 90 K Street NE., 10th Floor, Washington, DC 20229-1177.
    Instructions: All submissions received must include the agency name and docket number for this rulemaking. All comments received will be posted without change to
http://www.regulations.gov, including any personal information provided. For detailed instructions on submitting comments and additional information on the rulemaking process, see the “Public Participation” heading of the SUPPLEMENTARY INFORMATION section of this document.
    Docket: For access to the docket to read background documents or comments received, go to
http://www.regulations.gov. Submitted comments may be inspected during regular business days between the hours of 9 a.m. and 4:30 p.m. at the Trade and Commercial Regulations Branch, Regulations and Rulings, Office of Trade, Customs and Border Protection, 90 K Street NE., 10th Floor, Washington, DC. Arrangements to inspect submitted comments should be made in advance by calling Mr. Joseph Clark at (202) 325-0118.
* FOR FURTHER INFORMATION CONTACT: Lori Whitehurst, CBP Office of Field Operations by telephone (202) 344-2536 or by email,
lori.j.whitehurst@cbp.dhs.gov; or Susan S. Thomas, CBP Office of Field Operations by telephone (202) 344-2511 or by email,
susan.s.thomas@cbp.dhs.gov. …
 
    Dated: January 18, 2017.

Richard F. DiNucci, Executive Director, Cargo and Conveyance Security, Office of Field Operations. 

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

OGSOTHER GOVERNMENT SOURCES

OGS_a15. Ex/Im Items Scheduled for Publication in Future Federal Register Editions

(Source:
Federal Register)
 
* Alcohol, Tobacco, Firearms, and Explosives Bureau; NOTICES; 

Agency Information Collection Activities; Proposals, Submissions, and Approvals: Request for ATF Background Investigation Information [Publication Date: 30 January 2017.]

* Drug Enforcement Administration; RULES; Import and Export Requirements: Controlled Substances, Listed Chemicals, and Tableting and Encapsulating Machines, etc. [Publication Date: 30 January 2017.] 

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

OGS_a02
6. Commerce/BIS: (No new postings.)

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

OGS_a2a
7. Commerce/Census Posts ACE Export Reports Update

(Source: census@subscriptions.census.gov, 27 Jan 2017.)
 
Dear ACE Export Reports Users,
 
The Country of Ultimate Destination field has been added to the data element universe for ACE Export Reports. This data element can now be added to customized reports in the AES 201: Filer Transactions Report and the AES 202: USPPI Transactions Report.
 
For additional information regarding ACE Export Reports, visit our site or view our recent webinar.

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

OGS_a3
8. DHS/CBP Announces ACE Production Outage on Jan 28-29

(Source: CSMS# 17-000040, 27 Jan 2017.)
 
Please be advised that there will be an ACE PRODUCTION Outage Saturday evening, January 28, 2017 starting 2200 ET and ending Sunday, January 29, 2017 at 0400 ET.
 
ACE O&M (ACE Manifest, ACE Portal, ACE Accounts, ACE Reports) will perform infrastructure maintenance activities, and the following ACE Deployment will take place during this time:
 
  – ACE Import Air Manifest:  CAOM-7742: Ticket #7017169-Express House BOL with entry type 87: 1C posted initially, but not reposted after last Delete/Amend/Add. This caused the bill to stay Open and go to G.O., receiving 1S (Sent to G.O.) but not 1R (Pending G.O.) notifications.

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

OGS_a49
.

DHS/CBP Deactivates Several CBP El Paso Port Codes for Import Cargo


(Source: CSMS# 17-000039, 27 Jan 2017.)
 
The CBP Trade Transformation Office (formerly ACE Business Office), in conjunction with the Office of Field Operations, has identified port codes associated to import facilities that are no longer active and will be deactivating the port codes, one Field Office at a time. The El Paso Field Office has identified two (2) port codes to be deactivated. The trade will no longer be able to use these port codes on bills of lading for imports or in-bond movements.
 
During the week of February 6, 2017, the following Port Codes will be deactivated:
 
  – 2401: El Paso District
  – 2479: El Paso International Airport
 

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

OGS_a5
10. State/DDTC: (No new postings.)

(Source:
State/DDTC)

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

OGS_a6
11. EU Amends Restrictive Measures Concerning ISIL and Al-Qaida

 
Regulations:
  –
Commission Implementing Regulation (EU) 2017/142 of 26 January 2017 amending for the 258th time Council Regulation (EC) No 881/2002 imposing certain specific restrictive measures directed against certain persons and entities associated with the ISIL (Da’esh) and Al-Qaida organisations. 

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

NWSNEWS

NWS_a112.

 ST&R Trade Report: “Dates and Deadlines: Classification, Textiles and Apparel, Importer Loans, Broker Fees”

 
Following are highlights of regulatory effective dates and deadlines and federal agency meetings coming up in the next week.
 
  – Jan 30: effective date of
revocation or modification of classification rulings
  – Jan 30: effective date of DEA final rule on imports and exports of
controlled substances and listed chemicals
  – Jan 31: deadline for applications for
smart technologies trade mission to Taiwan and Hong Kong
  – Jan 31: deadline for requests for
administrative reviews of AD/CV duty orders with January anniversary dates
  – Feb 3: due date for annual
customs broker user fee
  – Feb 3: due date for comments on USDA interim rule
updating import and export regulations to support ITDS

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

COMMCOMMENTARY

COMM_a1
13M. Gajewski Barnhill: “Despite Changes to Iran Sanctions in 2016, U.S. Reporting Requirements Related to Iran Activities Remain in Place”

 
* Author: Megan Gajewski Barnhill, Esq., Bryan Cave,
megan.gajewskibarnhill@bryancave.com, 202-508-6302.
 
Despite changes in 2016 to the U.S. and E.U. sanctions against Iran, “issuers” registered under the U.S. securities laws should remember that certain reporting requirements continue to apply.  These requirements stem from the Iran Threat Reduction and Syria Human Rights Act of 2012 (“ITRSHRA”), which requires that any issuer required to file periodic reports with the U.S. Securities and Exchange Commission (“SEC”) disclose in its quarterly and annual reports information about dealings by the issuer or its affiliates with respect to specified activities involving Iran and certain sanctioned parties.
 
The revisions to the sanctions against Iran following Implementation Day did not affect reporting requirements under ITRSHRA.  Even if an activity is now authorized under the U.S. and/or E.U. sanctions, it may nonetheless require reporting.
 
Activities with the Government of Iran require reporting only if they are not authorized by the U.S. Government.  The SEC has clarified that reporting is not required for activities involving the Government of Iran when such activities are conducted in accordance with specific or general OFAC licenses, so long as all conditions associated with the particular license are met.  Hence, reporting would not be required for transactions conducted by a foreign subsidiary of a U.S. company in accordance with General License H, provided that the activity with the Government of Iran does not fall under any of the other categories of reportable activity.
 
The other activities by an issuer or affiliate that require reporting under ITRSHRA are the following:
 
  – investments in, and transactions with, Iran’s petroleum sector meeting specified financial thresholds;
  – the export or supply of items to Iran that would contribute to Iran’s ability to acquire weapons of mass destruction or conventional weapons;
  – participation in a joint venture for mining, production, or transportation of uranium if the Government of Iran or an Iranian entity is involved;
  – facilitation for the Government of Iran to acquire or develop weapons of mass destruction and/or delivery systems or provide support to terrorism organizations;
  – the supply of or assistance in the supply of certain goods or technology to Iran, an Iranian entity, or an Iranian national that are likely to be used by the Government of Iran to commit human rights abuses against the people of Iran; or
  – transactions with persons designated under certain Executive Orders related to the support of terrorism and the proliferation of weapons of mass destruction.
 
These activities listed above are reportable even if they are authorized by a general or specific license from OFAC and, more importantly, even if they otherwise would not violate US law or require a license.  Thus, for example, if a foreign affiliate of an issuer, independently of any U.S. involvement or nexus, engaged in a petroleum transaction with a company in Iran it might not violate U.S. sanctions but would still require reporting if the transaction exceeded the dollar thresholds under ITRSHRA.
 
Companies registered under the U.S. securities laws or which are affiliates of a company registered under the U.S. securities laws should ensure that they have in place procedures to identify and gather information regarding the above listed activities to ensure that such information is included in the next annual or quarterly report filed with the SEC.

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

TEEX/IM TRAINING EVENTS & CONFERENCES

TE_a214
. 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:

* Jan 31-Feb 1: Houston TX; “
Foreign Corrupt Practices Act
;” American Conference Institute

* Jan 31-Feb 1: Toronto; “
6th Forum on US Export & Re-Export for Canadian Operations;” American Conference Institute

* Jan 31: Webinar; “
CUI and CDI – The Federal Push to Protect Sensitive Technical Information
;” Federal Publications Seminars

* Feb 1: Wash DC; “
3rd National Forum on CFIUS & Team Telecom;” American Conference Institute

* Feb 1: Webinar; “FCPA: 2016 in Review;” Bryan Cave LLP

*
Feb 1: Webinar; “ITAR Hardware License Exemptions Explained;” ECTI; danielle@learnexportcompliance.com; 540-433-3977

* Feb 6: Manchester UK; “
Nuclear Course
;” UK/BIS Export Control Organisation;
denise.carter@bis.gsi.gov.uk 

* Feb 7: Webinar; “
Tariff Engineering to Legally Reduce or Eliminate Duty
;”
Sandler, Travis & Rosenberg, P.A.;
webinarorganizers@strtrade.com

* Feb 8-9: Wash DC; “7th Annual Advanced ITAR & EAR Compliance;” marcus evans

* Feb 8: Webinar; “
CBP Audit Surveys: What’s at Stake?
;”
Sandler, Travis & Rosenberg, P.A.;
webinarorganizers@strtrade.com

* Feb 10: Melbourne FL; “Accelerated Advanced Export Compliance Workshop;” Space Coast World Trade Council;
bcantillon@bellsouth.net
, 321-373-2047

* Feb 13-15: Las Vegas NV; “
Basics of Government Contracting
;” Federal Publications Seminars

* Feb 15: Webinar; “
Identifying Agents for Customs Purposes – Traps for the Unwary Importer
;”
Sandler, Travis & Rosenberg, P.A.;
webinarorganizers@strtrade.com

* Feb 16: Webinar; “
The Fundamentals of Product Classification
;” ECTI;
danielle@learnexportcompliance.com
; 540-433-3977

* Feb 20-23: Orlando; “
United States Export Control (EAR/OFAC/ITAR) Seminar
;” ECTI;
jessica@learnexportcompliance.com
; 540-433-3977

* Feb 20; San Diego; “
AES Compliance Seminar in Spanish
;”Dept. of Commerce/Census Bureau;
itmd.outreach@census.gov 

* Feb 21: San Diego CA; “AES Compliance Seminar;” Dept. of Commerce/Census Bureau; itmd.outreach@census.gov 

* Feb 21-22: Santa Clara CA; “
12th Annual Export Control Forum: A Compliance Symposium
;” Dept. of Commerce/Bureau of Industry and Security, and Professional Association of Exporters and Importers


* Feb 22: Newcastle UK; “
Intermediate Seminar
;” UK/BIS Export Control Organisation;
denise.carter@bis.gsi.gov.uk 

* Feb 22: Southfield MI; “Harmonized Tariff Schedule – Classifications;” Sandler, Travis & Rosenberg, P.A.; imeyer@sttas.com
* Feb 23: Long Beach CA; “AES Compliance Seminar;” Dept. of Commerce/Census Bureau; itmd.outreach@census.gov 

* Feb 23: Newcastle UK; “
Beginners Workshop
;” UK/BIS Export Control Organisation;
denise.carter@bis.gsi.gov.uk 
* Feb 23: Newcastle UK; “
Making Better License Applications
;” UK/BIS Export Control Organisation;
denise.carter@bis.gsi.gov.uk 
* Feb 23: Newcastle UK; “
Control List Classification – Combined Dual Use and Military
;” UK/BIS Export Control Organisation;
denise.carter@bis.gsi.gov.uk 
*
Feb 27-Apr 3: Santa Ana CA; “
Import Compliance Training Program (Mondays 8am-11am)
;” California Global Trade Logistics Initiative, Orange County Center for International Trade
Development

* Mar 5-6: Dubai UAE; “Trade Compliance in the Middle East;” C5

* Mar 6-8: San Diego CA; “
Basics of Government Contracting
;” Federal Publications Seminars

* Mar 7-10: Orlando; “
‘Partnering for Compliance™’ East Export/Import Control Training and Education Program
;” Partnering for Compliance East;
Ailish@PartneringForCompliance.org
; 321-952-2978 

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

* Mar 12-15: Miami; “ICPA Miami Conference;”

International Compliance Professionals Association;
wizard@icpainc.org 

* Mar 13-15: Newport Beach CA; “2017 Winter Back to Basics Conference;” Society for International Affairs

* Mar 15: Birmingham UK; “
Intermediate Seminar
;” UK/BIS Export Control Organisation;
denise.carter@bis.gsi.gov.uk 

* Mar 15: Miami FL; “AES Compliance Seminar in Spanish;” Dept. of Commerce/Census

* Mar 16: Miami FL; “AES Compliance Seminar;” Dept. of Commerce/Census
* Mar 16: Birmingham UK; “
Beginners Workshop
;” UK/BIS Export Control Organisation;
denise.carter@bis.gsi.gov.uk 
* Mar 16: Birmingham UK; “
Making Better License Applications
;” UK/BIS Export Control Organisation;
denise.carter@bis.gsi.gov.uk 
* Mar 16: Birmingham UK; “
Control List Classification – Combined Dual Use and Military
;” UK/BIS Export Control Organisation;
denise.carter@bis.gsi.gov.uk 

* Mar 17: Chicago IL; “
Customs Education & Solutions Seminar
;” AAEI; Chris Enyart,
cenyart@aaei.org
, +1-202-857-8009

* Mar 20-22: Orlando FL; “
Basics of Government Contracting
;” Federal Publications Seminars

* Mar 20-23: Singapore; “United States Export Control (EAR/OFAC/ITAR) (for Asia-Pacific and other non-US Companies);” ECTI; jessica@learnexportcompliance.com; 540-433-3977

* Mar 21: Webinar; “
Importer Self-Assessment – What It Really Takes
;”
Sandler, Travis & Rosenberg, P.A.;
webinarorganizers@strtrade.com

* Mar 22: Detroit MI; “AES Compliance Seminar;” Dept. of Commerce/Census itmd.outreach@census.gov 

* Mar 29: London UK; “
Control List Classification – Combined Dual Use and Military
;” UK/BIS Export Control Organisation;
denise.carter@bis.gsi.gov.uk 
*  Mar 29-30: Phoenix/Scottsdale AZ; “Critical Compliance & TAA Workshop;” spalmer@exportcompliancesolutions.com; 866-238-4018 / 410-757-1919
* Apr 3-5: Sterling VA; “
Basics of Government Contracting
;” Federal Publications Seminars

* Apr 3-6: Wash DC; “
EAR/OFAC/ITAR Commercial and Military Export Controls/How US Controls Impact Non-US Companies, Affiliates and Transactions, PLUS Other Country Controls Comparison to US (EU & Canada) Seminar
;” ECTI;
jessica@learnexportcompliance.com
; 540-433-3977


* Apr 18: Milwaukee WI; “AES Compliance Seminar;” Dept. of Commerce/Census itmd.outreach@census.gov 
* Apr 26: London UK; “
Intermediate Seminar
;” UK/BIS Export Control Organisation;
denise.carter@bis.gsi.gov.uk 
* Apr 27: London UK; “
Beginners Workshop
;” UK/BIS Export Control Organisation;
denise.carter@bis.gsi.gov.uk 
* Apr 27: London UK; “
Making Better License Applications
;” UK/BIS Export Control Organisation;
denise.carter@bis.gsi.gov.uk 

* May 1-4: Las Vegas; “
EAR Export Controls / ITAR Defense Trade Controls Seminar
;” ECTI;
jessica@learnexportcompliance.com
; 540-433-3977


* May 1-2: Tucson AZ; “2017 Spring Conference;” Society for International Affairs

* May 7-9: Toronto; “ICPA Toronto Conference;”
International Compliance Professionals Association;
wizard@icpainc.org 

* May 8-10: San Diego CA; “
Basics of Government Contracting
;” Federal Publications Seminars

* May 10: London UK; “
Control List Classification – Military
;” UK/BIS Export Control Organisation;
denise.carter@bis.gsi.gov.uk 

* May 10: Wash DC; “
AES Compliance Seminar
;” Dept. of Commerce/Census Bureau;
itmd.outreach@census.gov 

* May 11: London UK; “

Making Better License Applications
;” UK/BIS Export Control Organisation;
denise.carter@bis.gsi.gov.uk 

* May 15-18: London UK; “
United States Export Control (EAR/OFAC/ITAR) Seminar in London (for EU and other non-US Companies)
;” ECTI;
jessica@learnexportcompliance.com
; 540-433-3977

* May 17-19: Minneapolis MN; “
Basics of Government Contracting
;” Federal Publications Seminars

* May 17: Southampton UK; “
Intermediate Seminar
;” UK/BIS Export Control Organisation;
denise.carter@bis.gsi.gov.uk 

* May 18: Southampton UK; “
Beginners Workshop
;” UK/BIS Export Control Organisation;
denise.carter@bis.gsi.gov.uk 

* May 23: Tampa FL; “AES Compliance Seminar;” Dept. of Commerce/Census Bureau; itmd.outreach@census.gov 

* Jun 5-7: Boston MA; “
Basics of Government Contracting
;” Federal Publications Seminars

* Jun 5-8: Wash DC; “
United States Export Control (EAR/OFAC/ITAR) Seminar
;” ECTI;
jessica@learnexportcompliance.com
; 540-433-3977

* Jun 7: London UK; “
Control List Classification – Combined Dual Use and Military
;” UK/BIS Export Control Organisation;
denise.carter@bis.gsi.gov.uk 
* Jul 10-12; Baltimore MD; “
2017 Summer Back to Basics Conference
;” Society for International Affairs

* Jun 11-13: Dublin IRL; “ICPA Dublin Conference;”

International Compliance Professionals Association;
wizard@icpainc.org 

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

* Jun 13: Philadelphia PA; “AES Compliance Seminar;” Dept. of Commerce/Census Bureau; itmd.outreach@census.gov 
* Jun 14: Kegsworth, Derby UK; “
Intermediate Seminar
;” UK/BIS Export Control Organisation;
denise.carter@bis.gsi.gov.uk 
* Jun 15: Kegsworth, Derby UK; “
Beginners Workshop
;” UK/BIS Export Control Organisation;
denise.carter@bis.gsi.gov.uk 
* Jun 15: Kegsworth, Derby UK; “
Making Better License Applications
;” UK/BIS Export Control Organisation;
denise.carter@bis.gsi.gov.uk 
* Jun 15: Kegsworth, Derby UK; “
Control List Classification – Combined Dual Use and Military
;” UK/BIS Export Control Organisation;
denise.carter@bis.gsi.gov.uk 
* July 11-12: Seattle WA; “ITAR/EAR Boot Camp;” spalmer@exportcompliancesolutions.com; 866-238-4018 / 410-757-1919
* Jul 17-19: Hilton Head Island SC; “
Basics of Government Contracting
;” Federal Publications Seminars
* Aug 14-16: McLean VA; “
Basics of Government Contracting
;” Federal Publications Seminars

* Sep 4-9: Galveston TX; “ICPA Conference at Sea;”

International Compliance Professionals Association;
wizard@icpainc.org

* Sep 6: Nashville TN; “AES Compliance Seminar;” Dept. of Commerce/Census Bureau; itmd.outreach@census.gov 

* Sep 12-13: Annapolis MD; “ITAR/EAR Boot Camp;” spalmer@exportcompliancesolutions.com; 866-238-4018 / 410-757-1919

* Sep 12-13: Wash DC; “Interactive Export Controls Workshop;” ECTI; jessica@learnexportcompliance.com; 540-433-3977

* Sep 18-20: Las Vegas NV; “
Basics of Government Contracting
;” Federal Publications Seminars

* Oct 2-5: Columbus OH; “University Export Controls Seminar;” ECTI; jessica@learnexportcompliance.com; 540-433-3977

* Oct 12: Boston MA; “AES Compliance Seminar;” Dept. of Commerce/Census Bureau; itmd.outreach@census.gov 

* Oct 23-24: Arlington VA; “
2017 Fall Advanced Conference
;” Society for International Affairs
* Nov 6-8: Chicago IL; “
Basics of Government Contracting
;” Federal Publications Seminars

* Nov 7: Norfolk, VA; “AES Compliance Seminar;” Dept. of Commerce/Census Bureau; itmd.outreach@census.gov 

* Dec 5: San Juan PR; “AES Compliance Seminar in Spanish;” Dept. of Commerce/Census Bureau; itmd.outreach@census.gov 
* Dec 7: Laredo, TX; “AES Compliance Seminar in Spanish;” Dept. of Commerce/Census Bureau; itmd.outreach@census.gov 

* Dec 11-13: Sterling VA; “
Basics of Government Contracting
;” Federal Publications Seminars


* Dec 12: Jersey City NJ; “
AES Compliance Seminar
;” Dept. of Commerce/Census Bureau;
itmd.outreach@census.gov 

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

ENEDITOR’S NOTES

EN_a115. Bartlett’s Unfamiliar Quotations

(Source: Editor) 

*
Jose Marti (José Julián Martí Pérez, 28 Jan 1853 – 19 May 1895, was a Cuban national hero and an important figure in Latin American literature. In his short life (he died in military action at age 42), he was a poet, an essayist, a journalist, a revolutionary philosopher, a translator, a professor, and a publisher.)
  – “Only those who spread treachery, fire, and death out of hatred for the prosperity of others are undeserving of pity.”
 
*
Mozart (Wolfgang Amadeus Mozart, 27 Jan 1756 – 5 Dec 1791, was a prolific and influential composer of the Classical era.)
  – “When I am traveling in a carriage, or walking after a good meal, or during the night when I cannot sleep; it is on such occasions that ideas flow best and most abundantly.”


Friday funnies:

A guy got drunk and when the bar closed, his friends offered take him to his apartment. Helping him up the stairs, and putting him to bed, they notice a big gong hanging on the wall by his bed, and asked, “What’s with the gong on the wall?” “It’s a talking clock”, the drunk replies. “Watch…” He picks up a mallet next to the bed and hits the gong loudly. A moment later, they hear a voice from the other side of the wall say, “Hey you idiot – it’s 2:15 a.m.!”

  — Michael Danielson, Burbank, CA 

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

EN_a216. 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:
20 Dec 2016: 81 FR 92978-93027: Regulatory Implementation of the Centers of Excellence and Expertise

* 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 Jan 2017: 82 FR 7641-7642: Updated Statements of Legal Authority for the Export Administration Regulations 

  
*
FOREIGN ASSETS CONTROL REGULATIONS (OFAC FACR)
: 31 CFR, Parts 500-599, Embargoes, Sanctions, Executive Orders
  – Last Amendment: 17 Jan 2017: 82 FR 4793-4794: Sudanese 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 (15 Nov 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. 
 
*
HARMONIZED TARIFF SCHEDULE OF THE UNITED STATES (HTS, HTSA or HTSUSA)
, 1 Jan 2017: 19 USC 1202 Annex. (“HTS” and “HTSA” are often seen as abbreviations for the Harmonized Tariff Schedule of the United States Annotated, shortened versions of “HTSUSA”.)
  – Last Amendment: 1 Jan 2017: 2017 Basic HTS
  – 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: 11 Jan 2017: 82 FR 3168-3170: 2017 Civil Monetary Penalties Inflationary Adjustment
  – The only available fully updated copy (latest edition 24 Jan 2017) of the ITAR with all amendments is contained in Bartlett’s Annotated ITAR (“BITAR”), by James E. Bartlett III.  The BITAR contains all ITAR amendments to date, plus a large Index, over 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.  

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

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 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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