;

17-0210 Friday “The Daily Bugle”

17-0210 Friday “Daily Bugle”

Friday, 10 February 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. Treasury/OFAC Posts Inflation Adjustment of Civil Monetary Penalties 
  2. DHS/CBP: Commercial Customs Operations Advisory Committee to Meet on 1 Mar in Wash DC 
  1. Ex/Im Items Scheduled for Publication in Future Federal Register Editions 
  2. Commerce/BIS: (No new postings.) 
  3. DHS/CBP: “Ace Production Outage Scheduled for 11-12 Feb”
  4. State/DDTC: (No new postings.)
  5. EU Implements Regulation (EU) 2017/226 Concerning the Classification of Certain Goods in the Combined Nomenclature
  6. UK/DIT: “All About SIELs”
  1. ST&R Trade Report: “Reliable Data Needed to Better Monitor C-TPAT Benefits and Validations, GAO Says”
  1. C.T. Cherniak: “What Is A Ministerial Authorization To Transact With A Sanctioned Country/Person?”
  2. T. Wright & S.J. Pearse: “White Paper Sets Out UK Government’s Brexit Strategy”
  3. T. Murphy: “GAO Reports on Efficiency of CBP’s C-TPAT Program and Benefits to Participation”
  4. R.C. Burns: “Sometimes Mistaken Identity Is Not A Laughing Matter”
  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 (27 Jan 2017), DOD/NISPOM (18 May 2016), EAR (1 Feb 2017), FACR/OFAC (10 Feb 2017), FTR (15 May 2015), HTSUS (1 Jan 2017), ITAR (11 Jan 2017)

EXIMEX/IM ITEMS FROM TODAY’S FEDERAL REGISTER

EXIM_a01
1
Treasury/OFAC Posts Inflation Adjustment of Civil Monetary Penalties

(Source:
Federal Register) [Excerpts.]
 
82 FR 10434-10440: Inflation Adjustment of Civil Monetary Penalties
* AGENCY: Departmental Offices, Financial Crimes Enforcement Network, and Office of Foreign Assets Control, Treasury.
* ACTION: Final rule.
* SUMMARY: The Department of the Treasury (“Department” or “Treasury”) publishes this final rule to adjust its civil monetary penalties (“CMPs”) for inflation as mandated by the Federal Civil Penalties Inflation Adjustment Act of 1990, as amended by the Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015 (collectively referred to herein as “the Act”). This rule adjusts CMPs within the jurisdiction of certain components of the Department to the maximum amount required by the Act.
* DATES:
Effective February 10, 2017.
* FOR FURTHER INFORMATION CONTACT: For information regarding the Terrorism Risk Insurance Program’s CMPs, contact Richard Ifft, Senior Insurance Regulatory Policy Analyst, Federal Insurance Office, Room 1410 MT, Department of the Treasury, 1500 Pennsylvania Avenue NW., Washington, DC 20220, at (202) 622-2922 (not a toll-free number), Kevin Meehan, Senior Insurance Regulatory Policy Analyst, Federal Insurance Office, at (202) 622-7009 (not a toll-free number), or Lindsey Baldwin, Senior Policy Analyst, Federal Insurance Office, at (202) 622-3220 (not a toll free number). Persons who have difficulty hearing or speaking may access these numbers via TTY by calling the toll-free Federal Relay Service at (800) 877-8339.
  For information regarding Financial Crimes Enforcement Network’s CMPs, contact the FinCEN Resource Center at (800) 767-2825 or email
frc@fincen.gov.
  For information regarding the Office of Foreign Assets Control’s CMPs, contact the Assistant Director for Enforcement, tel.: 202-622-2430; Assistant Director for Licensing, tel.: 202-622-2480, Assistant Director for Regulatory Affairs, tel.: 202-622-4855, Assistant Director for Sanctions Compliance & Evaluation, tel.: 202-622-2490; or the Department of the Treasury’s Office of the Chief Counsel (Foreign Assets Control), Office of the General Counsel, tel.: 202-622-2410.
* SUPPLEMENTARY INFORMATION: …
 
Sec.  50.83   Adjustment of civil monetary penalty amount.
 
  (a) Inflation adjustment. Any penalty under the Act and these
regulations may not exceed the greater of $1,333,312 and, in the case of any failure to pay, charge, collect or remit amounts in accordance with the Act or these regulations such amount in dispute. …
 
David R. Pearl, Executive Secretary.
 
[Editor’s Note: The “Penalty Adjustment and Table” is available at here.]

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

EXIM_a2
2
DHS/CBP: Commercial Customs Operations Advisory Committee to Meet on 1 Mar in Wash DC

(Source:
Federal Register
[Excerpts.]
 
82 FR 10376-10377: Commercial Customs Operations Advisory Committee (COAC)
* AGENCY: U.S. Customs and Border Protection (CBP), Department of Homeland Security (DHS).
* ACTION: Committee Management; Notice of Federal Advisory Committee Meeting.
* SUMMARY: The Commercial Customs Operations Advisory Committee (COAC) will meet in Washington, DC. The meeting will be open to the public.
* DATES: The Commercial Customs Operations Advisory Committee (COAC) will meet on Wednesday, March 1, 2017, from 9:00 a.m. to 1:00 p.m. EST. Please note that the meeting may close early if the committee has completed its business.
  Pre-Registration: Meeting participants may attend either in person or via webinar after pre-registering using a method indicated below:
  – For members of the public who plan to attend the meeting in person, please register by 5:00 p.m. EST by February 28, 2017, either online at
here by email to
tradeevents@dhs.gov; or by fax to (202) 325-4290. You must register prior to the meeting in order to attend the meeting in person.
  – For members of the public who plan to participate via webinar, please register online at
here by 5:00 p.m. EST by February 28, 2017. …
* ADDRESSES: The meeting will be held at the U.S. Customs and Border Protection, Office of Training and Development, 1717 H Street NW., Training Rooms 7300 A-C, Washington, DC 20006. There will be signage posted directing visitors to the location of the meeting room.
  For information on facilities or services for individuals with disabilities or to request special assistance at the meeting, contact Ms. Wanda Tate, Office of Trade Relations, U.S. Customs and Border Protection at (202) 344-1661 as soon as possible.
  To facilitate public participation, we are inviting public comment on the issues the committee will consider prior to the formulation of recommendations as listed in the “Agenda” section below.
  Comments must be submitted in writing no later than February 22, 2017, and must be identified by Docket No. USCBP-2017-0001, and may be submitted by one (1) of the following methods:
  Federal eRulemaking Portal: at
here. Follow the instructions for submitting comments.
  Email:
Tradeevents@dhs.gov. Include the docket number in the subject line of the message.
  Fax: (202) 325-4290.
  Mail: Ms. Wanda Tate, Office of Trade Relations, U.S. Customs and Border Protection, 1300 Pennsylvania Avenue NW., Room 3.5A, Washington, DC 20229.
  Instructions: All submissions received must include the words “Department of Homeland Security” and the docket number (USCBP-2017-0001) for this action. Comments received will be posted without alteration at
here. Please do not submit personal information to this docket.
  Docket: For access to the docket or to read background documents or comments, go to
here and search for Docket Number USCBP-2017-0001. To submit a comment, click the “Comment Now!” button located on the top-right hand side of the docket page.
  There will be multiple public comment periods held during the meeting on March 1, 2017. Speakers are requested to limit their comments to two (2) minutes or less to facilitate greater participation. Contact the individual listed below to register as a speaker. Please note that the public comment period for speakers may end before the time indicated on the schedule that is posted on the CBP Web page, at
here.
* FOR FURTHER INFORMATION CONTACT: Ms. Wanda Tate, Office of Trade Relations, U.S. Customs and Border Protection, 1300 Pennsylvania Avenue NW., Room 3.5A, Washington, DC 20229; telephone (202) 344-1661; facsimile (202) 325-4290.
* SUPPLEMENTARY INFORMATION: Notice of this meeting is given under the Federal Advisory Committee Act, 5 U.S.C. Appendix. The Commercial Customs Operations Advisory Committee (COAC) provides advice to the Secretary of Homeland Security, the Secretary of the Treasury, and the Commissioner of U.S. Customs and Border Protection (CBP) on matters pertaining to the commercial operations of CBP and related functions within the Department of Homeland Security and the Department of the Treasury. …
  Meeting materials will be available by February 27, 2017, at:
here.
 
  Dated: February 7, 2017.
Valarie Neuhart, Acting Director, Office of Trade Relations.

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

OGSOTHER GOVERNMENT SOURCES

OGS_a13. Ex/Im Items Scheduled for Publication in Future Federal Register Editions

(Source:
Federal Register)
 
* State; MEETINGS; Defense Trade Advisory Group [Publication Date: 13 February 2017.]

* U.S. Customs and Border Protection; NOTICES; Agency Information Collection Activities; Proposals, Submissions, and Approvals:
  – Commercial Invoice
  – Transportation Entry and Manifest of Goods Subject to Inspection and Permit

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

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

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

OGS_a2a
5.
DHS/CBP: “Ace Production Outage Scheduled 11-12 Feb”

 
Please be advised that there will be an ACE PRODUCTION Outage Saturday evening, February 11, 2017 starting 2200 ET and ending Sunday, February 12, 2017 at 0400 ET.
 
ACE will perform infrastructure maintenance activities, along with the following ACE Deployments:
 
ACE Import Manifest
 
  – CAOM-7248 (Air): Fixed scenario where a Master BOL with in-bond is deleted, and upon re-add the TRN line is ignored with the following error: ERR/185XFER AT HOUSE LEVEL – MASTER XFER INVALID
– CAOM-8720 (Air), Ticket# 7103155: 1C (Release) notifications stayed in Message Pending status for some CBP-mass-posted non-express SEC 321 airway bills, causing trade not to receive the notifications.
  – CAOM-6811: Ticket#2629793-Fixed 2I (Hold Removal) notifications for house bills not getting sent to the carrier if the Master bill came on file after the house bill had a hold and hold removal.
 
ACE Secure Data Portal – Trade Account
 
  – CAOM-9227: “Search Forms” under the Home tab’s “Task List”: When Searching for CBP Forms under a Trade account, retrieve data based on the Entry date stored in the new ACE system instead of from the ACS system.

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

OGS_a3
6. State/DDTC: (No new postings.)

(Source:
State/DDTC)

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

OGS_a47.

EU Implements Regulation (EU) 2017/226 Concerning the Classification of Certain Goods in the Combined Nomenclature

 
Regulations:
  – Commission Implementing
Regulation (EU) 2017/226 of 7 February 2017 concerning the classification of certain goods in the Combined Nomenclature.

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

OGS_a58
. UK/DIT: “All About SIELs”

 
One of the most used areas of SPIRE is, unsurprisingly, the SIEL application form. Finding out which licence might apply to an export isn’t much use if you can’t then get your hands on that licence. Fair to say if we don’t get the process for applying for a single individual licence right, we won’t be able to consider this project a success.
 
It’s a lot of work, though. Here’s how we’re going about it.
 
Agility
 
Everything we do on this project is done within an Agile framework. We’ve mentioned this methodology in various blogs along the way, but to recap this means delivering the product in stages, so it’s easy to iterate and change each stage quickly in response to both positive and negative user feedback.
 
The opposite approach would be to build the entire thing and release it with the whole development team’s fingers crossed. Get it right: pats on backs. Get it wrong and, well, the amount of effort and expense wasted doesn’t bear thinking about.
 
If we want to get this right we need your feedback along the way. We’ll be delivering the new SIEL application bit by bit so we can find out what you like about it, and what you think we’ve missed out.
 
Maintaining Convenience
 
This might cause you to worry that some aspects of SPIRE that you need and use now might not make it across to the new service. This is a fear we can put to bed right now.
 
You’ll be able to continue to use SPIRE until we’re certain its replacement does the things you want and need it to.
 
We don’t plan to remove any SPIRE functionality, or your ability to use SPIRE to apply for SIELs, while we develop the new system. As we deliver the different components of the new application journey we hope you’ll try it out and give us your feedback.
 
If things are going well, you should want to switch to the new system for your own convenience. We’ve no interest in making your day-to-day interactions with government any harder.
 
Development in Stages
 
We’ve mentioned that it’ll be delivered as ‘components’, but what might these look like?
 
In recent days we’ve been having a first stab at what should and shouldn’t be in scope for the first stages of delivery of the new SIEL application journey. Apart from the obvious – filling in details and submitting the application – we’ll be including the capability to save and resume part-completed applications, tying in a digital version of the end-user undertaking and other things to hopefully simplify the licensing process.
 
That might seem pretty bare bones. In particular, exporters are going to want the ability to copy or ‘clone’ previous applications so they don’t have to fill in the same details over and over. We’ll definitely be doing that – but not at the start.
 
The new system’s interactions with SPIRE make copying previous applications a tricky piece of development. If we include that in the first version of the new application, we’re going to lose valuable time that we could have spent asking users what they think about everything else we’ve done.
 
But if we release an early version without the ability to copy or template previous applications, our researchers can be asking people to try that out, while our developers carry on working on the more complicated components. And all the while, the old functionality will remain available on SPIRE.
 
Early Feedback
 
We’ve done a lot of work on open licences and on our ‘permissions finder’ tool, but now the hard yards on SIELs begin. We’d like to hear from you on what you like about SIEL applications in SPIRE. What do you need us to retain in the new service? What are your gripes with how things work now?
 
If you have views on how SPIRE handles SIEL applications, or ideas about improved features for the new service, please get in touch with our research team at
userresearchforlite@digital.beis.gov.uk.
 
We’re looking for your views over the next few weeks. And if you’d be happy to be a test subject for the initial version of the new SIEL application, we’d love to hear from you.
 
(And let us know if you think we should have used
this image instead – it caused serious debate within the team!)

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

NWSNEWS

NWS_a19.

ST&R Trade Report: “Reliable Data Needed to Better Monitor C-TPAT Benefits and Validations, GAO Says”

 
A recent Government Accountability Office report finds that a lack of reliable data has challenged U.S. Customs and Border Protection’s ability to effectively manage the Customs-Trade Partnership Against Terrorism. CBP responded that it is taking steps to address the shortcomings identified, including developing a new reporting tool.
 
C-TPAT is a voluntary program in which CBP staff validate that members’ supply chain security practices meet minimum security criteria, in return for which members are eligible to receive benefits such reduced exam rates and shipment processing times. However, GAO finds that certain aspects of this program have been adversely affected by problems with the C-TPAT Portal 2.0 data system that began in August 2015.
 
One challenge has been a series of problems that have impaired the ability of CBP staff to identify and complete required C-TPAT member certification procedures and security profile reviews in a timely and efficient manner. For example, CBP has identified instances when the Portal 2.0 system incorrectly altered C-TPAT members’ certification or security profile dates, requiring manual verification of member data. While C-TPAT field offices have implemented procedures for ensuring that validations are identified and completed, these procedures are varied because CBP headquarters has not developed standardized guidance.
 
In response to a GAO recommendation that it develop such guidance, CBP noted that its C-TPAT program manager has selected a methodology that will include uniform monthly reporting from field offices and anticipates that these efforts will be put into effect by May. CBP is also continuing to work on identifying and addressing potential root causes of the Portal 2.0 problems.
 
Another issue is that because the data contained in its Dashboard data reporting tool cannot be relied upon, CBP is unable to determine the extent to which C-TPAT members are receiving the benefits the agency has publicized. For example, GAO’s own analyses of this data show that C-TPAT members’ shipments did not consistently experience lower exam and hold rates and processing times compared to non-members’ shipments, in contrast to CBP’s assertions to members and to Congress.
 
After determining that there appear to be errors in the data or formulas used to compute exam and hold rates and other actions uploaded into the Dashboard, CBP said it has decided to terminate the Dashboard and instead create a new benefit measuring tool by the end of June. CBP officials also said this effort will take precedence over trying to quantify and track other C-TPAT benefits that are more qualitative in nature.

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

COMMCOMMENTARY

COMM_a1
10C.T. Cherniak: “What Is A Ministerial Authorization To Transact With A Sanctioned Country/Person?”

(Source:
Canada-US Blog)
 
* Author: Cyndee Todgham Cherniak, Esq., LexSage PC,
cyndee@lexsage.com, 416-307-4168
 
Canada imposes various economic sanctions and trade restrictions pursuant to the United Nations Act (“UNA”) and the Special Economic Measures Act (“SEMA”). The specific sanctions are implemented in country specific or targeted regulations.  That being said, most regulations promulgated under SEMA have a sister regulation that grants authority to the Minister of Foreign Affairs and/or Minister of International Trade to grant authorizations (called a “Ministerial Authorization”) to allow certain transactions.  Most regulations promulgated under the UNA contain exemptions that may be granted by way of a Ministerial certificate (we call these Ministerial Authorizations also).
Ministerial Authorizations are only granted pursuant to a specific request that is carefully considered on a case-by-case basis.  One person can be granted a Ministerial Authorization for a transaction and it is not guaranteed that a second Ministerial Authorization will be granted to that same person.
 
The Ministerial Authorization can be a general authorization or may be granted in specific situations.
 
General authorizations are set out in SEMA regulations.  For example, the
Special Economic Measures (Iran) Authorization Order provides that it:
“hereby authorizes the Minister of Foreign Affairs to issue to any person in Canada or any Canadian outside Canada a permit to carry out a specified activity or transaction, or any class of activity or transaction, that is restricted or prohibited pursuant to the
Special Economic Measures (Iran) Regulations.” 
Similar provisions are found in respect of Canada’s sanctions against Burma/Myanmar, Iran, Libya, South Sudan, Syria, Russia, Ukraine and Zimbabwe.
 
The more specific authorizations are contained in UNA regulations.  For example, section 13 of the
Regulations Implementing the United Nations Resolutions on the Democratic People’s Republic of Korea (DPRK) provides that:
 
  (1) A person that wishes to do an act or thing that is prohibited under these Regulations may, before doing the act or thing, apply to the Minister in writing for a certificate to exempt the act or thing from the application of the Regulations.
  (2) The Minister may issue the certificate if the Security Council did not intend that such an act or thing be prohibited or if it is established that the requirements of Security Council Resolution 1718 and Security Council Resolution 2270 have been met and, if required by those resolutions, that the Committee of the Security Council has approved the act or thing in advance.
 
Section 14 contains an exemption for property:
 
  (1) A person whose property has been affected by the application of section 3 may apply to the Minister in writing for a certificate to exempt the property from the application of that section if the property
    (a) is necessary for basic or extraordinary expenses; or
    (b) is subject to a lien, mortgage or security interest, to a hypothec or prior claim, to a charge or to a judicial, administrative or arbitral decision.
  (2) If it is established in accordance with Security Council Resolution 1718 that the property is necessary for basic or extraordinary expenses or is subject to a lien, mortgage or security interest, to a hypothec or prior claim, to a charge or to a judicial, administrative or arbitral decision, the Minister must issue a certificate within the following deadlines:
    (a) within 15 working days after receiving the application, in the case of property that is necessary for basic expenses, if the Committee of the Security Council does not oppose the application;
    (b) within 30 working days after receiving the application, in the case of property that is necessary for extraordinary expenses, if the Committee of the Security Council approves the application; and
    (c) within 90 days after receiving the application, in the case of property that is subject to a lien, mortgage or security interest, to a hypothec or prior claim, to a charge or to a judicial, administrative or arbitral decision that
      (i) was created or issued before the coming into force of these Regulations,
      (ii) is not for the benefit of a designated person, and
      (iii) has been brought to the attention of the Committee of the Security Council by the Minister.
 
There are no other restrictions on the Minister’s authority to issue Ministerial Authorizations.  That being said, the Minister does not like to ignore the policy considerations behind the sanctions that his office pursues.  The most common reason for granting Ministerial Authorizations are (1) on humanitarian grounds or (2) the proposed transaction does not offend the policy behind the sanctions.
 
For example, the Minister has issued Ministerial Authorizations for payments to a Canadian company for goods and services provided and/or supplied pursuant to a contract entered into prior to the commencement of the sanctions (where payment is after the sanctions are imposed) because Canadian companies being paid for legal supplies of goods and services is not inconsistent with the policy behind the sanctions.
 
Ministerial Authorizations are granted where it can be shown that the people who will benefit are not intended targets of the sanctions and are suffering due to the sanctions.  Canada realizes that sanctions can hurt the most vulnerable.

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

COMM_a2
11
T. Wright & S.J. Pearse: “White Paper Sets Out UK Government’s Brexit Strategy”

 
* Tim Wright, Esq.,
tim.wright@pillsburylaw.com, +44-20-7847-9505; Samuel J. Pearse,
samuel.pearse@pillsburylaw.com, +44-20-7847-9597. Both of Pillsbury Winthrop Shaw Pittman LLP London, UK.
 
Key Points
 
  – The European Union Bill-authorizing Article 50 notice-passed its first hurdle on February 1, 2017.
  – MPs in the House of Commons voted by 498 to 114 in favour of the Bill.
  – The Bill now moves to the Committee phase: hundreds of amendments have been tabled by MPs, some of which will be debated in Parliament between Monday and Wednesday next week.
  – MPs will then vote again on the amended draft law before it is sent to the House of Lords.
 
Against this backdrop, the government has published a
White Paper-an official policy document-setting out the Government’s principles and objectives for Brexit. The accompanying
press release put out by the Department for Exiting the European Union (DExEU) refers to the White Paper (full title-‘The United Kingdom’s Exit from, and New Partnership with, the European Union’) as the Government’s “plan for ‘a new, positive and constructive’ partnership in the mutual interest of the UK and the EU.” Introducing the White Paper to MPs in Parliament, Brexit Secretary David Davis said:
 
The White Paper confirms the Prime Minister’s vision of an independent, truly global UK and an ambitious future relationship with the EU…It is in the UK’s interest for the EU to succeed politically and economically. And so we approach the negotiation to come in a spirit of goodwill and working to an outcome in our mutual benefit.
 
Lancaster House Speech Revisited
 
The White Paper expands on the 12 principles laid out by Prime Minister Theresa May in a
recent speech at Lancaster House in London. But at only 77 pages, with a foreword from Theresa May, the document is light on specifics in a number of areas, consistent with the Prime Minister’s assertion that details which would undermine the Government’s negotiation position should not be made public.
 
Leverage Play
 
Pointing out that the UK exported some £230 billion worth of goods and services to the EU while importing £290 billion’s worth in 2015, the White Paper argues that it is in the interests of both the UK and the EU27 to build a new strategic partnership.
 
12-Point Plan
 
  (1) Providing certainty & clarity
  (2) Taking control of our own Laws
  (3) Strengthening the Union
  (4) Protecting historic ties with Ireland and maintaining the Common Travel Area 
  (5) Controlling immigration
  (6) Securing rights for EU Nationals in the UK and vice versa
  (7) Protecting workers’ rights
  (8) Ensuring free trade with European markets
  (9) Securing new trade agreements with other countries
  (10) Ensuring the UK remains the best place for science and innovation
  (11) Cooperating in the fight against crime and terrorism
  (12) Delivering a smooth, orderly exit from the EU
 
Samual J. Pearse, Pillsbury:
 
The Government has set out its stall for an ambitious and comprehensive free trade agreement, and a new customs agreement, without giving away too much in terms of what it expects to have to trade in return.

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

COMM_a3
12T. Murphy: “GAO Reports on Efficiency of CBP’s C-TPAT Program and Benefits to Participation”

(Source: Author)
 
* Author: Ted Murphy, Esq., Baker & McKenzie LLP,
ted.murphy@bakermckenzie.com, 1-202-452-7069.
 
The U.S. Government Accountability Office (GAO) recently released a report on the U.S. Customs and Border Protection (CBP) Customs-Trade Partnership Against Terrorism (C-TPAT) program that we thought you might find to be of interest.  In conducting this review, the GAO sought to assess the extent to which (1) CBP is meeting its security validation responsibilities, and (2) C-TPAT members are receiving the benefits promised by CBP for participation.
 
While the full report is worth a quick read (available at
here), the GAO concluded that problems with the data management system (i.e., the Portal) have led to problems with C-TPAT validations (e.g., incorrect tier levels being reflected in the system, incorrect dates for profile updates/reviews, lack of standardized guidance from CBP HQ, etc.) and that CBP cannot determine the extent to which C-TPAT members are actually receiving benefits because of these data problems.  On this latter point, GAO stated:
 
Since 2012, CBP has compiled data on certain events or actions it has taken regarding arriving shipments-such as examinations, holds, and processing times-for both C-TPAT and non-C-TPAT members through its C-TPAT Dashboard.20 However, based on GAO’s preliminary analyses of data contained in the Dashboard, and data accuracy and reliability concerns cited by C-TPAT program officials, we concluded that CBP staff are not able to determine the extent to which C-TPAT members are receiving benefits, such as reduced likelihood of examinations of their shipments and expedited shipment processing, compared to non-members.  . . . We conducted preliminary analyses of C-TPAT program data from the Dashboard to understand, for example, how the examination rates of C-TPAT members’ shipments compared with those of non-C-TPAT members across different modes of transportation (air, truck, vessel, and rail) for each year from fiscal year 2011 through fiscal year 2015. The results of our analyses showed that C-TPAT members’ shipments did not consistently experience lower examination and hold rates and processing times compared to non-members’ shipments across the different modes of transportation. [FN/1]
 
While the findings of this report many not come as much of a surprise to the companies that participate in the program, it is good to see the government auditing the program and trying to make it better.
 
——-
  [FN/1]:
Report at p. 18.

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COMM_a4
13R.C. Burns: “Sometimes Mistaken Identity is Not a Laughing Matter”

(Source:
Export Law Blog. Reprinted by permission.)
 
* Author: R. Clifton Burns, Esq., Bryan Cave LLP, Wash DC,
Clif.Burns@bryancave.com, 202-508-6067)
 
Last week, on the heels of Iran’s ballistic missile test, the Office of Foreign Assets Control (“OFAC”)
announced new sanctions on Iran. These sanctions appear to have been in the works for some time judging by wealth of detail in the
explanatory press release.
 
The sanctions target, among other individuals, Abdollah Asgharzadeh and a network of people and companies that have assisted him in procuring items for Iran’s ballistic missile program. One person alleged to be in the network is Carol Zhou, who is described as one of “three China-based brokers” who assisted in these procurement activities. No  information is provided with respect to Carol Zhou other than her date of birth. And because she is being sanctioned under the
Weapons of Mass Destruction Proliferators Sanctions, this means that secondary sanctions can be imposed under the
Iran Financial Sanctions Regulations against foreign financial institutions that deal with Ms. Zhou.
 
It should come as no surprise to anyone, including the staff at OFAC, that Carol Zhou is an extremely common name and a name that no one would want to have right now. Not only will any transaction with the name of Carol Zhou on it, whether or not it involves the designated Carol Zhou, risk being blocked by U.S. financial institutions and entities but also that transaction will risk being rejected by every other financial institution in the world. Of course, for blocked transactions, the other Carol Zhous can just hire lawyers and march into OFAC with their passports (which hopefully will show a different birthdate) to get the blocked funds back. But there is nothing an innocent Carol Zhou can do about a rejection by a non-U.S. bank, which likely will not want to be bothered inspecting passports and will simply automatically reject the transaction.
 
So, while the Daniel Garcias of the world
get a reprieve, the Carol Zhous of the world get a raw deal. If OFAC is going to continue to designate people with common names, it has an obligation to craft a process to minimize the collateral damage of the designation.

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

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:

* Feb 13-15: Las Vegas NV; “
Basics of Government Contracting
;” Federal Publications Seminars
*
Feb 15: Webinar; “
EAR Hardware License Exceptions Explained
;”
ECTI;
danielle@learnexportcompliance.com
; 540-433-3977

* 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 21: Webinar; “GTM Webinar Series Part One: Restricted Party Screening;” Amber Road

* 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 22: Webinar; “
Harmonized Tariff Schedule – Classifications
;”
Sandler, Travis & Rosenberg, P.A.;
webinarorganizers@strtrade.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 8: Webinar; “
GTM Webinar Series Part Two: Product Classification;” Amber Road

* 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 16: Webinar; “
Faculty or Consultant? Implications for University Export Compliance
;”
ECTI; danielle@learnexportcompliance.com; 540-433-3977

* 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 20: Webinar; “
GTM Webinar Series Part Three: License Determination;” Amber Road

* Mar 21: London UK; “
Export Control Symposium 2017
;” Department for International Trade;
denise.carter@trade.gsi.gov.uk 
* Mar 21: Wash DC; “
Hiccup or Hardball: China’s Role in America’s Future
;” American Bar Association

* 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 28-29: San Francisco CA; “7th Advanced Industry Forum on Global Encryption, Cloud & Cyber Export Controls;” American Conference Institute
* Mar 28-29: Scottsdale AZ; “ITAR/EAR Critical Compliance;” Export Compliance Solutions; spalmer@exportcompliancesolutions.com

* Mar 28: Webinar; “
In Uncertain Times, the Only Certainty is Enforcement
;” ECTI;
danielle@learnexportcompliance.com
; 540-433-3977

* 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 4: Webinar; “
GTM Webinar Series Part Four: Supply Chain Collaboration;” Amber Road
* Apr 11: Webinar; “
GTM Webinar Series Part Five: Free Trade Agreements;” Amber Road

* 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 

* May 24-25: Annapolis MD; “
Advanced ITAR/EAR Compliance: Using Export Controls to Your Advantage
;” 
spalmer@exportcompliancesolutions.com
; 866-238-4018 / 410-757-1919

* 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) 

*
William Allen White (10 Feb 1868 – 29 Jan 1944, was a renowned American newspaper editor, politician, author, and leader of the Progressive movement.)
  – “I have never been bored an hour in my life. I get up every morning wondering what new strange glamorous thing is going to happen and it happens at fairly regular intervals.”
 
*
Boris Pasternak (Boris Leonidovich Pasternak, 10 Feb 1890 – 30 May 1960, was a Soviet Russian poet, novelist, and literary translator, best known for his novel
Doctor Zhivago.)
  – “Surprise is the greatest gift which life can grant us.”
 
*
Jimmy Durante (James Francis “Jimmy” Durante, 10 Feb 1893 – 29 Jan 1980, was an American singer, pianist, comedian, and actor. His distinctive clipped gravelly speech, New York accent, comic language butchery, jazz-influenced songs, and prominent nose helped make him one of America’s most familiar and popular personalities of the 1920s through the 1970s.)
  – “If I’d known how old I was going to be I’d have taken better care of myself.”
 
Friday Funnies:

A funeral was in progress and a country preacher gave a eulogy praising the good qualities of the deceased – what an honest, hard-working man he was, and what a loving husband and kind father he was. After a few minutes, the man’s widow leaned over and whispered to one of her children, “Go up there and take a look in the coffin and see if that’s your Pa.”
  — John Mitchell, Southampton, NY

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

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: 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: 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: 10 Feb 2017: 
82 FR 10434-10440: Inflation Adjustment of Civil Monetary Penalties 
 
*
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.

* SUBSCRIPTIONS: Subscriptions are free.  Subscribe by completing the request form on the Full Circle Compliance website.

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