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17-0201 Wednesday “The Daily Bugle”

17-0201 Wednesday “Daily Bugle”

Wednesday, 1 February 2017

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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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  1. Commerce/BIS Delays Implementation Date Concerning Removal of Certain NP Column 2 Controls
  1. Ex/Im Items Scheduled for Publication in Future Federal Register Editions 
  2. Commerce/BIS: (No new postings.) 
  3. DHS/CBP Announces Drawback Simplification Newsletter 
  4. Justice: Kansas Man Sentenced to 52 Months for Exporting Firearms to Overseas Purchasers Using Hidden Marketplace Website 
  5. State/DDTC Posts Address Change of BAE Systems Surface Ships Limited 
  1. Niagara-Gazette: “Pakistani Man Indicted in Weapons Case” 
  2. ST&R Trade Report: “Export Control Change on Software Delayed”  
  1. D.M. Edelman: “Demonstration of Compliance with Hong Kong Law Now A Must for U.S. Exporters to Hong Kong” 
  2. M.L. Fleischaker, D.C. McLean & Andrew M. Murad: “Trump Administration Orders Regulatory Freeze and the Elimination of Two Pre-existing Regulations for Every New Regulation Issued” 
  1. Bartlett’s Unfamiliar Quotations 
  2. Are Your Copies of Regulations Up to Date? Latest Changes: ATF (15 Jan 2016), Customs (27 Jan 2017), DOD/NISPOM (18 May 2016), EAR (1 Feb 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. Commerce/BIS Delays Implementation Date Concerning Removal of Certain NP Column 2 Controls
(Source: Federal Register) [Excerpts.]
 
82 FR 8893-8894: Commerce Control List: Removal of Certain Nuclear Nonproliferation (NP) Column 2 Controls
* AGENCY: Bureau of Industry and Security, Commerce.
* ACTION: Final rule; delay of implementation date.
* SUMMARY: In accordance with the memorandum of January 20, 2017, from the Assistant to the President and Chief of Staff, entitled “Regulatory Freeze Pending Review,” published in the Federal Register on January 24, 2017 (the Memorandum), this action temporarily delays the implementation date of one revision implemented by the final rule entitled “Commerce Control List: Removal of Certain Nuclear Nonproliferation (NP) Column 2 Controls” published by the Bureau of Industry and Security (BIS) in the Federal Register on November 25, 2016. The final rule amended the Export Administration Regulations (EAR) to remove nuclear nonproliferation (NP) Column 2 license requirements from certain pressure tubes, pipes, fittings, pipe valves, pumps, numerically controlled machine tools, oscilloscopes, and transient recorders on the Commerce Control List (CCL).
* DATES: This rule is effective January 31, 2017. “Software” “specially designed” for the “development,” “production,” or “use” of items previously controlled under ECCN 3A292, as discussed in the final rule published in the Federal Register of November 25, 2016 (81 FR 85138), will continue to be classified and licensed by BIS under the designation EAR99 through a delayed date of March 21, 2017. As of March 22, 2017, such “software” will be classified and licensed by BIS under ECCN 3D991.
* FOR FURTHER INFORMATION CONTACT: Steven Clagett, Director, Nuclear and Missile Technology Controls Division, Office of Nonproliferation and Treaty Compliance, Bureau of Industry and Security, Telephone: (202) 482-1641.
* SUPPLEMENTARY INFORMATION: …
   This action delays the implementation date of the imposition of anti-terrorism controls on “software” “specially designed” for the “development,” “production,” or “use” of items previously controlled under ECCN 3A292 but reclassified by the November 25 rule. Such “software” had been classified and licensed by BIS under the designation EAR99; as a result of the November 25 rule, it will be classified and licensed by BIS under ECCN 3D991. The implementation date of this change had been January 31, 2017, but this action delays the implementation date to March 21, 2017. This action is issued in accordance with the Memorandum that required temporary postponement of rules that have been published in the Federal Register but have not yet taken effect, for 60 days from the date of the Memorandum for the purpose of reviewing questions of fact, law, and policy.
 
   Dated: January 27, 2017.
Matthew S. Borman, Deputy Assistant Secretary for Export Administration.  

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OGSOTHER GOVERNMENT SOURCES

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


[No items of interest noted today.]  

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OGS_a34
. DHS/CBP Announces Drawback Simplification Newsletter

(Source:
CSMS# 17-000047, 31 January 2017.)
 
In support of upcoming drawback program changes mandated by the Trade Facilitation and Trade Enforcement Act of 2015 (TFTEA), U.S. Customs and Border Protection (CBP) has published the Drawback Simplification Newsletter on CBP.gov. This newsletter provides TFTEA Drawback development and deployment information for the trade community. CBP intends to update information each month and plans to publish the newsletter on its website through February 2019.
 
To access the Drawback Simplification Newsletter, please copy and paste the following URL to your Internet browser:
 
 
For questions about the newsletter or the TFTEA Drawback program, please send an email to: OTDrawback@cbp.dhs.gov

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(Source:
Justice) [Excerpts.] 
 
A Kansas man was sentenced today (30 January 2017, ed.) to 52 months in prison for his role in a scheme involving the illegal export of firearms from the United States using a hidden online marketplace, announced Acting Assistant Attorney General Kenneth A. Blanco of the Justice Department’s Criminal Division and Acting U.S. Attorney Tom Beall of the District of Kansas.
 
Michael Andrew Ryan, aka Brad Jones and GunRunner, 36, of Manhattan, Kansas, previously pleaded guilty to six counts of exporting and attempting to export firearms illegally from the United States to individuals located in other countries on June 6, 2016, and was remanded into custody on Oct. 6, 2016. In addition to imposing today’s prison sentence, U.S. District Judge Daniel D. Crabtree of the District of Kansas ordered Ryan to forfeit all firearms and ammunition seized by law enforcement during the investigation.
 
In connection with his plea, Ryan admitted that he used the hidden internet marketplace Black Market Reloaded, a website hosted on the Tor network where users can traffic anonymously in illegal drugs and other illegal goods, to unlawfully export or attempt to export firearms from the United States to Cork, Ireland; Mallow, Ireland; Pinner, England; Edinburgh, Scotland; Victoria, Australia. These goods included dozens of firearms, including pistols, revolvers, UZIs and Glocks, some from which the manufacturer’s serial numbers had been removed, altered or obliterated, as well as magazines and hundreds of rounds of ammunition. … 
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(Source:
State/DDTC) [Excerpts.]
 
Effective March 3, 2017, BAE Systems Surface Ships Limited will change as follows:
 
From:
 
BAE Systems Surface Ships Limited
Eastwood House, Glebe Road, Chelmsford
Essex, CM1 1QW, United Kingdom
 
To:
 
BAE Systems Surface Ships Limited
West Hanningfield Road, Great Baddow, Great
Baddow, Chelmsford, Essex, CM2 8HN,
United Kingdom
 
and
 
BAE Systems Surface Ships Limited
Eastwood House, Glebe Road, Chelmsford,
Essex, CM1 1QW, United Kingdom
 
Due to the volume of authorizations requiring amendments to reflect this change, the Deputy Assistant Secretary for Defense Trade Controls is exercising the authority under 22 CFR 126.3 to waive the requirement for amendments to change currently approved license authorizations. The amendment waiver does notapply to approved or pending agreements. …

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NWSNEWS

 
A federal grand jury in Buffalo has indicted a Pakistani man for lying in an attempt to export parts for assault weapons.
 
The indictment charges Agha Muhammad Khan Durrani, 27, of Pakistan, with a violation of the Arms Export Control Act, a violation of the International Emergency Economic Powers Act, and with making false statements during an attempt to unlawfully export merchandise consisting of weapons parts. The charges carry a maximum penalty of 20 years in prison and a fine of $1 million.
 
Prosecutors, in the indictment and a previously filed complaint, said that on July 19, Durrani and his father, tried unsuccessfully to bring assault rifle accessories into Canada. They were stopped by Canada Border Services Agency officers and U.S. Customs and Border Protection agents at the Rainbow Bridge.
 
Durrani told a CBP officer that he and his father were going to Cabela’s Sporting Goods in Cheektowaga to return the accessories and a scope they had purchased the day before.
 
Among the items in their possession were assault rifle rail systems, assault rifle grips, an assault rifle mounting system, assault rifle buffer systems, assault rifle stocks, assault rifle hand guards and assault rifle backup lights.
 
All those items are included on the U.S. Munitions List and require a license to export. Durrani did not have an export license.
 
During a secondary inspection, Durrani told a CBP officer that he wanted to bring the assault rifle accessories back to Pakistan to be used for hunting and defending his family’s land. In a later interview with federal agents, Durrani, after telling them that the weapons parts would only be used for personal use, admitted that he sells guns, gun parts, ammo, and accessories in Pakistan through a business that he owns there.
 
Agents also examined Durrani’s cell phone and found photographs of multiple variants of assault rifles and handguns and rifle components and accessories. There was also a photograph of a Nightforce BEAST 5-25x56mm F1 Riflescope on Amazon.com with the message, “This item does not ship to Canada. Please check other sellers who may ship internationally.”
 
A check of Durrani’s email showed a series of messages with another individual, dated July 14, concerning a shipment of similar weapons accessories ready to be picked up in Thailand. The value of those parts was $10,800.
 
Durrani told the seller that he was currently in Canada and that he would have to pick-up his shipment at a later date.
 
He had pleaded not guilty to the charges, but is being detained by U.S. Marshals.

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NWS_a2
8. ST&R Trade Report: “Export Control Change on Software Delayed”

 
The Bureau of Industry and Security has postponed a change in export controls on certain software in light of President Trump’s Jan. 20 memorandum directing federal agencies to postpone for 60 days pending regulations that had not taken effect as of that date.
 
In a Nov. 25, 2016, final rule BIS amended the Export Administration Regulations to remove nuclear nonproliferation Column 2 license requirements from certain pressure tubes, pipes, fittings, pipe valves, pumps, numerically controlled machine tools, oscilloscopes, and transient recorders on the Commerce Control List. This rule also created four new Export Control Classification Numbers to maintain anti-terrorism controls on certain affected commodities and related software and technology.
 
BIS states that a consequence of the amendment of ECCN 3A992 to add certain oscilloscopes and transient recorders under new paragraphs 3A992.d through .g was that ECCN 3D991, which includes certain software for general purpose electronic equipment described in ECCN 3A992, then also controlled software for the development, production, or use of those devices. Such software had been classified and licensed under the designation EAR99 and its classification under ECCN 3D991 imposed a foreign policy control for anti-terrorism reasons. Because such controls must first be notified to Congress, BIS delayed implementation of this control until Jan. 31, 2017.
 
However, in light of the presidential memorandum, BIS now states that software specially designed for the development, production, or use of items previously controlled under ECCN 3A992 will continue to be classified and licensed under the designation EAR99 through March 21. As of March 22, such software will be classified and licensed under ECCN 3D991.

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COMMCOMMENTARY

COMM_a19. D.M. Edelman: “Demonstration of Compliance with Hong Kong Law Now A Must for U.S. Exporters to Hong Kong”

 
* Author: Doreen M. Edelman, Esq., Baker Donelson LLP, 202-508-3460, dedelman@bakerdonelson.com
 
The Commerce Department’s Bureau for Industry and Security (BIS) has issued a new rule that requires exporters to Hong Kong of items subject to certain controls under the Export Administration Regulations (EAR) to obtain either an import license or a written statement from the Hong Kong government as to why an import license is not required. The rule will be effective on April 19, 2017.
 
The new rule applies to items controlled for National Security (NS), missile technology (MT), nuclear nonproliferation (NP Column 1), and chemical or biological weapons (CB) reasons. If an item is controlled for one of these reasons and is being exported to Hong Kong, an exporter must demonstrate compliance with Hong Kong law, in addition to any U.S. requirements.
 
The goal of the new regulation is to ensure compliance with existing United States and Hong Kong law. United States authorities continue to be concerned about items transshipped from Hong Kong to other countries, particularly China. Thus, the reexport of any items from Hong Kong to another country must also comply with United States and Hong Kong law.
 
When a U.S. export license is needed from BIS, the exporter may apply for an export license from BIS before receiving any import authorization from Hong Kong. However, a U.S. exporter cannot actually ship a controlled item to Hong Kong until it receives either an import license from Hong Kong or a written statement from Hong Kong stating an import permit is not required.
 
U.S. exporters must add the Hong Kong documentation requirement to their compliance program requirements. Therefore, although neither U.S. nor Hong Kong licensing requirements are changing, companies will face additional compliance requirements for exports to and through Hong Kong to address transshipment risks.
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COMM_a210. M.L. Fleischaker, D.C. McLean & Andrew M. Murad: “Trump Administration Orders Regulatory Freeze and the Elimination of Two Pre-existing Regulations for Every New Regulation Issued”

(Source: Arent Fox LLP)
 
* Authors: Marc L. Fleischaker, Esq., marc.fleischaker@arentfox.com, 202-857-6053; Donald C. McLean, Esq., donald.mclean@arentfox.com, 202-857-6469; and Andrew M. Murad, Esq., andrew.murad@arentfox.com, 202-857-6040. All of Arent Fox LLP.
 
On January 20, 2017, President Trump’s Chief of Staff, Reince Priebus, issued a memorandum implementing an immediate regulatory freeze of any new or pending regulations until they have been reviewed and approved by Trump Administration appointees. Days later, on January 30, President Trump signed an executive order that requires agencies to repeal at least two pre-existing regulations for every new regulation issued. These actions signal the start of the Trump Administration’s efforts to scale back and eliminate some of President Obama’s key regulatory initiatives, and to reduce the compliance costs stemming from regulations going forward.
 
The January 20th Memorandum
 
It is not uncommon for a new administration to temporarily suspend regulatory activity pending review by the new President’s designees-President Obama’s and George W. Bush’s Chiefs of Staff issued similar directives in 2009 and 2001, respectively. Nonetheless, the January 20th Memorandum, one of the President’s first executive actions, is likely the start of many moves intended to chip away at President Obama’s regulatory legacy.
 
Specifically, the January 20th Memorandum instructs agencies to immediately stop submitting any regulations for publication in the Federal Register until a Trump agency head reviews and approves the proposed action. Similarly, agencies are required to withdraw any regulations that have already been sent to, but not published by, the Federal Register, so that a Trump designee can first review and approve the proposal.
 
The memorandum also instructs agencies to further review questions of fact, law, and policy raised by any regulations that have already been published in the Federal Register, but not yet become effective. The effective date of such regulations will be temporarily postponed for 60 days to allow the agencies to conduct this review. At the end of the 60-day freeze, agencies are requested to notify the Office of Management and Budget Director of any regulations “that raise substantial questions of law or policy” and “take further appropriate action in consultation with the OMB Director.” Agencies are asked to consider further notice-and-comment rulemaking to review the substance of the proposed action or to delay the effective date of the regulations beyond the 60-day period.
 
The memorandum applies to “regulatory action” and “guidance document[s],” meaning “any substantive action by an agency (normally published in the Federal Register) that promulgates or is expected to lead to the promulgation of a final rule or regulation, including notices of inquiry, advance notices of proposed rulemaking, and notices of proposed rulemaking,” and also covers any agency statement of general applicability and future effect “that sets forth a policy on a statutory, regulatory, or technical issue or an interpretation of a statutory or regulatory issue.” However, regulatory actions that are subject to statutory or court deadlines are excluded from these requirements, as are regulations that are necessary to address emergency or urgent circumstances relating to health, safety, financial, or national security matters. The memorandum instructs agency heads to initially identify and notify the OMB Director of any regulations that the agency head believes should be excluded from the freeze due to statutory or judicial deadlines or because “the regulations affect critical health, safety, financial, or national security matters, or for some other reason.” Thereafter, the OMB Director will make the final determination as to whether “such exclusion is appropriate under the circumstances.”
 
The Executive Order
 
The January 30th Executive Order is intended to help “manage the costs associated with the governmental imposition of private expenditures required to comply with Federal regulations.” To that end, the Executive Order requires agencies and executive departments to “identify at least two existing regulations to be repealed” whenever they publicly propose or promulgate a new regulation. The Order applies to “regulations” or “rules,” which are defined as agency statements of “general or particular applicability and future effect designed to implement, interpret, or prescribe law or policy, or to describe the procedure or practice requirements of an agency.” Rules that are related to the military or national security, or agency management or organization, are excluded from the Executive Order, as are “any other category of regulations” exempted by the Director of OMB.
 
In particular, the Executive Order requires the total incremental costs of any new regulation to be offset by the elimination of the costs associated with the repealed regulations. Beginning with fiscal year 2018, agencies will be required to identify each new regulation that increases incremental costs along with the offsetting rules that it expects to eliminate in that fiscal year. The agency must also provide an approximation of the total costs or savings associated with the new and repealed regulations.
 
The Executive Order contemplates future guidance from the Director of OMB before certain provisions become effective. For example, agencies are prohibited from issuing any regulations that exceed the individual agency’s “total incremental cost allowance” for the relevant fiscal year, which will be set by the OMB Director. And the Executive Order requires additional guidance from the OMB Director on a number of standards, including: standards for determining the costs of new and existing regulations; what qualifies as new and offsetting actions; and the process for accounting for costs in different fiscal years.
   
Take Away

While only time will tell the full impact of Trump’s recent regulatory actions, agencies have already taken swift action, particularly in response to the January 20th Memorandum. Some agencies have already postponed the effective date of certain regulations that had been published in the Federal Register, but had not yet taken effect. The Environmental Protection Agency, for example, recently delayed the effective date of 30 regulations until March 21, 2017, including a final rule establishing biomass-based diesel standards for 2017 that was scheduled to take effect on February 10, 2017. The EPA noted that it may consider delaying the effective dates of these regulations even further.
 
Likewise, a number of proposed regulatory actions have been withdrawn from further consideration by the Office of Information and Regulatory Affairs, an office within the OMB that is responsible for reviewing certain agency actions prior to publication in the Federal Register. The move effects a number of proposals that were under OIRA review, including EPA’s final rule establishing standards of performance for grain elevators, and USDA’s proposal to establish a national GMO ingredient disclosure standard and its long-pending organic aquaculture standard. These proposals will be returned to the agencies for further consideration by new agency officials.
 
The January 20th Memorandum and recent Executive Order are just the start of the new Administration’s efforts to eliminate what it views as over-burdensome regulations. Given that most of President Trump’s cabinet nominees have not yet been confirmed, it is too soon to tell how long the temporary freeze on new rulemaking activities will last or determine the ultimate fate of the final rules that are currently in limbo under the January 20th Memorandum. Likewise, because agencies cannot repeal existing regulations without going through the notice and comment rulemaking process, it is not clear how easy it will be for an agency to implement the Executive Order’s two-for-one elimination requirement. Moreover, we will not know which future regulatory actions could be subject to the Executive Order until agencies take further action or the OMB releases additional guidance.
 
In the meantime, however, at least until the President’s appointees are confirmed, interim or acting agency heads will be responsible for carrying out the recent executive actions, including identifying regulations that are subject to the regulatory freeze or notifying the OMB Director of those that should be excluded from it. It is wise for any stakeholder with an interest in pending or future regulations that are possibly covered by these recent actions to keep a close eye on regulatory activity over the coming weeks and months, both at the relevant regulatory agencies and OMB.

We will continue to monitor these events as they unfold. If you have any questions, please feel free to contact the authors of this alert or other Arent Fox professional who regularly handles your matters.

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ENEDITOR’S NOTES

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EN_a312
. 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: 27 Jan 2017: 82 FR 8589-8590: Delay of Effective Date for Importations of Certain Vehicles and Engines Subject to Federal Antipollution Emission Standards; and 82 FR 8590: Delay of Effective Date for Toxic Substance Control Act Chemical Substance Import Certification Process Revisions 

* 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: 1 Feb 2017: 82 FR 8893-8894: Commerce Control List: Removal of Certain Nuclear Nonproliferation (NP) Column 2 Controls 

  
*
FOREIGN ASSETS CONTROL REGULATIONS (OFAC FACR)
: 31 CFR, Parts 500-599, Embargoes, Sanctions, Executive Orders
  – Last Amendment: 17 Jan 2017: 
82 FR 7641-7642: Updated Statements of Legal Authority for the Export Administration Regulations.
 
*
FOREIGN TRADE REGULATIONS (FTR)
: 15 CFR Part 30
  – Last Amendment: 15 May 2015; 80 FR 27853-27854: Foreign Trade Regulations (FTR): Reinstatement of Exemptions Related to Temporary Exports, Carnets, and Shipments Under a Temporary Import Bond 
  – HTS codes that are not valid for AES are available
here.
  – The latest edition (9 Mar 2016) of Bartlett’s Annotated FTR (“BAFTR”), by James E. Bartlett III, is available for downloading in Word format. The BAFTR contains all FTR amendments, FTR Letters and Notices, a large Index, and footnotes containing case annotations, practice tips, and Census/AES guidance.  Subscribers receive revised copies every time the FTR is amended. The BAFTR is available by annual subscription from the Full Circle Compliance website.  BITAR subscribers are entitled to a 25% discount on subscriptions to the BAFTR.
 
*
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 is 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.  

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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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