;

17-0505 Friday “Daily Bugle”

17-0505 Friday “Daily Bugle”

Friday, 5 May 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

[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. DoD/DSS Posts NISPOM Change 2 Insider Threat Employee Awareness Training Requirement
  4. DHS/CBP Announces Mandatory Filing of Contact Name and Phone
  5. DHS/CBP Posts Notice on ACE PRODUCTION Outage on 6-7 May
  6. DHS/CBP Updates Web Content Concerning ACE Secure Data Portal
  7. State/DDTC: (No new postings.)
  8. EU Extends Existing Restrictive Measures Concerning Situation in Ukraine Until 15 Sep
  9. EU Amends for the 267th Time Certain Specific Restrictive Measures Concerning ISIL (Da’esh) and Al-Qaida
  1. ST&R Trade Report: “Dates and Deadlines: Classification, Exports, China, Customs Forms”
  1. M. Volkov: “Compliance and Financial Audits – Distinctions with Substance”
  2. O. Coulon & G. Kreijen: “Dual-Use Application of Key Enabling Technologies”
  3. Gary Stanley’s ECR Tip of the Day
  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 (18 Apr 2017), FACR/OFAC (10 Feb 2017), FTR (19 Apr 2017), HTSUS (26 Apr 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)
 
* Justice; 
Alcohol, Tobacco, Firearms, and Explosives Bureau
; NOTICES; Agency Information Collection Activities; Proposals, Submissions, and Approvals: Firearms Transaction Record/Registro de Transaccion de Armas [Publication Date: 8 May 2017.]  

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

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

 
Industry is reminded that insider threat employee awareness training is required for all cleared employees before being granted access to classified information and annually thereafter. The suspense for the completion of training for those employees currently in access is May 31, 2017. After May 31, 2017, all cleared contractor employees must complete the employee awareness training prior to being placed into access for classified information and thereafter annually.
 
Information on the employee awareness training requirements can be found in NISPOM 3-103b and in ISL 2016-02; and information on industry insider threat programs is available here.

Training is also available through the Center for Development of Security Excellence, in the CDSE catalog under Insider Threat.

CDSE Available Training Courses:  

  –
Insider Threat Awareness, course CI121.16
  Counterintelligence Awareness and Security Briefing, course CI112.16

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

(Source:
CSMS# 17-000258
, 4 May 2017.)
 
In June 2017, CBP will make it mandatory for the trade to provide the Contact Name and Contact Phone for all entries on the SE13 Record. This will assist the trade and CBP in facilitating the movement of cargo during the inspection process as well as expedite the release process. A date will be given as to when CBP will make the Contact Name and Contact Phone mandatory. Changes to the CATAIR will be made at a later date.
* * * * * * * * * * * * * * * * * * * *

(Source:
CSMS# 17-000259, 5 May 2017.)
 
There will be an ACE PRODUCTION Outage Saturday evening, May 6, 2017 from 2200 ET to 0400 ET Sunday, May 7, 2017 for ACE infrastructure maintenance.
* * * * * * * * * * * * * * * * * * * *

(Source:
CSMS# 17-000260, 5 May 2017.)
 
U.S. Customs and Border Protection (CBP) has updated web content to help users better understand the ACE Secure Data Portal. The updated content is for members with existing portal access, and new trade members who are looking to gain access to the ACE Portal. The new pages including:

  (3) Applying for an ACE Portal account

The intention of this new content is to help ACE Portal users have a better understanding of the account process and to address frequently asked questions.

None of the new content affects the structure of existing ACE Portal accounts, and no immediate action is required on your part.   

A one page summary and reference sheet of the material is available by way of ACE Basics – ACE Portal Account.
* * * * * * * * * * * * * * * * * * * *

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

OGS_a8
8. EU Extends Existing Restrictive Measures Concerning Situation in Ukraine Until 15 Sep
 
On 13 March 2017, the Council adopted Council Decision (CFSP) 2017/445. The Council Decision extends the existing restrictive measures until 15 September 2017. The measures in question are asset freezes and travel bans against persons and entities responsible for actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine.
 
The Candidate Countries Montenegro and Albania, and the EFTA country Norway, member of the European Economic Area, as well as Ukraine align themselves with this Council Decision.
 
They will ensure that their national policies conform to this Council Decision.
 
The European Union takes note of this commitment and welcomes it.
* * * * * * * * * * * * * * * * * * * *

 
Regulations:
  – Commission Implementing Regulation (EU) 2017/778 of 4 May 2017 amending for the 267th time Council Regulation (EC) No 881/2002 imposing certain specific restrictive measures directed against certain persons and entities associated with the ISIL (Da’esh) and Al-Qaida organisations.
* * * * * * * * * * * * * * * * * * * *

NWSNEWS

 
Following are highlights of regulatory effective dates and deadlines and federal agency meetings coming up in the next week.
 
  – 9 May: deadline for comments to FTZ Board on requests for new and expanded subzones
  – 10 May: deadline for comments to ITA on market economy status for China
  – 11 May: ITC hearing on economic impact of Caribbean Basin preferences
  – 11 May: deadline for comments on USDA information collections on imports of citrus and beans
  – 11 May: meeting of U.S. Investment Advisory Council
  – 11 May: meeting of BIS Materials Technical Advisory Committee
  – 12 May: deadline for comments to CBP on general declaration, warehouse submission
  – 12 May: deadline for comments to CBP on proposed revocation or modification of rulings
  – 12 May: deadline for comments to ITC on IPR infringement complaint on digital cameras, magnetic tape cartridges
* * * * * * * * * * * * * * * * * * * *

COMMCOMMENTARY

(Source:
Volkov Law Group Blog. Reprinted by permission.)
 
* Author: Michael Volkov, Esq., Volkov Law Group, mvolkov@volkovlaw.com, 240-505-1992.
 
Chief compliance officers and internal auditors are natural friends and allies. In the corporate governance world, they share many common interests.
 
The natural partnership between compliance and audit reflects their substantive overlap of responsibilities. Internal auditors are guardians of a company’s internal controls, and ever since Sarbanes-Oxley, they have even greater responsibility for the accuracy of a company’s financial reporting system.
 
A compliance program is a part of, or a subset, of a company’s internal controls. Hence, the substantive overlap. Compliance policies and procedures establish internal policies and procedures governing compliance-related function.
 
For example, a company’s gifts, meals and entertainment policy sets out basic procedures that must be followed for spending money on gifts, meals and entertainment. In most cases, companies have adopted a threshold above which an individual must secure pre-approval. If the procedures are properly followed, an individual will obtain pre-approval for a meal that exceeds the threshold.
 
After spending the money using a company credit card, the individual may seek reimbursement for the expenditure. The company’s financial controls will reflect the requirements that need to be satisfied for reimbursement, including pre-approval of certain expenditures, before authorizing repayment of the funds.
 
The company’s compliance controls and financial controls interact with each other to reinforce an overall compliance program and relevant financial controls.
 
My purpose in outlining this distinction is to show the closeness with which compliance and internal audit operate. In time, compliance and internal audit may work even more closely to leverage cost-effective strategies.
 
Internal auditors often travel to company locations to conduct financial audits. When conducting audits, compliance officers often ask internal auditors to examine compliance issues or ask specific compliance-related questions. While I am not a big proponent of this strategy, there are ways to gain benefits from having internal audit staff focus partially on compliance issues.
 
My concern with respect to asking internal audit to conduct compliance inquiries is that it dilutes compliance officers’ responsibilities, compliance officers’ presence in the field and compliance officer’s ability to exercise their responsibilities under the watchful eye of global managers and employees. Compliance officers need to spend time outside of headquarters and in the field. Compliance officers also need to conduct compliance audits. To the extent these can be coordinated with internal audit, a joint audit maximizes the benefits of an audit.
 
If, on the other hand, having internal audit supplement its audit with compliance questions is not done at the expense or as an alternative to a compliance audit, then collecting information that would not otherwise be available is perfectly proper. Compliance audits are valuable as a separate matter and should not depend on nor resemble a financial audit.
 
Compliance and audit functions share a lot in common. But a compliance program extends beyond its financial controls to include a company’s culture, training, communications, internal investigations and other components that are not directly tied to financial controls. As a result, compliance has to exercise its responsibilities to maximize its impact and its overall objectives. Internal auditors, while helpful in many respects, need to focus on their objectives, offer to support the compliance functions, and do so where it makes sense.
 
If the compliance profession wants to continue its robust growth in influence and status in the corporate governance world, compliance officers have to step up and assume responsibility for compliance programs, and when resources are needed, compliance officers cannot sit idly by and complain to themselves. They need to communicate clearly their needs and the important functions that they carry out.
* * * * * * * * * * * * * * * * * * * *

COMM_a212
. O. Coulon & G. Kreijen: “Dual-Use Application of Key Enabling Technologies”

 
* Authors: Oliver Coulon, Esq., Olivier.Coulon@loyensloeff.com, +32 2 743 43 43; and Gerard Kreijen, Esq., Gerard.Kreijen@loyensloeff.com, +31 20 578 53 95. Both of Loyens & Loeff.
 
A recent study report (accessible here), originally ordered by EASME (the European Executive Agency for SMEs), addresses the dual-use potential of Key Enabling Technologies (KETs). The report deserves the particular attention of SMEs involved in KET research and development, because the dual-use potential of these technologies, if realized, is likely to bring the activities of these SMEs within the scope of trade controls. By implication, the realization of the KET’s dual-use potential could also have a considerable impact on existing export control regimes such as the regime established by Council Regulation (EU) 428/2009.
 
The study report, which constitutes an additional step in the EU’s strategy on a more competitive and efficient defense sector, sets out a list of the most relevant dual-use innovation fields, as well as the strengths, weaknesses, opportunities and threats of each field. R&D and policy recommendations conclude the study, tackling in particular the issues of the regulatory frameworks and public awareness.
 
The origin of the study can be traced back to a 2013 Communication from the Commission entitled “Towards a more competitive and efficient defence and security sector” which sets out an action plan featuring inter alia a call to exploit the dual-use potential of research and reinforce innovation.
 
KETs are those technologies which provide the basis for innovation in a range of products across all industrial sectors and, as such, will enable the development of new goods and services, as well as the restructuring of industrial processes within Europe. The most commonly designated KETs are micro and nanoelectronics, nanotechnology, industrial biotechnology, advanced materials, photonics, and advanced manufacturing technologies.
 
The report identifies thirty-eight innovation fields, each representing innovative new products, processes or services that result from cutting edge research in KETs, and categorized in the following seven clusters:
 
  – Fundamental non-dependence material and components
  – Energy for mobility
  – Heat and sanitary protection, including against CBRN-E threats
  – Communication, navigation and surveillance systems
  – Human assistance and robotics
  – Security/Cybersecurity systems
  – Production and supply chain solutions
 
Amongst the innovation fields, which derive from a wide array of industry sectors, are high performance / low weight materials; screening devices for detection of traces, including that of CBRN-E; advanced broadband wireless communication; robotic devices for search and rescue; improved encryption solutions and tracking devices to secure supply chains.
 
The study provides an in-depth analysis of each innovation field, including its key players and upcoming breakthroughs, but also their weaknesses – such as the fragmentation of the R&D efforts or the sourcing of raw material – and threats, including the protection of IP rights and global competition.
 
Having identified the technological and market areas of common interest for both civilian and military use, the study concludes with R&D and policy recommendations, tailored for each of the above mentioned seven clusters, and points, within each cluster, at specific technologies recommended as most relevant for R&D dual-use purposes.
 
The report will be of particular interest to SMEs dedicated to the research and production of KETs with a potential for military applications. The report serves at the same time as a reminder for many technology companies that their work might be(come) controlled under trade control regulations.

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

COMM_a313
. Gary Stanley’s ECR Tip of the Day

 
* Author: Gary Stanley, Esq., Global Legal Services, PC, (202) 352-3059,
gstanley@glstrade.com.
 

In general, the effect Export Control Reform has had on the FMS program has been minimal. Per the EAR, § 734.3(b)(1)(vi), “… items that would otherwise be subject to the EAR and that are sold, leased or loaned by the Department of Defense to a foreign country or international organization under the Foreign Military Sales (FMS) Program of the Arms Export Control Act, pursuant to a Letter of Offer and Acceptance (LOA) authorizing such transfers, are not ‘subject to the EAR’ but rather, are subject to the authority of the Arms Export Control Act.” The U.S. Department of State’s Office of Regional Security and Arms Transfers (RSAT) licenses 
Third Party Transfers of FMS items.  

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

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)

#” 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:

* 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; Fargo ND; “
Export Compliance Training
;” Allocca Enterprises, Inc.; 
admin@alloccaenterprises.com 
# May 9: Wash DC; “
Export Controls and Compliance Seminar
;” American Association of Exporters and Importers
# May 9: Webinar; “
Brexit’s Effect on Global Trade
;” IntegrationPoint

* 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 11: Milwaukee WI; “
Wisconsin International Trade Conference
;” MMAC’s World Trade Association

* 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 16: Webinar; “
Regulatory Updates: Town Hall Series
;” Dept. of Commerce/Census Bureau

* 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; “
Best Practices for Automating RPS
;” Amber Road

* 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 

* May 22-24: San Diego CA; ”
ITAR/EAR Boot Camp;” American Conference Institute

# May 22: Webinar; “
Regulatory Updates: Town Hall Series Q&A Teleconference
;” Dept. of Commerce/Census Bureau

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

* May 23-24: Detroit MI; ”
Complying with U.S. Export Controls;” Dept. of Commerce/Bureau of Industry and Security

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

* May 24-25: Annapolis MD; “
‘Benchmarking Your ITAR/EAR Compliance Programs’ featuring Gerry Horner, Commerce/BIS; Byron Angvall, The Boeing Company and Christine Lee, UTC
;” 
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

* May 25: Detroit MI; ”
U.S. Munitions List to Commerce Control List;” Dept. of Commerce/Bureau of Industry and Security

* Jun 1: Webinar; ”
Identifying Agents for Customs Purposes – Traps for the Unwary Importer;” Sandler, Travis & Rosenberg, P.A.;
webinarorganizers@strtrade.com 

* 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 


* Jun 8-9: Seattle WA; ”
Complying with U.S. Export Controls;” Dept. of Commerce/Bureau of Industry and Security

* Jun 11-13: Dublin IRL; “ICPA Dublin Conference;”
International Compliance Professionals Association;
wizard@icpainc.org 


* Jun 12-14: Arlington VA; ”
8th Advanced Forum on DCAA & DCMA Cost, Pricing, Compliance & Audits;” American Conference Institute

* 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 13: Webinar; ”
Using Incoterms® Properly to Avoid Disputes;” Sandler, Travis & Rosenberg, P.A.;
webinarorganizers@strtrade.com 

* 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 20: Webinar; ”
International Payment Options 101;” Sandler, Travis & Rosenberg, P.A.;
webinarorganizers@strtrade.com 

* Jun 21-22: Miami FL; ”
Miami Forum on Anti-Corruption;” American Conference Institute

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

* Jul 10-12; Baltimore MD; “
2017 Summer Back to Basics Conference
;” Society for International Affairs

* 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: Oklahoma OK; ”
Complying with U.S. Export Controls;” Dept. of Commerce/Bureau of Industry and Security

* 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 2-3: Los Angeles; ”
Complying with U.S. Export Controls;” Dept. of Commerce/Bureau of Industry and Security

* 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: Louisville KY; ”
Complying with U.S. Export Controls;” Dept. of Commerce/Bureau of Industry and Security

* Sep 12-13: Milpitas CA; ”
Complying with U.S. Export Controls;” Dept. of Commerce/Bureau of Industry and Security

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

* Sep 14: Milpitas CA; “
Encryption Controls;”
Dept. of Commerce/Bureau of Industry and Security

* Sep 18-21: Austin TX; “
ITAR Defense Trade Controls / EAR Export Controls Seminar
; 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

* Sep 27-28: Rome, Italy; “
Defence Exports 2017
;” SMi

* 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 5-7: Singapore; ”
ICPA Singapore Conference;”
International Compliance Professionals Association;
wizard@icpainc.org 

* 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 

* Nov 9-10: Shanghai, China; ”
ICPA China Conference;”
International Compliance Professionals Association;
wizard@icpainc.org 

* Nov 13-16: Wash DC; “ITAR Defense Trade Controls / EAR Export Controls Seminar;” ECTI; jessica@learnexportcompliance.com; 540-433-3977

* 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

* Mar 11-14: San Diego CA; ”
ICPA Annual Conference;”
International Compliance Professionals Association;
wizard@icpainc.org  

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

ENEDITOR’S NOTES

EN_a115
. Bartlett’s Unfamiliar Quotations

(Source: Editor)

*
 
Karl Marx
 (5 May 1818 – 14 March 1883; was a Prussian-born philosopher, economist, sociologist, journalist, and revolutionary socialist. Marx spent much of his life in London, England, where he developed his thought in collaboration with German thinker Friedrich Engels and published various works, the most well-known being
 
Manifest der Kommunistischen Partei
 (
The Communist Manifesto) and
 
Das Kapital (Capital: Critique of Political Economy), a work in which analysed the capitalist process of production.
  – “Social progress can be measured by the social position of the female sex.”
  – “History repeats itself, first as tragedy, second as farce.”

*
 
Søren Aabye Kierkegaard
 (5 May 1813 – 11 November 1855) was a Danish philosopher, theologian, poet, social critic and religious author who is widely considered to be the first existentialist philosopher.
 
  – “Life can only be understood backwards; but it must be lived forwards.”


Friday funnies:

A jazz band is playing in a Chicago club when a gangster and his entourage come in and take a few tables. One of the hoodlums approaches the bandleader… “The boss wants you should play ‘Come Rain or Come Shine,'” he says. “And if I was you, I’d play ’em both!”  
  — Morris Schorr, Woodland Hills, CA

And instead of a blonde joke this week, we offer a lawyer joke:

A guy walks into a bar pulling a long rope. At the end of the rope there is an enormous alligator. The guy asks the bartender, “Do you serve lawyers here?” “Sure, we serve lawyers,” replies the bartender. “Good. I’ll have a beer, and the alligator will have a lawyer.”  
  — Peter Bentel, Oyster Bay Cove, 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 [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: 18 Apr 2017: 82 FR 18217-18220: Revision to an Entry on the Entity List)

  
*
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: 
19 Apr 2017: 
82 FR 18383-18393: Foreign Trade Regulations: Clarification on Filing Requirements 
  – HTS codes that are not valid for AES are available 
here.
  – The latest edition (19 Apr 2017) 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: 26 Apr 2017: Harmonized System Update 1703, containing 2,512 ABI records and 395 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.  

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EN_a317
. Weekly Highlights of the Daily Bugle Top Stories

(Source: Editor)
 

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

* 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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