17-0808 Tuesday “Daily Bugle”

17-0808 Tuesday “Daily Bugle”

Tuesday, 8 August 2017

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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  1. DHS/CBP Seeks Comments on Form 26, Report of Diversion 
  1. Ex/Im Items Scheduled for Publication in Future Federal Register Editions
  2. Commerce/BIS: (No new postings.)
  3. State/DDTC: (No new postings.)
  1. ST&R Trade Report: “Tougher Trade Policy Measures Urged by Senate Democrats”
  1. A. Marchand & O. Coulon: “EU Commission and Member States to Fight Any Extraterritorial Application of the New U.S. Sanctions”
  2. M. Volkov: “New Sanctions Law Complicates Trade Compliance”
  3. R. Pellafone: “How to Implement the DOJ’s Evaluation of Corporate Compliance Programs”
  4. Gary Stanley’s ECR Tip of the Day
  1. Bartlett’s Unfamiliar Quotations 
  2. Are Your Copies of Regulations Up to Date? Latest Changes: ATF (15 Jan 2016), Customs (28 Jul 2017), DOD/NISPOM (18 May 2016), EAR (7 Jul 2017), FACR/OFAC (16 Jun 2017), FTR (19 Apr 2017), HTSUS (25 Jul 2017), ITAR (11 Jan 2017) 
  3. Weekly Highlights of the Daily Bugle Top Stories 


1. DHS/CBP Seeks Comments on Form 26, Report of Diversion

(Source: Federal Register) [Excerpts.]
82 FR 37105-37106: Agency Information Collection Activities: Report of Diversion
* AGENCY: U.S. Customs and Border Protection (CBP), Department of Homeland Security.
* ACTION: 60-Day notice and request for comments; extension of an existing collection of information. …
* FOR FURTHER INFORMATION CONTACT: Requests for additional PRA information should be directed to CBP Paperwork Reduction Act Officer, U.S. Customs and Border Protection, Office of Trade, Regulations and Rulings, Economic Impact Analysis Branch, 90 K Street NE., 10th Floor, Washington, DC 20229-1177, or via email CBP_PRA@cbp.dhs.gov. Please note that the contact information provided here is solely for questions regarding this notice. Individuals seeking information about other CBP programs should contact the CBP National Customer Service Center at 877-227-5511, (TTY) 1-800-877-8339, or CBP Web site.
  – Title: Report of Diversion.
  – OMB Number: 1651-0025.
  – Form Number: CBP Form 26. …
  – Type of Review: Extension (without change).
  – Abstract: CBP Form 26, Report of Diversion, is used to track vessels traveling coastwise from U.S. ports to other U.S. ports when a change occurs in scheduled itineraries. This form is initiated by the vessel owner or agent to notify and request approval by CBP for a vessel to divert while traveling coastwise from a U.S. port to another U.S. port, or a vessel traveling to a foreign port having to divert to a U.S. port when a change occurs in the vessel itinerary. CBP Form 26 collects information such as the name and nationality of the vessel, the expected port and date of arrival, and information about any related penalty cases, if applicable. This information collection is authorized by 46 U.S.C. 60105 and is provided for in 19 CFR 4.91. CBP Form 26 is accessible here. …
  Dated: August 3, 2017.
Seth Renkema, Branch Chief, Economic Impact Analysis Branch, U.S. Customs and Border Protection.  

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OGS_a12. Ex/Im Items Scheduled for Publication in Future Federal Register Editions
(Source: Federal Register

* Treasury; Foreign Assets Control Office; NOTICES; Blocking or Unblocking of Persons and Properties [Publication Date: 9 August 2017.]

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A new initiative by Senate Democrats seeks to “fundamentally transform [U.S.] trade policies by giving American workers and small businesses the tools to combat those countries that try to cheat on trade and a stronger voice in negotiating trade agreements.” Press sources characterize the plan as an effort to reclaim momentum on this issue, which played a major role in last year’s presidential election, but point out that it contains few new ideas and in many cases aligns closely with objectives advanced by President Trump. Democrats say they plan to introduce legislation this fall to start implementing the plan, which focuses on the following provisions.
Circumvent the WTO
. The plan would establish a new independent trade prosecutor who would challenge unfair trade practices outside of the World Trade Organization or free trade agreement mechanisms. These processes take many years to resolve problems, the plan states, and WTO decisions in particular have eroded a number of U.S. trade enforcement tools.
The trade prosecutor would be housed at a new office in the International Trade Commission and would thus be able to address “more trade cheating than USTR is currently able to” (e.g., subsidies, forced technology transfers, cyber espionage, intellectual property theft, import restrictions) under strict timelines and independent from U.S. foreign policy goals and WTO constraints. If foreign countries are found to be in violation and do not agree to eliminate offending policies they would face retaliation in the form of U.S. market access restrictions in proportion with a U.S. company’s losses or the foreign company’s unfair advantage.                                            
Review Foreign Acquisitions
. The plan would establish a new council of independent economic experts that would have the authority to consider major investments, mergers, and acquisitions by foreign entities and to stop such deals if they would create significant market distortion or have other detrimental economic impacts, including intellectual property leakage, loss of market share in critical industries, and U.S. job losses. The council’s consideration would focus on entities that either have ties to or are directly controlled by certain governments or state actors that do not abide by market principles or have a history of intellectual property theft. The plan explains that countries like China and Russia are using state-owned enterprises to acquire U.S. companies in an effort to “siphon trade secrets and technology to directly compete with other U.S. firms.”
Renegotiate NAFTA
. The plan seeks to ensure that NAFTA is renegotiated “in the open with workers at the table” (by revamping the trade advisory committee structure and providing regular updates to the public), includes enforceable labor and environmental standards that are “much stronger than those in any past trade agreement,” provides greater and more secure market access for U.S. exports, and creates new economic opportunities in services and digital trade. The plan blames NAFTA’s “unenforceable labor and environment standards” for the offshoring of U.S. jobs and declining U.S. wages, asserts that the agreement benefits primarily large corporations, and claims that Mexico and Canada “have been cheating without repercussions” because NAFTA does not address practices such as currency manipulation and unfair government subsidy programs.
Penalize Outsourcing
. “Many companies that receive federal grants or loans are outsourcing customer service functions, like call centers that handle sensitive U.S. consumer information, to countries that have poor data security protections,” the plan states. The plan would penalize such contractors by requiring federal agencies to consider a company’s record of outsourcing for three years prior to application for federal contracts and establishing a negative preference of up to 10 percent of the cost of a contract for that company for outsourcing activity. The plan would also create “a public ‘shame’ list” of U.S. companies that regularly relocate U.S. jobs overseas and establish a negative preference for issuing certain federal grants and loans for companies on that list.
Further, the plan would (a) deny current tax deductions for the cost of moving U.S. production and jobs outside the U.S., (b) create a tax credit of up to 20 percent for the cost of relocating production and jobs to the U.S., (c) require companies that outsource jobs to forfeit up to five years’ worth of tax benefits, and (d) require companies that move their headquarters overseas to pay their full U.S. tax bills on all profits they hold overseas before such a move.
Expand Buy-America Requirements
. The plan laments the failure of the WTO Government Procurement Agreement to open foreign markets, stating that “many of our trade partners have much stronger programs and protections favoring their domestic companies.” In response, the plan would (1) require taxpayer dollars to be spent on U.S. companies and U.S. jobs for all federal public works and infrastructure projects, (b) limit the amount of manufactured products in transportation and water infrastructure projects that can be foreign-made, (c) limit the amount of foreign production in military contracts, (d) require up-to-date reporting on the use of Buy America waivers for foreign firms, (e) maintain the existing “melted and poured” standard for iron and steel, with no exceptions, and (f) restrict the use of Buy America waivers for products from non-market economies.
Address Currency Manipulation
. The plan would clarify that countervailing duty law can address currency undervaluation, require the Department of Commerce to investigate currency undervaluation as a subsidy if a U.S. industry requests it, and allow duties to be assessed against countries that manipulate their currencies equal to the effect of that manipulation.
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. A. Marchand & O. Coulon: “EU Commission and Member States to Fight Any Extraterritorial Application of the New U.S. Sanctions”

* Author: Aurore Marchand, Esq., Aurore.Marchand@loyensloeff.com; and Olivier Coulon, Esq., Olivier.Coulon@loyensloeff.com. Both of Loyens & Loeff, Luxembourg and Brussels, respectively.
On 2 August 2017, following days of political discussion and speculation, President Trump signed into law the “Countering America’s Adversaries Through Sanctions Act” (CAATS), imposing new sanctions on Russia, Iran and North Korea. While the question of the nature of these new sanctions has been addressed in a previous post (available here), a specific topic – of particular interest and importance for EU entities – remains to be tackled: that of the extra-territorial application of these sanctions.
Following the adoption of the bill by the House of Representative on 25 July 2017, several EU countries, together with the EU Commission, had expressed their concern about the impact of the sanctions, in particular on the European energy sector.
Indeed, Section 232 of the CAATS allows for the imposition of sanctions on a person who knowingly invests in, sells, leases or provides to Russia, for the construction of Russian energy export pipelines, goods, services, technology, information, or support. The sanctions, listed in Section 235 of the CAATS, range from a prohibition on access to financing by U.S. institutions, and a vote against such financing by international institutions, to a prohibition on foreign exchange and banking transactions, asset freezes and visa bans.
This broad wording of the CAATS provides for the possibility to regulate the activities of EU entities, despite the absence of personal or territorial connecting factors with the U.S. This potential extra-territorial application of the U.S. sanctions may therefore affect EU companies dealing with the infrastructures transporting energy resources to Europe, such as the Nord Stream 2 gas pipeline (from Russia to Germany) or the Baltic Liquefied Natural Gas plant project.
The addition of the specific wording “in coordination with allies of the United States”, as a potential opt-out, in Section 232 appears to have appeased – for now – EU concerns, although Jean-Claude Juncker, President of the EU Commission, reserved in a statement issued on 2 August 2017 “the right to take adequate measures” should European interests not be taken into account in the implementation of the sanctions, adding that the EU is prepared and intends to defend its economic interests vis-à-vis the U.S.
Should the diplomacy card not have the desired result, other options remain available to the EU. First, the EU could file a claim before the WTO Dispute Settlement Body, as Russia threatened to do in 2014 following the adoption of the U.S. Ukraine-related sanctions. Secondly, the EU Council could adopt a “Blocking Statute”, preventing the application of the U.S.’ measures, recognition and enforcement of the U.S.’ decisions within the EU, and providing for a recovery mechanism should damages be imposed on EU entities.
Both options were already used by the EU, since the adoption of extra-territorial sanctions by the U.S. is indeed not without precedent: in 1996 the U.S. sanctioned Cuba, Syria and Libya through the adoption of the Helms-Burton and d’Amato-Kennedy Acts, leading to a WTO claim in relation to the Helms-Burton Act and to the adoption of Council Regulation (EC) n°2271/96 of 22 November 1996 protecting against the effects of the extra-territorial application of legislation adopted by a third country, and actions based thereon or resulting therefrom, to address both the Helms-Burton and d’Amato-Kennedy provisions.
At this stage, it remains to be seen how the U.S. will implement and enforce their new set of sanctions. It seems clear, however, that the EU, as well as its Member States, are prepared to take active measures to prevent any adverse impact on EU interests.

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7. M. Volkov: “New Sanctions Law Complicates Trade Compliance”

(Source: Volkov Law Group Blog. Reprinted by permission.)
* Author: Michael Volkov, Esq., Volkov Law Group, mvolkov@volkovlaw.com, 240-505-1992.
Politics and sanctions law go hand-in-hand. In a rare instance of bi-partisanship, Congress united to constrain the administration’s ability to modify the existing sanctions program against Russia. At the same time, Congress expanded the sanctions regime for Russia, Iran and North Korea. The administration was forced to sign the bill given the overwhelming vote in favor of the measure.
As a result, compliance practitioners have to review and update their trade compliance programs.
The new law, Countering America’s Adversaries Through Sanctions Act (“CAATSA” or “Act”) includes a number of provisions restraining the administration’s ability to relax sanctions against Russia. For global business, however, the new law expands “sectoral” sanctions against Russian banks and oil and gas companies, and creates new “secondary sanctions” applicable to non-US persons who conduct certain transactions with Russia. It remains to be seen how much of the law is actually implemented by the Department of Treasury’s Office of Foreign Asset Control (“OFAC”).
The Act codifies all the existing Executive Orders relating to the Russia sanctions program, and sets out an elaborate Congressional procedure to review any proposed changes in existing Russia sanctions. Under the new procedures, the administration must submit a proposed change to Congress and Congress must act to reject the change. The procedures, however, does not apply to general licenses for specific transactions that would not harm the United States’ foreign policy interests.
The Act directs OFAC to expand existing Russia sectoral sanctions. Specifically, the Act requires OFAC to revise Directives 1 and 2 of the sectoral sanctions program to prohibit US persons’ involvement in new financing for designated Russian banks, and oil and gas companies. The Act expands coverage to new financing of 14 days or more (from 30 days) for banks, and 60 days or more (from 90 days) for oil and gas companies.
The impact of these changes is likely to be significant. The prohibition applies to payment terms of any invoice for goods or services involving these specified countries. As a result, companies may have to receive payment for goods or services within 14 and 60 days, respectively, from certain banks and oil and gas companies.
The Act also directs OFAC to expand Directive 4, which bars US persons from providing goods, technology and non-financial services for exploration and production by certain targeted Russian oil and gas companies involved in Russian deepwater, arctic offshore and shale oil and gas operations. Specifically, OFAC is required to expand Directive 4 to cover all deepwater, arctic offshore and shale oil and gas fields anywhere in the world beyond offshore Russia under current law, applicable to any company in which a prohibited Russian company has an ownership interest of 33 percent or more.
Finally, the Act also creates new secondary sanctions authorizing OFAC to penalize non-US persons engaged in certain sensitive activities even if the company has no connection to the United States. The sensitive activities include transactions relating to: (i) oil and gas export pipelines; (ii) privatization of state-owned Russian assets; and (iii) persons involved in defense or intelligence services in Russia.   It is unclear if OFAC will exercise its authority under this new provision.
The provisions relating to the Iran sanctions program do not significantly alter the existing program. Most of the provisions overlap with existing sanctions measures and require the administration to report to Congress on a variety of topics. However, in one area relating to human rights abuses, the Act targets Iranian government officials and others engaged in gross violation of human rights against Iranians. The Act also retains the exclusion of humanitarian transactions, including the sale of agricultural commodities, and medicines and medical devices to Iran.
North Korea
The Act amends a 2016 law to expand US sanctions against North Korea and expands prohibited activities to include: (i) purchasing certain metals and minerals from North Korea, or selling to North Korea of rocket, aviation or jet fuel; (ii) promoting the operation of vessels and aircraft, and the insurance of such vessel and aircraft; and (iii) maintaining a correspondent banking account for a North Korean financial institution.
The Act prohibits vessels over 300 gross tons from entering US waters if the vessel is operated by the North Korean government, by a North Korean person, or by a country not complying with UN sanctions against North Korea. The Department of Homeland Security is required to publish within 180 days a list of all prohibited vessels.

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8. R. Pellafone: “How to Implement the DOJ’s Evaluation of Corporate Compliance Programs”

* Author: Ricardo Pellafone, Founder/Creative Director, Broadcat, Contact here.
  “This is interesting, but what am I supposed to do with, like, a million questions?”
    — you, after reading the DOJ’s Evaluation of Corporate Compliance Programs.
Don’t worry. You’re not alone.
In fact, if that’s what you’re thinking: take heart. At least you’re in the 50% that has actually attempted to read it.
To be clear, this is the document that the DOJ put out to explain how they tend to evaluate compliance programs. So it’s fair to say you should read it and figure out how to implement it-before you’re sitting across from a prosecutor.
The “implementation” part, however, is admittedly tough. That’s because the 100+ questions are organized by concept, reflecting how the DOJ thinks-not how you would use it.  And making the jump from “how the DOJ thinks” to “how we’ll use this” is a mammoth task.
We know, because we made a roadmap that does exactly that.
You can cut to the chase and download that here, or you can read on to learn how we broke it down-so you can take a similar approach when you have to translate something from one context to another (like when giving compliance training).
Frame things around how they’ll be used.
If you want something to be useful, you need to frame it around the context in which it’ll be used.
Otherwise you’re asking someone to (1) understand it (2) translate it into their own context and then (3) apply it. Most people give up after #1-because #2 is really hard.
(This is why most compliance training fails, by the way; it’s not an “engagement” problem. It’s because it’s framed around risks instead of business process, and it’s too much work for people to figure out how a bunch of abstract legal concepts apply to what they actually do-while also actually doing their real jobs. We did a deep dive on that topic at last year’s Compliance and Ethics Institute in Chicago; if you missed it, you can grab a writeup of the presentation here.)
In this case, the context we want is basically “project planning.” So to put it into your context, you need to understand and reframe the content along how you do project planning.

And project planning is a lot of “who/when/how” stuff, because that’s how you parcel out the work and create schedules for getting it done. So we went through every question in the DOJ’s document and coded it based on:
  – When you’d ask each question,
  – Who you’d probably task with answering it, and
  – How often you’d be likely to update your response.
Next, we went through the coded questions-repeatedly-to see how we could sort them into categories based on how they were coded. That’s because at this point we had 100+ data points, and we needed to organize them in some way to make using them more achievable.
And we found that we could sort them into three big practical categories, which we called “Governance and Structure,” “Program Operations,” and “Incident Response.”
Each category reflects a consistent approach to when you’ll answer its questions, who will answer them, and how often you’ll need to check in for an update.
And that’s how we organized the final version; it uses the DOJ’s original questions-they’re just sorted by how you’ll actually answer them.
That’s the high-level process for reframing something complicated:
  (1) figure out how it’ll be used;
  (2) “code” the pieces of it based on how they’d be used; and
  (3) identify patterns that let you sort those pieces into new categories to simplify the result.
Example: Senior and Middle Management
Let’s look at how this shakes out for an “easy” one. This is a screenshot of the questions from the DOJ’s “Senior and Middle Management” topic.
It’s only 9 questions-so, easy. Right?
Sure. Until you go to use it.
Because you’ll find that those questions will be answered by different people, at different points in time, and will be updated on different rhythms. And you need to sort that out before you can, you know, answer them.
So, we applied the process we described above, and here’s what happened.
First, a couple questions fell into what we called the “Governance and Structure” category.
Questions in this category get to how your program is set up and governed. The pattern we saw for the “when, who, how often” was this:
  – When
: you’ll answer these proactively. They’re not tied to a specific compliance incident-you don’t need to wait for the hotline to ring.
  – Who
: you’ll give these to a senior team member (like your Deputy CCO) engaged with high-level, program-wide issues like reporting lines, budget, compensation, and board oversight.
  – How often
: you’ll update your answers when things change-because the types of issues these questions tackle don’t usually change very often, and you should know when they do.
Next, about half of the questions fell under the “Program Operations” category.
These questions are about day-to-day risk management stuff. The pattern for “when, who, how often” was this:
  – When
: you’ll answer these operations-focused questions proactively, just like the Governance and Structure questions.
  – Who
: you’ll give these to individual risk owners to complete on a risk-by-risk basis. Your program’s operations will vary by risk-so you’ll want to know how things work for each key risk you have.
  – How often
: you’ll do these on a regular rhythm as a health check. These questions get operational, and operations change fast. A time-based cadence helps make sure you don’t miss something.
Finally, let’s look at the most straightforward questions-the ones we’ve put under the “Incident Response” category.
These questions get at specific compliance issues your company has faced. The “when, who, how often” pattern looks like this:
  – When
: you’ll answer these reactively, in response to specific compliance issues.
  – Who
: you’ll give these to the investigator and risk owner(s) relevant to the specific issue.
  – How often
: you’ll do these in response to significant cases-for example, cases you’d flag to your board in a quarterly meeting. (If that’s more than a few a year, you might be over-reporting. Ask outside counsel for a refresher on board duties.)
Now, if you looked at the pictures closely, you probably noticed there’s overlap between the “Program Operations” and “Incident Response” categories. Some of the questions appear in both categories.
That was deliberate. The DOJ’s document contains about a half-dozen compound questions that can be answered partially proactively, partially reactively-so we listed them in both categories.
And that’s it! The other DOJ topics shake out the same way.
Now, if doing this seems like a ton of work, it is. Translating something into a new context requires you to master both contexts and it takes a ton of time to execute. (That’s why making good compliance training is so hard-you have to frame it around the stuff your audience actually does at work, instead of just telling them about anti-corruption or privacy or whatever.)
But it’s also worth it.
Because compliance is about driving behavior, not just conveying abstract knowledge. And so investing the time to make applying something accessible to your audience-so that they can use it-is always time well-spent.

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9. Gary Stanley’s ECR Tip of the Day

(Source: Defense and Export-Import Update; available by subscription from
* Author: Gary Stanley, Esq., Global Legal Services, PC, (202) 352-3059,
Since 19 April 2017, a copy of the Hong Kong import license or a written statement that no license is required issued by the Government of the Hong Kong Special Administrative Region must be obtained before shipping an item under a license exception. The written statement may come in the form of a “NLR Notification” or “website information.”

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* Marjorie Kinnan Rawlings (8 Aug 1896 – 14 Dec 1953, was an American author who lived in rural Florida and wrote novels with rural themes and settings. Her best known work, The Yearling, about a boy who adopts an orphaned fawn, won a Pulitzer Prize for fiction in 1939, and was later made into a movie of the same name.)
  – “Writing is agony for me. I work at it eight hours every day, hoping to get six pages, but I am satisfied with three.”
* Emiliano Zapata (Emiliano Zapata Salazar; 8 Aug 1879 – 10 Apr 1919; was a leading figure in the Mexican Revolution, the main leader of the peasant revolution in the state of Morelos, and the inspiration of the agrarian movement called Zapatismo.)
  – “It is better to die on your feet than to live on your knees.”

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. 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.
: 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. 
: 19 CFR, Ch. 1, Pts. 0-199
  – Last Amendment: 28 Jul 2017: 82 FR 35064-35065: Technical Corrections to U.S. Customs and Border Protection Regulations
  – 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.)

: 15 CFR Subtit. B, Ch. VII, Pts. 730-774

  – Last Amendment: 7 July 2017: 
82 FR 31442-31449: Revisions to the Export Administration Regulations Based on the 
2016 Missile Technology Control Regime Plenary Agreements. 

: 31 CFR, Parts 500-599, Embargoes, Sanctions, Executive Orders
  – Last Amendment: 16 Jun 2017: 82 FR 27613-27614: Removal of Burmese Sanctions Regulations 
: 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
  – The latest edition (18 July 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, Census/AES guidance, and to many errors contained in the official text. 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.
, 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: 25 Jul 2017: Harmonized System Update 1706, containing 834 ABI records and 157 harmonized tariff records.
  – HTS codes for AES are available
  – HTS codes that are not valid for AES are available
  – 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.

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Weekly Highlights of the Daily Bugle Top Stories

(Source: Editor) 

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

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* 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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