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17-0901 Friday “The Daily Bugle”

17-0901 Friday “Daily Bugle”

Friday, 1 September, 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 Contact us for advertising inquiries and rates(The Daily Bugle will not be published Monday, 4 September, a U.S. Federal Holiday.)

[No items of interest noted today.] 

  1. Ex/Im Items Scheduled for Publication in Future Federal Register Editions 
  2. Commerce/BIS: (No new postings.)
  3. Justice: “Chinese National Sentenced to Three Years for Attempting to Illegally Export High-Grade Carbon Fiber to China”
  4. State/DDTC Posts 2016 Section 655 Annual Military Assistance Report
  5. State/DDTC Updates Personnel List
  6. EU Amends for 276th Time Restrictive Measures Against ISIL (Da’esh) and Al-Qaida
  7. Singapore Customs Announces Tradenet Downtime on 10 Sep
  1. Business Insider: “Man on Trial Over Illegal Weapons Sales Says He ‘Didn’t Try to Hide Anything'”
  2. Haaretz: “Israeli Firm Loses Kamikaze-drone Export License After Complaint It Carried Out Live Demo on Armenian Army”
  3. ST&R Trade Report: “Dates and Deadlines: Trademarks, AEO, Defense Trade, Classification, FDA Ban”
  1. Global Trade News: “Valuation: Perfecting the Entry Webcast Q&A”
  2. T. McVey: “ITAR For Government Contractors” (Part 2 of 4)
  3. R. Thomsen II, A.D. Paytas & M.M. Shomali: “Changes to Export Controls in August 2017”
  4. Gary Stanley’s ECR Tip of the Day
  1. Friday List of Approaching Events
  1. Bartlett’s Unfamiliar Quotations 
  2. Are Your Copies of Regulations Up to Date? Latest Changes: ATF (15 Jan 2016), Customs (28 Jul 2017), DOD/NISPOM (18 May 2016), EAR (15 Aug 2017), FACR/OFAC (16 Jun 2017), FTR (19 Apr 2017), HTSUS (25 Jul 2017), ITAR (30 Aug 2017)
  3. Weekly Highlights of the Daily Bugle Top Stories 

EXIMEX/IM ITEMS FROM TODAY’S FEDERAL REGISTER

EXIM_a1

[No items of interest noted today.]

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OGSOTHER GOVERNMENT SOURCES

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

(Source:
Federal Register)
 
[No items of interest noted today.]

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(Source:
Justice) [Excerpts.]
 
Fuyi Sun, aka “Frank,” 53, a citizen of the People’s Republic of China (China), was sentenced today to three years in prison for violating the International Emergency Economic Powers Act (IEEPA) in connection with a scheme to illegally export to China, without a license, high-grade carbon fiber, which is used primarily in aerospace and military applications. Sun pleaded guilty on April 21. …
 
  “Today, Sun is being held accountable for attempting to procure high grade carbon fiber – a material which has dual aerospace and defense applications – for a source he identified as the Chinese military,” said Acting Assistant Attorney General Boente. “Identifying and prosecuting those who seek to violate IEEPA and other laws designed to protect our strategic commodities from those who may wish us harm remains a top priority of the National Security Division.”
 
  “For nearly five years, Fuyi Sun tried to skirt U.S. export laws to obtain high-grade carbon fiber for the Chinese government. He spent thousands of dollars and took years of covert actions to avoid detection of his plan to purchase this highly protected material,” said Acting U.S. Attorney Kim. “Unbeknownst to Sun, however, he wasn’t making a deal with an unscrupulous company – he was dealing with undercover federal law enforcement agents, who foiled his clandestine plot.”
 
According to the allegations contained in the Complaint and Indictment filed against Sun, and statements made in court filings and proceedings in open court:
 
Since approximately 2011, Sun has attempted to acquire extremely high-grade carbon fiber, including Toray type M60JB-3000-50B carbon fiber (M60 Carbon Fiber). M60 Carbon Fiber has applications in aerospace technologies, unmanned aerial vehicles (commonly known as drones) and other government defense applications. Accordingly, M60 Carbon Fiber is strictly controlled for nuclear non-proliferation and anti-terrorism reasons. As part of these restrictions, the export of M60 Carbon Fiber to China without a license is prohibited.
 
In furtherance of his attempts to illegally export M60 Carbon Fiber from the U.S. to China without a license, Sun contacted what he believed was a distributor of carbon fiber – but which was, in fact, an undercover entity created by the Department of Homeland Security, Homeland Security Investigations (HSI) and “staffed” by HSI undercover special agents (the UC Company). Sun inquired about purchasing the M60 Carbon Fiber without the required license. In the course of his years-long communications with the undercover agents and UC Company, Sun suggested various security measures that he believed would protect them from “U.S. intelligence.” Among other such measures, at one point, Sun instructed the undercover agents to use the term “banana” instead of “carbon fiber” in their communications. Consequently, soon thereafter he inquired about purchasing 450 kilograms of “banana” for more than $62,000. In order to avoid detection, Sun also suggested removing the identifying barcodes for the M60 Carbon Fiber, prior to transshipment, and further suggested that they identify the M60 Carbon Fiber as “acrylic fiber” in customs documents.
 
On April 11, 2016, Sun traveled from China to New York for the purpose of purchasing M60 Carbon Fiber from the UC Company. During meetings with the undercover agents on April 11 and 12, among other things, Sun repeatedly suggested that the Chinese military was the ultimate end-user for the M60 Carbon Fiber he sought to acquire from the UC Company, and claimed to have personally worked in the Chinese missile program. Sun further asserted that he maintained a close relationship with the Chinese military, had a sophisticated understanding of the Chinese military’s need for carbon fiber, and suggested that he would be supplying the M60 Carbon Fiber to the Chinese military or to institutions closely associated with it.
 
On April 12, 2016, Sun agreed to purchase two cases of M60 Carbon Fiber from the UC Company. On that date, Sun paid the undercover agents purporting to represent the UC Company $23,000 in cash for the carbon fiber, as well as an additional $2,000 as compensation for the risk he believed the UC Company was taking to illegally export the carbon fiber to China without a license. Sun was arrested the next day. …
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The Section 655 Annual Military Assistance Report for FY 2016 for defense articles and defense services licensed for export under 22 U.S.C. 2778 of the Arms Export Control Act has been posted. 
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The State Department Directorate of Defense Trade Controls has posted a revised personnel list, effective 29 Aug 2017, HERE, containing names, titles, and telephone numbers of persons working at DDTC.
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Regulations
  – Commission Implementing Regulation (EU) 2017/1516 of 31 August 2017 amending for the 276th time Council Regulation (EC) No 881/2002 imposing certain specific restrictive measures directed against certain persons and entities associated with the ISIL (Da’esh) and Al-Qaida organisations
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Singapore Customs will be performing system maintenance work which will affect TradeNet from 0400 hours to 1200 hours on 10 September 2017.
 
During this period, there will not be any processing of amendment, cancellation, refund and stock related permit applications submitted through TradeNet®. Processing of such applications will resume after 1200 hours on 10 September 2017.
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NWSNEWS

(Source:
Business Insider, 31 Aug 2017.) [Excerpts.]
 
More than $1 million in weapons parts and sensitive military equipment was stolen out of Fort Campbell, Kentucky, and sold in a vast black market, some of it to foreign buyers through eBay, according to testimony at a federal trial this week.
 
The equipment – some of it re-sold to buyers in Russia, China, Mexico, Hong Kong, Kazakhstan and Ukraine – included machine gun and rifle parts, body armor, helmets, gun sights, generators, medical equipment and more.
 
John Roberts, of Clarksville, Tennessee, is being tried in Nashville on charges of wire fraud, conspiracy to steal and sell government property, and violating the Arms Export Control Act. Six soldiers and his civilian business partner made plea deals in exchange for their testimony.
 
Roberts, 27, testified Wednesday that he did not know the soldiers were bringing him stolen equipment, and said the military items he bought and sold were commonly found in surplus stores, on eBay and in gun stores.
 
  “I didn’t try to hide anything,” Roberts said Wednesday. “That’s why I filed taxes on everything I sold on eBay. I thought it was OK.” …
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(Source:
Haaretz, 31 Aug 2017.) [Excerpts.]
 
Defense Minister freezes license for Azerbaijan amid investigation over reports that Aeronautics demonstrated use of aircraft by attacking Armenian army position.
 
Israel’s Defense Ministry has frozen some of the licenses of Aeronautics, preventing the firm from exporting its drones to Azerbaijan, one of its major clients.
 
The action comes in the wake of an investigation of the Israeli firm by the Ministry of Defense Security Authority which was examining a complaint that Aeronautics representatives demonstrated the use of a kamikaze drone in Azerbaijan, by attacking a manned position of the Armenian army.
 
On Monday night Aeronautics informed the stock market that the Defense Ministry had frozen the marketing and export licenses of its Orbiter 1k to “an important customer of the company in a foreign country.” The company didn’t mention the name of the country, but Azerbaijan has been the company’s most important customer in recent years.
 
The company cannot export the drone to Azerbaijan – as per its original contract- or demonstrate its use, or form any ties with representatives of the Azeri army involving the drone. …
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Following are highlights of regulatory effective dates and deadlines and federal agency meetings coming up in the next week.
 
  – 5 Sep: deadline for comments to USDA on import compliance guide for meat, poultry, and egg products
  – 6 Sep: effective date of FDA final rule banning antibacterial consumer washes with any of 19 active ingredients
  – 6 Sep: deadline for comments to DEA on proposed import, production limits for controlled substances
  – 8 Sep: meeting of Defense Trade Advisory Group

  – 8 Sep: deadline for comments to CBP on proposed revocation or modification of classification rulings

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COMMCOMMENTARY

COMM_a211
. Global Trade News: “Valuation: Perfecting the Entry Webcast Q&A”

 
* August Webcast Q&A Wrap-up
  – Presented by Denise Guzialek
  – Program Manager of Compliance Services, Copper Hill Inc.
 
Q: ­Since you cannot flag Anti-dumping duty entries, what do you recommend for adjustments to value for entries with ADD? ­
A: I would recommend filing a Post-Summary Correction (PSC).
 
Q: ­After you have been approved for RECON and you change Brokers, do you have to notify CBP again of the change? 
A: ­Yes.
 
Q: ­Are all RECON entries now filed with the CEE, if you have been approved to participate with a CEE? ­ 
A: If you are a “Center participate”, you will file your entries with your designated Center. If you are not a “Center participate”, you will file with your assigned reconciliation port.
 
Q: ­If some entries were not flagged for recon, and the entries have already been liquidated, then retro flagging cannot be done, what happens to the entries not flagged in error? ­
A: If you are in the time frame to do so, you can file a protest for the liquidated entries with Customs. 
 
Q: ­Please advise about rounding and extra digits after two cents/digits.­ 
A: Rounding can occur when data in your file is calculated using formulas. Submit values at a maximum of two decimals.
 
Q: ­I have 25 entries to fix from last year. How do I know which option to use: PSC or Reconciliation?
A: ­PSC would be the quickest, most convenient option.  Recon is best used if you are looking at filing a large volume of corrections.
 
Q: ­If there is only one line submitted incorrect, will the rejection occur just on that line or would the rejection occur on the whole recon submission? ­
A: The rejection occurs on the entry summary with a comment as to why the entry summary was rejected.
 
Q: ­If you track PSC’s and do not submit until Recon and the subject entry has not yet liquidated–Recon data submitted will not match CBP data and will cause a rejection–yes? How do you effectively address that scenario? ­
A: The updated data in the PSC must be corrected in the Recon entry submission. You must make the appropriate changes in the entry data recon submission to reflect the changes made in the PSC.
 
Q: ­Would you recommend marking informal entries as formal entries for recon purposes? 
A: ­Yes, I would recommend this if, based on your entry data review, you have a high volume of corrections on previous informal entries.

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* Author: Thomas B. McVey, Chair of the International Practice Group of Williams Mullen, tmcmcvey@williamsmullen.com.
 
[Editor’s Note: Due to space limitations, Thomas B. McVey’s ITAR Guide for Government Contractors has been divided into four parts. The four parts will be published in the Daily Bugle of 31 August, and 1, 5 and 6 September 2017. The Guide been revised for recent amendments on 10 August 2017.]
 
Introduction
 
One of the most important areas of regulation for defense contractors is the International Traffic in Arms Regulations (ITAR). ITAR are the State Department controls that regulate the defense industry. [FN/2] Companies regulated under ITAR are subject to a number of requirements including registration, licensing, restrictions on transferring controlled technical data and performing defense services, among others. Following recent amendments, a second set of regulations – the Export Administration Regulations (EAR) [FN/3] – impose related requirements for government contracts firms and must be considered alongside ITAR. Contrary to popular belief, these apply beyond export transactions to many domestic activities of U.S. defense firms – they can apply even if the company’s only customer is the U.S. Government. Due to the potential civil and criminal liability involved, it is imperative for defense firms to have a clear understanding of these laws. The following provides an overview of these requirements and strategies for complying with them.
 
(Part 2) Export Administration Regulations – Companion Controls Under Recent Amendments.
 
The Export Administration Regulations (EAR) are administered by the U.S. Department of Commerce. The EAR were originally adopted to regulate commercial and “dual use” products. However, under a series of recent amendments known as “Export Control Reform” a large number of items previously regulated under ITAR were transferred to the EAR and hence the EAR now covers certain military products as well. Consequently, contractors must be cognizant of both ITAR and EAR in their compliance activities.
 
  (1) CCL-Based Controls. The EAR contain a list of products called the Commerce Control List (CCL). If an item is listed on the CCL it may be subject to export licensing and other controls depending upon the country to which it will be exported and other factors (these requirements are referred to as the “CCL-Based Controls”). Military products that were transferred from ITAR to EAR jurisdiction under Export Control Reform are listed on the CCL under the newly established “600 Series.”
 
As with ITAR, the EAR applies not just to physical products but also technology and software as well. The term “technology” is defined broadly at 15 CFR Part 772 as “specific information necessary for the development, production, or use of a product.” [FN/12] Thus if technology or software is on the CCL, there may be restrictions on exporting such items out of the U.S. and disclosing such items to foreign nationals in the U.S.
 
The requirements under the CCL-Based Controls are similar to many of the requirements under ITAR, including the requirements to obtain export licenses for the export of certain products, restrictions on the transfer of controlled technology and software (including transfers to foreign nationals in the United States or overseas), restrictions on reexports of U.S.-origin products and the incorporation of U.S. components into items manufactured abroad that contain above a de minimis level of US content, and restrictions on the performance of services related to weapons of mass destruction and other restricted activities. [FN/13]
 
Many subsystems, parts, components, accessories and attachments that are “specially designed” for items on the USML or the CCL are listed on the CCL and subject to controls under the EAR. The term “specially designed” has a specific definition that was adopted as part of Export Control Reform and parties need to apply the “specially designed” definition in interpreting ITAR and EAR. [FN/14]
 
  (2) Broad “Catch-All” Provisions For Many Products and Components Specially Designed For Military Use. As referenced above, under Export Control Reform a significant number of defense items were transferred from the USML onto the CCL and are now regulated under the EAR. As a result, the CCL now includes many “catch-all” subcategories that were previously listed on the USML – these are broad open-ended designations that cover items that were “specially designed” for military use. One significant example of this new “catch-all” under the CCL is ECCN 3A611.a, which reads as follows:
 
3A611 Military electronics, as follows:
*****
a. Electronic equipment, end items, and systems ”specially designed” for a military application that are not enumerated or otherwise described in either a USML category or another ”600 series” ECCN.
 
Note to 3A611.a: ECCN 3A611.a includes any radar, telecommunications, acoustic or computer equipment, end items, or systems ”specially designed” for military application that are not enumerated or otherwise described in any USML category or controlled by another ”600 series” ECCN.
** *
x. Parts, components, accessories and attachments that are “specially designed” for a commodity controlled by this entry or for an article controlled by USML Category XI, and not enumerated or described in any USML category or another 600 series ECCN or in paragraph .y of this entry.
 
There are also similarly broad “catch-all” categories for other types of products that are “specially designed for a military application” including computers, [FN/15] telecommunications equipment, [FN/16] radar and acoustic systems, [FN/17] navigation/avionics equipment [FN/18] and aircraft. [FN/19] Hence, many components used in the defense industry are listed on the CCL and it is imperative for defense contractors to be cognizant of these.
 
  (3) Export Requirements for All Export Transactions Subject to the EAR. In addition to the CCL-Based Controls, the EAR contain a number of additional requirements that apply to all export and reexport transactions that are subject to the EAR, even if the item in question is not listed on the CCL. These requirements include the prohibition against undertaking exports and reexports to certain embargoed countries, [FN/20] to certain restricted parties [FN/21] and for use in certain prohibited end-uses. [FN/22]
 
  (4) Penalties for Violations. Penalties for violations of EAR are similar to ITAR, i.e., civil and criminal penalties including monetary fines of up to $1,000,000 per violation and up to 20 years imprisonment.
 
————
  [FN/12] Effective September 1, 2016 the definition of “Technology” set forth in 15 CFR Part 772 will be amended to include: “Information necessary for the ”development,” ”production,” ”use,” operation, installation, maintenance, repair, overhaul, or refurbishing (or other terms specified in ECCNs on the CCL that control ”technology”) of an item….” See Federal Register, Vol. 81, No. 107, June 3, 2016.
  [FN/13] The EAR set forth restrictions on certain services performed by U.S. persons at 15 CFR §744.6.
  [FN/14] The ITAR definition of “specially designed” can be found in 22 CFR §120.41. The BIS definition of “specially designed” can be found at 15 CFR Part 772.
  [FN/15] See ECCN 4A611, which directs the reader to ECCN 3A611.
  [FN/16] See ECCN 5A611, which directs the reader to ECCN 3A611.
  [FN/17] See ECCN 6A611, which directs the reader to ECCN 3A611.
  [FN/18] See ECCN 7A611, which directs the reader to ECCN 3A611.
  [FN/19] See ECCN 9A610.
  [FN/20] See 15 CFR Part 746.
  [FN/21] See 15 CFR Part 744.
  [FN/22] See 15 CFR Part 744. 
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(Source: Editor) [Excerpts.] 
 

* Authors: Roszel C. Thomsen II, Esq.,
roz@t-b.com; Antoinette D. Paytas, Esq.,
toni@t-b.com; and Maher M. Shomali, Esq.,
maher@t-b.com.  All of Thomsen & Burke LLP.
 
REGULATORY CHANGES
 
Wassenaar Arrangement 2016 Plenary Agreements Implementation
 
The Bureau of Industry and Security (BIS) maintains, as part of its Export Administration Regulations (EAR), the Commerce Control List (CCL), which identifies certain items subject to Department of Commerce jurisdiction. This final rule revises the CCL, as well as corresponding parts of the EAR, to implement changes made to the Wassenaar Arrangement List of Dual-Use Goods and Technologies (WA List) maintained and agreed to by governments participating in the Wassenaar Arrangement on Export Controls for Conventional Arms and Dual-Use Goods and Technologies (Wassenaar Arrangement, or WA) at the December 2016 WA Plenary meeting. The Wassenaar Arrangement advocates implementation of effective export controls on strategic items with the objective of improving regional and international security and stability. This rule harmonizes the CCL with the agreements reached at the 2016 Plenary meeting by revising Export Control Classification Numbers (ECCNs) controlled for national security reasons in each category of the CCL, as well as making other associated changes to the EAR. … 
 
As we described in our Export Controls and Sanctions Update earlier this month, the following changes to Categories 3, 4 and 5 may affect our clients:
Summary of Changes to Category 3
 
3A001.a.5.a
is updated. This control on analog-to-digital converters (ADCs) is revised by updating the ADC control thresholds (resolution) for the higher performance ADCs to reflect the technology that is used in the commercial mainstream, which will result in a decrease of license application submissions. In addition, the unit for resolution is amended by replacing “billion words per second” with “Giga Samples Per Second (GSPS)” and “million words per second” with “Mega
 
Samples Per Second (MSPS)” to clarify what is being measured for this parameter.
 
For example, ECCN 3A001.a.5.a.1 used to control ADCs with a resolution of 8 bit or more, but less than 10 bit, with an output rate greater than 1 billion words per second. The new ECCN 3A001.a.5.a.1 will control ADCs with a resolution of 8 bit or more, but less than 10 bit, with an output rate greater than 1.3 Giga Samples Per Second (GSPS).
 
3A001.b.11 is updated
. “Frequency synthesizer” “electronic assemblies” is amended by updating the parameters to align the 3A001.b.11 frequency synthesizer controls with the 3A002.d.3 signal generator controls. Specifically, Items paragraphs 3A001.b.11.a through .e are revised and b.11.c and .f are removed and reserved.
 
For example, ECCN 3A001.b.11.a used to control “Frequency synthesizer” “electronic assemblies” having “frequency switching time” less than 156 ps. The new ECCN 3A001.b.11.a will control “Frequency synthesizer” “electronic assemblies” having a “frequency switching time” less than 143 ps.
 
Summary of Changes to Category 4
 
Increase in the Adjusted Peak Performance for Computers
 
4A003 “Digital computers,” “electronic assemblies,” and related equipment: The “Adjusted Peak Performance” for “digital computers” is raised from 12.5 to 16 Weighted TeraFLOPS (WT) in Items paragraph 4A003.b.
 
4D001 “Software” and 4E001 “technology” is amended as follows:
  (1) The TSR paragraph in the List Based License Exceptions section is revising the APP from 12.5 to 16 WT
  (2) The Special Conditions for STA paragraph is revising the APP from 12.5 to 16 WT and
  (3) Items paragraph .b.1 in the List of Items Controlled section is amended by revising the APP from 6.0 to 8.0 WT.
 
Under License Exception APP, this rule also moves Burma from paragraph (d)(1) “Computer Tier 3” to the more favorable paragraph (c)(1) “Computer Tier 1.”
 
Summary of Changes to Category 5, Part 1: Telecommunications
 
5A001.b.6 is updated
. It now controls equipment employing digital signal processing to provide voice coding output at rates less than 700 bit/s. [This refers to taking samples of human voice and then converting these samples of human voice into a digital signal taking into account specific characteristics of human speech.] The previous entry specified 2,400 bit/s.
 
5B001.b.2.c is removed
. It previously controlled equipment used to develop telecommunications equipment employing coherent optical transmission or coherent optical detection techniques
 
5E001.c.1 is removed
. It previously controlled technology for the development/production of equipment employing digital techniques designed to operate at a total digital transfer rate exceeding 560 Gbit/s.
 
5E001.c.2.c is removed
. It previously controlled technology for the development/production of equipment employing coherent optical transmission or coherent optical detection techniques
 
Summary of Changes to Category 5, Part 2: Information Security
Reorganized various decontrol and exclusionary notes into more positive language:
 
Reorganized the Note 4 decontrol note as a more positive list, by removing it and rewriting ECCN 5A002 and its sub-paragraphs. Previously, 5A002.a.1 was a catch-all and covered most encryption items classified under 5A002. Now, the new subparagraphs track the types of items previously ineligible for decontrol under Note 4:
  – Paragraph a.1: Items having information security as a primary function
   – Paragraph a.2: Digital communication or networking systems, equipment or components
   – Paragraph a.3: Computers, other items having information storage or processing as a primary function, and components therefor
   – Paragraph a.4: Other items where the cryptographic functionality supports a non-primary function AND where such cryptographic functionality is performed by incorporated components/software that are, as standalone items, decontrolled from 5A/5D002. [See commentary below on this sub-paragraph]
 
Moved cryptographic activation software from ECCN 5D002.d to 5D002.b
Added a definition of the uses of encryption that are decontrolled:
  – Authentication
  – Digital signature
  – Data integrity
  – Non-repudiation
  – Digital rights management, including the execution of copy-protected software
  – Encryption or decryption in support of entertainment, mass commercial broadcasts or
  – Medical records management
  – Key management in support of any function described above
 
Expanded the scope of the Note 4 decontrol through new catch-all language at 5A002.a.4
. Previously, all uses of encryption must have supported the primary function of the item in order to qualify for Note 4 decontrol. Now, encryption that supports a non-primary function is still within the decontrol if the component providing that encryption is itself excluded from 5A002 (e.g., a mass-market component controlled under 5A992.c). Examples of items covered by this new expanded scope include:
  – An automobile where the only cryptographic functionality is provided by a mobile telephone that is built into the car
  – An exercise bike with an embedded web browse
 
Clarified the scope of the decontrol notes to 5A002.a (now reorganized as Note 2 to 5A002.a)
so that components specially designed for a listed decontrolled item are also themselves decontrolled from 5A002. For example, this could include components for wireless PANs, components for certain RAN equipment with an RF output power limited to 0.1W, or components for certain routers/switches performing only OAM encryption.
 
Venezuela Sanctions Update
 
In our last Export Controls and Sanctions Update, we notified you that the United States issued new sanctions making the Government of Venezuela a restricted party. These sanctions apply to any agency of the Government of Venezuela, as well as any organization/entity owned 50% or more by the government (except there is a general license covering CITGO Holding, Inc.).
 
The scope of these sanctions is limited to financial-related transactions, and is similar in scope to OFAC’s Sectoral Sanctions program previously imposed against Russian entities . The sanctions that are most likely applicable to U.S. exporters are those prohibiting any dealing in “new debt” of the Government of Venezuela longer than 30 days or 90 days, depending on the situation.
“New debt” includes offering credit terms for new purchases, such as NET-60 payment terms.
 
Specifically, the restrictions on new debt cover:
  – New debt with a maturity of greater than 90 days of Petroleos de Venezuela, S.A. (PdVSA); and
   – New debt with a maturity of greater than 30 days of the Government of Venezuela, other than debt of PdVSA.
 
The following web links provide additional information related to these sanctions:
  – The President’s Executive Order containing the new prohibitions
   – OFAC FAQs
   – OFAC Venezuela-related sanctions web page
 
Temporary Modification of Category XI of the U.S. Munitions List
 
The Department of State, pursuant to its regulations and in the interest of the security of the United States, temporarily modifies Category XI of the United States Munitions List (USML). On July 1, 2014, the Department published a final rule revising Category XI of the USML, 79 FR 37536, effective December 30, 2014. That final rule, consistent with the two prior proposed rules for USML Category XI (78 FR 45018, July 25, 2013 and 77 FR 70958, November 28, 2012), revised paragraph (b) of Category XI to clarify the extent of control and maintain the existing scope of control on items described in paragraph (b) and the directly related software described in paragraph (d). The Department has determined that exporters may read the revised control language to exclude certain intelligence-analytics software that has been and remains controlled on the USML. Therefore, the Department determined that it is in the interest of the security of the United States to temporarily revise USML Category XI paragraph (b), pursuant to the provisions of 22 CFR 126.2, while a long-term solution is developed. The Department will publish any permanent revision to USML Category XI paragraph (b) addressing this issue as a proposed rule for public comment.   This temporary revision clarifies that the scope of control in existence prior to December 30, 2014 for USML paragraph (b) and directly related software in paragraph (d) remains in effect. This clarification is achieved by reinserting the words “analyze and produce information from” and by adding software to the description of items controlled.
 
The Department previously published a final rule on July 2, 2015 (80 FR 37974) that temporarily modified USML Category XI(b) until December 29, 2015. The Department published a final rule on December 16, 2015 (80 FR 78130) that continued the July 2, 2015 modification to August 30, 2017. This final rule extends the July 2, 2015 modification to August 30, 2018 to allow the U.S. government to review USML Category XI in full and publish proposed and final rules. … 
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COMM_a414. Gary Stanley’s ECR Tip of the Day

(Source: Defense and Export-Import Update; available by subscription from
gstanley@glstrade.com
)
 
* Author: Gary Stanley, Esq., Global Legal Services, PC, (202) 352-3059,
gstanley@glstrade.com
.
 
For purposes of the ITAR, a foreign person is considered an employee of a U.S. company when the foreign person is a full time regular employee, directly paid, insured, hired/fired and/or promoted exclusively by the U.S. person. The employee, however, need not LIVE in the U.S. to be employed by the U.S. person. The U.S. person is liable to ensure all foreign person employees are compliant with U.S. export laws regardless of residence.  

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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
jwbartlett@fullcirclecompliance.eu
, composed in the below format:

* DATE: PLACE; “TITLE;” SPONSOR; WEBLINK; CONTACT (email and phone number)

#” New listing this week:   
 
Continuously Available Training:
 
* 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:

 

* 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;
# Sep 6: London, UK;
Wassenaar and Dual-Use Workshop; Steptoe LLP
* Sep 6: Webinar; Trademark Basics and Benefits for the Smart International Trader 
; Sandler, Travis, & Rosenberg

* Sep 6: Nashville, TN; “
AES Compliance Seminar
;” Dept. of Commerce/Census
Bureau;
itmd.outreach@census.gov

* Sep 7: Marina Del Ray CA: ”
Strategizing for Dealing with the Government Under the New Administration;” Crowell and Moring

* Sep 7: Webinar; ”
Understanding Mexico’s AEO Program;” 
Sandler, Travis & Rosenberg, P.A.;
webinarorganizers@strtrade.com 

* Sep 12: Webinar; “Meeting CBP’s Informed Compliance and Reasonable Care Standards;” Sandler, Travis & Rosenberg, P.A.;  webinarorganizers@strtrade.com 


* 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 13: Webinar; ”
Definition of ‘Firearm’ Under the Gun Control Act;” Reeves & Dola LLP; Teresa Ficaretta;
tficaretta@reevesdola.com; 202-715-9183
* Sep 14: Webinar; A Product of Where? Country of Origin Marking 101
; Sandler, Travis, & Rosenberg 

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

* Sep 18-19: Huntsville, AL; ”
NAITA Export Control Update;” North American International Trade Association

* 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 19: Amsterdam, Netherlands; ”
Amsterdam International Trade and Compliance Conference;” Register
here, OR contact
Sue Menon, 202-887-4375; Akin Gump



* Sep 21: 
Webinar; “
US Export Administration Regulations
;
” Foreign Trade Association
* Sep 21-22; Brisbane, Australia; Defense Export Controls Outreach Program; Australian Department of Defense

* Sep 20-22: Houston, TX; ”
Advanced Topics in Customs Compliance Conference;” Deleon Trade LLC
# Sep 25-27: Wash DC; ”
1st Advanced Forum on Customs and Trade Enforcement, Washington, DC;” American Conference Institute

* Sep 26: Cupertino, CA; ”
11th CompTIA Global Trade Compliance Best Practices Conference;” CompTIA; OR contact
Ken Montgomery, 202-682-4433
* Sep 26: Webinar; “[Monthly Update] The Latest in Administration and Congressional Trade Actions
;” Sandler, Travis, & Rosenberg
* Sep 27: Tysons Corner, VA; ”
IT Capabilities and Solutions for the Trade Compliance Community;” Society for International Affairs (“SIA”)
* Sep 27: Oxford, UK; ”
Intermediate Seminar;” UK Department for International Trade;
denise.carter@trade.gsi.gov.uk 
* Sep 27: Webinar; “Understanding the European Union’s AEO Program
;” Sandler, Travis, & Rosenberg

* 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 4: Toronto, Canada; ”
2nd National Institute on US-Canadian Securities Litigation;” American Bar Association
* Oct 4: Webinar; “
Exports – New Incentives, Old Rules
;” 
Sandler, Travis & Rosenberg, P.A.; 
webinarorganizers@strtrade.com
  

* Oct 4-5:  Miramar (Miami/Fort Lauderdale), FL; ”
9th Maritime Logistics Training Course
“; Contact ABS Consulting, phone:
 
(954) 218-5285


* Oct 5-6: London, UK; ”
The World ECR Forum 2017;” World ECR 


* Oct 10: Aberdeen, UK; ”
UK Strategic Export Controls: Control List Classification – Combined Dual Use and Military;” Code Coct2017; or contact
Denise Carter at 020-7215-4459; 
UK Department for International Trade
* Oct 10: Aberdeen, UK; “UK Strategic Export Controls: Licenses Workshop;” Code Loct2017; or contact Denise Carter at 020-7215-4459; UK Department for International Trade;
*
 Oct 10: Rotterdam, the Netherlands; “
Awareness Training Export Control, Dual-Use, and Sanctions
” day I/3 [in Dutch]; Fenex 

* Oct 10-12: Dallas, TX; “
‘Partnering for Compliance™’ West Export/Import Control Training and Education Program
;” Partnering for Compliance
 
* Oct 11: Aberdeen, UK; “UK Strategic Export Controls: Intermediate Oil and Gas Seminar;” Code loct2017-2; or contact Denise Carter at 020-7215-4459; UK Department for International Trade;

* Oct 11: Webinar; ”
Basics of Importation Under the Gun Control Act;” Reeves & Dola LLP; Teresa Ficaretta;
tficaretta@reevesdola.com; 202-715-9183
# Oct 12: Brussels, Belgium; 
Compliance in Export Control of Dual-Use Items; EU Federal Ministry for Economic Affairs and Energy


* Oct 12-13: Boston, MA; “Automated Export System Compliance Seminar and Workshop;” Commerce/Census, Commerce/BIS, DHS/CBP, State/DDTC, Treasury 

* Oct 13: Dallas, TX; “
Customs/Import Boot Camp
;” Partnering for Compliance

* Oct 16: Toronto; ”
3rd Canadian Forum on Economic Sanctions Compliance and Enforcement, Toronto;” American Conference Institute and Canadian Institute

* 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 24: Rotterdam, the Netherlands; “
Awareness Training Export Control, Dual-Use, and Sanctions
” day 2/3 [in Dutch]; Fenex 
* Oct 25-26: Tysons Corner, VA; ITAR Fundamentals; FD Associates

* Oct 30-Nov 2: Phoenix, AZ; “
ITAR Defense Trade Controls / EAR Export Controls Seminar
;” ECTI;
jessica@learnexportcompliance.com
; 540-433-3977
* Oct 31: Manchester, UK; “UK Strategic Export Controls: Intermediate Seminar;” Code loct2017; or contact Denise Carter at 020-7215-4459; UK Department for International Trade;
* Nov 1: Manchester, UK; “UK Strategic Export Controls: Beginner’s Workshop;” Code Bnov2017-1; or contact Denise Carter at 020-7215-4459; UK Department for International Trade; 
* Nov 1: Manchester, UK; “UK Strategic Export Controls: Licenses Workshop;” Code Lnov2017-1; or contact Denise Carter at 020-7215-4459; UK Department for International Trade; 
* Nov 1: Manchester, UK; “UK Strategic Export Controls: Control List Classification – Combined Dual Use and Military;” Code Cnov2017-1; or contact Denise Carter at 020-7215-4459; UK Department for International Trade; 
* Nov 2-3: Las Vegas, NV; “The 22nd National M&A Institute;” American Bar Association
* Nov 5-7: Singapore; ”
ICPA Singapore Conference;”
International Compliance Professionals Association;
wizard@icpainc.org
*
 Nov 6: Rotterdam, the Netherlands; “
Awareness Training Export Control, Dual-Use, and Sanctions
” day 3/3 [in Dutch]; Fenex 

* 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 8: Webinar; “Introduction to the National Firearms Act;” Reeves & Dola LLP; Teresa Ficaretta; tficaretta@reevesdola.com; 202-715-9183
* Nov 9: Tysons Corner, VA; ITAR for the Empowered Official; FD Associates

* 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” [in Dutch]; Fenedex

* Nov 29: Wash DC; ”
4th U.S. Customs Compliance Boot Camp, Washington, DC;” American Conference Institute

* Dec 4: NYC; ”
8th Annual New York Forum on Economic Sanctions, New York“, American Conference Institute

 * Dec 4-7: Miami FL; “ITAR Defense Trade Controls / EAR Export Controls Seminar;” ECTI; jessica@learnexportcompliance.com; 540-433-3977

* Dec 5: Brussels, Belgium; ”
Dual Use For Beginners
” [In Dutch]; Flemish Department of Foreign Affairs

* Dec 5: San Juan, PR; “AES Compliance Seminar in Spanish;” Dept. of Commerce/Census Bureau; itmd.outreach@census.gov

* Dec 6: Webinar; ”
Introduction to Firearms and Ammunition Excise Tax (FAET);” Reeves & Dola LLP; Teresa Ficaretta;
tficaretta@reevesdola.com; 202-715-9183

* 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
                                                2018
 

* Jan 22-25: San Diego CA; “
ITAR Defense Trade Controls / EAR Export Controls Seminar
;” ECTI; 
jessica@learnexportcompliance.com
; 540-433-3977

* Feb 19-22: Huntsville AL; “
ITAR Defense Trade Controls / EAR Export Controls Seminar
;” ECTI; 
jessica@learnexportcompliance.com
; 540-433-3977 * Mar 11-14: San Diego, CA; ”
ICPA Annual Conference;”
International Compliance Professionals Association;
wizard@icpainc.org

# Mar 6-8: Orlando, FL; “
‘Partnering for Compliance’ East Export/Import Control Training and Education Program
;” Partnering for Compliance
# Mar 9: Dallas, TX; “
Customs/Import Boot Camp
;” Partnering for Compliance

* Apr 16-19: Las Vegas NV; “
ITAR Defense Trade Controls / EAR Export Controls Seminar
;” ECTI; 
jessica@learnexportcompliance.com
; 540-433-3977
* Apr 30-May 3: Wash DC; “
ITAR Defense Trade Controls / EAR Export Controls Seminar
;” ECTI; 
jessica@learnexportcompliance.com
; 540-433-3977

ENEDITOR’S NOTES

EN_a116
. Bartlett’s Unfamiliar Quotations

(Source: Editor)

* Marguerite Gardiner (Marguerite Gardiner, Countess of Blessington; 1 Sep 1789 – 4 Jun 1849; was an Irish novelist, journalist, and literary hostess.)
   – “Happiness consists not in having much, but in being content with little.”
 
* William Cartwright (1 Sep 1611 – 29 Nov 1643; was an English poet, dramatist and churchman.)
  – “Love makes those young whom age doth chill, and whom he finds young keeps young still.”
 
* Henry George (2 Sep 1839 – 29 Oct 1897; was an American political economist and journalist. His writing was popular in the 19th century, and sparked several reform movements of the Progressive Era. His writings also inspired the economic philosophy known as Georgism, based on the belief that people should own the value they produce themselves, but the economic value derived from land (including natural resources) should belong equally to all members of society.)
  – “Poorly paid labor is inefficient labor, the world over.”
 
Friday Funnies — Some musical humor:
 
Q. How many bluegrass pickers does it take to change a light bulb?
A. Six: one to change the bulb and five to complain that it’s electric.
  — Barry Clark, Fredericksburg, VA
 
Q. What is the difference between God and an orchestra conductor?
A. God does not think He is an orchestra conductor.
  — Per-Arne Éberg, Umea, Sweden
 
Q. What do you call someone who like to hang out with musicians?
A. A drummer.
  — George Bigelow, Vadnais Heights, MN

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

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: 28 Jul 2017: 82 FR 35064-35065: Technical Corrections to U.S. Customs and Border Protection Regulations
 
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: 15 Aug 2017: 
82 FR 38764-38819: Wassenaar Arrangement 2016 Plenary Agreements Implementation
 

  

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 (18 Jul 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: 25 Jul 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: Last Amendment: 30 Aug 2017: 82 FR 41172-41173: Temporary Modification of Category XI of the United States Munitions List
  – The only available fully updated copy (latest edition: 30 Aug 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.

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

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.

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

* 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 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.

* TO UNSUBSCRIBE: Use the Safe Unsubscribe link below.

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