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17-0703 Monday “Daily Bugle”

17-0703 Monday “Daily Bugle”

Monday, 3 July 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 
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for advertising inquiries and rates(The Daily Bugle will not be published tomorrow, 4 July, U.S. Independence Day.)

  1. Commerce/BIS Announces ETRAC Meeting, 20-21 Jul in Berkeley, CA
  2. Commerce/BIS Announces ISTAC Meeting, 26-27 Jul in Wash DC
  3. Commerce/BIS Announces MPETAC Meeting, 8 Aug in Wash DC
  4. Commerce/BIS Announces MTAC Meeting, 20 Jul in Arvada, CO
  5. Commerce/BIS Announces SITAC Meeting, 25 Jul in Wash DC
  6. Commerce/BIS Announces TransTAC Meeting, 6 Sept in Wash DC
  7. Commerce/BIS: Edwin Navarro Makasiar II of Folkston, GA, Denied Export Privileges for 10 Years
  8. Commerce/BIS: Jose Abraham Benavides-Cira of Big Spring, TX, Denied Export Privileges for 5 Years
  9. Commerce/BIS: Manuel Morales of Phoenix, AZ, Denied Export Privileges for 10 Years
  10. Commerce/BIS Renews Mahan Airways of Teheran, Iran, and Others Temporary Denial Order With 180 Days
  11. DHS/CBP Seeks Comments on Proposal to Extend Geographical Limits of Port of Entry of Savannah, GA
  12. U.S.-China Economic and Security Review Commission Announces Meeting, 13 and 14 Jul in Wash DC
  1. Ex/Im Items Scheduled for Publication in Future Federal Register Editions
  2. Commerce/BIS: (No new postings.)
  3. DoD/DSS Releases Revised ISL
  4. State/DDTC: (No new postings.)
  5. EU Council Releases Declaration on the Alignment of Certain Countries Concerning Restrictive Measures Against Syria
  6. EU P2P Publishes Summary of Activities
  7. EU Publishes Implementing Regulations Concerning the Classification of Certain Goods in the Combined Nomenclature
  1. ST&R Trade Report: “Legislative Update: Enforcement, Port Security, Cuba, Natural Gas, Freight Transport”
  1. Inside Counsel: “Traveling with a Laptop: What In-House Counsel Should Know”
  2. J.E. Bartlett: “More on ITAR Classification of BOMs: The Engineering BOM”
  3. M. Lester: “Three Latvian Banks Fined for Compliance Failure Relating to DPRK Sanctions”
  4. Smart Business: “How to Stay Compliant When Growing into Foreign Markets”
  5. R.C. Burns: “Jury Award for $60 Million Entered Against Transunion over SDN List Reports”
  1. Monday List of Ex/Im Job Openings: 98 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 (22 Jun 2017), FACR/OFAC (16 Jun 2017), FTR (19 Apr 2017), HTSUS (28 Jun 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 Announces ETRAC Meeting, 20-21 Jul in Berkeley, CA
(Source: Federal Register) [Excerpts.]
 
82 FR 30829-30830: Emerging Technology and Research Advisory Committee; Notice of Partially Closed Meeting
 
The Emerging Technology and Research Advisory Committee (ETRAC) will meet on 20 and 21 July 2017, 8:30 a.m. (Pacific Daylight Time), at the University of California, Berkeley, Toll Room, Alumni Hall, Berkeley, CA 94720. The Committee advises the Office of the Assistant Secretary for Export Administration on emerging technology and research activities, including those related to deemed exports. …
  Discussion of matters determined to be exempt from the provisions relating to public meetings found in 5 U.S.C., App. 2, 10(a)(1) and 10(a)(3).
  The open sessions will be accessible via teleconference to 25 participants on a first come, first serve basis. To join the conference, submit inquiries to Ms. Yvette Springer at Yvette.Springer@bis.doc.gov no later than 13 July 2017.
  A limited number of seats will be available for the public session. Reservations are not accepted. To the extent that time permits, members of the public may present oral statements to the Committee. The public may submit written statements at any time before or after the meeting. However, to facilitate the distribution of public presentation materials to the Committee members, the Committee suggests that presenters forward the public presentation materials prior to the meeting to Ms. Springer via email. …
  For more information, call Yvette Springer at (202) 482-2813.
 
Yvette Springer, Committee Liaison Officer.

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EXIM_a22.
Commerce/BIS Announces ISTAC Meeting, 26-27 Jul in Wash DC
(Source: Federal Register) [Excerpts.]
 
82 FR 30831: Information Systems Technical Advisory Committee; Notice of Partially Closed Meeting
 
The Information Systems Technical Advisory Committee (ISTAC) will meet on 26 and 27 July 2017, 9:00 a.m., in the Herbert C. Hoover Building, Room 3884, 14th Street between Constitution and Pennsylvania Avenues NW., Washington, DC. The Committee advises the Office of the Assistant Secretary for Export Administration on technical questions that affect the level of export controls applicable to information systems equipment and technology. …
  Discussion of Matters Determined to be Exempt From the Provisions Relating to Public Meetings Found in 5 U.S.C. App. 2, 10(a)(1) and 10(a)(3).
  The open session will be accessible via teleconference to 20 participants on a first come, first serve basis. To join the conference, submit inquiries to Ms. Yvette Springer at
Yvette.Springer@bis.doc.gov, no later than 19 July 2017.
  A limited number of seats will be available for the public session. Reservations are not accepted. To the extent time permits, members of the public may present oral statements to the Committee. The public may submit written statements at any time before or after the meeting. However, to facilitate distribution of public presentation materials to Committee members, the Committee suggests that public presentation materials or comments be forwarded before the meeting to Ms. Springer. …
  For more information, call Yvette Springer at (202) 482-2813.
 
Yvette Springer, Committee Liaison Officer.

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EXIM_a33. Commerce/BIS Announces MPETAC Meeting, 8 Aug in Wash DC

(Source: Federal Register) [Excerpts.]
 
82 FR 30822-30823: Materials Processing Equipment Technical Advisory Committee; Notice of Partially Closed Meeting
 
The Materials Processing Equipment Technical Advisory Committee (MPETAC) will meet on 8 August 2017, 9:00 a.m., Room 3884, in the Herbert C. Hoover Building, 14th Street between Pennsylvania and Constitution Avenues NW., Washington, DC. The Committee advises the Office of the Assistant Secretary for Export Administration with respect to technical questions that affect the level of export controls applicable to materials processing equipment and related technology. …
  Discussion of matters determined to be exempt from the provisions relating to public meetings found in 5 U.S.C. app. 2 §§ 10(a)(1) and 10(a)(3).
  The open session will be accessible via teleconference to 20 participants on a first come, first serve basis. To join the conference, submit inquiries to Ms. Yvette Springer at Yvette.Springer@bis.doc.gov, no later than 1 August 2017.
A limited number of seats will be available for the public session. Reservations are not accepted. To the extent that time permits, members of the public may present oral statements to the Committee. The public may submit written statements at any time before or after the meeting. However, to facilitate the distribution of public presentation materials to the Committee members, the Committee suggests that presenters forward the public presentation materials prior to the meeting to Ms. Springer via email.
  For more information, call Yvette Springer at (202) 482-2813.
 

Yvette Springer, Committee Liaison Officer.

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EXIM_a44. Commerce/BIS Announces MTAC Meeting, 20 Jul in Arvada, CO

(Source: Federal Register) [Excerpts.]
 
82 FR 30828-30829: Notice of Partially Closed Meeting of the Materials Technical Advisory Committee
 
The Materials Technical Advisory Committee (MTAC) will meet on 20 July 2017, 10:00 a.m. (Mountain Daylight Time), at Sundyne, 14845 W. 64th Avenue, Arvada, CO 80007. The Committee advises the Office of the Assistant Secretary for Export Administration with respect to technical questions that affect the level of export controls applicable to materials and related technology. …
  Discussion of matters determined to be exempt from the provisions relating to public meetings found in 5 U.S.C. app. 2 sec. 10(a)(1) and 10(a)(3).
  The open session will be accessible via teleconference to 20 participants on a first come, first serve basis. To join the conference, submit inquiries to Ms. Yvette Springer at
Yvette.Springer@bis.doc.gov, no later than 13 July 2017.
  A limited number of seats will be available during the public session of the meeting. Reservations are not accepted. To the extent time permits, members of the public may present oral statements to the Committee. Written statements may be submitted at any time before or after the meeting. However, to facilitate distribution of public presentation materials to Committee members, the materials should be forwarded prior to the meeting to Ms. Springer via email. …
  For more information, call Yvette Springer at (202) 482-2813.
 
Yvette Springer, Committee Liaison Officer.

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EXIM_a55. Commerce/BIS Announces SITAC Meeting, 25 Jul in Wash DC

(Source: Federal Register) [Excerpts.]
 
82 FR 30822: Sensors and Instrumentation Technical Advisory Committee; Notice of Partially Closed Meeting
 
The Sensors and Instrumentation Technical Advisory Committee (SITAC) will meet on 25 July 2017, 9:30 a.m., in the Herbert C. Hoover Building, Room 3884, 14th Street between Constitution and Pennsylvania Avenues NW., Washington, DC. The Committee advises the Office of the Assistant Secretary for Export Administration on technical questions that affect the level of export controls applicable to sensors and instrumentation equipment and technology. …
  Discussion of Matters Determined to be Exempt From the Provisions Relating to Public Meetings Found in 5 U.S.C. App. 2 §§ 10(a)(1) and 10(a)(3).
  The open session will be accessible via teleconference to 20 participants on a first come, first serve basis. To join the conference, submit inquiries to Ms. Yvette Springer at
Yvette.Springer@bis.doc.gov no later than 18 July 2017.
  A limited number of seats will be available during the public session of the meeting. Reservations are not accepted. To the extent that time permits, members of the public may present oral statements to the Committee. The public may submit written statements at any time before or after the meeting. However, to facilitate distribution of public presentation materials to the Committee members, the Committee suggests that the materials be forwarded before the meeting to Ms. Springer. …
  For more information, call Yvette Springer at (202) 482-2813.
 
Yvette Springer, Committee Liaison Officer.

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EXIM_a66. Commerce/BIS Announces TransTAC Meeting, 6 Sept in Wash DC

(Source: Federal Register) [Excerpts.]
 
82 FR 30831: Notice of Partially Closed Meeting of the Transportation and Related Equipment Technical Advisory Committee
 
The Transportation and Related Equipment Technical Advisory Committee (TransTAC) will meet on 6 September 2017, 9:30 a.m., in the Herbert C. Hoover Building, Room 3884, 14th 
Street between Constitution & Pennsylvania Avenues NW., Washington, DC. The Committee advises the Office of the Assistant Secretary for Export Administration with respect to technical questions that affect the level of export controls applicable to transportation and related equipment or technology. …
  Discussion of matters determined to be exempt from the provisions relating to public meetings found in 5 U.S.C. app. 2 §§ 10(a)(1) and 10(a)(3).
  The open session will be accessible via teleconference to 20 participants on a first come, first serve basis. To join the conference, submit inquiries to Ms. Yvette Springer at Yvette.Springer@bis.doc.gov no later than 30 August 2017.
  A limited number of seats will be available during the public session of the meeting. Reservations are not accepted. To the extent time permits, members of the public may present oral statements to the Committee. The public may submit written statements at any time before or after the meeting. However, to facilitate distribution of public presentation materials to Committee members, the Committee suggests that presenters forward the public presentation materials prior to the meeting to Ms. Springer via email. …
  For more information, call Yvette Springer at (202) 482-2813.
 
Yvette Springer, Committee Liaison Officer.

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EXIM_a77. Commerce/BIS: Edwin Navarro Makasiar II of Folkston, GA, Denied Export Privileges for 10 Years

(Source: Federal Register) [Excerpts.]
 
82 FR 30831-30832: Order Denying Export Privileges

In the Matter of: Edwin Navarro Makasiar II, Inmate Number: 47704-424, D. Ray James Correctional Institution, P.O. Box 2000, Folkston, GA 31437.
  On June 30, 2015, in the U.S. District Court for the Northern District of Illinois, Edwin Navarro Makasiar II (”Makasiar”) was convicted of violating Section 38 of the Arms Export Control Act (22 U.S.C. 2778 (2012)) (”AECA”). Specifically, Makasiar was convicted of knowingly and willfully attempting to export from the United States to the Philippines defense articles designated on the United States Munitions List, namely, two Glock Model 23, .40 caliber pistols and approximately 2,500 rounds of .223 caliber and 5.56 mm ammunition, without the required U.S. Department of State licenses. Makasiar was sentenced to 60 months in prison, a $2,000 criminal fine, and a $200 assessment. …
  Based upon my review and consultations with BIS’s Office of Export Enforcement, including its Director, and the facts available to BIS, I have decided to deny Makasiar’s export privileges under the Regulations for a period of 10 years from the date of Makasiar’s conviction. I have also decided to revoke all licenses issued pursuant to the Act or Regulations in which Makasiar had an interest at the time of his conviction. …
 
  Dated: June 27, 2017.
Karen H. Nies-Vogel, Director, Office of Exporter Services.

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EXIM_a88. Commerce/BIS: Jose Abraham Benavides-Cira of Big Spring, TX, Denied Export Privileges for 5 Years

(Source: Federal Register) [Excerpts.]
 
82 FR 30832-30833: Order Denying Export Privileges
 
In the Matter of: Jose Abraham Benavides-Cira, Inmate Number: 85048-379, FCI Big Spring, 1900 Simler Avenue, Big Spring, TX 79720.
  On May 23, 2016, in the U.S. District Court for the Southern District of Texas, Jose Abraham Benavides-Cira was convicted of violating Section 38 of the Arms Export Control Act (22 U.S.C. 2778 (2012)) (”AECA”). Specifically, Jose Abraham Benavides-Cira was convicted of intentionally and knowingly conspiring and agreeing with other persons to knowingly and willfully export, and cause to be exported, from the United States to Mexico defense articles designated on the United States Munitions List, namely, 5.56 caliber rifles, without the required U.S. Department of State licenses. Jose Abraham Benavides-Cira was sentenced to 135 months in prison and a $200 assessment. …
  Based upon my review and consultations with BIS’s Office of Export Enforcement, including its Director, and the facts available to BIS, I have decided to deny Jose Abraham Benavides-Cira’s export privileges under the Regulations for a period of five years from the date of Jose Abraham Benavides-Cira’s conviction. I have also decided to revoke all licenses issued pursuant to the Act or Regulations in which Jose Abraham Benavides-Cira had an interest at the time of his conviction. …
 
  Dated: June 27, 2017.
Karen H. Nies-Vogel, Director, Office of Exporter Services.

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EXIM_a99. Commerce/BIS: Manuel Morales of Phoenix, AZ, Denied Export Privileges for 10 Years

(Source: Federal Register) [Excerpts.]
 
82 FR 30830-30831: Order Denying Export Privileges
 
In the Matter of Manuel Morales, Inmate Number: 45841-051, FCI Phoenix, 37910 N. 45th Avenue, Phoenix, AZ 85086.
  On June 1, 2016, in the U.S. District Court for the District of Arizona, Manuel Morales (”Morales”) was convicted of violating Section 38 of the Arms Export Control Act (22 U.S.C. 2778 (2012)) (”AECA”). Specifically, Morales was convicted of knowingly and intentionally combining, conspiring, confederating and agreeing with other persons, known and unknown, to export from the United States to Mexico defense articles designated on the United States Munitions List, namely, 540 rounds of 7.62 x 39 caliber ammunition and seven 7.62 x 39 caliber magazines, without the required U.S. Department of State licenses. Morales was sentenced to 50 months in prison with credit for time served, 36 months of supervised release, and a $100 special assessment. …
  Based upon my review and consultations with BIS’s Office of Export Enforcement, including its Director, and the facts available to BIS, I have decided to deny Morales’s export privileges under the Regulations for a period of 10 years from the date of Morales’s conviction. I have also decided to revoke all licenses issued pursuant to the Act or Regulations in which Morales had an interest at the time of his conviction. …
 
  Dated: June 27, 2017.

Karen H. Nies-Vogel, Director, Office of Exporter Services.

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EXIM_a1010. Commerce/BIS Renews Mahan Airways of Teheran, Iran, and Others Temporary Denial Order With 180 Days

(Source: Federal Register) [Excerpts.]
 
82 FR 30823-30828: Order Renewing Order Temporarily Denying Export Privileges
 
Mahan Airways, Mahan Tower, No. 21, Azadegan St., M.A. Jenah Exp. Way, Tehran, Iran [and others]. … 
  Pursuant to Section 766.24 of the Export Administration Regulations, 15 CFR parts 730-774 (2016) (”EAR” or the ”Regulations”), [FN/1] I hereby grant the request of the Office of Export Enforcement (”OEE”) to renew the December 30, 2016 Temporary Denial Order (the ”TDO”). The December 30, 2016 Order denied the export privileges of Mahan Airways [and others]. [FN/2] I find that renewal of the TDO is necessary in the public interest to prevent an imminent violation of the EAR. …
  This Order is effective immediately and shall remain in effect for 180 days.
 
  Dated: June 27, 2017.
Richard R. Majauskas, Acting Assistant Secretary of Commerce for Export Enforcement.
 
——–
  [FN/1] The Regulations, currently codified at 15 CFR parts 730-774 (2017), originally issued pursuant to the Export Administration Act of 1979. Since August 21, 2001, the Act has been in lapse and the President, through Executive Order 13222 of August 17, 2001 (3 CFR, 2001 Comp. 783 (2002)), which has been extended by successive Presidential Notices, the most recent being that of August 4, 2016 (81 FR 52,58748,223 (Aug. 8, 2016)), has continued the Regulations in effect under the International Emergency Economic Powers Act (50 U.S.C. 1701, et seq. (2006 & Supp. IV 2010)).
  [FN/2] See note 3 [in full notice at Source URL]. 

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EXIM_a1111. DHS/CBP Seeks Comments on Proposal to Extend Geographical Limits of Port of Entry of Savannah, GA

(Source: Federal Register) [Excerpts.]
 
82 FR 30807-30808: Extension of Port Limits of Savannah, GA
 
* AGENCY: U.S. Customs and Border Protection, Department of Homeland Security.
* ACTION: Notice of proposed rulemaking.
* SUMMARY: U.S. Customs and Border Protection (CBP) is proposing to extend the geographical limits of the port of entry of Savannah, Georgia. The proposed extension will make the boundaries more easily identifiable to the public and will allow for uniform and continuous service to the extended area of Savannah, Georgia. The proposed change is part of CBP’s continuing program to use its personnel, facilities, and resources more efficiently and to provide better service to carriers, importers, and the general public.
* DATES: Comments must be received on or before 1 September 2017. …
* SUPPLEMENTARY INFORMATION: … 
The proposed change is intended to expand the geographical boundaries of the Savannah, Georgia, port of entry, and make the boundaries more easily identifiable to the public. There are no new costs to the public associated with this rule.
  This proposed rule merely expands the limits of an existing port of entry and does not impose any new costs on the public. Accordingly, we certify that this rule would not have a significant economic impact on a substantial number of small entities. …
  If the proposed port limits for Savannah, Georgia, are adopted, CBP will amend 19 CFR 101.3(b)(1) as necessary to reflect the new port limits.
 
  Dated: June 27, 2017.
Elaine C. Duke, Deputy Secretary.

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EXIM_a1212. U.S.-China Economic and Security Review Commission Announces Meeting, 13 and 14 Jul in Wash DC

(Source: Federal Register) [Excerpts.]
 
82 FR 30944: Notice of Open Public Meeting
 
* AGENCY: U.S.-China Economic and Security Review Commission.
* ACTION: Notice of open public meeting.
* SUMMARY: Notice is hereby given of a meeting of the U.S.-China Economic and Security Review Commission to review and edit drafts of the 2017 Annual Report to Congress. The Commission is mandated by Congress to investigate, assess, and report to Congress annually on the ”the national security implications of the economic relationship between the United States and the People’s Republic of China.” Pursuant to this mandate, the Commission will hold a public meeting to review and edit drafts of the 2017 Annual Report to Congress.
* DATES: The meeting is scheduled for Thursday, 13 July 2017, from 9:00 a.m. to 5:00 p.m. and Friday, 14 July 2017, from 9:00 a.m. to 5:00 p.m.
* ADDRESSES: 444 North Capitol Street NW., Room 231, Washington, DC 20001. Public seating is limited and will be available on a ”first-come, first-served” basis. Reservations are not required to attend the meeting.
* SUPPLEMENTARY INFORMATION: … 
The Commission will consider draft report sections addressing the following topics:
  – U.S.-China Economic and Trade Relations, including: Chinese Investment in the United States.
  – U.S.-China Security Relations, including: Hotspots along China’s Maritime Periphery.
  – China and the World, including: Hong Kong.
  – China’s High Tech Development, including: China’s Pursuit of Global Dominance in Computing, Robotics, and Biotechnology; and China’s Pursuit of Advanced Weapons. …
 
  Dated: June 28, 2017.
Michael Danis, Executive Director, U.S.-China Economic and Security Review Commission.

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OGSOTHER GOVERNMENT SOURCES

OGS_a113. Ex/Im Items Scheduled for Publication in Future Federal Register Editions
(Source: Federal Register

* President; ADMINISTRATIVE ORDERS; Defense and National Security: National Defense Authorization Act for Fiscal Year 1998; Delegation of Authority (Memorandum of 29 June 2017) [Publication Date: 5 July 2017.]
* * * * * * * * * * * * * * * * * * * *

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OGS_a315.

DoD/DSS Releases Revised ISL

 
ISL 2016-02 has been revised to incorporate administrative changes regarding insider threat course designators and links to those courses. The link e-FCL has also been updated. Changes are indicated in red font. Click here for the revised Industry Security Letter (ISL).
 
Note: ISLs are issued periodically to inform cleared contractors, government contracting activities and DoD activities of developments relating to industrial security. These letters are for information and clarification of existing policy and requirements. Suggestions for ISLs are appreciated and should be submitted to the local Defense Security Service Industrial Security Field Office.
Please address specific inquiries about this ISL to DSS.

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OGS_a517
.
EU Council Releases Declaration on the Alignment of Certain Countries Concerning Restrictive Measures Against Syria

 
On 29 May 2017, the Council adopted Council Decision (CFSP) 2017/917 [FN/1]. The Council Decision extends the existing restrictive measures until 1 June 2018.
 
The Candidate Countries the former Yugoslav Republic of Macedonia*, Montenegro*, Serbia* and Albania*, and the EFTA countries Iceland, Liechtenstein and Norway, members of the European Economic Area, as well as Ukraine, the Republic of Moldova and Georgia 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.

———
  [FN/1] Published on 30 May 2017 in the Official Journal of the European Union no. L139, p. 62.
 
  * The former Yugoslav Republic of Macedonia, Montenegro, Serbia and Albania continue to be part of the Stabilisation and Association Process.

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OGS_a618
EU P2P Publishes Summary of Activities

(Source: EU P2P)
 
The EU Partner-to-Partner (EU P2P) Program has published the following summary of its activities in Romania:
 
  – 28-29 June 2017: Chisinau, Romania: Regional Workshop for Eastern Europe.

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OGS_a719
EU Publishes Implementing Regulations Concerning the Classification of Certain Goods in the Combined Nomenclature

 
Regulations
  –
Commission Implementing Regulation (EU) 2017/1166 of 26 June 2017 concerning the classification of certain goods in the Combined Nomenclature
  – Commission Implementing Regulation (EU) 2017/1167 of 26 June 2017 concerning the classification of certain goods in the Combined Nomenclature
  – Commission Implementing Regulation (EU) 2017/1168 of 26 June 2017 concerning the classification of certain goods in the Combined Nomenclature
  – Commission Implementing Regulation (EU) 2017/1169 of 26 June 2017 concerning the classification of certain goods in the Combined Nomenclature
  – Commission Implementing Regulation (EU) 2017/1170 of 26 June 2017 concerning the classification of certain goods in the Combined Nomenclature

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NWSNEWS

NWS_a120
.

ST&R Trade Report: “Legislative Update: Enforcement, Port Security, Cuba, Natural Gas, Freight Transport”

 
Trade Enforcement
. The Trade Enforcement and Trade Deficit Reduction Act (H.R. 2734, introduced May 25 by Rep. Slaughter, D-N.Y.) would direct the Department of Commerce to withdraw trade concessions like tariff reductions if a trade partner does not live up to its obligations under a free trade agreement or adds new tariff or non-tariff trade barriers. It would also require the U.S. to halt all imports from countries with which it runs a trade deficit that totals twice the value of imports as U.S. exports for six consecutive months. Trading would resume when the trade deficit becomes more balanced or the president signals an intent to renegotiate the trade agreement with that country. U.S. companies could apply for a one-year wavier to allow products to be imported if they are not available from other sources.
 
Port Security
. The Maritime Security Coordination Improvement Act (H.R. 2831, introduced June 8 by Rep. Rutherford, R-Fla.) aims to improve the port and maritime security functions of the Department of Homeland Security. This bill includes provisions on supply chain security, the Container Security Initiative, cyber security at ports, and recognition of other countries’ trusted shipper programs.
 
Cuba
. The U.S.-Cuba Normalization Act (H.R. 2966, introduced June 20 by Rep. Rush, D-Ill.) would lift the trade embargo on Cuba and extend permanent normal trade relations status to products of that country.
 
Natural
Gas. The License Natural Gas Now Act (S. 1415, introduced June 22 by Sen. Cassidy, R-La.) would terminate restrictions on the importation and exportation of natural gas and guarantee the acceptance without delay of export volume applications to the Department of Energy for natural gas imports and exports. The bill would also allow the president to limit such imports and exports during emergencies or disasters as well as exchanges with particular foreign nations.
 
Freight Transportation. The National Multimodal and Sustainable Freight Infrastructure Act (H.R. 3001, introduced June 22 by Rep. Lowenthal, D-Calif.) would establish a trust fund, funded by a national one percent waybill fee on the transportation cost of goods, that would raise about $8 billion a year for freight-related infrastructure projects across the country, with a focus on multimodal projects and projects that rebuild aging infrastructure while relieving bottlenecks in the freight transportation system. 

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COMMCOMMENTARY

COMM_a01
21. Inside Counsel: “Traveling with a Laptop: What In-House Counsel Should Know”

(Source: Inside Counsel, subscription required.) [Excerpts.]
 
Sales executives travel abroad often with company-issued or personal laptops, tablets, and handheld devices.
 
Today, sales executives are traveling abroad now more than ever. Do you know what they are taking with them? In-house counsel should be aware of the export controls associated with traveling with a laptop or mobile device.
 
Michelle Schulz and Elsa Manzanares, co-chairs of the International Trade Group with Gardere, recently sat down with Inside Counsel to discuss how U.S. companies are managing export controls on laptop travel from a practical perspective.
 
Sales executives travel abroad often with company-issued or personal laptops, tablets, and handheld devices. It is common to carry product information, presentations, and other information on these devices when making a sales pitch. For example, according to Schulz, an executive may have a proposal that includes detailed product specifications as well as information on pricing and delivery. The device itself may contain software that is controlled for export to the destination country, or it may contain encryption items.
 
Under the Export Administration Regulations (EAR) and the International Traffic in Arms Regulations (ITAR), the U.S. government controls the release of certain technology and software abroad. These releases are exports from the U.S., and may require a license. A release can occur as soon as a sales executive crosses the border of the destination country – meaning an export license may be required to travel to a country with certain technical information, software, or encryption items. …   

[Editor’s Note: Due to copyright restrictions, we are not authorized to publish the entire article. To read the remaining parts, click on the source link below the item title.]

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COMM_a2
22. J.E. Bartlett: “More on ITAR Classification of BOMs: The Engineering BOM”

 
* Author: James E. Bartlett, Principal, Law Office of James E. Bartlett III, PLLC, JEBartlett@JEBartlett.com, +1 202-802-0646; and Partner, Full Circle Compliance.
 
Many readers have responded to our Daily Bugle article, “Export Classification of a Bill of Materials (BOM) or Other List of Defense Articles,” published on 30 June 2017.  One subscriber commented (summarized):
 
I appreciate your article on Bills of Materials (BOMs).  I would like to clarify that BOMs come in more than one form.  Your article from last Friday described BOMs that are simple lists of parts with descriptions and prices.  But many BOMs (we call them Engineering BOMs or E-BOMs) are more than just a list of parts.  These E-BOMs come in a multi-level format and show an assembly.  Most ERP systems have E-BOMs.  These are mostly for lead time assessment.  Our company received a reply from DDTC stating that these Engineering BOMs are technical data, as defined in ITAR § 120.10(a)(1). 
 
Question
: Can the order of the BOM parts list and a multi-level nature, set up like a tree to illustrate assembly, change the BOM from EAR99 to ITAR-controlled technical data?
 
Answer
: Yes. Although a simple list of defense articles or parts of a defense articles is not technical data, an “E-BOM” that shows how to assemble the parts would be technical data:
 
ITAR 120.10(a): “Technical data means, for purposes of this subchapter: (1) Information, other than software as defined in § 120.10(a)(4), which is required for the design, development, production, manufacture, assembly, operation, repair, testing, maintenance, or modification of defense articles. This includes information in the form of blueprints, drawings, photographs, plans, instructions, or documentation.” [Emphasis added.]
 
Bugle readers:  If you have a DDTC reply to your Commodity Jurisdiction or Advisory Opinion request which illustrates the classification of other varieties of BOMs, and you would like to share it with other Daily Bugle readers, send it to us for publication.  (We will protect your identity at your request.)

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

COMM_a3
23. M. Lester: “Three Latvian Banks Fined for Compliance Failure Relating to DPRK Sanctions”

 
* Author: Maya Lester, Esq., Brick Court Chambers, maya.lester@brickcourt.co.uk, +44 20 7379 3550.
 
Latvia’s banking regulator has fined 3 Latvian banks, Regionala Investiciju Banka, Privatbank, and Baltikums Bank, for failing to prevent their clients from using them to circumvent sanctions on DPRK.  The investigation was conducted in collaboration with the US Treasury and the FBI.
 
The Latvian Financial and Capital Market Commission, said in a statement that “several customers of the banks, making use of offshore companies and complicated chain transactions, transferred funds from their bank accounts to circumvent international sanctions requirements against North Korea”. Privatbank and Baltikums bank were both fined €35,575 for having weaknesses in their customer due diligence and transaction monitoring systems, Regionala was fined €570,364 and warnings were issued to its compliance team for weaknesses in its compliance systems and failing to ensure they were functioning correctly.

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

COMM_a4
24. Smart Business: “How to Stay Compliant When Growing into Foreign Markets”

(Source: Smart Business) [Excerpts.]
 
When it comes to doing business in another country, U.S. companies are confronted with an increasingly complex legal and regulatory landscape. As a result, it is critical for international businesses to find ways to ensure compliance as efficiently as possible. An important, but often overlooked, aspect is selecting and managing local counsel for the most cost-effective compliance result possible.
 
  “Foreign jurisdictions – China is a good example – have legal systems that are becoming much more sophisticated,” says Walter R. “Bob” Bashaw II, Managing Shareholder and Director at Sherrard,
German & Kelly, P.C. “The muscles of these legal systems are exercising themselves more every day. That creates a need for companies to build effective compliance programs that are capable of supporting both their U.S. and overseas businesses.”
 
Smart Business spoke with Bashaw about common mistakes made by companies as they pursue growth in foreign markets, and how to structure compliance departments capable of staying on top U.S. and foreign regulatory requirements. …
 
[Editor’s Note: Due to copyright restrictions, we are not authorized to publish the entire article. To read the remaining parts, click on the source link below the item title.]

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

COMM_a5
25R.C. Burns: “Jury Award for $60 Million Entered Against Transunion over SDN List Reports”

(Source:
Export Law Blog
. Reprinted by permission.)
 
* Author: R. Clifton Burns, Esq., Bryan Cave LLP, Wash DC,
Clif.Burns@bryancave.com
, 202-508-6067).
 
On 20 June, a federal jury
awarded
a $60 million damage verdict against mammoth credit reporting agency Transunion arising from the company’s misuse of the Office of Foreign Assets Control’s List of Specially Designated Nationals and Blocked Persons (the “SDN List”) on credit reports. The plaintiffs in that case were individuals who were not on the SDN List, but whom Transunion identified as such, resulting in adverse credit decisions for these individuals.
 
The class action lawsuit was based on a number of related violations of the federal Fair Credit Reporting Act and a similar California statute. Among the violations at issue were the provisions of
section 1681(e)
which requires credit bureaus to “follow reasonable procedures to assure maximum possible accuracy of the information concerning the individual about whom the report relates.” The Third Circuit in Cortez v. Trans Union, 617 F.3d 688 (3d Cir. 2010)
, previously rejected Transunion’s efforts in that case to make the implausible argument that the SDN List information it supplied with respect to credit applicants was not part of their credit report.
 
In the current case, the
complaint
details the experience of one of the representative plaintiffs with Transunion’s OFAC reporting. That plaintiff, Sergio L. Ramirez, had a car loan denied because his name was similar to two entries on the SDN List, namely, Sergio Humberto Ramirez Aguirre and Sergio Alberto Cedulo Ramirez Rivera. Not only were the names different, but also the birthdate for Plaintiff Ramirez, which Transunion had in its file on the plaintiff, was different from the birthdates listed in the entries for the two aforementioned SDNs.
 
OFAC has issued
guidance
about the use of the SDN List by credit bureaus:
 
The text on the report should explain that the individual’s information is similar to the information of an individual on OFAC’s SDN list. It should not state that the information matches or that the credit applicant is in fact the individual on the SDN list unless the credit bureau has already verified that the person is indeed the SDN.
 
Even assuming that Transunion followed this guidance, which is not clear, it seems hard to justify transmitting the information to the car dealership when Transunion had information that clearly indicated the credit applicant was not either of the SDNs. It seems to me that credit bureaus can easily protect themselves from outcomes like the $60 million verdict by transmitting SDN information with a disclaimer but doing so only in cases where the credit bureau does not itself have information, such as birthdates, places of birth, etc., sufficient to resolve the potential hit.

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

MSEX/IM MOVERS & SHAKERS

MS_a126. Monday List of Ex/Im Job Openings: 98 Jobs Posted

(Source: Editor)  
 
Published every Monday or first business day of the week. Please send openings in the following format to jobs@fullcirclecompliance.eu.
 
* COMPANY; LOCATION; POSITION TITLE (WEBLINK); CONTACT INFORMATION; REQUISITION ID
 
#” New listing this week:
 
* Abcam; Cambridge, United Kingdom;
Trade Compliance Coordinator; Requisition ID: CAM-012-996
* Acteon Group Ltd.; Norwich, Suffolk, or London, UK;
Head of Compliance; or email
Mike Pay
* Advanced Micro Devices (AMD); Austin TX; 
Import/Export Compliance Manager
; Requisition ID: 24061


Akin Gump Strauss Hauer & Feld LLP; Washington DC; 
International Trade and Customs Specialist
; 
staffrecruiter@akingump.com
; Requisition ID: 147

* Amazon; Mexico City, Mexico; Mexico Trade Compliance Program Manager; Requisition ID: 520481

* Amazon; Mexico City, Mexico;
Senior Manager, Mexico Trade Compliance
; Requisition ID: 520460

* 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

* Ansell; Iselin NJ;
Senior Specialist NA Trade Compliance; Requisition ID: IRC6513
* Applied Materials; Alzenau, Germany;
Europe Trade Manager
; Requisition ID: (M3)-1701376

* Arthrex; Naples FL;
Senior Compliance Officer;

* ASML; Veldhoven, the Netherlands;
Senior Manager Trade & Customs;
Requisition ID: RC05619
* Babcock; Portsmouth, United Kingdom; 
Divisional Trade & Compliance Manager

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

* Boeing; Sydney, Australia, and other locations;
Global Trade Control Manager; Requisition ID: 1700006067

* Boeing; Amsterdam, The Netherlands, and Brussels, Belgium;


Trade Control Specialist
; Requisition ID: 1700006121

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

* Cobham Advanced Electronic Solutions; Exeter, NH, Plainview, NY, Eatontown, NJ, or Lansdale, PA;
Export Compliance Manager
; Charles Trokey
Charles.trokey@yoh.com

* CSRA Inc.; Falls Church VA;
Global Trade & Compliance Principal
; Alan Strober 571-375-4890; Requisition ID: 17002RN
*
Cubic Corporation; San Diego, CA; 
Senior Export Compliance Analyst

Requisition ID: 5982


* 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

* DRS Technologies; Dayton, OH;
Senior Trade Compliance Manager

* Eaton; Titchfield, United Kingdom;
Global Trade Manager (Trade Compliance); Requisition ID: 020681

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

* Esterline CMC Electronics; Montreal, Quebec, Canada;
Senior Manager Trade Compliance; Requisition ID: 9971BR

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

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

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

* Fluke; Everett WA; 
Trade Compliance Manager
; Requisition ID: FLU005544


* General Atomics Aeronautical Systems, Inc.; San Diego CA; 


International Trade Compliance Analyst (ITC) / Export Import Specialist / Global Trade Administrator
; Requisition ID: 12252BR

*
General Dynamics Land Systems; Sterling Heights, MI; Site Lead/Compliance OfficerRequisition ID: 
SHC-LC-17-19647


General Dynamics Land Systems; Sterling Heights, MI; Compliance Officer

SHC-LC-17-19648

* George Washington University; Washington DC;
Research Compliance Officer, Export Control
; Requisition ID: PI97906765

* Givaudan; Bogor, Indonesia;
Compliance Manager
; Requisition ID: 68063
* Harris Corporation; Clifton NJ; 
Trade Compliance Analyst
;  
lsolomon@harris.com
; Requisition ID: ES20172404-18675

*
 Huntington Ingalls Industries, Newport News Shipbuilding Division; Newport News, VA; International Trade Compliance Analyst 3; Requisition ID:  18350BR
# Indiana Mills & Manufacturing, Inc.; Westfield, IN; International Trade Compliance Manager

* KPMG; Antwerp, Brussels;
Manager Global Trade & Customs – SAP GTS
; 122756BR

* 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
*
Livingston International; Western Region (TX, CA, OR, WA preferred)
;

Trade Ad
visory
Consu
ltant

*
Livingston International; Western Region (TX, CA, OR, WA preferred);
Research Consultant

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

* L-3 Technologies, Platform Integration Division; Waco TX;
 
Import/Export Compliance Administrator 3
; Requisition ID 
089343

* Lockheed Martin; Orlando FL;
International Trade Compliance Sr Staff / ITAR / EAR / Export Control Officer
; Requisition ID: 387435BR

* ManTech International; Herndon VA; 
Director of Corporate Export Control
;
Jenna.Brady@ManTech.com
; Requisition ID: 90965BR

* Mars – Wrigley; Chicago IL; 
Global Trade Compliance Analyst (Corporate Export)
;
Ryan.Martin@effem.com
; Requisition ID: 69452

* Maxim Integrated; Dallas TX;
Manager, Global Trade
; 3304BR

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

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

* Meggitt PLC; Maidenhead, UK;
Trade Compliance Officer 
# Momentive Performance Materials, Inc.; Waterfield, NY;
Manager, Global Trade Compliance

* North Dakota State University; Fargo ND;
Director for Research Integrity Compliance; Requisition ID: 1700372

* Northrop Grumman; Falls Church VA; 
International Trade Compliance Analyst 3/4
; Patricia Vives, 
patricia.vives@ngc.com
; Requisition ID: 17011893

* Northrop Grumman Corporation; Herndon VA;
International Trade Compliance Analyst 2
; Requisition ID: 17010105

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

* Northrop Grumman Corporation; Linthicum MD;
International Trade Compliance Analyst 1
; 17003433
* Northrop Grumman Corporation; Linthicum MD;
International Trade Compliance Analyst 3
; 17005262

* Northrop Grumman Sperry Marine; New Malden, UK;
Trade Compliance Coordinator
;
careers.uk@sperry.ngc.com

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

* Plexus Corporation; Neenah Wi;
Manager – Export Compliance
; Requisition ID: 14645BR
* Plexus Corporation; Neenah Wi;
Manager – Import Compliance
; Requisition ID: 14593BR
* Premier Farnell Organisation; Leeds, UK;
Trade Compliance Specialist – Europe
; Requisition ID: 4301
* Raytheon; (El Segundo CA, McKinney TX, Dallas TX, Marlborough MA, or Washington D.C.);
Senior Manager of Global Trade Management
; Requisition ID: 98724BR

# Raytheon; Rosslyn, VA; 
Export Trade Compliance Specialist; Requisition ID: 97978BR

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

* Saab Defense and Security USA LLC; Syracuse NY;
Senior Import/Export Analyst
; Requisition ID: USA_00413

* Science and Engineering Services, LLC; Huntsville AL;
Export Compliance Specialist
bob.davis@ses-i.com; Requisition ID: 157

* SIRE: Noord-Brabant province, the Netherlands;
Trade Compliance Expert; Requisition ID: 33934

* 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; Breda, the Netherlands;
Import/Export Specialist – EMEA CMD Commercial Offices
; Requisition ID: 44930BR

* UBC; Monheim, Germany;
Manager Customs and Trade Compliance 
* Ultra Electronics; Greater London, United Kingdom;
International Trade and Export Compliance Specialist

* United Technologies Corporation, UTC Aerospace Systems; Brea CA;
Sr. Anlst, Intl Trade Compl
; Requisition ID: 46798BR


* United Technologies Corporation, UTC Aerospace Systems; Burnsville MN;


ITC Tech Manager- SIS
; Requisition ID:38565BR

* United Technologies Corporation, UTC Aerospace Systems; Chula Vista CA;
International Trade Compliance Analyst
; Requisition ID: 46876BR


*
United Technologies Corporation, UTC Aerospace Systems; Rockford IL;
Specialist, International Trade Compliance- Operations and Licensing
; Requisition ID: 50118BR

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

# University of North Carolina; Chapel Hill, NC; Export Control Officer

* VAG; Mannheim, Germany;
Trade Compliance Manager (m/w)
; Contact: Mr. Florian Uhl, +49 621 749 – 1870

Vertiv (formerly Emerson Network Power); Columbus, OH,  
International Trade Management (ITM) Senior Specialist
; Req #1700001087

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

* Xilinx, Inc.; San Jose, CA, US;
Global Trade Compliance Program Manager; Requisition ID: 153811

* XPO Logistics; Greenwich CT;
Global Trade Compliance Analyst

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

ENEDITOR’S NOTES


Hermann Hesse
(2 July 1877 – 9 August 1962) was a German-born Swiss poet, novelist, and painter.  His best-known works include 
Demian
,
Steppenwolf
Siddhartha
, and 
The 
Glass 
Bead 
Game
, each of which explores an individual’s search for authenticity, self-knowledge and spirituality. In 1946, he received the Nobel Prize in Literature.)

  – “Some of us think holding on makes us strong; but sometimes it is letting go.”
  – “Whatever good or bad fortune may come our way, we can always give it meaning and transform it into something of value.”
 
* Franz Kafka (3 Jul 1883 – 3 Jun 1924, borne in Prague, today part of the Czech Republic, was a novelist and short story writer. His best-known works include “Die Verwandlung” (“The Metamorphosis“), Der Process (“The Trial”), and Das Schloss (“The Castle”). The term Kafkaesque has entered the English language to describe situations like those in his writing.)
  – “God gives the nuts, but he does not crack them.”
 
Monday is Pun Day

* A green grape and a purple grape were in a kitchen. The green grape turned to the purple grape and said, “Breathe!”
* A prisoner’s favorite punctuation mark is the period. It marks the end of his sentence.

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

EN_a328
. 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: 30 Jun 2017:
82 FR 29714-29719
: Modernization of the Customs Brokers Examination [Effective Date: 31 July 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 cancelled Supp. 1 to the NISPOM  (Summary here.)

* EXPORT ADMINISTRATION REGULATIONS (EAR): 15 CFR Subtit. B, Ch. VII, Pts. 730-774 
  – Last Amendment: 30 Jun 2017: 92 FR 29714: Control Policy: End-User and End-Use Based [Removal of Indira Mirchandani from Entity List.] 

  
*
FOREIGN ASSETS CONTROL REGULATIONS (OFAC FACR)
: 31 CFR, Parts 500-599, Embargoes, Sanctions, Executive Orders
  – Last Amendment: 16 Jun 2017: 82 FR 27613-27614: Removal of Burmese Sanctions Regulations 
 
*
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: 28 Jun 2017: Harmonized System Update 1704, containing 2,564 ABI records and 463 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.
  – Last Amendment: 11 Jan 2017: 82 FR 3168-3170: 2017 Civil Monetary Penalties Inflationary Adjustment
  – The only available fully updated copy (latest edition: 10 Jun 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 800 footnotes containing amendment histories, 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.

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

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

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

EPEDITORIAL POLICY

* The Ex/Im Daily Update is a publication of FCC Advisory B.V., compiled by: Editor, James E. Bartlett III; Assistant Editors, Alexander P. Bosch and Vincent J.A. Goossen; and Events & Jobs Editor, John Bartlett. The Ex/Im Daily Update is 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 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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