;

17-0417 Monday “The Daily Bugle”

17-0417 Monday “Daily Bugle”

Monday, 17 April 2017

TOP
The Daily Bugle is a free daily newsletter from Full Circle Compliance, containing changes to export/import regulations (ATF, Customs, NISPOM, EAR, FACR/OFAC, FTR/AES, HTSUS, and ITAR), plus news and events.  Subscribe 
here for free subscription.  Contact us
for advertising inquiries and rates.

[No items of interest noted today.] 

  1. Ex/Im Items Scheduled for Publication in Future Federal Register Editions 
  2. Commerce/BIS: (No new postings.) 
  3. State/DDTC Announces Leadership Changes 
  4. Canada Adds Syrian Officials to Sanctions List 
  5. Japan METI Extends Ban on Imports from and Exports to North Korea 
  1. The Express Tribune: “Canada Moves to Join Treaty Curbing Foreign Arms Sales” 
  1. M. Miller Proctor: “New Unmanned Aerial Vehicles Agreement May Be Stalled as Numerous Key State Department Positions Remain Vacant” 
  2. M. Volkov: “TD Bank and Sanctions Violations” 
  1. Monday List of Ex/Im Job Openings: 93 Jobs Posted 
  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) 
  3. Weekly Highlights of the Daily Bugle Top Stories 

EXIMEX/IM ITEMS FROM TODAY’S FEDERAL REGISTER

EXIM_a1

[No items of interest noted today.]

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

OGSOTHER GOVERNMENT SOURCES

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

* Treasury; Foreign Assets Control Office; NOTICES; Blocking or Unblocking of Persons and Properties [Publication Date: 18 April 2017.]
  – Sanctions Actions Pursuant to Executive Order 13224
  – Sanctions Actions Pursuant to Executive Order 13553
 
* Industry and Security Bureau; RULES; Revision to an Entry on the Entity List [Publication Date: 18 April 2017.] 
* * * * * * * * * * * * * * * * * * * *

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OGS_33.

State/DDTC Announces Leadership Changes

 
Effective immediately, Ms. Alisa Forby assumes duties as Division Chief of the Sea, Land, and Aircraft Systems Division within the Office of Defense Trade Controls Licensing. Mr. Robert Warren is retiring from the Department of State effective April 30. The position of Division Chief of the Plans, Personnel, Programs, and Procedures Division will be vacant until filled at a later time.
 
  – Note: an overview of DDTC’s Key Personnel can be found
here

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

OGS_aa44. 
Canada Adds Syrian Officials to Sanctions List

 
Canada supports the Syrian people and is working with the international community to find a solution to end the war in Syria.
 
The Honourable Chrystia Freeland, Minister of Foreign Affairs, today announced new sanctions against the Assad regime. Canada’s Special Economic Measures (Syria) Regulations have been amended to list 27 additional individuals who are now subject to an asset freeze and dealings prohibition.
 
These individuals are high-ranking officials in the Assad regime. Adding their names to the sanctions list is part of additional international pressure on the regime to immediately end indiscriminate violence against its own people, like this month’s chemical weapons attack, and engage in meaningful negotiations.
 
Canada is focused on supporting the Syrian people. It has committed $1.6 billion to efforts in the region to provide humanitarian, security, stabilization and development assistance, in addition to having welcomed over 40,000 Syrian refugees to Canada.
 
Quotes
 
“Today’s new sanctions against key officials are part of our continued efforts to increase pressure on the Assad regime to stop the violence against innocent children, women and men. Last week’s chemical weapons attack in southern Idlib is a war crime and is unacceptable. Canada is working with its allies to end the war in Syria and hold those responsible to account.”
  – Hon. Chrystia Freeland, P.C., M.P., Minister of Foreign Affairs
 
Quick Facts
 
  – Canada reviews its sanctions on an ongoing basis and takes action as appropriate.
  – Canada contributes to investigations on the use of chemical weapons and the collection of evidence to support the prosecution of war crimes and crimes against humanity in Syria.
  – Canada is contributing more than $1.6 billion over the course of three years toward its approach to security, stabilization, and humanitarian and development assistance in response to the crises in Iraq and Syria and their impacts on neighbouring countries.
 
Associated Links
 
 
Contacts
 
Media Relations Office
Global Affairs Canada
343-203-7700

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OGS_a55. 
Japan METI Extends Ban on Imports from and Exports to North Korea

(Source:
METI)
 
On Monday, 17 April 2017, the Japanese Ministry of Economy, Trade and Industry (METI) released the below update.
 
Extension of Ban on Imports from and Exports to North Korea, Pursuant to the Foreign Exchange and Foreign Trade Act
 
The Ministry of Economy, Trade and Industry (METI) has decided to extend the ban on all exports destined for North Korea, and all imports originating in or shipped from North Korea, in line with the “Measures against North Korea Pursuant to the Foreign Exchange and Foreign Trade Act” (decided by the Cabinet on April 7, 2017).
* Outline of the measures:
  (1) The ban on all exports of goods destined for North Korea will be extended by imposing the requirement that exporters obtain export approval from the Minister of Economy, Trade and Industry (related article: Article 48, Paragraph 3 of the Foreign Exchange and Foreign Trade Act; hereinafter referred to as the “Act”).
  (2) The ban on all imports of goods originating in or shipped from North Korea will be extended by imposing the requirement that importers obtain import approval from the Minister of Economy, Trade and Industry (related article: Article 52 of the Act).
  (3) To ensure the enforcement of these restrictions, the following transactions shall be banned:
Transactions involving buying/selling, loaning/borrowing, or giving of goods that involve the movement of the goods between North Korea and third countries (intermediate trade) (related article: Article 25, Paragraph 6 of the Act); and
Payments of import bills for goods originating in or shipped from North Korea which are imported without import approval (related article: Article 16, Paragraph 5 of the Act).
Goods exported for humanitarian purposes are exempt from the above restrictions.
 
* Effective period: These restrictions will enter into effect
from 14 April 2017 to 13 April 2019.
* Release date: April 7, 2017.
* Division in Charge: Trade Control Policy Division, Trade Control Department, Trade and Economic Cooperation Bureau. 

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NWSNEWS

NWS_a16.

The Express Tribune: “Canada Moves to Join Treaty Curbing Foreign Arms Sales”

 
Canada introduced a bill Thursday opening the way for it to join a UN Arms Trade Treaty which effectively curbs some foreign weapons sales.
 
Foreign Minister Chrystia Freeland introduced the legislation, saying it would formalize Canada’s current system of export controls which already “meets most of the treaty’s thresholds.” … 

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COMMCOMMENTARY

COMM_a17.

M. Miller Proctor: “New Unmanned Aerial Vehicles Agreement May Be Stalled as Numerous Key State Department Positions Remain Vacant”

 
* Author: Melissa Miller Proctor, Esq., Polsinelli LLP Phoenix, AZ,
mproctor@polsinelli.com.
 
A
recent article by Defense News reports that the movement towards an international agreement on the responsible use and export of drones may be stalled as a result of numerous vacancies in key positions within the State Department that would normally be working to push out a U.S. policy on armed Unmanned Aerial Vehicles (UAVs).
 
In the Fall of 2016, the U.S. and 44 other countries signed a joint declaration on the export and use of armed and strike-enabled drones-this was viewed as a first step towards the implementation of formal, international standards for the transfer and use of UAVs. The joint declaration was driven by an uptick in the commercial availability and proliferation of UAVs around the world was intended to trigger additional formal discussions culminating in an international agreement. 
The declaration set forth the following 5 principles:
 
  – Armed UAVs should be subject to international law, including the law of armed conflict and international humans rights law;
  – Exports of armed and strike-enabled UAVs should comport with other established arms control standards and those of existing multilateral export and non-proliferation organizations;
  – Exporters should be required to consider an end user’s previous history of compliance with international obligations before transferring armed or strike-enabled UAVS;
  – Exports should be transparent and require reporting through existing mechanisms; and,
  – Each country should start collaborating on the establishment of international standards for armed UAVs.
 
The signatories had planned to meet in early 2017 to discuss next steps but decided to postpone the meeting until June to give the new administration time to set policy. As a general rule, licenses are required to be obtained from the State Department’s Directorate of Defense Trade Controls (DDTC) in accordance with the International Traffic in Arms Regulations before such systems may be exported, reexported or temporarily imported into the United States-unless an exemption applies. One of the challenges faced by the new administration in this area is the fact that there are more than 110 currently unfilled positions, including Under Secretary for Arms Control and International Security Affairs and Under Secretary for Civilian Secretary, key positions that would be expected to drive U.S. policy on armed UAVs.
 
There are positive reports from the White House regarding meetings that addressed the joint declaration. 

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COMM_a28.

M. Volkov: “TD Bank and Sanctions Violations”

(Source:
Volkov Law Group Blog. Reprinted by permission.)
 
* Author: Michael Volkov, Esq., Volkov Law Group,
mvolkov@volkovlaw.com, 240-505-1992.
 
Sanctions enforcement continues to be a significant risk. With the focus on unraveling elaborate corporate ownership schemes, the risk of conducting business with sanctioned individuals or entities is increasing.
 
The Treasury Department’s Office of Foreign Asset Control has increased expectations regarding corporate compliance programs. In addition, OFAC encourages voluntary disclosures when violations occur, and has set out an elaborate scheme regarding transparency. On the criminal side, the Justice Department’s National Security Division focuses enforcement efforts against those serious violations that may have national security implications. The line between criminal and civil is fairly clear when it comes to circumventing sanctions prohibitions.
 
For the last few years, international banks have been the focus of enforcement efforts. In January of this year, TD Bank was required to pay a civil penalty of $516,105, earning just under a 50 percent discount from the base penalty, for conducting 167 transactions in violation of the Cuba and Iran sanctions programs. TD Bank voluntarily disclosed the violations to OFAC.
 
TD Bank, which is based in Montreal, Canada, issued a series of letters of credit to Canadian customers engaged in transactions with Iran and Cuba. The transactions, with the letters of credit, were processed through the United States’ financial system, thereby triggering United States jurisdiction. A Cuban company owned one Canadian customer, and TD Bank had knowledge of this relationship.
 
TD Bank also assisted a customer shipping company that transported oil and gas equipment to customers in the Middle East, and was listed as an agent of Specially Designated National located in Iran.
 
TD Bank also had 62 customers who were Cuban nationals residing in Canada.
 
TD Bank supervisory personnel knew or should have known of the continuing conduct with the exception of certain violations. OFAC cited TD Bank’s weak OFAC compliance program as contributing to the series of violations.
 
On the mitigating side of equation, OFAC cited the fact that TD Bank could have obtained a license to provide services to the Cuban nationals under a general license issued in 2011.
 
The focus of OFAC’s enforcement action centered on TDWIS, TD Bank’s securities trading subsidiary. Between 2007 and 2013, TDWIS, the subsidiary company opened trading accounts for 4 individuals subject to the Iran and Cuba sanctions, and processed almost four thousand transactions over the six-year period for these four customers. TDWIS processed securities trading transactions for Internaax, an international brokerage firm.
 
Internaax shared customer and trading information with TDWIS, which in turn processed the transactions through a United States broker-dealer. Both Internaax and TDWIS had sufficient identifying information to recognizer that the proposed transactions were barred under the Cuba and Iran sanctions programs.
 
TDWIS made little to no attempt to ensure that Internaax complied with OFAC restrictions. OFAC cited this fact in its enforcement order.
 
OFAC also cited this case to underscore that securities firms operating outside the United States understand and fully comply with sanctions regulations imposed on United States parent companies. Additionally, OFAC noted that online payment platforms have to be monitored to ensure compliance with OFAC sanctions.

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MSEX/IM MOVERS & SHAKERS

MS_a19. Monday List of Ex/Im Job Openings: 93 Jobs Posted

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

* Aerojet Rocketdyne; Huntsville AL; 
Specialist, International Trade & Compliance
; Requisition ID: 11972

* Amazon; Luxembourg, Luxembourg;
Trade Compliance Project Integration Manager (M/F)
; Requisition ID: 479077

* Amazon; Mexico City, Mexico;
Mexico Trade Compliance Program Manager
; Requisition ID: 481541
* Amazon; Seattle WA;
NA Compliance Analyst
; Requisition ID: 256357

* Amazon; Seattle WA;
U.S. Export Compliance PM
; Requisition ID: 475927

* Amazon; Tokyo, Japan;
Trade Compliance Specialist
; Requisition ID: 481891

* Advanced Micro Devices (AMD); Austin TX;
Import/Export Compliance Manager; Requisition ID: 24061

#
BAE Systems Plc; Farnborough, United Kingdom; 
Deputy Head of Licensing & Policy
; Requisition ID: 
00045464

* Barnes Group Inc.,; Bristol CT and Windsor CT;
Counsel & Director of Trade Compliance, Government Contracts Program; Requisition ID: 2200-271

* Bemis Company; Neenah WI;
Director – Global Trade Compliance
; Requisition ID: REQ_13735
* Berry Plastics Corporation; Evansville IN;
International Trade Compliance Administrator
; Requisition ID: 4054

* Biogen; Cambridge MA;
Trade Compliance Specialist
; Requisition ID: 30956BR

# Brunswick Corporation; Lake Forest IL;
Trade Compliance Auditor
; Becky Longrie, 847-735-4755,
becky.longrie@brunswick.com
; Requisition ID: 22999

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

* CSL Behring; King of Prussia PN;
Global Trade Compliance Senior Analyst
; Requisition ID: R-038869

# CSRA Inc.; Falls Church VA;
Global Trade & Compliance Principal
; Alan Strober 571-375-4890; Requisition ID: 17002RN

* Danaher; Wash DC (Other locations possible);
Global Trade Compliance Manager; Requisition ID: DAN000510

* DB Schenker (2 positions); Atlanta GA, and Long Beach CA;
Area Customs Director
;
Crystal.Adair@dbschenker.com
; Requisition ID: 17P009

* Elbit Systems of America; Forth Worth TX or Merrimack NH;
Import Compliance Manager
; Requisition ID: 017-4965

* Erickson Inc.; Portland OR;
Trade Compliance Manager
; 
Joanna Rafiner-Jarboe
; Requisition 2017-2267

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

* Esterline Technologies Corporation; Bellevue WA;
Sr. Trade Compliance Manager – Sensors & Systems (Engineering)
; Requisition ID: 8791BR
* Esterline Technologies Corporation; Brea CA;
Sr. Trade Compliance Manager;
Requisition ID: 7333BR

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

* Expeditors; Sunnyvale CA;
Customs Compliance Specialist
* Export Solutions Inc.; Melbourne FL; Trade Compliance Specialist;
info@exportsolutionsinc.com

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

* FlightSafety International; Oklahoma; Trade Compliance Advisor; Requisition ID 16480

*
FLIR; Billerica MA; 
Sr. Defense Trade Licensing & Compliance Analyst
; Requisition ID: 8008

* General Dynamics Information Technology; Falls Church VA;
Principal Contracts Administrator – Export Compliance Coordinator
;
Kara.Reynolds@gdit.com
; Requisition ID: 2017-21288

* Givaudan; Bogor, Indonesia;
Compliance Manager
; Requisition ID: 68063

* The Hershey Company; Hershey PA;
Global Customs and Trade Analyst
* Infinera Corporation; Sunnyvale CA;
Director, Global Logistics and Trade Compliance
; Requisition ID: 2016840

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

* Intel; Santa Clara CA;
Global Export Compliance Specialist
; Requisition ID: JR0814909
* Intel; Santa Clara CA;
Export Compliance Specialist
; Requisition ID: JR0005160

* Johnson Controls; Monroe NC;
Shipping Logistics Coordinator; Requisition ID: 1710087

* Lam Research Corporation; Fremont CA;
Foreign Trade Intern 1

* Lam Research Corporation; Shanghai, China;
Foreign Trade Analyst 

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

* L-3 Technologies; Arlington VA;
Sr. Mgr. Corporate Customs Compliance
; Requisition ID: 087862

* L3 Technologies, Platform Integration Division; Waco TX;
Export/Import Compliance Administrator 3
; Requisition ID 088725

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

* Medtronic; Wash DC;
Global Trade Lawyer
;
stacy.m.johnson@medtronic.com
; Requisition ID: 170002ON

* Meggitt PLC; Maidenhead, UK;
Trade Compliance Officer 

* Meggit-USA, Inc.; Simi Valley CA;
Trade Compliance Administrator
; Requisition ID: 25172

* Michael Page; Oestgeest, The Netherlands
Sr. Manager – Global Trade Management

* Netflix; Los Gatos CA;
Global Export Compliance Manager

* Northrop Grumman Corporation; Herndon VA;
International Trade Compliance Analyst 3
; Requisition ID: 17000826

* Northrop Grumman Corporation; Herndon VA;
International Trade Compliance Analyst 3/4; Requisition ID: 17001180

* Northrop Grumman Corporation; Linthicum MD;
International Trade Compliance Analyst 3
; Requisition ID: 17001930

* Northrop Grumman Sperry Marine; New Malden, UK;
Trade Compliance Coordinator
;
careers.uk@sperry.ngc.com
* Pall Corporation; Portsmouth, UK;
Trade Compliance Specialist
; Requisition ID: SHA000201

* Panduit; Tinley Park IL;
Global Trade Compliance Agent
; Requisition ID: PAND-03297

* Parexel; Billerica MA;
Vice President, Chief Compliance Officer; Requisition ID: pare-00024091

* Parexel; Kiev, Ukraine;
Global Trade Compliance Specialist
; Requisition ID: pare-10056329

* Plexus Corporation; Neenah Wi;
Manager – Export Compliance
; Requisition ID: 14645BR
* Plexus Corporation; Neenah Wi;
Manager – Import Compliance
; Requisition ID: 14593BR

* Roanoke Insurance Group; Schaumburg IL;
Carnet Service Representative
; Requisition ID: 1019

* Raytheon; Andover MA and Woburn MA;
Manager of Export Import Control, Empowered Officials
; Requisition ID: 93622

* Raytheon; Arlington VA;
Export Licensing Manager I
; Requisition ID: 94113BR

* Raytheon Australia; Canberra, Australia;
Export/Import Operations Advisor; Requisition ID: 86438BR

* Raytheon; Fullerton CA;
Manager of Export-Import Control, Empowered Official (RCCS); Requisition ID: 93625BR

* Raytheon; McKinney TX;
Counsel Global Trade Compliance
; Requisition ID: 94826BR

* Raytheon; Portsmouth RI;
Manager of Export Import Control, Empowered Official
; Requisition ID: 93628

* Raytheon; Woburn MA;
Supply Chain Compliance Manager; Requisition ID: 93734BR

* Raytheon; Woburn MA;
Supply Chain Subcontract Manager; Requisition ID: 93615BR

* Raytheon Integrated Defense Systems; Andover MA;
Export Licensing & Compliance Advisor, Global Trade; Requisition ID: 93670BR

* Raytheon Intelligence, Information and Services; Annapolis Junction MD or Dulles VA;
Sr Exp License&Compliance Adv; Requisition ID: 91338BR

* Raytheon Intelligence, Information and Services; Orlando FL;
Sr Exp License&Compliance Adv; Requisition ID: 92852BR

* Raytheon Space & Airborne Systems; McKinney TX;
Sr Exp License & Compliance Adv;
Jennifer.a.martindale@raytheon.com
; 310-334-7499; Requisition ID:
91503BR

* Synopsys; Mountain View CA;
Senior Manager, Export Compliance
;
moudakas@synopsys.com
;
650-584-1676; Requisition ID: 13208BR
* Talbots; Hingham MA;
Sr Mgr Global Trade & Customs Compliance
; Requisition ID: 1077
* Talbots; Lakeville MA;
Dir., Global Logistics & Customs Com
; Requisition ID: 1085

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

* Thales Defense and Security, Inc.; Clarksburg MD; Senior Manager Trade Compliance
; William.Denning@thalesdsi.com; Requisition ID: 2592

* ThermoFisher Scientific; Matamoros, Mexico;
Import/Export Supervisor
; Requisition ID: 39750BR
* ThermoFisher Scientific; Shanghai, China;
Trade Compliance Specialist – CMC
; Requisition ID: 42143BR

* United Technologies Corporation, UTC Aerospace Systems; Charlotte NC
Intern, International Trade Compliance
; Requisition ID: 45442BR


* United Technologies Corporation, UTC Aerospace Systems; Charlotte NC;
Specialist, ITC IT Systems
; Requisition ID:
33792BR

* United Technologies Corporation, UTC Aerospace Systems; Chula Vista CA;

International Trade Compliance Intern
; Requisition ID:
39406BR

* United Technologies Corporation, Otis; Farmington CT;
Senior International Trade Compliance Counsel
; Requisition ID: 38518BR

* United Technologies Corporation, Otis; Farmington, CT;
International Trade Compliance (ITC) Program Manager
; Requisition ID: 44984BR

* United Technologies Corporation, UTC Aerospace Systems; Santa Fe Springs CA;
Sr. Analyst, International Trade Compliance
; Requisition ID: 46184BR

* United Technologies Corporation, UTC Aerospace Systems; Troy OH;
Sr. Manager, Intl Trade Compliance
; Requisition ID: 44065BR 

* United Technologies Corporation, UTC Aerospace Systems; Vergennes, VT;

ITC Generalist
; Requisition ID:
44040BR
* United Technologies Corporation, UTC Aerospace Systems; Westford MA;
Senior Analyst, International Trade Compliance
; Requisition ID: 31576BR
* United Technologies Corporation, UTC Aerospace Systems; Windsor Locks, CT;
IT Export & Compliance Intern
; Requisition ID: 42148BR
* United Technologies Corporation, UTC Aerospace Systems; Windsor Locks, CT; 
Spec, Intl Trade Compl
; Requisition ID: 44177BBR

* Vigilant; Unknown location in the U.S.;
BioTech/Pharmaceutical Global Trade Analyst

* Wurth Industry of North America; Indianapolis IN; Trade Compliance Officer;
International Trade Compliance Officer
; Requisition ID: 389-720
* Wurth Snider Bolt and Screw; Louisville KY; 
Trade Compliance Specialist
; Sylvia Smith,
SSmith@wurthsnider.com
; Requisition ID: 1124

* XPO Logistics; Greenwich CT;
Global Trade Compliance Analyst

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ENEDITOR’S NOTES

*
Thornton Wilder (Thornton Niven Wilder, 17 Apr 1897 – 7 Dec 1975, was an American playwright and novelist.  He won three Pulitzer Prizes-for the novel,
The Bridge of San Luis Rey, and for the two plays,
Our Town and
The Skin of Our Teeth – and a U.S. National Book Award for the novel,
The Eighth Day.)
  – “The more decisions that you are forced to make alone, the more you are aware of your freedom to choose.”
  – “When you’re safe at home you wish you were having an adventure; when you’re having an adventure you wish you were safe at home.”
 
*
Anatole France (born François-Anatole Thibault, 16 Apr 1844 – 12 Oct 1924, was a French poet, journalist, and novelist. He was a successful novelist, with several best-sellers. Ironic and skeptical, he was considered in his day the ideal French man of letters.  He was a member of the Académie Française, and won the 1921 Nobel Prize in Literature “in recognition of his brilliant literary achievements, characterized as they are by a nobility of style, a profound human sympathy, grace, and a true Gallic temperament.”)
  – “Wandering re-establishes the original harmony which once existed between man and the universe.”
 
Monday is pun day.
 
Q. Why did the skeleton NOT cross the road?
A. It didn’t have the guts.
  – Stacy Pasch, Alexandria, MN
 
Q. What did the big chimney say to the little chimney?
A. You’re too little to be smoking!
  – Jo Harper, Ashland, OH

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EN_a311
. 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: 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 (9 Mar 2016) of Bartlett’s Annotated FTR (“BAFTR”), by James E. Bartlett III, is available for downloading in Word format. The BAFTR contains all FTR amendments, FTR Letters and Notices, a large Index, and footnotes containing case annotations, practice tips, and Census/AES guidance.  Subscribers receive revised copies every time the FTR is amended. The BAFTR is available by annual subscription from the Full Circle Compliance website.  BITAR subscribers are entitled to a 25% discount on subscriptions to the BAFTR.
 
*
HARMONIZED TARIFF SCHEDULE OF THE UNITED STATES (HTS, HTSA or HTSUSA)
, 1 Jan 2017: 19 USC 1202 Annex. (“HTS” and “HTSA” are often seen as abbreviations for the Harmonized Tariff Schedule of the United States Annotated, shortened versions of “HTSUSA”.)
  – Last Amendment: 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 is Bartlett’s Annotated ITAR (“BITAR”), by James E. Bartlett III. The BITAR contains all ITAR amendments to date, plus a large Index, over 750 footnotes containing case annotations, practice tips, DDTC guidance, and explanations of errors in the official ITAR text.  Subscribers receive updated copies of the BITAR in Word by email, usually revised within 24 hours after every ITAR amendment.  The BITAR is available by annual subscription from the Full Circle Compliance website.  BAFTR subscribers receive a 25% discount on subscriptions to the BITAR, please contact us to receive your discount code.

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Review last week’s top Ex/Im stories in “Weekly Highlights of the Daily Bugle Top Stories” published
here

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EPEDITORIAL POLICY

* The Ex/Im Daily Update is a publication of FCC Advisory B.V., edited by James E. Bartlett III and Alexander Bosch, and emailed every business day to approximately 8,000 readers of changes to defense and high-tech trade laws and regulations. We check the following sources daily: Federal Register, Congressional Record, Commerce/AES, Commerce/BIS, DHS/CBP, DOJ/ATF, DoD/DSS, DoD/DTSA, State/DDTC, Treasury/OFAC, White House, and similar websites of Australia, Canada, U.K., and other countries and international organizations.  Due to space limitations, we do not post Arms Sales notifications, Denied Party listings, or Customs AD/CVD items.

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* CAVEAT: The contents of this newsletter cannot be relied upon as legal or expert advice.  Consult your own legal counsel or compliance specialists before taking actions based upon news items or opinions from this or other unofficial sources.  If any U.S. federal tax issue is discussed in this communication, it was not intended or written by the author or sender for tax or legal advice, and cannot be used for the purpose of avoiding penalties under the Internal Revenue Code or promoting, marketing, or recommending to another party any transaction or tax-related matter.

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