| Friday, 8 September, 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 here for free subscription. Contact us for advertising inquiries and rates. |
| | | [No items of interest noted today.] | | | - Ex/Im Items Scheduled for Publication in Future Federal Register Editions
- Commerce/BIS: (No new postings.)
- DHS/CBP Announces ACE PRODUCTION Outage, 9-10 Sep
- DHS/CBP Ceases Operations at the Area Port of Savannah due to Hurricane Irma
- J.E. Bartlett: Notes from Today’s DTAG Public Meeting
- DoD/DSS Posts Report “Targeting U.S. Technologies: A Trend Analysis of Cleared Industry Reporting”
- Justice: “CEO of International Metallurgical Company Sentenced to 57 Months in Prison for Conspiring to Export Specialty Metals to Iran”
- State/DDTC Posts Name Change for RLC (UK) Limited
| | | - ST&R Trade Report: “Dates and Deadlines: Informed Compliance, AEO, Origin Marking, Classification, ACE”
| | | - M. Volkov: “Financial Controls and Contract Management Systems”
- P. Patel: “Sanctions: ‘What Tech Companies Should Consider When Operating in the UK'”
- D.R. Stepp, R.C. Burns, Z. Chen: “Change is Coming: China Proposes New Export Control Law”
| | | - Friday List of Approaching Events
| | | - Bartlett’s Unfamiliar Quotations
- 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)
- Weekly Highlights of the Daily Bugle Top Stories
|  | | EX/IM ITEMS FROM TODAY’S FEDERAL REGISTER |
[No items of interest noted today.] * * * * * * * * * * * * * * * * * * * *
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OTHER GOVERNMENT SOURCES |
1 . Ex/Im Items Scheduled for Publication in Future Federal Register Editions * Justice; Alcohol, Tobacco, Firearms, and Explosives Bureau; NOTICES; Agency Information Collection Activities; Proposals, Submissions, and Approvals: Application and Permit for Temporary Importation of Firearms and Ammunition By Nonimmigrant Aliens [Publication Date: 11 September 2017.] * * * * * * * * * * * * * * * * * * * *
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| There will be an ACE PRODUCTION Outage Saturday evening, September 9, 2017 from 2200 ET to 0400 ET Sunday, September 10, 2017 for ACE Infrastructure Maintenance. * * * * * * * * * * * * * * * * * * * *
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| U.S. Customs and Border Protection at the Area Port of Savannah will cease trade operations on Friday, September 8, 2017 at 1700 due to potential impacts of Hurricane Irma. Vessel and aircraft arrival clearance will cease Friday, September 8, 2017 at 2359 at the Port of Savannah, Georgia. For the Port of Brunswick, Georgia all operations will cease on Friday, September 8, 2017 at 0800. At this time there is not an anticipated resumption date/time for operations as that decision is dependent on recovery efforts/issues. CBP will provide necessary updates. For questions call the Duty Watch Commander Linda Thornbloom at 912-210-1185 or Assistant Port Director Lynn Brennan at 912-210-0077. During an emergency, CBP’s emergency response is conducted in accordance with the Department of Homeland Security’s National Response Framework. Follow U.S. Customs and Border Protection on Twitter at @CustomsBorder @CBPFlorida and @CBPCaribbean for news and information updates. * * * * * * * * * * * * * * * * * * * *
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| (Source: Editor) The Defense Trade Advisory Group (DTAG) held a public meeting today, September 8th, in Washington, DC, attended by approximately 50 DTAG members, 30 members of the public, members of the staff of the Defense Directorate of Trade Compliance (DDTC), led by Brian Nilsson, Deputy Assistant Secretary of State for Defense Trade (DAS). Mr. Nilsson provided the following information about DDTC actions that can be expected in the coming months: - USML Categories I, II, and III are expected to move to the CCL for EAR control within the next year.
- A change to ITAR 126.4 has been drafted and is being circulated for review.
- A change to the ITAR 123.4 exemption for temporary imports for repair and return of articles would allow it to apply to non-US origin articles.
- DDTC is performing a review of the UAV export policy.
- DDTC is considering improvements to the Australian and UK ITAR authorization sections.
- DDTC is planning a rewrite of the entire ITAR.
- First rule would be limited to restructuring; no policy would be changed.
- The second rule would be a section-by-section analysis of the regulations.
- The ITAR will be shortened and simplified.
- All definitions will be in one part of the ITAR.
- DDTC will address whether the separate guidance currently posted on the DDTC website (e.g., licensing and agreements) will be incorporated into the ITAR.
- Will be structured more like the EAR, with the intention of eventually being combined with the EAR to form the one regulation envisioned by Export Control Reform.
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| The DSS Counterintelligence Directorate announces the release of the 2017 edition of the unclassified publication, “Targeting U.S. Technologies: A Trend Analysis of Cleared Industry Reporting.” This report analyzes suspicious contact reports received from cleared industry in fiscal year 2016. It is currently available online. Hardcopy editions will be available in October from your servicing Industrial Security Representative or Counterintelligence Special Agent. * * * * * * * * * * * * * * * * * * * *
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| Earlier today, at the federal courthouse in Brooklyn, New York, Erdal Kuyumcu, the chief executive officer of Global Metallurgy, LLC, based in Woodside, New York, was sentenced to 57 months in prison following his June 14, 2016 guilty plea to conspiracy to violate the International Emergency Economic Powers Act by exporting specialty metals from the United States to Iran. The sentencing proceeding was held before Chief United States District Judge Dora L. Irizarry. … According to court documents, Kuyumcu, a U.S. citizen, conspired to export from the United States to Iran a metallic powder primarily composed of cobalt and nickel, without having obtained the required license from the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC). As established during a two-day presentencing evidentiary hearing, the metallic powder has potential military and nuclear applications. Such specialized metals are regulated by the U.S. Department of Commerce to combat nuclear proliferation and terrorism, and exporting them without the required license is illegal. In furtherance of the illegal scheme, Kuyumcu and others plotted to obtain more than 1,000 pounds of the metallic powder from a U.S.-based supplier. To hide the true destination of the goods from the supplier, Kuyumcu arranged for the metallic powder to be shipped first to Turkey and then to Iran. Kuyumcu used coded language when discussing shipment of the powder with a Turkey-based co-conspirator, such as referring to Iran as the “neighbor.” Shortly after one of the shipments was sent from Turkey to Iran, a steel company in Iran sent a letter-sized package to Kuyumcu’s Turkey-based co-conspirator. The Iranian steel company had the same address as an OFAC-designated Iranian entity under the Weapons of Mass Destruction proliferators sanctions program that was associated with Iran’s nuclear and ballistic missile programs. … * * * * * * * * * * * * * * * * * * * *
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| Effective immediately, RLC (UK) Limited will change as follows: RLC Langford Lodge Limited. Due to the volume of authorizations requiring amendments to reflect this change, the Deputy Assistant Secretary for Defense Trade Controls is exercising the authority under 22 CFR 126.3 to waive the requirement for amendments to change currently approved license authorizations. The amendment waiver does not apply to approved or pending agreements. … * * * * * * * * * * * * * * * * * * * *
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NEWS |
| Following are highlights of regulatory effective dates and deadlines and federal agency meetings coming up in the next week. 11 Sep: 12 Sep: 13 Sep: – deadline for comments on potential IPR infringement investigations of Wi-Fi enabled devices, omega-3 products 14 Sep: – effective date of USDA final rule allowing imports of Hass avocados from Colombia 15 Sep: – deadline for comments to USTR on Caribbean trade preference program – deadline for comments to USDA on reducing regulatory burden 16 Sep: – ACE deployment of non-ABI entry summary, duty deferral, e214, and manufacturer ID functionality * * * * * * * * * * * * * * * * * * * *
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COMMENTARY |
10. M. Volkov: “Financial Controls and Contract Management Systems” (Source: Volkov Law Group Blog. Reprinted by permission.) * Author: Michael Volkov, Esq., Volkov Law Group, mvolkov@volkovlaw.com, 240-505-1992. Compliance officers understand that a company’s greatest risks surround access to and use of money. A CCO has to understand a company’s financial controls, and in a perfect world, should have a seat at the table in the crafting and enforcement of such controls. A company faces serious harms, enforcement risks and collateral consequences from deficiencies in its financial controls. Sarbanes-Oxley requires public companies to maintain effective internal controls for financial accounting and reporting. The FCPA also imposes a requirement that a public company keep accurate books and records, and a system of internal controls sufficient to ensure management’s control over the company’s assets. When questioned about weaknesses in its financial controls, a company’s financial officers will respond with the defense of “materiality.” In other words, the deficiency does not rise to the level of “material,” requiring disclosure under the Sarbanes-Oxley law. For a CCO, such non-material weaknesses may be relevant, because non-material transactions can be used to fund illegal activities – from basic theft to complex bribery schemes. A critical part of a company’s financial controls involves accounts payable and accounts receivable. In the regular course of business, a company makes numerous payments to vendors and suppliers, and receives payments from customers. As I noted above, the functions surrounding money – payables and receivables are high-risk activities. A core requirement for these functions is a contract management system. Many companies do not effectively manage their contracting function and contract records. Companies have to require all contracts to be coordinated through the legal office. Nonetheless, many companies have contracts drafted and executed without consistent standards and sometimes without the required approval for retaining a vendor/supplier or a third-party representative. A company’s legal department has to remedy this issue s quickly as possible. A second significant area around contract management relates to payment and receivables. The accounts payable function is triggered by an invoice or purchase order. In most cases, the company has executed a contract with the vendor/supplier, although some relationships may be based on purchase orders. If a company has a contract with the vendor/supplier and receives an invoice, the company has to verify that the charges are accurate and reflect the contract terms. In the absence of a contract management system, the company may not be able to conduct this basic verification function. The same concern applies when receiving payments from customers. If a company cannot match a payment to the contract terms, a company ignores a risk that the payment is inaccurate, or the risk that the payment from a risky third party. A company’s contracting system has to develop standards for use of contracts versus purchase orders. Employees favor purchase orders as a less burdensome process to finalize a sale. In many cases, companies have long-term relationships where contracts have expired but continued through the use of purchase orders. A deficient contract system creates significant risks for compliance and commercial liability. A company’s purchase orders rarely contain robust compliance certifications. In addition, the use of purchase orders rather than contracts exposes a company to potential litigation in the event of a commercial dispute. A company cannot ignore the risks of a deficient contract management system. While such deficiencies may not rise to the level of a material weakness, the risks can be exploited by bad actors. * * * * * * * * * * * * * * * * * * * *
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| * Author: Prina Patel, Esq., ppatel@cooley.com , Cooley UK LLP. While sanctions restrict trade and dealings with specified individuals, entities and states, export controls restrict the distribution of specified products & services, namely military goods and items that can have a dual civilian and military use. In the past, compliance with sanction and export regimes was largely seen to be an issue for companies that dealt with military hardware or products that had a clear potential military use & for banks supplying financial assistance to sanctioned entities. That mind-set is now dangerously outmoded. Technological advancement in ‘civilian’ products and software has resulted in many of these products and services being caught by sanctions and export control regimes. The most obvious example being the now widespread use of encryption software in civilian products and services used to secure data that is transmitted wirelessly between electronic devices. This presents significant challenges for tech companies. These challenges are compounded by the ease with which technology and software services can be transferred globally and the difficulties with identifying and restricting potential access. With the ever-increasing use of cloud services, this is a growing issue. Tech companies considering sanction and export compliance must address three fundamental questions: Are Any of Our Products or Services (Or Part of Them) Controlled? To establish the status of products/services, tech companies operating in the UK must refer to the UK Strategic Export Control Lists (which incorporate EU controls). They should also be aware of the US export control regime, which has wide-reaching extraterritorial effect. Exemptions may apply. For example, certain open source software and “mass-market” software products using encrypted technology are exempt from requiring a license. To Whom Do We Supply Our Products/Services? Companies should have a method of screening customers and related parties before access is given to products/services to ensure they are not on any sanctions list. This can be managed internally with specialized software or subcontracted to third party providers. These checks should also be carried out periodically on existing customers to capture any updates to sanction lists. What is Our Geographic Scope? This can often be the hardest question for tech companies that supply goods/services electronically. All companies should understand their potential geographic scope of supply to ensure they are not providing goods or services to sanctioned states or entities. For companies supplying controlled products or services, it is essential that access is geographically limited or that appropriate export licences are obtained. Limitation can be achieved in a number of ways: by restriction of supply to specific servers; or, if cloud services are being used for distribution, ensuring that the cloud service itself has appropriate restrictions in place. Navigating the complexities of international sanctions and export control regimes is daunting but crucial. Where there is any doubt as to the status of goods, the geographic scope of supply, or the application of sanction and/or export control regimes, legal advice should be sought as a matter of urgency. * * * * * * * * * * * * * * * * * * * *
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| * Author: David R. Stepp, Esq., david.stepp@bryancave.com, 310-576-2199; R. Clifton Burns, Esq., Clif.Burns@bryancave.com , 202-508-6067; and Zhiwei Chen, Esq., zhiwei.chen@bryancave.com, +86 21 2308 3032. All of Bryan Cave LLP On June 16, 2017, China’s Ministry of Commerce (“MOFCOM”) released for public comments the draft Export Control Law of the People’s Republic of China (the “ECL”). The ECL, once enacted, could substantially change China’s current export controls regime and affect the business operations of EU and U.S. multinationals within and outside of China. Export control appears to be an overlooked area in China for years. Up until now in China, more focus was placed on the import side of international trade, which provides around one-third of the total revenue for the Chinese government. Although China is not yet a member state to the Wassenaar Arrangement, China has enacted a number of separate administrative regulations and lists on each specific category of controlled items, such as biological, nuclear and chemical dual-use items and military items, by referring to the Wassenaar Arrangement. China, however, has lacked a comprehensive export control law and, as a result, very few enforcement actions apparently occurred over the past years. However, this situation is going to be changed following the issuance of the draft ECL. The draft ECL is not just a simple combination or repetition of the existing separate PRC export control regulations and rules. Instead, it introduces a comprehensive series of new legal concepts and raises maximum penalties. Once enacted, the law will substantially broaden the outreach of the PRC export control regime and pose significant compliance challenges for multinationals dealing with the PRC controlled items. (1) Who Will Be Impacted? Under the draft ECL, the PRC export control regime can essentially impact any companies buying, selling, shipping, and otherwise dealing with the PRC controlled items. Jurisdiction is extended not only to individuals or entities of the PRC nationality, but also to non-PRC individuals and entities. A wide range of industries may be affected, such as those related to aerospace, military and defense, energy, material-processing, electronics, semiconductor and navigation. Notably, in addition to exporters, foreign importers and end users, the draft ECL also explicitly lists agents, freight forwarders, customs brokers, e-commerce platforms and financial service providers as the parties subject to the PRC export control. (2) What Items Will Be Controlled? Generally, the following four (4) categories of items will be subject to control under the draft ECL: (1) dual-use items; (2) military items; (3) nuclear items; and (4) other items that may affect the national security of China. The control will apply not only to the transfer of “tangible” items, but also to “intangible” items like technologies and services. Most of the items subject to control will be listed in the Dual-Use Items Control List and Munitions Control List to be formulated and periodically adjusted by the PRC regulatory authorities. (3) What Activities Will Be Controlled? The draft ECL applies to a wide array of activities relevant to controlled items, including exports, re-exports deemed exports, and goods subject to transit, transshipment and export via Special Customs Supervision Areas. EU and U.S. companies are already subject to many of these restrictions outside of China, so they likely will be able to navigate the new ECL. That said, they will have to redouble efforts to ensure compliance with BOTH Chinese and EU or US export control laws as China implements the ECL. (4) What Types of Controls? The draft ECL provides for a variety of measures to restrict the export of controlled items. These include export qualification requirements, licensing requirements, comprehensive control requirements (in the case of national security of the PRC), temporary export controls, embargoes, blacklists, and retaliatory measures against “discriminatory” actions by foreign countries. (5) What Types of Penalties for Violations of PRC Export Control Laws? Violation of the PRC export control laws may result in severe administrative or even criminal penalties on the companies and individuals involved. Administrative Penalties
– Depending on the specific situations and severity of the violations, the export operators may be subject to, among others, a fine up to ten (10) times the “illegal turnover,” confiscation of illegal gains (if any) and suspension or revocation of the export license or qualification. The employees, if deemed as the “persons-in-charge” or “other direct responsible persons” (not defined in the draft ECL), may be subject to a fine up to RMB 300,000 (around USD 43,000) as well. Criminal Penalties
– Criminal prosecution will be pursued if the violations constitute a crime. Under the current PRC criminal laws, the following crimes, among others, may be implicated for violations of PRC export control laws: (1) the crime of smuggling weapons, nuclear materials or prohibited items; (2) the crime of illegal operation; and (3) the crime of stealing, spying, acquiring or illegally providing state secrets or intelligence to foreign entities or individuals. The penalties for these violations could include both a monetary fine and imprisonment (up to life imprisonment in some cases, for instance, the smuggling of military products and similar items). * * * * * * * * * * * * * * * * * * * *
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EX/IM TRAINING EVENTS & CONFERENCES |
13 . 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: “ Webinars On-Demand Library ;” Sandler, Travis & Rosenberg, P.A. Training by Date: * Sep 14: Milpitas, CA; “ Encryption Controls;” Dept. of Commerce/Bureau of Industry and Security * Sep 18-21: Austin, TX; “ITAR Defense Trade Controls / EAR Export Controls Seminar; ECTI; jessica@learnexportcompliance.com; 540-433-3977 * Sep 27-28: Rome, Italy; “Defence Exports 2017;” SMi * Oct 25-26: Tysons Corner, VA; ITAR Fundamentals; FD Associates * Nov 16: Nijkerk, the Netherlands; “Training Export Control” [in Dutch]; Fenedex * Dec 4-7: Miami FL; “ITAR Defense Trade Controls / EAR Export Controls Seminar;” ECTI; jessica@learnexportcompliance.com; 540-433-3977 * Dec 5: San Juan, PR; “AES Compliance Seminar in Spanish;” Dept. of Commerce/Census Bureau; itmd.outreach@census.gov 2018 * * * * * * * * * * * * * * * * * * * * | |
| EDITOR’S NOTES |
14 . Bartlett’s Unfamiliar Quotations (Source: Editor) * Swami Sivananda (Sivananda Saraswati (or Swami Sivanada); 8 Sep 1887 – 14 Jul 1963; was a Hindu spiritual teacher and a proponent of Yoga and Vedanta. He was the founder of the Divine Life Society (DLS) in 1936, Yoga-Vedanta Forest Academy (1948) and author of over 200 books on yoga, Vedanta, and a variety of subjects. Sivananda Yoga, the yoga form propagated by his disciple Vishnudevananda, is now spread in many parts of the world through Sivananda Yoga Vedanta Centres.) – “Put your heart, mind, and soul into even your smallest acts. This is the secret of success.” – “Do not brood over your past mistakes and failures as this will only fill your mind with grief, regret, and depression. Do not repeat them in the future.” Friday Funnies: A customer was continually bothering a waiter in a restaurant. First, he asked that the air conditioning be turned up because he was too cold, then he asked it be turned down because he was too hot, and so on, for about half an hour. Surprisingly, the waiter was very patient, he walked back and forth at every request and never once got angry. So finally, a second customer asked him why he didn’t throw out the pest. “Oh I don’t care,” said the waiter with a smile. “We don’t even have an air conditioner.” Q. How many college registrar workers does it take to change a light bulb? A. One, but they’ll make you wait in line for three hours before they let you know that the bulb you want is no longer available. — George Brusseler, Allentown, PA * * * * * * * * * * * * * * * * * * * *
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15. 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. – 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. – Last Amendment: 28 Jul 2017: 82 FR 35064-35065: Technical Corrections to U.S. Customs and Border Protection Regulations – Last Amendment: 15 Aug 2017: 82 FR 38764-38819: Wassenaar Arrangement 2016 Plenary Agreements Implementation – Last Amendment: 16 Jun 2017: 82 FR 27613-27614: Removal of Burmese Sanctions Regulations – 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. – HTS codes for AES are available here. – HTS codes that are not valid for AES are available here. – 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. * * * * * * * * * * * * * * * * * * * *
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16 . Weekly Highlights of the Daily Bugle Top Stories (Source: Editor) Review last week’s top Ex/Im stories in “Weekly Highlights of Daily Bugle Top Stories” posted here. * * * * * * * * * * * * * * * * * * * *
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| * 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.
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