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17-0526 Friday “Daily Bugle”

17-0526 Friday “Daily Bugle”

Friday, 26 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 Contact us for advertising inquiries and rates(The Daily Bugle will not be published on Monday, 29 May, a U.S. Federal holiday.)

  1. Commerce/BIS Amends EAR, Adds Sixteen Persons to, and Modifies Two Entries on the Entity List 
  2. HHS/FDA Seeks Comments Concerning Import Trade Auxiliary Communication System
  3. State/DDTC Seeks Comments on Form DS-7786, Request for Advisory Opinion 
  4. State Posts Determines and Certifies that Five Countries Are Not Fully Cooperating with U.S. Antiterrorism Efforts 
  5. DHS/CBP Posts Quarterly IRS Interest Rates Used in Calculating Interest on Overdue Accounts and Refunds on Customs Duties 
  1. Ex/Im Items Scheduled for Publication in Future Federal Register Editions 
  2. Commerce/BIS: (No new postings.) 
  3. DHS/CBP Posts Notice Concerning PGA Correction Transaction (CA) P00 Error
  4. State/DDTC: (No new postings.)
  1. Reuters: “U.S. Lawmakers to Fight Massive Trump Saudi Arms Deal”
  2. ST&R Trade Report: “Dates and Deadlines: AD Rules, Food Safety, Customs Enforcement, and Steel Imports”
  1. A.T. Thrall: “The Saudi Deal Shows Just How Broken the U.S. Arms Export Process Has Become”
  2. D.M. Edelman: “What Is the New U.S.-China Trade Deal and How Will It Affect Exporters?”
  3. J. Ku: “Why Is the U.S. More Likely to Sanction Chinese Companies for Supporting Iran than for Supporting North Korea?”
  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 (26 May 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

1. Commerce/BIS Amends EAR, Adds Sixteen Persons to, and Modifies Two Entries on the Entity List

(Source: Federal Register) [Excerpts.]
 
82 FR 24242-24248: Addition of Certain Persons and Revisions to Entries on the Entity List
* AGENCY: Bureau of Industry and Security, Commerce.
* ACTION: Final rule. …
* DATES: This rule is effective May 26, 2017.
* FOR FURTHER INFORMATION CONTACT: Chair, End-User Review Committee, Office of the Assistant Secretary, Export Administration, Bureau of Industry and Security, Department of Commerce, Phone: (202) 482-5991, Email: ERC@bis.doc.gov.
* SUPPLEMENTARY INFORMATION: …
  This rule implements the decision of the ERC to add sixteen persons to the Entity List. These sixteen persons are being added on the basis of Sec. 744.11 (License requirements that apply to entities acting contrary to the national security or foreign policy interests of the United States) of the EAR. The sixteen entries added to the Entity List consist of eleven entries located in Pakistan, three entries in Turkey and two entries in the United Arab Emirates (UAE). …
  Of the eleven entries that are being added to the Entity List under the destination of Pakistan, the ERC determined that nine of the entities–MSN International, Creative Dynamics Engineering, FACO Trading, Interscan, Micado, Premier International, Sumico Technologies, Oriental Engineers and Imam Group–are government, parastatal and private entities involved in activities that are contrary to the national security and/or foreign policy interests of the United States. The ERC determined that for one entity, KMA International Import and Export Co., information is available indicating that the company is acting and procuring items on behalf of Abdul Qader Khan Research Laboratories (AQKRL). AQKRL was added to the Entity list on November 19, 1998 (63 FR 64322).
  One of the Pakistani entities, Makkays Hi-Tech Systems, is being added to the Entity List, along with two persons under the destination of the UAE, Euromoto Middle East FZE and its owner, Talaat Mehmood. The ERC determined that Makkays Hi-Tech Systems directed Euromoto Middle East FZE and Talaat Mehmood to supply U.S.-origin items, without obtaining the necessary licenses, to Pakistan’s Advanced Engineering Research Organization (AERO). AERO was added to the Entity List on September 18, 2014 (79 FR 5999), based on its involvement in the procurement of sensitive U.S. technology in support of Pakistan’s development of its missile and strategic unmanned aerial vehicle (UAV) programs.
  This final rule also adds three persons located in the destination of Turkey–ERA Metalurji San. Ve Tic. Ltd. Sti., Mehmet Cingi and Cenk Ozturk–to the Entity List. These persons are being added on the basis of their involvement in the reexportation of U.S.-origin metal alloy powders with aerospace, missile and nuclear applications to Iran without the required license, in violation of both the EAR and the Department of the Treasury’s Iranian Transactions and Sanctions Regulations (ITSR). …
    For the sixteen persons added to the Entity List, BIS imposes a license requirement for all items subject to the EAR, and a license review policy of presumption of denial. The license requirements apply to any transaction in which items are to be exported, reexported, or transferred (in-country) to any of the persons or in which such persons act as purchaser, intermediate consignee, ultimate consignee, or end-user. In addition, no license exceptions are available for exports, reexports, or transfers (in-country) to the persons being added to the Entity List in this rule. The acronym “a.k.a.” (also known as) is used in entries on the Entity List to identify aliases and help exporters, reexporters and transferors to better identify persons on the Entity List. …
  This final rule implements a decision of the ERC to modify two existing entries on the Entity List under the destinations of China and Hong Kong. The modifications include the addition of the name Xianfa Lin to two existing entries and the identification of the previously listed name (Alpha Lam) in these entries as an alias. This final rule does not make any other changes to these two entries, except for revising the Federal Register citation column to reflect this modification. The license requirement for these two existing entries remains for all items subject to the EAR and the license review policy remains a presumption of denial. …
 
  Dated: May 22, 2017.
Matthew S. Borman, Deputy Assistant Secretary for Export Administration.

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EXIM_a2

2. HHS/FDA Seeks Comments Concerning Import Trade Auxiliary Communication System

(Source: Federal Register) [Excerpts.]
 
82 FR 24357: Agency Information Collection Activities; Submission for Office of Management and Budget Review; Comment Request; Import Trade Auxiliary Communication System
* AGENCY: Food and Drug Administration, HHS.
* ACTION: Notice. …
* DATES: Fax written comments on the collection of information by June 26, 2017. …
* FOR FURTHER INFORMATION CONTACT: JonnaLynn Capezzuto, Office of Operations, Food and Drug Administration, Three White Flint North, 10A63, 11601 Landsdown St., North Bethesda, MD 20852, 301-796-3794.
* SUPPLEMENTARY INFORMATION: …
  The Import Trade Auxiliary Communication System (ITACS) currently provides the import trade community with four functions: The ability to check the status of FDA-regulated entries and lines, the ability to submit entry documentation electronically, the ability to electronically submit the location of goods for those lines targeted for FDA physical examination, and the ability to check estimated laboratory analysis completion dates. No user login accounts are currently necessary to access these functions; all that is necessary is a valid customs entry number that has been successfully transmitted to FDA.
  FDA has developed ITACS user account management functionality. Implementation of this functionality would allow members of the import trade community to create and manage secure user accounts in ITACS, which would enable FDA to distribute Notices of FDA Action to users electronically via email (rather than regular mail), enable users to download Notices of FDA Action from within ITACS, and allow users to view in ITACS the details of specific information requests which are currently delivered via hard copy Notices of FDA Action. ITACS user account management functionality would also allow for potential future ITACS enhancements, requested by the import trade community, that require user authentication.
  To create a secure user account for ITACS via the user account management function, a person would have to enter basic information such as the person’s name, their employer’s name, a contact email address, an account password, etc., into ITACS via the user account management function interface.
  In the Federal Register of August 26, 2016 (81 FR 58942), FDA published a 60-day notice requesting public comment on the proposed collection of information. FDA received one comment. …
 
  Dated: May 18, 2017.
Anna K. Abram, Deputy Commissioner for Policy, Planning, Legislation, and Analysis.

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

EXIM_a3

3. State/DDTC Seeks Comments on Form DS-7786, Request for Advisory Opinion

(Source: Federal Register) [Excerpts.]
 
82 FR 24425-24427: 30-Day Notice of Proposed Information Collection: Request for Advisory Opinion
* ACTION: Notice of request for public comment and submission to OMB of proposed collection of information.
* DATES: Submit comments directly to the Office of Management and Budget (OMB) up to June 26, 2017.
* FOR FURTHER INFORMATION CONTACT: Please visit DDTC’s Web site to view a copy of the proposed form and instructions. Contact Danielle Canfield at CanfieldDP@state.gov for further information regarding this notice or if you are unable to access the proposed form and instructions on the DDTC internet site.
* SUPPLEMENTARY INFORMATION:
  – Title of information collection: Request for Advisory
Opinion.
  – OMB control number: 1405-0174. …
  – Originating office: T/PM/DDTC.
  – Form number: DS-7786. …
  – Abstract: The Directorate of Defense Trade Controls (DDTC), located in the Political-Military Affairs Bureau of the Department of State, has the principal mission of licensing the export, temporary import, and brokering of defense articles or defense services as enumerated in the United States Munitions List (USML), and to ensure that the sale, transfer, or brokering of such items are in the interest of United States national security and foreign policy.
  Sections 126.9 (Advisory opinions and related authorizations) and 129.9 (Guidance) of the International Traffic in Arms Regulations (ITAR, 22 CFR parts 120-130) may be used by entities and individuals involved in the manufacture, export, temporary import, and brokering, of defense articles and defense services to request an advisory opinion as to whether DDTC would be likely to grant a license or other approval for the export of a particular defense article or defense service to a particular country (126.9(a)); for an interpretation of regulatory requirements (126.9(c)); whether certain activity constitutes brokering under the ITAR (129.9(a)); or for other guidance pertaining to brokering (129.9(c)). DDTC has recently acquired an electronic case management system to update its business processes and how it receives and handles information from industry. This system, once deployed, will allow users to electronically submit requests for advisory opinions to DDTC; users will be able to retrieve responses using the same system. DDTC staff members have defined the data fields which are most relevant and necessary for requests for advisory opinions and developed the means to accept this information from the industry in a secure system. The revision of this information collection is meant to conform the current OMB-approved data collection to DDTC’s new case management system. DDTC is, therefore, requesting industry comments on the new advisory opinion form, which will be mirrored in the case management system, once deployed. A copy of the draft form may be requested from DDTC using the contact information in the FOR FURTHER INFORMATION CONTACT section above. A copy of the draft form will also be placed for review on the DDTC Web site. …
 
  Dated: May 22, 2017.
Anthony M. Dearth, Managing Director, Acting Directorate of Defense Trade Controls, Department of State.

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

EXIM_a4

4. State Certifies that Five Countries Are Not Fully Cooperating with U.S. Antiterrorism Efforts

(Source: Federal Register) [Excerpts.]
 
82 FR 24424: Determination and Certification Under Section 40A of the Arms Export Control Act
  Pursuant to section 40A of the Arms Export Control Act (22 U.S.C. 2781), and Executive Order 13637, as amended, I hereby determine and certify to the Congress that the following countries are not cooperating fully with United States antiterrorism efforts:
 
  – Eritrea
  – Iran
  – Democratic People’s Republic of Korea (DPRK, or North Korea)
  – Syria
  – Venezuela 
 
  Dated: May 1, 2017.
Rex Tillerson, Secretary of State.

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EXIM_a5

5. DHS/CBP Posts Quarterly IRS Interest Rates Used in Calculating Interest on Overdue Accounts and Refunds on Customs Duties

(Source: Federal Register) [Excerpts.]
 
82 FR 24370-24371: Quarterly IRS Interest Rates Used in Calculating Interest on Overdue Accounts and Refunds on Customs Duties
* AGENCY: U.S. Customs and Border Protection, Department of Homeland Security.
* ACTION: General notice.
* SUMMARY: This notice advises the public that the quarterly Internal Revenue Service interest rates used to calculate interest on overdue accounts (underpayments) and refunds (overpayments) of customs duties will remain the same from the previous quarter. For the calendar quarter beginning April 1, 2017, the interest rates for overpayments will be 3 percent for corporations and 4 percent for non-corporations, and the interest rate for underpayments will be 4 percent for both corporations and non-corporations. This notice is published for the convenience of the importing public and U.S. Customs and Border Protection personnel.
* DATES: Effective Date: April 1, 2017.
* FOR FURTHER INFORMATION CONTACT: Shandy Plicka, Revenue Division, Collection and Refunds Branch, 6650 Telecom Drive, Suite #100, Indianapolis, Indiana 46278; telephone (317) 298-1717.
* SUPPLEMENTARY INFORMATION: …
  For the convenience of the importing public and U.S. Customs and Border Protection personnel the following list of IRS interest rates used, covering the period from before July of 1974 to date, to calculate interest on overdue accounts and refunds of customs duties, is published in summary format. …
 
  Dated: May 16, 2017.
Sean M. Mildrew, Acting Chief Financial Officer, Office of Finance.

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OGSOTHER GOVERNMENT SOURCES

OGS_a16
. Ex/Im Items Scheduled for Publication in Future Federal Register Editions
 

(Source:
Federal Register)
 
* U.S. Customs and Border Protection; NOTICES; Requests for Nominations: U.S. Customs and Border Protection User Fee Advisory Committee [Publication Date: 30 May 2017.]  

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

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(Source:
CSMS# 17-000306, 25 May 2017.)
 
Some PGA correction CA) transactions are failing starting today, May 25, 2017. The rejection is
 
P00 PGA DATA MISSING PER PGA FLAG
 
CBP expects to have a fix implemented for this on Tuesday morning, May 30.
 
There are 2 different processes trade can follow while this is resolved.
 
  (1) If the ACE Cargo Release entry is not both ARRIVED and RELEASED, filer can make the correction and submit an ACE Cargo Release (SE) Replace (or the ACE Entry Summary Replace [AE] with ACE Cargo Release). Depending on the entry arrival and release status, the entry may be subject to correction review and approval by CBP at the entry port.
  (2) If the ACE Cargo Release has been both ARRIVED and RELEASED, the only option is to file a new entry with all the corrected data, and request cancellation of the current entry.
 
The issue seems to be limited to corrections that involve FDA data as at least one of the PGA flags on the tariffs on the entry.
 
CBP regrets the inconvenience. Another CSMS will be issued when this is resolved. If you have any questions, contact your assigned CBP client representative.
* * * * * * * * * * * * * * * * * * * *

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NWSNEWS

 
U.S. lawmakers introduced legislation on Thursday seeking to stop at least a portion of President Donald Trump’s sale of weapons to Saudi Arabia.
 
Republican Rand Paul and Democrats Chris Murphy and Al Franken introduced a resolution of disapproval in the Senate to force a vote on whether to block part of the sale.
 
The Senate Foreign Relations Committee received formal notice of the pending sale on May 19.
 
The Arms Export Control Act of 1976 allows a senator to force a vote on an arms sale, once Congress is formally notified of plans to go ahead. The same three senators introduced a similar resolution last year seeking to block the sale of $1.15 billion of tanks and other equipment to Saudi Arabia. That measure was defeated overwhelmingly.
 
Saudi Arabia was the first stop on Trump’s first international trip this week, and he marked the visit by announcing the arms deal in Riyadh on May 20. Saudi Arabia agreed to by $110 billion of U.S. arms, with options running as high as $350 billion over 10 years.
 
The lawmakers aim to block about $500 million of the sale, the portion including precision-guided munitions and other offensive weapons.
 
  “Given Saudi Arabia’s past support of terror, poor human rights record, and questionable tactics in its war in Yemen, Congress must carefully consider and thoroughly debate if selling them billions of dollars of arms is in our best national security interest at this time,” Paul said in a statement.
 
Members of the U.S. House of Representatives also took action on the planned sale on Thursday. Republican Representative Ted Yoho and Democrat Ted Lieu wrote to the chairman of the House Foreign Affairs Committee asking for a hearing to review the sale of precision-guided munitions to Riyadh.
 
Democratic President Barack Obama’s administration suspended the planned sale of precision-guided munitions in December because of concerns over the Saudi-led military campaign in Yemen and civilian casualties.
 
But Trump has said he wants to encourage international weapons sales as a way to create jobs in the United States.
* * * * * * * * * * * * * * * * * * * *

 
Following are highlights of regulatory effective dates and deadlines and federal agency meetings coming up in the next week. …
 
  – 30 May: deadline for comments to CBP on information collections on duty-free entry, FTZ certification
  – 30 May: deadline for comments to USDA on information collections on imports of fruit and pork
  – 30 May: deadline for comments to FTZ Board on revised production authority at carbon fiber facility
  – 30 May: first compliance deadline under FDA foreign supplier verification program rule
  – 31 May: deadline for comments to BIS on national security review of steel imports
  – 31 May: deadline for requests for AD/CV administrative reviews
  – 31 May: deadline for comments on CBP information collections on Haiti, temporary exports, in-bond cargo
  – 2 Jun: deadline for comments to CBP on proposed revocation or modification of rulings
* * * * * * * * * * * * * * * * * * * *

COMMCOMMENTARY

COMM_a212
. A.T. Thrall: “The Saudi Deal Shows Just How Broken the U.S. Arms Export Process Has Become”

 
* Author: A. Trevor Thrall, Senior Fellow Cato Institute and associate professor in the Schar School of Policy and Government at George Mason University, tthrall@cato.org, 202-216-1480.
 
A system meant to keep weapons sales from undermining U.S. national security has become a sham.
 
The Trump administration made headlines last week
when it announced a $110 billion arms deal with Saudi Arabia, signed with pomp and circumstance during the president’s first international trip. But even though Donald Trump’s team was thrilled, this record-setting deal is in fact another sign that the American arms sales process is broken.
 
At the most fundamental level, the process by which the executive branch determines the security implications of arms sales has become a sham. The process, led by the Pentagon and dictated by the Arms Export Control Act, is designed to ensure that every arms deal furthers U.S. national security and does not amplify conflicts, instability, or human rights abuses elsewhere. But increasingly since the end of the Cold War, and especially since 9/11, U.S. arms sales have upset regional balances of power, provided our adversaries with weapons, enabled violence, and contributed to ongoing human rights abuses.
 
In the case of Saudi Arabia, even a cursory geostrategic review should have led the Pentagon to advise against Trump’s deal. Most obviously, the deal will provide Saudi Arabia with advanced weapons to use in its war in Yemen, where it has been accused of deliberately bombing civilian areas and committing other war crimes, helping to create what the United Nations calls the “largest humanitarian crisis” in the world. Beyond that, any major weapons sale to the Middle East – already in turmoil and driven by civil and sectarian conflict – risks further destabilizing the region. This deal may encourage the Kingdom to favor military solutions to its problems, will almost certainly heighten tensions with Israel, and poses a real risk of igniting an arms race with Iran. These are precisely the conditions that the Arms Export Control Act identifies as reasons to reject arms sales requests. 
 
Unfortunately, the Saudi deal is simply one instance in a long historical pattern of failures to realistically assess the risks. As a result, many such deals have created serious downstream problems. Under President George W. Bush, for example, the United States transferred vast quantities of infantry weapons to Iraq, most of which went missing and many of which wound up in the hands of the Islamic State. President Obama’s plan to train and equip Syrian rebels not only failed to produce meaningful results but similarly ended up with the Islamic State getting its hands on those weapons too. And even before the Saudi deal, the Trump administration announced plans to sell attack aircraft to Nigeria and machine guns to Tunisia, despite the chaotic conditions in both countries and the obvious potential for those weapons to be misused by governments with terrible human-rights records. This track record makes it difficult to believe that the Pentagon conducts any serious review of these deals whatsoever. 
 
In theory, the Arms Export Control Act gives Congress the power to restrain an imprudent executive branch from making bad arms deals. In reality, however, lawmakers have rarely proven willing or able to stop even the most dangerous sales. To his credit, Sen. Rand Paul, R-Kentucky, will soon offer legislation in an attempt to block the Saudi deal, and others like Sen. Chris Murphy, D-Connecticut, have blasted it publicly. But history suggests that their efforts will be fruitless. Last November, a resolution by Sens. Murphy; Paul; Mike Lee, R-Utah; and Al Franken, D-Minn., to block the sale of Abrams tanks to Saudi Arabia was defeated, 71-27. The last time Congress actually stopped a sale of any kind, in fact, was in the early 1990s.
 
Today we have a White House obsessed with making deals, a Pentagon that doesn’t provide wise counsel to its political masters, and a Congress that has abdicated responsibility for checking the executive branch. Leaders in Washington must recommit themselves to a more honest and realistic process for assessing the implications of Trump’s arms deals. America’s interest in global security far outweighs its interest in making a few billion dollars.  

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COMM_a313
. D.M. Edelman: “What Is the New U.S.-China Trade Deal and How Will It Affect Exporters?”

        
* Author: Doreen M. Edelman, Esq., Baker Donelson LLP, 202-508-3460, dedelman@bakerdonelson.com
 
On May 12, Wilbur Ross, the U.S. Commerce Secretary, announced that the U.S. and China have reached a new trade deal with four components that are supposed to boost U.S. exports and close America’s trade gap with China. The questions at hand are 1) what does this trade deal mean? and 2) how will this help U.S. exporters?
 
  (1) China Lifts Ban on U.S. Beef Imports. Since 2003, China has banned U.S. beef imports because of the outbreak of mad cow disease. Lifting this ban will open a $2.5 billion market to American beef exporters giving them more access to the growing Chinese middle class. After 13 years of being locked out of the Chinese market, American beef exporters will now have access to China’s 1.4 billion consumers.
 
  (2) U.S. Allows Importation of Chinese Cooked Chicken. The U.S. has agreed to allow Chinese imports of cooked chicken. This trade deal is only focused on cooked chicken rather than raw chicken because of China’s reputation for failed food-safety inspections: the U.S. wants to make sure that the Chinese demonstrate equivalence to U.S. safety inspections. This new trade deal did not address the 2015 Chinese ban of chicken imports from the U.S. after an outbreak of the avian flu in the Midwest, allowing for the blockage of U.S. chicken exports to China.
 
  (3) Chinese Import of Liquefied Natural Gas. The U.S. has invited the Chinese to import U.S.-produced liquefied natural gas. The Chinese need natural gas in order to reduce their dependence on coal and combat the country’s extensive air pollution. The Energy Department has authorized shipments of natural gas from the U.S. of 19.2 billion cubic feet per day to China. Although this expansion could lead to higher prices for U.S. consumers, this component of the new trade deal would provide a major market for American exporters. Helium is a highly sought after liquefied natural gas. China uses helium in its development of the nuclear fusion process, which is a way to produce natural resources and harness energy.
 
  (4) U.S. Biotechnology & Credit Cards. The U.S. has agreed to allow the Chinese access to the U.S. banking market if the Chinese comply with normal U.S. rules. Under this new trade deal, Chinese financial institutions, some of the largest in the world, will be treated the same way as other foreign banks doing business in the U.S.
 
The Trump Administration claims that this deal will be critical in advancing and boosting U.S. exports and states that any concrete progress is better than no progress at all. Critics say that this deal is not significant because these changes have been long promised by the Chinese and there is not anything in this deal to suggest China is going to become more open to U.S. manufactured exports. Either way, this trade deal will affect American exporters, it is just unclear how great the
impact will be.

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COMM_a4
14. J. Ku: “Why Is the U.S. More Likely to Sanction Chinese Companies for Supporting Iran than for Supporting North Korea?”

(Source: Lawfare Blog)
 
* Author: Julian Ku, Maurice A. Deane Distinguished Professor of Constitutional Law, Hofstra University School of Law, Julian.G.Ku@hofstra.edu, 516-463-4237.
 
Lost amid the fallout of President Trump’s firing of FBI Director James Comey last week was the U.S. Treasury Department’s announcement of new sanctions on individuals and companies found to be supporting Iran’s missile program.  Four of the seven new sanctions targets are Chinese. This matters because although this is the second time since President Trump has taken office that the U.S. has sanctioned Chinese nationals for supporting Iran’s weapons programs, his administration has not yet imposed any sanctions on Chinese nationals and companies for supporting North Korea. Though treating China lightly on North Korea sanctions is consistent with the approach of the Bush and Obama administrations, it makes little legal or strategic sense today.  After all, it was North Korea, and not Iran, that tested another potentially dangerous and threatening missile yesterday.
 
According to Treasury, Ruan Runling, a Chinese national, and three Chinese companies associated with Ruan sold over $17 million worth of navigation-applicable technology and guidance systems to Iranian companies controlled by Iran’s Ministry of Defense for the production of missile guidance technology for the Iranian military.  As of the date of the order last week, Ruan and his affiliated companies are “blocked,” which means that “all property and interests in property” they might have that are in the United States is now frozen and cannot be transferred or withdrawn. Furthermore, all transactions between these targets and U.S. persons (including foreign companies resident in the United States) are now prohibited. 
 
The main legal basis for these sanctions is the International Emergency Economic Powers Act  (IEEPA), 50 U.S.C. 1701 et seq., which delegates broad powers to the President to impose sanctions on individuals he deems threats to the national security of the United States.  Iran’s various weapons programs have long been deemed to constitute such a threat under Executive Order 13382, issued by President Bush in 2005. 
 
But individuals and companies supporting North Korea’s weapons programs are also subjected to sanctions under the same statute and several executive orders. Indeed, U.S. sanctions against North Korea are, if anything, broader than those currently imposed against Iran.  Not only do they apply to any individual or entity that directly or indirectly assisted North Korea’s weapons programs in ways similar to the Iran sanctions, but U.S. sanctions on North Korea also apply to anyone who has sold luxury goods or supported illegal financial transactions like money laundering, or indirectly or directly supported the North Korean government or its ruling party. 
 
The key question for U.S. sanctions on North Korea is how they will be applied to foreign nationals, since the U.S. essentially imposes an embargo on all transactions between the U.S. and North Korea and the U.S. has never done any serious trade with North Korea since before the Korean War.  As everyone is well aware, Chinese individuals and companies are the key source of outside economic support for North Korea. 
 
Yet as Politico recently reported, sanctions on Chinese companies supporting North Korea’s missile programs or the North Korean government’s money laundering schemes are rare.  Last September, the U.S. sanctioned Dandong Hongxiang, a Chinese company, for supporting North Korea’s weapons programs and money laundering operations. But although the U.S. seized 25 bank accounts belonging to Dandong, it did not sanction the Chinese banks that held the accounts and facilitated the payments to North Korean front companies.
 
According to former U.S. government officials, the U.S. has spent years compiling a long list of Chinese individuals and companies whom it can immediately sanction for violating its North Korea sanctions.  The argument against imposing these sanctions is that doing so will undermine Chinese cooperation in pressuring North Korea.  But even if that cooperation from China was effective (and the evidence is thin so far), any sanctions would target individual Chinese companies and individuals. It does not sanction the Chinese government in any way, nor does it impose an embargo on trade akin to U.S. trade with Cuba.  It would simply sanction Chinese companies and individuals for doing what the Chinese government claims they should not be doing anyway: supporting North Korea’s weapons programs.
 
To be sure, imposing sanctions will not solve the North Korea problem.  But imposing sanctions is a more tangible and sustainable action to show U.S. resolve on North Korea than making empty threats of military action.  If imposed on Chinese financial institutions, it could also put serious new pressure on China’s leadership and economy.  At the very least, it might show China that the U.S. government cares as much about North Korea’s weapons program as it does about Iran’s.  That would be a good start.

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TEEX/IM TRAINING EVENTS & CONFERENCES

TE_a215
. 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:


* Jun 1: Webinar; ”
Hot Topics in Export Controls and Sanctions Investigations;” Miller & Chevalier;
events@milchev.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


J
un 6: Eindhoven, the Netherlands; “
Training Export Control
;” evofenedex

* Jun 6: Webinar; “
Managing Supply Chain Risks
;” Volkov Law Group

* Jun 7: London UK; “
Control List Classification – Combined Dual Use and Military
;” UK/BIS Export Control Organisation;
denise.carter@bis.gsi.gov.uk


Jun 7 & 14: Webinar; “
EAR Technology Classifications: Learning By Doing
;” ECTI; 540-433-3977

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

* 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: The Hague; “
Trade Controls: Current Challenges and Critical Issues from a US and EU Perspective
;” Netherlands International Chamber of Commerce

* 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

# Jun 21: Webinar; ”
Trade Preferences: One Goal, Different Approaches;” Sandler, Travis & Rosenberg, P.A.;
webinarorganizers@strtrade.com

Jun 22: Sydney, Australia; “
ITAR, EAR and AU Export Controls Training
;” Defence Connect

# Jun 26: London, UK; ”
Smart Practice in Trade Security;” Trade Security Journal

# Jul 5: Cambridge UK; ”
Beginners Workshop;” UK Department for International Trade;
denise.carter@trade.gsi.gov.uk 

# Jul 5: Cambridge UK; ”
Licenses Workshop;” UK Department for International Trade;
denise.carter@trade.gsi.gov.uk 

* 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 City 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 2-4: Wash D.C.; “Annual Import/Export Conference;” National Shooting Sports Foundation

* 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 4: Glasgow, UK; ”
Intermediate Seminar;” UK Department for International Trade;
denise.carter@trade.gsi.gov.uk 

# Sep 5: Glasgow, UK; ”
Beginners Workshop;” UK Department for International Trade;
denise.carter@trade.gsi.gov.uk 

# Sep 5: Glasgow, UK; ”
Licenses Workshop;” UK Department for International Trade;
denise.carter@trade.gsi.gov.uk 

# Sep 5: Glasgow, UK; ”
Control List Classification – Combined Dual Use and Military;” UK Department for International Trade;
denise.carter@trade.gsi.gov.uk 

* 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: Oxford, UK; ”
Intermediate Seminar;” UK Department for International Trade;
denise.carter@trade.gsi.gov.uk 

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

# Sep 28: Oxford, UK; ”
Beginners Workshop;” UK Department for International Trade;
denise.carter@trade.gsi.gov.uk 

# Sep 28: Oxford, UK; ”
Licenses Workshop;” UK Department for International Trade;
denise.carter@trade.gsi.gov.uk 

* 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

# Nov 15: Leeds, UK; ”
Intermediate Seminar;” UK Department for International Trade;
denise.carter@trade.gsi.gov.uk

# Nov 16: Leeds, UK; ”
Beginners Workshop;” UK Department for International Trade;
denise.carter@trade.gsi.gov.uk

# Nov 16: Leeds, UK; ”
Licenses Workshop;” UK Department for International Trade;
denise.carter@trade.gsi.gov.uk

# Nov 16: Leeds, UK; ”
Control List Classification – Combined Dual Use and Military;” UK Department for International Trade;
denise.carter@trade.gsi.gov.uk

* Nov 16: Nijkerk, the Netherlands; ”
Training Export Control;” evofenedex

* Dec 4-7: Miami FL; “
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_a116
. Bartlett’s Unfamiliar Quotations

(Source: Editor)

Cornelius Vanderbilt (27 May 1794 – 4 Jan 1877, was an American business magnate and philanthropist who built his wealth in railroads and shipping. He is best known for building the New York Central Railroad. As one of the richest Americans in history and wealthiest figures overall, Vanderbilt was the patriarch of a wealthy, influential family. He provided the initial gift to found Vanderbilt University in Nashville, Tennessee.) 
  – “You have undertaken to cheat me. I won’t sue you, for the law is too slow. I’ll ruin you.”
 
* Lady Mary Wortley Montagu (
born Mary Pierrepont, 
26 May 1689 – 21 Aug 1762, was an English aristocrat, letter writer, and poet. Lady Mary is today chiefly remembered for her letters, particularly her letters from travels to the Ottoman Empire, as wife to the British ambassador to Turkey, which have been described as “the first example of a secular work by a woman about the Muslim Orient.”
  – “No modest man ever did or ever will make a fortune.”
 
Friday funnies:
 
A car comes screeching into the driveway and a woman gets out and runs into the house shouting to her husband, “I just won the lottery. Start packing!” Her husband says, “Great news! Should I pack for the beach or the mountains?” She says, “It doesn’t matter. Just get out!” 
  — Eric Rosengren, Circle Pines, MN

Friday’s Fun Facts:
(Source: Laura Lyons. Laura.Lyons@efi.com)

What was life like in America 100 years ago?  Here are some facts for the Year 1917:

  – The average life expectancy for men was 47 years.
  – Fuel for automobiles was sold in drug stores.
  – Only 14 percent of the homes had a bathtub.
  – Only 8 percent of the homes had a telephone.
  – The maximum speed limit for motor vehicles in most cities was 10 mph.
  – The tallest structure in the world was the Eiffel Tower.
  – The average US wage in 1910 was 22 cents per hour.
  – The average US worker made between $200 and $400 per year.
  – A competent accountant could expect to earn $2000 per year, a dentist $2,500 per year, a veterinarian between $1,500 and $4,000 per year, and  a mechanical engineer about $5,000 per year.
  – More than 95 percent of all births took place at home.
  – 90% physicians had no college education.  Instead, they attended so-called medical schools, many of which were condemned in the press and by the government as “substandard.”
  – Sugar cost four cents a pound, eggs were fourteen cents a dozen, and coffee was fifteen cents a pound.
  – Most women only washed their hair once a month, and, used Borax or egg yolks for shampoo.
  – Canada passed a law that prohibited poor people from entering into their country for any reason.
  – The five leading causes of death in the US were:
    (1) Pneumonia and influenza
    (2) Tuberculosis
    (3) Diarrhea
    (4) Heart disease
    (5) Stroke
  – The population of Las Vegas, Nevada, was only 30 residents.
  – There was neither a Mother’s Day nor a Father’s Day.
  – Two out of every 10 adults couldn’t read or write.
  – Only 6 percent of all Americans had graduated from high school.
  – Marijuana, heroin, and morphine were all available over the counter at local corner drugstores.  Some pharmacists advertised, “Heroin clears the complexion, gives buoyancy to the mind, regulates the stomach, bowels, and is a guardian of health!”
  – 18% of households had at least one full-time servant or domestic help.
  – There were about 230 reported murders in the entire United States. 

Is it possible to imagine what life here may be like in another 100 years? 

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

EN_a217. 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: 26 May 2017: 82 FR 24242-24248: Addition of Certain Persons and Revisions to Entries 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.  

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

EN_a318
. 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.

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

EPEDITORIAL POLICY

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

* RIGHTS & RESTRICTIONS: This email contains no proprietary, classified, or export-controlled information. All items are obtained from public sources or are published with permission of private contributors, and may be freely circulated without further permission. Any further use of contributors’ material, however, must comply with applicable copyright laws.

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

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

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