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17-0407 Friday “The Daily Bugle”

17-0407 Friday “Daily Bugle”

Friday, 7 April 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. President Continues National Emergency with Respect to Somalia 
  2. DHS/CBP Announces 2017 West Coast Trade Symposium
  1. Ex/Im Items Scheduled for Publication in Future Federal Register Editions 
  2. Commerce/BIS: (No new postings.) 
  3. DHS/CBP Announces ACE Production Outage, 8-9 Apr
  4. DHS/CBP Sends Out Weekly Trade FAQs
  5. GAO Posts Report “Conflict Minerals: Insights from Company Disclosures and Agency Actions”
  6. State/DDTC Posts Name Change for Beechcraft Defense Company, LLC
  7. Australia DFAT Announces Agreement on Australia-EU FTA Scoping Exercise
  8. EU Amends Restrictive Measures Against North Korea
  1. Defense News: “Swedish Defense Industry Uneasy Over Proposed Export Controls”
  2. Global Trade News: “Finding and Managing Hidden Compliance Issues”
  3. ST&R Trade Report: “Dates and Deadlines — Trade Laws and Agencies, Customs Forms, Cargo Vessels, Labeling”
  1. A. Roy: “International Trade Frequently Asked Questions” (Part I of III)
  2. R.C. Burns: “Wilkommen im Hotel Norkschwein”
  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 (6 Apr 2017), FACR/OFAC (10 Feb 2017), FTR (15 May 2015), HTSUS (7 Mar 2017), ITAR (11 Jan 2017)

EXIMEX/IM ITEMS FROM TODAY’S FEDERAL REGISTER

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1. President Continues National Emergency with Respect to Somalia

(Source: Federal Register)
 
82 FR 17095-17096: Continuation of the National Emergency with Respect to Somalia
 
On April 12, 2010, by Executive Order 13536, the President declared a national emergency to deal with the unusual and extraordinary threat to the national security and foreign policy of the United States constituted by the deterioration of the security situation and the persistence of violence in Somalia, acts of piracy and armed robbery at sea off the coast of Somalia, which have repeatedly been the subject of United Nations Security Council resolutions, and violations of the arms embargo imposed by the United Nations Security Council.
 
On July 20, 2012, the President issued Executive Order 13620 to take additional steps to deal with the national emergency declared in Executive Order 13536 in view of United Nations Security Council Resolution 2036 of February 22, 2012, and Resolution 2002 of July 29, 2011, and to address: exports of charcoal from Somalia, which generate significant revenue for al-Shabaab; the misappropriation of Somali public assets; and certain acts of violence committed against civilians in Somalia–all of which contribute to the deterioration of the security situation and the persistence of violence in Somalia.
 
The situation with respect to Somalia continues to pose an unusual and extraordinary threat to the national security and foreign policy of the United States. For this reason, the national emergency declared on April 12, 2010, and the measures adopted on that date and on July 20, 2012, to deal with that emergency, must continue in effect beyond April 12, 2017. Therefore, in accordance with section 202(d) of the National Emergencies Act (50 U.S.C. 1622(d)), I am continuing for 1 year the national emergency declared in Executive Order 13536.
 
  (Presidential Sig.)
  THE WHITE HOUSE,
  April 6, 2017.

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2. DHS/CBP Announces 2017 West Coast Trade Symposium

(Source: Federal Register) [Excerpts.]
 
82 FR 17016-17017: U.S. Customs and Border Protection 2017 West Coast Trade Symposium: “Looking Ahead Together: What’s Next for Trade?”
* AGENCY: U.S. Customs and Border Protection (CBP), Department of Homeland Security (DHS).
* ACTION: Notice of trade symposium.
* SUMMARY: This document announces that U.S. Customs and Border Protection (CBP) will convene the 2017 West Coast Trade Symposium in Scottsdale, Arizona, on Wednesday, May 24, 2017, and Thursday, May 25, 2017. The 2017 West Coast Trade Symposium will feature panel discussions involving agency personnel, members of the trade community, and other government agencies, on the agency’s role in international trade initiatives and programs. Members of the international trade and transportation communities and other interested parties are encouraged to attend.
* DATES: Wednesday, May 24, 2017 (opening remarks and general sessions, 8:00 a.m.-4:45 p.m. MST), and Thursday, May 25, 2017 (break-out sessions, 8:00 a.m.-1:00 p.m. MST).
* ADDRESSES: The CBP 2017 West Coast Trade Symposium will be held at the Double Tree Resort at 5401 North Scottsdale Road, Scottsdale, AZ 85250.
* FOR FURTHER INFORMATION CONTACT: The Office of Trade Relations at (202) 344-1440, or at tradeevents@dhs.gov. To obtain the latest information on the Trade Symposium and to register online, visit the CBP Web site. Requests for special needs should be sent to the Office of Trade Relations at tradeevents@dhs.gov.
* SUPPLEMENTARY INFORMATION: …
   The agenda for the 2017 West Coast Trade Symposium can be found on the CBP Web site. Registration will be open from March 22 to May 11, 2017. The registration fee is $161.00 per person. Interested parties are requested to register immediately, as space is limited. All registrations must be made online at the CBP Web site and will be confirmed with payment by credit card only.
   Hotel accommodations have been made at the Double Tree Resort at 5401 North Scottsdale Road, Scottsdale, AZ 85250. Hotel room block reservation information can be found on the CBP Web site.
 
  Dated: April 4, 2017.
Valarie M. Neuhart, Acting Director, Office of Trade Relations, Office of the Commissioner, U.S. Customs and Border Protection.

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OGSOTHER GOVERNMENT SOURCES

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

(Source:
Federal Register)
* Commerce; Industry and Security Bureau; NOTICES; Denials of Export Privileges [Publication Date: 10 April 2017.]
  – Sam Rafic Ghanem

* Foreign Assets Control Office; NOTICES; Blocking or Unblocking of Persons and Properties [Publication Date: 10 April 2017.]

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5.

DHS/CBP Announces ACE Production Outage, 8-9 Apr

(Source:
CSMS# 17-000202, 7 April 2017.)
 
Export — T
here will be an ACE PRODUCTION Outage Saturday evening, April 8, 2017 from 2200 ET to 0400 ET Sunday, April 9, 2017 for routine ACE maintenance activities.

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OGS_a36.

DHS/CBP Sends Out Weekly Trade FAQs

(Source:
CSMS# 17-000201, 7 April 2017.)
 
New ACE Programming
 
(1) Question: When a TIB export exam designation is communicated in ACE via Automated Broker Interface (ABI) in the SO20 status notification record, what Reference Identifier Qualifier will be used?
 
  Answer: The TIB export exam determination will be communicated via the “CMT” Reference Identifier Qualifier, also known as “Public Notes/Comments.” For more information, please see Page 16 of the ACE Cargo Release – SO Status Notification CATAIR found
here.
 
(2) Question: If a Disclaimer is filed via PGA Message Set and PGA data is provided to CBP via the Document Image System (DIS), can a filer still receive a “May Proceed” response message?
 
  Answer: No, “May Proceed” messages are not sent in response to a PGA data Disclaimer.
 
(3) Question: Are there still some EPA HTS flags that need to be updated?
 
  Answer: Yes, EPA continues to update their HTS flagging. However, all importers are responsible for knowing what EPA data should be filed whether or not an HTS code is flagged. This information may be confirmed with the appropriate EPA hotlines/contacts. For more information, please see CSMS #17-000160.
 
(4) Question: What are the updated hours for FDA’s ACE Support Desk?
 
  Answer: FDA’s ACE Support Desk will be staffed from 6:00 AM to 10:00 PM, 7 days a week. They can be contacted at
ACE_Support@fda.hhs.gov or 877-345-1101.
 
(5) Question: What is the effective date for the Drug Enforcement Administration’s (DEA) Final Rule implementing the International Trade Data System, as applicable to tableting and encapsulating machines, controlled substances, and listed chemicals, permitting importers and exporters to file required DEA information electronically with CBP?
 
  Answer: The DEA “Final Rule; Delay of Effective Date” published on January 30, 2017 (82 FR 8688) states that “compliance with the revisions to DEA regulations made by this rule is not required until July 31, 2017.” For more information, please see the applicable FRN
here.
 
(6) Question: Where can I find information about the transition of ACS queries to ACE?
 
  Answer: Current information about the transition of ACS queries to ACE can be found in the ACS to ACE Application Transition Plan found
here. Please note that this document is periodically updated and should be checked regularly for updates.
 

For additional information regarding ACE, please dial in to the weekly ACE Status Update Call on Thursdays at 2pm. Phone Number: (877) 336-1828 Pass Code: 6124214.

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7.

GAO Posts Report “Conflict Minerals: Insights from Company Disclosures and Agency Actions”

 
WHAT GAO FOUND
 
Our analysis of a generalizable sample of conflict minerals disclosures filed with SEC in 2015 found that an estimated 49 percent of companies in 2015 reported having determined whether the conflict minerals in their products came from covered countries, compared with 30 percent in 2014-an increase of 19 percentage points. As a result of due diligence, a majority of companies reported in 2015 that they were unable to determine the country of origin of the conflict minerals in their products and whether such minerals benefited or financed armed groups in the covered countries. However, companies reported a range of actions they had taken, or planned to take, to build on or improve their due diligence efforts, such as shifting operations or encouraging those in their supply chain to shift from current suppliers to suppliers who are certified as conflict free.
 
As of July 2016, the Department of Commerce (Commerce) had not submitted to Congress a report that includes an assessment of the accuracy of Independent Private Sector Audits (IPSA) and other due diligence efforts as well as recommendations for IPSA processes, as the Dodd-Frank Act requires, and had not developed a plan for doing so. Commerce officials told us in July 2016 that they had not yet assessed the accuracy of the four IPSAs filed in 2014 or the six IPSAs filed in 2015. Commerce officials said they established a team to manage Commerce’s responsibilities related to IPSAs in March 2016, but the officials noted that they did not have the internal knowledge or skills to review IPSAs or establish best practices.
 
WHY GAO DID THIS STUDY
 
Armed groups in eastern DRC continue to profit from the exploitation of minerals, according to the United Nations. Provisions in the 2010 Dodd-Frank Wall Street Reform and Consumer Protection Act require that U.S. agencies take certain actions. For example, the act requires, among other things, SEC to promulgate regulations regarding the use of conflict minerals from the DRC and adjoining countries. The act also requires Commerce to submit a report that includes an assessment of IPSAs filed in conjunction with SEC disclosures. As we reported in 2015, U.S. agencies have supported a range of initiatives; for example, strengthening traceability mechanisms that minimize the risk that minerals that have been exploited by illegal armed groups will enter the supply chain.
 
Based on an August 2016 report (
GAO-16-805), this statement examines (1) company disclosures filed in 2015 in response to the SEC conflict minerals regulations and (2) Commerce’s actions regarding its conflict minerals-related requirements under the Dodd-Frank Act. GAO analyzed a generalizable random sample of Specialized Disclosures (Form SDs) filed with SEC and interviewed relevant officials for that report.
 
WHAT GAO RECOMMENDS
 
In its August 2016 report, GAO recommended that Commerce establish a plan outlining steps and time frames for assessing the accuracy of due diligence processes such as IPSAs, and developing the necessary expertise to fulfill these requirements. Commerce concurred with GAO’s recommendation.
 
For more information, contact Kimberly Gianopoulos at (202) 512-8612 or
gianopoulosk@gao.gov.
 
[Editor’s Note: The full report can be found
here
.]

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8.

State/DDTC Posts Name Change for Beechcraft Defense Company, LLC

(Source:
State/DDTC) [Excerpts.]
 
Effective immediately, Beechcraft Defense Company, LLC will change as follows: Textron Aviation Defense LLC. 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 not apply to approved or pending agreements. … 

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9.

Australia DFAT Announces Agreement on Australia-EU FTA Scoping Exercise

 
Australia and the European Union (EU) have successfully concluded a joint scoping exercise on a future free trade agreement (FTA) between the two economies.
 
This is a key step toward the launch of negotiations.  Both sides will now work through their domestic processes to secure approval of a negotiating mandate.

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OGS_aa810.

EU Amends Restrictive Measures Against North Korea

 
Regulations:
  –
Council Regulation (EU) 2017/658 of 6 April 2017 amending Regulation (EC) No 329/2007 concerning restrictive measures against the Democratic People’s Republic of Korea
  –
Commission Implementing Regulation (EU) 2017/661 of 6 April 2017 amending Council Regulation (EC) No 329/2007 concerning restrictive measures against the Democratic People’s Republic of Korea
 
Decisions:
  –
Council Decision (CFSP) 2017/666 of 6 April 2017 amending Decision (CFSP) 2016/849 concerning restrictive measures against the Democratic People’s Republic of Korea
  –
Council Decision (CFSP) 2017/667 of 6 April 2017 amending Decision (CFSP) 2016/849 concerning restrictive measures against the Democratic People’s Republic of Korea

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NWSNEWS

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Defense News: “Swedish Defense Industry Uneasy Over Proposed Export Controls”

 
A Swedish government plan to introduce a new legislative bill that would restrict arms exports to so-called non-democracies is causing disquiet within Sweden’s international sales-dependent defense sector.
 
The country’s leading defense group, Saab, has warned that proposed export-tightening legislation could “force” the company to move some or all of its research and development out of Sweden.
 
The minority coalition government – which is supported by the Green Party – of Swedish Prime Minister Kjell Löfven, a Social Democrat, has been working on the arms export controls bill since the administration took office after general elections in 2014. 
 
  “Sweden will maintain strict and effective export controls of military equipment. The government will present a bill on this in the first half of 2017 to tighten the export regulations to non-democracies,” said Margot Wallström, Sweden’s foreign affairs minister.
 
Sweden’s arms exports rose in value by 45 percent to $1.21 billion in 2016. About 88 percent of total exports were sold to European Union and Western “partner” countries, according to data from the Inspectorate of Strategic Products, the state-run agency responsible for export-related control and compliance of defense material and dual-use products. 
 
Defense sector unease over the planned tightening of arms export legislation is reinforced by the expanding market for Swedish weapons systems from outside the EU and Western customer loop. 
 
In this regard, Sweden’s military exports to Thailand, Qatar, Pakistan, Saudi Arabia, Oman, Brunei, Indonesia and the United Arab Emirates have been growing steadily since 2012. Sweden’s defense industry chiefs believe that Swedish arms exports to these countries could be negatively impacted by stricter export controls.
 
As the Swedish defense industry’s leading player, the planned legislation threatens to curb Saab’s overall growth and sales globally, particularly for the company’s flagship Gripen fighter aircraft and its air defense and underwater systems product offerings.
 
  “If politicians reduce export opportunities for Swedish defense, we will not be able to develop some products. The Swedish Armed Forces will need to purchase them from other countries. This will then be more expensive for our defense, but Saab’s competitors will naturally be happy,” said Håkan Buskhe, Saab’s president and CEO.
 
New curbs in the arms export controls bill could also make Swedish defense companies less attractive as international partners, said Eric Walum, a Brussels-based industry analyst.  
 
  “Everything depends on the detail in the new bill and how this translates as stricter rules on the export side. Joining international partnerships might become difficult for companies like Saab if they are unable to export freely and globally,” Walum said.
 
Saab’s CEO would be “most reluctant” to relocate its R&D outside Sweden. The Saab CEO wants harmonized arms export rules across the EU that would deliver a level playing field for all defense equipment producers and exporters operating from within the economic union.
 
Saab has 5,000 staff engaged in R&D activities. About 4,500 of these are based in Sweden.
 
New export controls should be flexible enough to allow for the sale of offensive weapons to support groups fighting the Islamic State group, said Allan Widman, chairman of the Swedish parliament’s Committee on Defence.
 
  “I would support efforts by Sweden to supply weapons to the Kurdish peshmerga who are fighting ISIS to liberate Mosul. This group’s need, for rocket-propelled grenades and machine guns in particular, is great,” Widman said.
 
The Swedish government’s desire to support export growth by defense industry companies is likely to produce a new arms export control law that carries a narrow definition of what military equipment may not be sold to “non-democracies,” Walum said. “It is probable that stricter export controls will be placed on battlefield and offensive weapons systems while a more relaxed attitude will be taken, on the rules side, to products such as battle-management systems, radar systems, military communications and systems training.”
 
In the event that the new arms export control law adheres to this narrow definition of equipment that can be exported to “non-democracies,” it is likely that export licenses, such as that given to Saab in the sale of the GlobalEye early warning and control radar system to the United Arab Emirates, would also be granted under future rules.
 
The importance with which the Swedish government still views long-term arms trade development with nations, such as those in the Middle East, was highlighted during a high-level trade delegation led by Sweden’s prime minister in Saudi Arabia last October.
 

Significantly, the trade delegation included several high-power defense industry leaders. These included Marcus Wallenberg, chairman of the board at Saab.

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NWS_a212.

Global Trade News: “Finding and Managing Hidden Compliance Issues”

 
Risk management. 
The U.S. Customs and Border Protection describe two words that identify imports representing the greatest risk of noncompliance so that manufacturers can focus resources in those areas.
 
To those in global trade, risk management can be two words that spell trouble. 
If unharnessed, risk can become pervasive when data is not retained, analyzed or tracked correctly. Failure to retain documents, using the incorrect Country of Origin or HS Classification can be a red flag for a Focused Assessment.
 
To be clear, U.S. CBP has a four-step approach to risk management:
 
  – Collect Data and Information: Regular, consistent and validated approach to collecting data.
  – Analyze and Assess Risk: Analyze the data and identify likely areas of noncompliance.
  – Prescribe Action Design: determine the appropriate action and dedicate the necessary resources.
  – Track and Report Ownership for the action must be assigned and its results tracked to develop a consistent risk management process.
 
Some issues to consider: 
 
  (1) Documentation
 
Electronic document retention should follow the prescribed regulatory guidelines (retaining documentation of all transactions within the past 5 years) of or corporate guidelines of an importer. Keeping documentation beyond these guidelines expands the base of liability for an organization and could be considered within the scope of any Focused Assessment.  Integration Point keeps electronic documentation, preferred by customs, to meet federal requirements or additional requirements defined and agreed by our clients to meet their internal requirements. 
 
  (2) Correct Country of Origin
 
Most companies spend considerable time linking a classification to all products within their catalog. By insuring the correct classification is used for a product, duty is accurately considered and declarations accurately describe their contents. However, small numbers of items routinely arrive with smaller values (R&D) or as part of a return materials authorization. In many cases, these are not returned goods of U.S origin, but simply parts returned after export or from a dealer/client. Since U.S. CBP rigorously confirms claims of U.S. goods returned, some entry operating procedures may require country of export to be claimed if a country of export cannot be determined.
 
Country of Origin is a critical audit component. When the commodity or classification under review includes items subject to anti-dumping /countervailing duties or other special duty provisions or requirements, the impact is substantial.
 
  (3) Entry Error
 
If your broker is still using manual data entry, those elements within a declaration may not produce accurate client data.
 
It is key to specific routines for manually verifying data elements that often result in errors as an increased risk. To avoid a declaration of errors and send a red flag to customs, Integration Point offers a post-entry auditing tool that allows you to electronically validate all entries.
 
  (4) A Scenario on Documentation
 
Imagine that an importer has solicited their supplier base in the past for the parts and Country of Origin in question. Qualification had been completed on the finished good, but the certificate was not obtained. Entries were then completed for preferential duty for multiple free trade agreements.
 
Claiming preferential duty treatment may bring on a focus of U.S CBP and a Focused Assessment. In addition, preferential duty treatment may provoke interest from other participating governments (such as South Korea).
 
Avoid this scenario completely. U.S- based free trade agreements confirm documentary requirements and retention requirements for specific free trade agreements. Ensure suppliers complete a signed certificate and that all certificates are in a central repository, ready for any regulatory reviews.
 
  (5) Due Diligence
 
Exporters are required to practice responsible due diligence in ensuring any “company, entity, or person on the list (i.e. BIS Denied Parties List)” matches a party potentially involved in any part of your export transaction.
 
Risk begins with orders for a transaction and continues through client delivery. Screening done at the transaction level is a limited approach to managing your risk with the U.S. Department of Commerce and may not prevent your organization from doing business with denied parties.
 
Other single-cloud platform solutions from Integration Point to manage risk include Global Trade Content, Global Classification, Entry Verification and Global Trade Visibility, especially, to analyze data, areas of non-compliance and preferential opportunities.
 
Manage risk and at the same time analyze data collection to help identify areas of non-compliance. The smart solution? Integrating a screening process from Integration Point using an automated system at the time of the sale-and beyond- aids in reducing risk.   

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13.

ST&R Trade Report: “Dates and Deadlines: Trade Laws and Agencies, Customs Forms, Cargo Vessels, Labeling”

 
Following are highlights of regulatory effective dates and deadlines and federal agency meetings coming up in the next week.
 
  – 10 Apr: deadline for comments on CBP information collections on
import bonds, temporary exports
  – 10 Apr: deadline for comments to FTZ Board on requests for
production authority, new subzone
  – 11 Apr: deadline for comments to ITC on potential
IPR import restrictions on two-way radios
  – 13 Apr: deadline for comments to USDA on proposed
mandatory country of origin labeling for venison
  – 13 Apr: deadline for comments to ITC on potential
IPR import restrictions on adjustable desks
  – 14 Apr: deadline for comments to CBP on
commercial invoice, HOPE Act, in-bond cargo information collections
  – 14 Apr: deadline for comments to FDA on information collection on
HACCP procedures for imported juice
  – 14 Apr: effective date of
conditions of entry for cargo vessels visiting Nauru

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COMMCOMMENTARY

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A. Roy: “International Trade Frequently Asked Questions” (Part I of III)

 
* Author: Arnesh Roy, Customer Satisfaction Specialist, Shipping Solutions.  Contact details Shipping Solutions are available
here.
 
[
Editor’s note: due to space limitations, this article has been divided into three parts.  Parts II and III will be published in the Daily Bugle of Monday, 10 April, and Tuesday, 11 April 2017.]
 
In my role at Shipping Solutions, I am privileged to talk to people from all kinds of companies involved in international trade. As you might expect, I receive a lot of questions!
 
Today’s blog post compiles some of the most frequently asked questions that I hear. I hope that by the time you reach the end of this article, you will have a better understanding of some of the most common issues relevant to international trade.
 
To make it easier to navigate, I have divided the article into five sections:
 
  (1) Export Definitions [Part I]
  (2) General Export Questions [Part I]
  (3) Export Regulations and Compliance [Part II]
  (4) Automated Export System [Part II]
  (5) Export Documents [Part III]
 
(1) EXPORT DEFINITIONS
 
What is an export?
 
Regardless of how it is transported out of the United States, any movement of goods outside of the country is considered an export. This also applies to technology, schematics or source code transmitted orally or in written form to a foreign national; these are called deemed exports, and it important to keep in mind that export regulations apply to these as well. An item is also considered an export even if it is leaving the U.S. temporarily, or if it is the return of an item to a foreign country.
 
 
What is the difference between the different product classifications: HS, HTS, Schedule B, ECCN, USML and ECN?
 
Harmonized System (HS) codes: HS codes are six-digit codes (e.g. 0701.90) used to identify products. HS codes are universal, and are used for most international export documentation and commercial invoices. They are administered by the World Customs Organization. You’ll use an HS number when you are referencing the classification with your customers, vendors and anyone outside of the U.S.
 
Many governments add additional digits to the HS number to further distinguish products in certain categories. These additional digits are typically different in every country.
 
Harmonized Tariff Schedule of the United States (HTSUS) codes: HTSUS codes are 10-digit codes (e.g. 0901.21.0045) used to identify products. They may be called HTS codes for short. HTS codes are U.S.-specific and are used for import into the U.S. They are administered by the U.S. International Trade Commission (ITC).
 
An HTS code takes the same form as an HS code for the first six digits and then has four differing last digits. It’s very important that all U.S. importers know and use the correct HTS codes, because commodity duties are assessed based on this classification. With some limited exception, HTSUS codes can also be used by U.S. exporters on their export paperwork. The full HTSUS list is available for free on the
ITC website.
 
Schedule B: Schedule B codes are 10-digit codes (e.g. 0101.21.0000) used to identify products. They are U.S.-specific and are used specifically for exports out of the U.S. Schedule B codes are administered by the Census Bureau’s Foreign Trade Division and are used to compile export statistics.
 
Schedule B numbers are required to be reported to the Automated Export System (AES) for shipments valued at more than $2,500 or when your shipment requires an export license. As with HTS codes, the first six digits of a Schedule B code should be the same as an HS number; however, the last four digits may be different than the HTS code. A full list of Schedule B codes is available for free on the
U.S. Census Bureau’s website.
 
Export Control Classification Number (ECCN): ECCNs are five-character alpha-numeric designations (e.g. 1A001) published on the Commerce Control List (CCL) to identify dual-use items for export control purposes. Dual-use items are products that have a commercial use, but also have the potential to be used in military applications as well.
 
An ECCN categorizes items based on the nature of the product, i.e. type of commodity, software or technology and its respective technical parameters. ECCNs are administered by the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) under the
Export Administration Regulations (EAR).
 
United States Munitions List (USML): Under the International Traffic in Arms Regulations (ITAR), the USML is a list of products, technologies, and services deemed as space- or defense-related. The Directorate of Defense Trade Controls (DDTC) is the organization within the U.S. Department of State that is tasked with enforcing the ITAR. Any product, technology, or service listed in the USML requires an export license to export, though license exceptions may be available in certain circumstances.
 
Export Control Number (ECN): A broad term meant to include all export control numbers including ECCN and USML listings.
 
 
What are Incoterms?
 
Incoterms are universal trade terms published by the International Chamber of Commerce (ICC.) They consist of three-letter codes that are intended to clearly communicate the tasks, costs and risks associated with the transportation and delivery of goods in an international transaction. They describe how responsibility is allocated between the seller and the buyer for different parts of the transaction.
 
 
What is a USPPI?
 
USPPI stands for United States Principal Party in Interest. In an international transaction, this is typically the exporter.
 
 
What is an FPPI?
 
FPPI stands for Foreign Principal Party in Interest. In an international transaction, this is typically the foreign buyer.
 

What is a routed export transaction?
 
A routed export transaction occurs when a foreign purchaser, or foreign principal party in interest (FPPI), requests to have their merchandise delivered to another location within the United States.
 
 
What is a freight forwarder?
 
A freight forwarder is a type of company that specializes in arranging the transportation of goods. A freight forwarder can be hired by either the buyer or the seller in an international transaction, and they may provide additional services such as packaging, document preparation, and customs clearance.
 
What is a carrier?
 
A carrier is a company or party that moves the goods in an international transaction. An inland carrier will move the goods from your warehouse to the port of export. From there, an air carrier would transport goods on an airplane, an ocean carrier would transport goods on a ship, a rail carrier would transport goods on a railroad, or a truck carrier would transport goods on a truck.
 
What is a customs broker?
 
Customs brokers are private individuals, partnerships, associations or corporations licensed, regulated and empowered by U.S. Customs and Border Protection (CBP) to assist importers and exporters in meeting federal requirements governing imports and exports.
 
 
What is customs, and what is its role in international trade?
 
Customs refers to the official department that administers and collects duties levied by a government on imported goods. Exports from the U.S. are monitored by U.S. Customs and Border Protection (CBP). The customs agency of the country of import is responsible for enforcement of import laws and the collection of duties and taxes.
 
What is a reexport?
 
According to the U.S. Bureau of Industry and Security (BIS), a reexport is “the shipment or transmission of an item subject to the Export Administration Regulations (EAR) from one foreign country (i.e., a country other than the United States) to another foreign country. A reexport also occurs when there is ‘release’ of technology or software (source code) subject to the EAR in one foreign country to a national of another foreign country.”
 
 
What is a power of attorney?
 
A power of attorney (POA), also called a letter of attorney, is a written authorization to represent or act on another’s behalf. The person authorizing the other to act is called the principal, grantor or donor (of power). The one authorized to act is called the agent.
 
What is IATA?
 
IATA stands for International Air Transport Association. This is a trade association of the world’s airlines. IATA publishes a list of codes that correspond to different air carriers, and these codes may be used on export paperwork.
 
What is SCAC?
 
SCAC stands for Standard Carrier Alpha Code. The National Motor Freight Traffic Association publishes a list of codes that correspond to different inland carriers, and these codes may be used on export paperwork.
 
What are the Foreign Trade Regulations?
 
The Foreign Trade Regulations (FTR) are published by the U.S. Census Bureau in
15 CFR Part 30 and are available for free on the U.S. Census Bureau website. The FTR includes provisions requiring exporters to file their
electronic export information (EEI) through the
Automated Export System (AES), export licensing requirements, as well as other regulations placed on international trade.
 
What are the Export Administration Regulations?
 
The Export Administration Regulations (EAR) are enforced by the U.S. Department of Commerce’s Bureau of Industry and Security (BIS). Among the content found in the EAR is the Commerce Control List (CCL), a list of dual-use items; that is, items that have both a commercial use as well as a potential military application. Each dual-use item has a corresponding Export Control Classification Number (ECCN), which is used to determine if an export license is required. The EAR are available for free on the
BIS website.
 
What are the International Traffic in Arms Regulations?
 
The International Traffic in Arms Regulations (ITAR) are administered by the U.S. Department of State under the Directorate of Defense Trade Controls (DDTC) and include controls placed on the import and export of space- and defense-related products listed on the United States Munitions List (USML.) The ITAR are available for free on the
U.S. Department of State website.
 
 
(2) GENERAL EXPORT QUESTIONS
 
What is the role of banks in an international transaction?
 
Both the buyer and seller will work with their own banks to transfer funds. The seller’s bank in the U.S. can help determine the best payment terms for a sale, such as a letter of credit, and will work with the buyer’s bank to facilitate payment based on their banking instructions.
 
What resources are available to help with international trade?
 
At the state level, state Trade Offices and District Export Councils can help companies engaged in international trade. At the federal level, there are U.S. Export Assistance Centers (USEACs) as well as Small Business Development Centers (SBDCs). At the international level, World Trade Centers and the U.S. Commercial Service’s international locations may be of assistance as well.
 

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

COMM_a215.

R.C. Burns: “Wilkommen im Hotel Norkschwein”

(Source:
Export Law Blog. Reprinted by permission.)
 
* Author: R. Clifton Burns, Esq., Bryan Cave LLP, Wash DC,
Clif.Burns@bryancave.com, 202-508-6067)
 
One of the problem with the Nork sanctions passed by the U.N. is that they rely on member states for their enforcement and not all member states are, well, super excited about sanctioning the Norks. We’re looking at you, China.
 
But it seems the Germans may also be looking the other way.  Consider the Cityhostel Berlin tucked away on the Glinkastraße, barely spitting distance from the Brandenburg Gate and, more importantly, the North Korean Embassy.  According to
this article in
Deutsche Welle, the Cityhostel is actually part of a large complex of buildings ceded to North Korea by the East Germans (bless their hearts) before the Berlin Wall was torn down.   They use it for their Embassy, and they rent space to the Berlin Cityhostel, which thereby provides extra income to Kim Jong Un and his nuclear program.
 
The problem is
UN Resolution 2321 prohibits member states from allowing the Norks to use real property that they own for anything other than diplomatic or consular activities.  The German foreign ministry, when asked about this, did a creditable imitation of
Baron Munchausen, with this obvious exaggeration:
 
We are closely monitoring potential violations of the sanctions regime imposed by the UN Security Council and, together with our partners, strictly observing the sanctions against North Korea.
 
Right. And I bet that the ministry also just saved itself from drowning by pulling on its hair and then, just for fun, took a ride on a cannonball.
 
Some of my U.S. readers are now probably wondering, besides how you can ride on a cannonball, whether they can stay at Hotel Norkschwein, I mean the Cityhostel, on their next trip to Berlin.
Executive Order 13722 blocks all property of the North Korean government and, more importantly, prohibits any U.S. person from “making of any contribution or provision of funds, goods, or services by, to, or for the benefit of” the North Korean government. Certainly there is an argument that paying a hotel bill in a hotel leased from the Norks might be considered to fall within this prohibition.
 
The question, then, is whether the travel exemption would permit U.S. citizens to spend the night in Kim Jong Un’s little Berlin hideaway. That exemption prohibits regulation under the International Emergency Economic Powers Act (“IEEPA”), of transactions “ordinarily incident to travel to or from any country.” This would normally cover, and exempt from prohibition, paying for hotels while in Berlin. But Executive Order 13722 was also enacted pursuant to the
North Korea Sanctions and Policy Enhancement Act of 2016, which means that the travel exemption in IEEPA would not apply. Nor has OFAC promulgated regulations under Executive Order 13722 which would exempt travel related transactions.
 
So, even if you are completely comfortable with throwing your hard-earned money into Kim Jong Un’s nuclear piggy bank, you do so at your own risk if you are a U.S. citizen. 

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

TEEX/IM TRAINING EVENTS & CONFERENCES

TE_a216
. 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)

#” New listing this week:   
 
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:

* Apr 11: Webinar; “
GTM Webinar Series Part Five: Free Trade Agreements;” Amber Road

* Apr 11: Webinar; ”
Trade Laws and Trade Agencies;”


Sandler, Travis & Rosenberg, P.A.; webinarorganizers@strtrade.com

# Apr 12: Brussels, Belgium; ”
Implementation of the EU Arms Export Control System;” European Parliament / Sub-Committee on Security and Defence

# Apr 12: San Diego CA; ”
Reconciliation Seminar;” CPH Group

* Apr 12: Sunnyvale CA; ”
Accounting for Global Trade Professionals: Expanded Knowledge & Skill-Building;” WIT-NC; Diana Lee,
jhdianalee@gmail.com 

* Apr 12: Webinar; “
Export Compliance Essentials for Defense Contractors and Subcontractors
;” ECTI; danielle@learnexportcompliance.com; 540-433-3977

* Apr 18: Milwaukee WI; “AES Compliance Seminar;” Dept. of Commerce/Census itmd.outreach@census.gov 

* Apr 25: Webinar; ”
Antidumping 101: Minimizing Risk, Maximizing Compliance;” Sandler, Travis & Rosenberg, P.A.;
webinarorganizers@strtrade.com 

* 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 
# Apr 28: Wash DC; “
Enforce and Protect Act Workshop
;” Dept. of Homeland Security/Customs and Border Protection

* 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 4-5: Aarhus, Denmark; “
Dual-Use Conference 2017 – Drones & Space
;” European Network of Defence-Related Regions

* 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 9: Webinar; ”
Exports – New Incentives, Old Rules;” Sandler, Travis & Rosenberg, P.A.;
webinarorganizers@strtrade.com 

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

* May 10: Baltimore MD; “
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 17: The Hague, Netherlands; ”
Exportcontrole en Strategische Goederen” (Event in Dutch); Dutch Ministry of Foreign Affairs

* May 17: Webinar; ”
Preparing for a Customs Investigation;” Sandler, Travis & Rosenberg, P.A.;
webinarorganizers@strtrade.com 

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

* Mary 23: Chicago IL; ”
2017 Global Trade & Commercial Compliance Update;” Baker McKenzie; Eunkyung Kim Shin, +1 312 861 8211,
eunkyung.kim.shin@bakermckenzie.com 

* 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

* May 24-25: Scottsdale AZ; ”
2017 West Coast Trade Symposium;” Dept. of Homeland Security/Customs and Border Protection

* 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 12: Shanghai China; “
5th Advanced China Forum on Import Compliance
;” American Conference Institute

* Jun 13: Philadelphia PA; “AES Compliance Seminar;” Dept. of Commerce/Census Bureau; itmd.outreach@census.gov 

# Jun 14: Frankfurt am Main, Germany; “
BAFA / BIS Export Control and Compliance Update 2
;” Bundesamt für Wirtschaft und Ausfuhrkontrolle  

* 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 
* Jun 21: Brussels, Belgium; “
Export Controls and Economic Sanctions: US & EU Update 2017
;” International Chamber of Commerce Belgium

* 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

* Jul 26-27
: Seattle WA; “
2017 Export Controls Conference
;” Dept. of Commerce/U.S. Commercial Service, Dept. of Homeland Security/Homeland Security Investigations, Seattle University, Dorsey & Whitney LLP

* 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

# Sep 20-22: Houston TX; ”
Advanced Topics in Customs Compliance Conference;” Deleon Trade LLC

* 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 22-24: Grapevine TX; “
Annual ICPA Fall Conference
;” International Compliance Professional Association;
Wizard@icpainc.org 

* Oct 23-24: Arlington VA; “
2017 Fall Advanced Conference
;” Society for International Affairs

* Oct 30-Nov 2: Phoenix AZ; “
ITAR Defense Trade Controls / EAR Export Controls Seminar
;” ECTI;
jessica@learnexportcompliance.com
; 540-433-3977

* 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 6: Wood Ridge NJ; “
AES Compliance Seminar
;” 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

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

ENEDITOR’S NOTES

EN_a117
. Bartlett’s Unfamiliar Quotations

(Source: Editor) 

*
William Wordsworth (7 Apr 1770 – 23 Apr 1850, was a major English Romantic poet who, with Samuel Taylor Coleridge, helped to launch the Romantic Age in English literature with their joint publication,
Lyrical Ballads.

  – “Life is divided into three terms — that which was, which is, and which will be. Let us learn from the past to profit by the present, and from the present, to live better in the future.”
  – “Pictures deface walls more often than they decorate them.”

* John Sheffield (John Sheffield, 1st Duke of Buckingham and Normandy, 7 Apr 1648 – 24 Feb 1721) was an English poet and Tory politician of the late Stuart period who served as Lord Privy Seal and Lord President of the Council. He was also known by his original title, Lord Mulgrave.)
  – “‘Tis the most tender part of love, each other to forgive.”

Friday funnies:

Ole slipped into the house, and from behind put his hands over his wife’s eyes, and asked, “Do you love me, Lena?” “Of course I do,” she said, “even more than life itself.” Ole uncovered her eyes, turned her around and said, “Really, after all these years?” Lena looked at him and said, “Oh, it’s YOU!”
  — Frank Miller, Desloge, MO                                                    

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

EN_a218. 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 [New effective date: 21 March 2017.]; and 82 FR 8590: Delay of Effective Date for Toxic Substance Control Act Chemical Substance Import Certification Process Revisions
[New effective date: 21 March 2017.]

* 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: 6 Apr 2017: 82 FR 16730-16733: Revisions to the Unverified List (UVL)

  
*
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: 7 Mar 2017: Harmonized System Update 1702, containing 1,754 ABI records and 360 harmonized tariff records.
  – HTS codes for AES are available

here
.
  – HTS codes that are not valid for AES are available
here.
 
*
INTERNATIONAL TRAFFIC IN ARMS REGULATIONS (ITAR)
: 22 C.F.R. Ch. I, Subch. M, Pts. 120-130
  – Latest Amendment: 11 Jan 2017: 82 FR 3168-3170: 2017 Civil Monetary Penalties Inflationary Adjustment
  – The only available fully updated copy (latest edition 8 Mar 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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