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17-0914 Thursday “Daily Bugle”

17-0914 Thursday “Daily Bugle”

Thursday, 14 September 2017

TOP
The Daily Bugle is a free daily newsletter from Full Circle Compliance, containing changes to export/import regulations (ATF, Customs, NISPOM, EAR, FACR/OFAC, FTR/AES, HTSUS, and ITAR), plus news and events.  Subscribe 
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  1. Commerce/BIS: Alexey Krutilin, a/k/a David Powell, of Ivanovskoe Village, Russia, Denied Export Privileges for 10 Years 
  2. Commerce/BIS: Ambar Esthela Morales of Fort Worth, TX, Denied Export Privileges for 5 Years
  3. Commerce/BIS: Dimitrii Karpenko, a/k/a Simon Fox, of Nevinnomyssk, Russia, Denied Export Privileges for 5 Years 
  1. Ex/Im Items Scheduled for Publication in Future Federal Register Editions
  2. Commerce/BIS: (No new postings.)
  3. DHS/CBP Disables Application IDs with ACE Deployment G2 on 15 Sep
  4. DHS/CBP Releases Update Concerning Local Closure for Ports of 5201,5203,5204, and 5206 During Hurricane Irma
  5. DHS/CBP Releases Update Concerning Operational Status for Port of Brunswick, GA (1701) 
  6. State/DDTC Posts Name and Address Change Announcement 
  7. Treasury/OFAC Releases Statement on the President’s Decision Concerning Lattice Semiconductor Corporation 
  8. White House Releases Presidential Order Concerning Proposed Acquisition of Lattice Semiconductor Corporation by China Venture Capital Fund Corporation Limited 
  1. Iran News Update: “Three People Charged with Exporting Goods to Iran in Violation of U.S. Embargo”
  2. The New York Times: “Forced Searches of Phones and Laptops at U.S. Border Are Illegal, Lawsuit Claims”
  3. Reuters: “U.S. to Extend Iran Sanctions Relief Under Nuclear Deal: Sources”
  4. The Washington Times: “Trump Blocks Chinese Deal to Buy U.S. Chips with Military Uses”
  1. A. Wong: “Malaysia’s Strategic Trade (Amendment) Act 2017”
  2. F. Jalinous, K. Mildorf & K. Schomig: “CFIUS: President Trump Blocks Acquisition of Lattice Semiconductor by Canyon Bridge”
  3. M. Lester: “UK Government Says UK and EU Will Be ‘Stronger Acting Together’ on Sanctions and Foreign Policy Post-Brexit”
  4. R.C. Burns: “Beware the Smiley Face!”
  1. ECTI Presents “EAR License Exceptions: Learning by Doing Webinar – A Two Part Series,” 17 & 26 Oct 
  2. NAITA Presents 2017 Export Control Update (ITAR/EAR/OFAC) on 18-19 Sep in Huntsville, AL 
  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
1. Commerce/BIS: Alexey Krutilin, a/k/a David Powell, of Ivanovskoe Village, Russia, Denied Export Privileges for 10 Years

(Source: Federal Register) [Excerpts.]
 
82 FR 43218-43219: In the Matter of: Alexey Krutilin, a/k/a David Powell, 16 Melioratorov Street, Ivanovskoe Village, Stavropol Region, Russia 357020; Order Denying Export Privileges
 
  On April 28, 2017, in the U.S. District Court for the Eastern District of New York, Alexey Krutilin a/k/a David Powell (“Krutilin”) was convicted of violating the International Emergency Economic Powers Act (50 U.S.C. 1701, et seq. (2012)) (“IEEPA”). Specifically, Krutilin was convicted of violating Section 206 of IEEPA, 50 U.S.C. 1705, by willfully conspiring with others to export from the United States to Russia microelectronics items controlled pursuant to the Export Administrations Regulations (“EAR” or “Regulations”), [FN/1] and under the jurisdiction of the Bureau of Industry and Security (“BIS”), U.S. Department of Commerce (“DOC”), without the required BIS/DOC license. Krutilin was sentenced to time served and an assessment of $100.00. …
  Based upon my review and consultations with BIS’s Office of Export Enforcement, including its Director, and the facts available to BIS, I have decided to deny Krutilin’s export privileges under the Regulations for a period of ten (10) years from the date of Krutilin’s conviction. I have also decided to revoke all licenses issued pursuant to the Act or Regulations in which Krutilin had an interest at the time of his conviction. …
  [T]his Order is effective immediately and shall remain in effect until April 28, 2027.
 
  Dated: September 8, 2017.
Karen H. Nies-Vogel, Director, Office of Exporter Services.

——–
  [FN/1] The Regulations are currently codified in the Code of 
Federal Regulations at 15 CFR parts 730-774 (2017). The Regulations issued pursuant to the Export Administration Act (50 U.S.C. 4601-4623 (Supp. III 2015) (available here) (“EAA” or “the Act”). Since August 21, 2001, the Act has been in lapse and the President, through Executive Order 13222 of August 17, 2001 (3 CFR, 2001 Comp. 783 (2002)), which has been extended by successive Presidential Notices, the most recent being that of 
August 15, 2017 (82 FR 39005 (Aug. 16, 2017)), has continued the Regulations in effect under the International Emergency Economic Powers Act (50 U.S.C. 1701, et seq. (2012)).

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EXIM_a22. Commerce/BIS: Ambar Esthela Morales of Fort Worth, TX, Denied Export Privileges for 5 Years

(Source: Federal Register) [Excerpts.]
 
82 FR 43216-43217: In the Matter of: Ambar Esthela Morales, Inmate Number: 42245-408, FMC Carswell, Federal Medical Center, P.O. Box 27137, Fort Worth, TX 76127; Order Denying Export Privileges
 
  On March 23, 2016, in the U.S. District Court for the District of Arizona, Ambar Esthela Morales (“Morales”) was convicted of violating Section 38 of the Arms Export Control Act (22 U.S.C. 2778 (2012)) (“AECA”). Specifically, Morales was convicted of knowingly and willfully attempting to export from the United States to Mexico defense articles designated on the United States Munition List, namely, 7,942 rounds of 7.62 x 39mm caliber ammunition, without the required U.S. Department of State license. Morales was sentenced to three years in prison, three years of supervised release, and a $100 assessment. …
  Based upon my review and consultations with BIS’s Office of Export Enforcement, including its Director, and the facts available to BIS, I have decided to deny Morales’s export privileges under the Regulations for a period of five years from the date of Morales’s conviction. I have also decided to revoke all licenses issued pursuant to the Act or Regulations in which Morales had an interest at the time of her conviction. …
  [T]his Order is effective immediately and shall remain in
effect until March 23, 2021.
 
  Dated: September 8, 2017.
Karen H. Nies-Vogel, Director, Office of Exporter Services.

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EXIM_a33. Commerce/BIS: Dimitrii Karpenko, a/k/a Simon Fox, of Nevinnomyssk, Russia, Denied Export Privileges for 5 Years

(Source: Federal Register) [Excerpts.]
 
82 FR 43217-43218: In the Matter of: Dmitrii Karpenko, a/k/a Simon Fox, Pavlova St 11-75, Nevinnomyssk, Stavropol Region, Russia; Order Denying Export Privileges
 
  On April 28, 2017, in the U.S. District Court for the Eastern District of New York, Dmitrii Karpenko, a/k/a Simon Fox (“Karpenko”) was convicted of violating the International Emergency Economic Powers Act (50 U.S.C. 1701, et seq. (2012)) (“IEEPA”). Specifically, Karpenko was convicted of violating Section 206 of IEEPA, 50 U.S.C. 1705, by willfully conspiring with others to export from the United States to Russia microelectronics items controlled pursuant to the Export Administration Regulations (“EAR” or “Regulations”) [FN/1], and under the jurisdiction of the Bureau of Industry and Security (“BIS”), U.S. Department of Commerce (“DOC”), without the required BIS/DOC license. Karpenko was sentenced to time served and an assessment of $100.00. …
  Based upon my review and consultations with BIS’s Office of Export Enforcement, including its Director, and the facts available to BIS, I have decided to deny Karpenko’s export privileges under the Regulations for a period of five (5) years from the date of Karpenko’s conviction. I have also decided to revoke all licenses issued pursuant to the Act or Regulations in which Karpenko had an interest at the time of his conviction. …
  [T]his Order is effective immediately and shall remain in effect until April 28, 2022.
 
  Dated: September 8, 2017.
Karen H. Nies-Vogel, Director, Office of Exporter Services.
 
——–
  [FN/1] The Regulations are currently codified in the Code of 
Federal Regulations at 15 CFR parts 730-774 (2017). The Regulations 
issued pursuant to the Export Administration Act (50 U.S.C. 4601-4623 (Supp. III 2015) (available here) (“EAA” or “the Act”). Since August 21, 2001, the Act has been in lapse and the President, through Executive Order 13222 of August 17, 2001 (3 CFR, 2001 Comp. 783 (2002)), which has been extended by 
successive Presidential Notices, the most recent being that of 
August 15, 2017 (82 FR 39005 (Aug. 16, 2017)), has continued the Regulations in effect under the International Emergency Economic Powers Act (50 U.S.C. 1701, et seq. (2012)).

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OGSOTHER GOVERNMENT SOURCES

OGS_a14. Ex/Im Items Scheduled for Publication in Future Federal Register Editions
(Source:
Federal Register)

 

* DHS/CBP; NOTICES; Electronic Foreign Trade Zone Admission Applications: Delay of Transition from the Automated Commercial System to the Automated Commercial Environment [Publication Date: 15 Sep 2017.]

 
* Treasury/OFAC; NOTICES; Blocking or Unblocking of Persons and Properties [Publication Date: 15 Sep 2017.]

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OGS_a36.

DHS/CBP Disables Application IDs with ACE Deployment G2 on 15 Sep

(Source:
CSMS# 17-000572, 14 Sep 2017)
 
On Friday, September 15, 2017, at 5:00 P.M. EST, the following Application IDs will be disabled in ACS:

– CI – Automated Invoice Interface
– CP – PGA Data Corrections
– DN – Entry Date Update Transaction
– EI – Entry Summary Create/Update
– FN – OGA Query FWS Species Query
– KN and IJ – Consignee Name/Address
– KJ – NAFTA Duty Deferral
– MJ – OGA Query – FDA Product Code Build Query
– NP – OGA Query – Product Code Query
– OP – PGA Query
– PP – OGA Query – FDA FEI Add/Query
 
U.S. Customs and Border Protection (CBP) has updated the ACS to ACE Application Transition Plan document posted on CBP.gov in accordance with the information above. The ACS to ACE Application Transition Plan document provides the trade community a list of Automated Broker Interface (ABI) transactions (a) available exclusively in ACE, (b) available concurrently in both ACS and ACE, (c) scheduled to be transitioned from ACS to ACE, (d) moved to other online resources, or (e) will not be transitioned to ACE. This document may be used to track the application IDs that have been disabled in ACS and transitioned to ACE to date.
 
To review the updated ACS to ACE Application Transition Plan, please visit the ACE ABI CBP and Trade Automated Interface Requirements (CATAIR) page of CBP.gov/ACE, and click on the ACS to ACE Application Transition Plan hyperlink. You may also go here.
 
For additional questions concerning the disabled ACS Application IDs, please contact your assigned Client Representative.

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OGS_a47
.

DHS/CBP Releases Update Concerning Local Closure for Ports of 5201,5203,5204, and 5206 During Hurricane Irma

(Source:
CSMS# 17-000571, 14 Sep 2017.)
 
Commercial trade operations at the Ports of 5201 (Miami Seaport) 5203 (Port Everglades) 5204 (Port of West Palm Beach) and 5206 (Miami International Airport) were temporarily suspended on September 11, 2017 due to the effects of Hurricane Irma. Commercial trade operations resumed normal operations on Tuesday, September 12, 2017.
 
Due to effects of Hurricane Irma, on September 8 through September 12, 2017, local closure days are granted to all who file entries at the Ports of 5201 (Miami Seaport), 5203 (Port Everglades), 5204 (Port of West Palm Beach), and 5206 (Miami International Airport).
 
CBP is extending additional days, without penalty, for any entry summaries and payments of duties that were due on September 8 through September 12, 2017 in the Ports of 5201 (Miami Seaport) 5203 (Port Everglades), 5201 (Port of West Palm Beach, and 5206 (Miami International Airport).

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OGS_a58
.

DHS/CBP Releases Update Concerning Operational Status for Port of Brunswick, GA (1701) 

(Source:
CSMS# 17-000570, 14 Sep 2017)
 
CBP at the Port of Brunswick, GA (1701) is operational for all commercial trade operations, vessel and aircraft operations as of Thursday, September 14, 2017 at 08:00.
 
  – Related CSMS No. 17-000567

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OGS_a69
.
State/DDTC Posts Name and Address Change Announcement

(Source: State/DDTC) [Excerpts.]
 
 
Effective immediately, Titan Company Limited at Precision Engineering Division, 15B, Bommasandra Industrial Area, Bangalore – 560099, Karnataka, India will change as follows: Titan Engineering & Automation Limited at Unit-II, No. 141, S. Muduganapalli, Denkanikottai Road, Hosur – 635110, Tamilnadu, India. 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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OGS_a710
.
Treasury/OFAC Releases Statement on the President’s Decision Concerning Lattice Semiconductor Corporation

(Source: Treasury/OFAC)
 
As chair of the Committee on Foreign Investment in the United States (CFIUS), Steven T. Mnuchin, Secretary of the Treasury today issued the following statement about the President’s decision regarding Lattice Semiconductor Corporation.
 
Today, consistent with the Administration’s commitment to take all actions necessary to ensure the protection of U.S. national security, the President issued an order prohibiting the acquisition of Lattice Semiconductor Corporation (Lattice) by Canyon Bridge Fund I, LP (CBFI); CBFI’s subsidiaries; CBFI’s limited partner, Yitai Capital Limited (Yitai); and Yitai’s parent company, China Venture Capital Fund Corporation Limited (CVCF) (together, the Purchasers). The order directs the Purchasers and Lattice to take all steps necessary to fully and permanently abandon the proposed acquisition of Lattice not later than 30 days after the date of the order.
 
CVCF is a Chinese corporation owned by Chinese state-owned entities that manages industrial investments and venture capital.  Lattice is a publicly traded company headquartered in Oregon that manufactures semiconductors for the consumer, communications, and industrial markets.  Lattice’s primary semiconductor product lines are programmable logic devices, which are general purpose semiconductors that customers can program to provide functionality similar to chips that are designed and produced for specific applications.
 
The President took this action pursuant to section 721 of the Defense Production Act of 1950, as amended by the Foreign Investment and National Security Act of 2007 (Section 721).  Section 721 authorizes the President to suspend or prohibit certain acquisitions of U.S. businesses by foreign persons where he finds that there is credible evidence that the foreign interest exercising control might take action that threatens to impair national security, and where provisions of law other than Section 721 and the International Emergency Economic Powers Act do not provide adequate and appropriate authority to protect national security in the matter under review.
 
The President’s decision took into consideration the factors described in Section 721’s subsection (f), as appropriate, and the recommendation by CFIUS that he issue an order prohibiting this transaction.  CFIUS and the President assess that the transaction poses a risk to the national security of the United States that cannot be resolved through mitigation. The national security risk posed by the transaction relates to, among other things, the potential transfer of intellectual property to the foreign acquirer, the Chinese government’s role in supporting this transaction, the importance of semiconductor supply chain integrity to the U.S. government, and the use of Lattice products by the U.S. government.
 
CFIUS is an interagency committee whose purpose is to review transactions that could result in the control of a U.S. business by a foreign person, in order to determine the effect of such transactions on the national security of the United States.  CFIUS’s detailed analysis of the proposed transaction took into account all relevant national security factors, as enumerated in Section 721.  CFIUS also received a thorough analysis of the threat posed by this transaction from the Office of the Director of National Intelligence, as required by Section 721.
 
Consistent with the longstanding, bi-partisan U.S. commitment to open investment, the CFIUS process focuses exclusively on identifying and addressing national security concerns.  This focused mandate reinforces our commitment to welcoming foreign investment, while at the same time reinforcing our commitment to protecting national security. 
 
Note: CFIUS is chaired by the Secretary of the Treasury and includes as members the Secretaries of State, Defense, Commerce, Energy, and Homeland Security, the Attorney General, the Director of the White House Office of Science and Technology Policy, and the U.S. Trade Representative.  The Director of National Intelligence and the Secretary of Labor participate as non-voting, ex-officio members. CFIUS involves other agencies of the Executive Branch in its deliberations on a case-by-case basis.

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OGS_a811
.
White House Releases Presidential Order Concerning Proposed Acquisition of Lattice Semiconductor Corporation by China Venture Capital Fund Corporation Limited

(Source: The White House)
 
ORDER REGARDING THE PROPOSED ACQUISITION OF LATTICE SEMICONDUCTOR CORPORATION BY CHINA VENTURE CAPITAL FUND CORPORATION LIMITED
 
By the authority vested in me as President by the Constitution and the laws of the United States of America, including section 721 of the Defense Production Act of 1950, as amended (section 721), 50 U.S.C. 4565, it is hereby ordered as follows:
 
Section 1.  Findings. 
  (a)  There is credible evidence that leads me to believe that (1) Canyon Bridge Merger Sub, Inc., a corporation organized under the laws of Delaware (Merger Sub); (2) Merger Sub’s parent companies Canyon Bridge Acquisition Company, Inc., a corporation organized under the laws of Delaware (Acquisition Company), Canyon Bridge Capital Investment Limited, an entity organized under the laws of the Cayman Islands (Capital Investment), and Canyon Bridge Fund I, LP (CBFI), a limited partnership organized under the laws of Delaware; and (3) CBFI’s limited partner Yitai Capital Limited, a company organized under the laws of Hong Kong (Yitai), and Yitai’s parent company China Venture Capital Fund Corporation Limited, a corporation organized under the laws of the People’s Republic of China (CVCF and, together with Merger Sub, Acquisition Company, Capital Investment, CBFI, and Yitai, the Purchasers), through exercising control of Lattice Semiconductor Corporation, a corporation organized under the laws of Delaware (Lattice), might take action that threatens to impair the national security of the United States; and
  (b)  Provisions of law, other than section 721 and the International Emergency Economic Powers Act (50 U.S.C. 1701 et seq.), do not, in my judgment, provide adequate and appropriate authority for me to protect the national security in this matter.
 
Sec. 2.  Actions Ordered and Authorized
.  On the basis of the findings set forth in section 1 of this order, considering the factors described in subsection 721(f) of the Defense Production Act of 1950, as appropriate, and pursuant to my authority under applicable law, including section 721, I hereby order that:
  (a)  The proposed acquisition of Lattice by the Purchasers (the proposed transaction) is prohibited, and any substantially equivalent transaction, whether effected directly or indirectly by the Purchasers, through the Purchasers’ shareholders or shareholders’ immediate, intermediate, or ultimate foreign person beneficial owners, or through the Purchasers’ subsidiaries, is also prohibited.
  (b)  The Purchasers and Lattice shall take all steps necessary to fully and permanently abandon the proposed transaction not later than 30 days after the date of this order, unless such date is extended by the Committee on Foreign Investment in the United States (CFIUS) for a period not to exceed 90 days, on such conditions as CFIUS may require.  Immediately upon completion of all steps necessary to terminate the proposed transaction, the Purchasers and Lattice shall certify in writing to CFIUS that such termination has been effected in accordance with this order and that all steps necessary to fully and permanently abandon the proposed transaction have been completed.
  (c)  From the date of this order until the Purchasers and Lattice provide a certification of termination of the proposed transaction to CFIUS pursuant to subsection (b) of this section, the Purchasers and Lattice shall certify to CFIUS on a weekly basis that they are in compliance with this order and include with that certification a description of all efforts to permanently abandon the proposed transaction and a timeline for projected completion of remaining actions necessary to effectuate the abandonment.
  (d)  Any transaction or other device entered into or employed for the purpose of, or with the effect of, avoiding or circumventing this order is prohibited.
  (e)  The Attorney General is authorized to take any steps necessary to enforce this order.
 
Sec. 3.  Reservation
.  I hereby reserve my authority to issue further orders with respect to the Purchasers or Lattice as shall in my judgment be necessary to protect the national security of the United States.
 
Sec. 4.  Publication and Transmittal. 
  (a)  This order shall be published in the Federal Register.
  (b)  I hereby direct the Secretary of the Treasury to transmit a copy of this order to the parties to the proposed transaction named in section 1 of this order.
 
  DONALD J. TRUMP
 
THE WHITE HOUSE,
September 13, 2017.

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NWSNEWS

NWS_a112
.
Iran News Update: “Three People Charged With Exporting Goods to Iran in Violation of U.S. Embargo”

(Source: Iran News Update, 13 Sep 2017) [Excerpts.]
 
Three people have been charged with exporting millions of dollars worth of goods to Iran in violation of US sanctions, in Ohio.
 
Mohammad Khazrai Shaneivar, Arezoo Hashemnejad Alalmdari, and Parisa Mohamadi were charged in Cleveland federal court earlier this week for exporting products to “safe” countries like the United Arab Emirates and Turkey, where they would they be forwarded to Iran.
 
They were charged with conspiracy to defraud the US, conspiracy to violate the International Emergency Economic Powers Act, and smuggling, back in June but the indictment was not unsealed until last week when Mohamadi, 52, was arrested in the US.
 
The trade embargo against Iran was passed in 1995 by Bill Clinton in response to policies and actions from the Iranian Regime, regarding terrorist activity and attempts at creating a nuclear weapons programme, which constituted a threat to US national security.
 
As a result, exports from the US to Iran are banned except in very rare circumstances, when the US government grants permission.
 
The Department of Homeland Security said that the defendants did not have permission to export these goods.
 
The defendants also used the Canadian company IC Link Industries, which is operated by Shaneivar, to export the goods to an affiliate business in Iran, as Shaneivar and Alamdari live in Canada.
 
According to the indictment, Shaneivar would receive orders for US industrial goods from Alamdari and others on behalf of customers in Iran.
 
IC Link would then send requests to a person, named only as “M.S” in the docket, who lives in Ohio and operates two businesses that obtain US goods for resale in other countries. If the price was acceptable, M.S would then ship the items, which would end up in Iran.
 
Occasionally, M.S would be told to undervalue the goods, repackage them, or remove serial numbers to avoid raising suspicion with the US Government about what was being shipped out of the country.
 
The goods were to be used in industries like oil, gas, energy and petroleum among others. One customer was Kala Naft, the procurement arm of the National Iranian Oil Company, according to the indictment.
 
Mohamadi, who also goes by Parisa Javidi, also has a criminal complaint filed against her in January for her involvement in over 70 potential or completed transactions worth more than $3 million between 2010 and 2012.
 

Mohamadi, who has addresses all over the world, has pleaded not guilty but remains in the custody of the US Marshals Service.

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NWS_a213

The New York Times: “Forced Searches of Phones and Laptops at U.S. Border Are Illegal, Lawsuit Claims”

(Source: The New York Times, 13 Sep 2017) [Excerpts.]
 
Eleven people whose phones and laptops were searched at United States airports and at the nation’s northern border are suing the Department of Homeland Security, joining a growing chorus of critics who say the forced inspections are invasive and unlawful.
 
The lawsuit, filed Wednesday by the American Civil Liberties Union and the Electronic Frontier Foundation, claims the plaintiffs’ First and Fourth Amendment rights were violated when United States agents searched, and in some cases confiscated, their devices without a warrant. The government has said those searches happen to fewer than one-hundredth of one percent of international travelers, and that they are authorized by the same laws that allow border agents to look through suitcases without a judge’s approval.
 
But privacy activists say the laws, which were crafted with luggage in mind, shouldn’t apply to digital devices that contain vast amounts of personal data related to the device owners and others they have contacted. …
 
The searches, which began under the George W. Bush administration and became more common during the Obama administration, have sharply increased in the past year. According to the most recent data available, there were nearly 15,000 searches from October 2016 to March 2017, compared with 8,383 in the same period a year before. …
 
In March, Joseph B. Maher, the acting general counsel for the agency, defended the practice in a USA Today opinion piece.
 
  “These electronic media searches have produced information used to combat terrorism, violations of export controls, and convictions for child pornography, intellectual property rights violations and visa fraud,” he wrote. “This authority is critical to our mission, and Customs exercises it judiciously.” …

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NWS_a314

Reuters: “U.S. to Extend Iran Sanctions Relief Under Nuclear Deal: Sources”

(Source: Reuters, 14 Sep 2017)
 
The United States on Thursday will announce that it will extend wide sanctions relief for Iran under the 2015 nuclear deal, sources familiar with the matter said, but no decision on whether to preserve the deal itself has yet been made.
 
The United States will renew a waiver of the key, and most punitive, sanctions that it imposed on Iran before the nuclear deal was ultimately struck, the sources said.
 
Tucked into Section 1245 of the 2012 National Defense Authorization Act, Washington threatened to sanction the banks of Iran’s main oil customers if they did not significantly cut their purchases of Iranian crude.
 
Under the law, these sanctions can be waived for a maximum of 120 days, forcing the U.S. government revisit the issue every four months. Former President Barack Obama’s administration, which negotiated the deal, did so in mid-January and President Donald Trump’s administration did so again on May 17.
 
Sources familiar with the matter stressed that the wider U.S. policy toward Iran, and whether to preserve the deal that gave Tehran sanctions relief in exchange for curbing its nuclear program, has yet to be decided. Trump has criticized the deal, but some of his top advisers believe he should preserve it.

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NWS_a415

The Washington Times: “Trump Blocks Chinese Deal to Buy U.S. Chips with Military Uses”

(Source: Washington Times, 13 Sep 2017.) [Excerpts.]
 
President Trump blocked a Chinese firm from buying a U.S. computer chip maker Wednesday, demonstrating to Beijing that he will oppose acquisition of technology with potential military applications.
 
The decision derailed a planned $1.3 billion deal for Chinese-backed venture capitalists, including Canyon Bridge Fund, to buy Lattice Semiconductor Corporation in Portland, Oregon.
 
It was the latest in a series of Mr. Trump’s get-tough trade moves against China, following investigations into the communist country’s dumping products in the U.S. and stealing American technology and intellectual property.
 
This time he opted for a rarely used power to block foreign business deals under the Defense Production Act. It authorizes the president to suspend or prohibit certain acquisitions that result in foreign control of a U.S. business when there is credible evidence it could pose a threat to national security.
 
  “The national-security risk posed by the transaction relates to, among other things, the potential transfer of intellectual property to the foreign acquirer, the Chinese government’s role in supporting this transaction, the importance of semiconductor supply chain integrity to the United States Government, and the use of Lattice products by the United States Government,” the White House said in a statement. … 

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COMMCOMMENTARY

COMM_a01
16

A. Wong: “Malaysia’s Strategic Trade (Amendment) Act 2017”

(Source: Baker McKenzie)
 
* Author: Adeline Wong, Esq., adeline.wong@wongpartners.com, Baker McKenzie, Kuala Lumpur, Malaysia.
 
Following the publication of the Strategic Trade (Amendment) Act 2017 (Amending Act) in the Federal Gazette on 21 June 2017, the Malaysian Government has appointed 8 September 2017 as the date on which the changes effected under the Amending Act have come into operation.
 
Background
 
The Malaysian export control rules are prescribed under the Strategic Trade Act 2010 (STA) which was first implemented on 1 January 2011. The provisions of the STA apply to any person who exports, transships, brings-in-transit and brokers strategic items or unlisted items, whereby a permit is required from relevant authorities including the Strategic Trade Controller of the Ministry of International Trade and Industry (MITI).
 
Key Changes
 
In our earlier client alert published on 4 July 2017, we have discussed in detail the key changes introduced under the Amending Act, which can be summarized as follows:
 
  (a) Refined ‘brokering’ definition and carve-out for ‘ancillary services’
  (b) Broader definition of ‘authorized officers’
  (c) Presumption as to export
  (d) Requirement of ‘End-Use’ Statements now optional rather than mandatory
  (e) Replacement of minimum fines to maximum fines
  (f) Power to compound offences under the STA
 
For more information on the Amending Act and how it can affect your business, please see our earlier client alert published on 4 July 2017 here.
 
Regulations for Compounding of Offences Expected to be Published
 
We wish to highlight that the new Section 50A under the Amending Act empowers MITI (with the approval of the Public Prosecutor) to make regulations to prescribe:
 
  (a) any offence under the STA and any regulations made under the STA that may be compounded;
  (b) the criteria for compounding such offence; and
  (c) the method and procedure for compounding such offence.
 
We understand that the drafting of the regulations are currently underway and the regulations are expected to be finalized and published in the Federal Gazette in due course, possibly by the end of the first quarter of 2018.
 
Conclusion
 
In view of the significant changes introduced by the Amending Act, companies must familiarize themselves with such amendments and thoroughly review their existing supply chain and internal protocols, to ensure continuous compliance with the law. As previously highlighted, whilst the Amendment Act has introduced more flexibility to the STA, the extension of enforcement powers to additional government authorities and agencies may result in more stringent enforcement of export control rules going forward.

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COMM_a1b
17
F. Jalinous, K. Mildorf & K. Schomig: “CFIUS: President Trump Blocks Acquisition of Lattice Semiconductor by Canyon Bridge”

(Source:
White & Case LLP
)
 
* Authors: Farhad Jalinous, Esq.,
farhad.jalinous@whitecase.com
; Karalyn Mildorf, Esq.,
karalyn.mildorf@whitecase.com
; and Keith Schomig, Esq.,
keith.schomig@whitecase.com
.  All of White & Case LLP, Wash DC.
 
President Trump blocked the proposed $1.3 billion acquisition of Lattice Semiconductor Corporation, a US chipmaker, by Canyon Bridge Capital Partners, a US-headquartered private equity firm reportedly funded by the Chinese government. This is only the fourth transaction blocked by a US president under the CFIUS statute, though it is the second in the past ten months.

Following the recommendation of the Committee on Foreign Investment in the United States (“CFIUS”), which is a committee of Executive Branch agencies tasked with assessing national security concerns associated with foreign direct investment into the United States, President Trump
issued an order
 on Wednesday blocking the proposed acquisition of Lattice Semiconductor Corporation (“Lattice”) by Canyon Bridge Capital Partners (“Canyon Bridge”). The proposed transaction went through three 75-day CFIUS review and investigation cycles, during which CFIUS apparently determined that the transaction presented national security concerns that could not be addressed through mitigation measures. The parties reportedly proposed mitigation terms to address national security concerns, which were not accepted. CFIUS referred the transaction to President Trump for a decision, which is a rare step.
 
Lattice is a US-based semiconductor company that makes programmable logic devices for the consumer, communications, and industrial markets. Canyon Bridge is a private equity firm headquartered in Silicon Valley with operations in Beijing, China. It has been reported that the sole identified investor in Canyon Bridge is owned and controlled by the Chinese government.

Under the CFIUS statute, only the President has the authority to prohibit transactions due to national security concerns. Although CFIUS is not authorized to block deals, it can impose broad mitigation measures where it determines such requirements can effectively address national security issues. In cases where CFIUS determines that national security concerns cannot be mitigated, it typically recommends that parties formally commit to abandoning the transaction and withdraw their filing. In most cases, the parties agree to terminate the transaction (or to divest, if the transaction has already been completed). In this case, however, the parties may have concluded that there was little downside to a presidential review and hoped that President Trump might be willing to approve the transaction despite CFIUS’s objections.
 
The following are some key takeaways:
 
  – Chinese investments, particularly in the semiconductor area, continue to get heavy scrutiny. CFIUS, Congress, and several published reports have focused substantial attention on risks related to foreign investment in semiconductor technology, which can have sensitive military applications. The Lattice transaction is the latest in a string of failed transactions involving foreign-primarily Chinese- investment in semiconductor companies. CFIUS concerns have pertained to a variety of issues, 
including the specific technology associated with the target companies, security of the defense supply chain, and the know-how and technical knowledge resident in the companies.
 
Given that China has reportedly committed to investing $150 billion to advance its semiconductor industry, Chinese investors are likely to continue to look for opportunities to invest in US semiconductor companies, and political attention around these transactions will likely continue. Therefore, parties should expect substantial scrutiny of all semiconductor transactions involving Chinese investors. CFIUS looks at each transaction on a case-by-case basis, considering the specific investor and target company. In this case, the White House and the Treasury Department specified that “the national security risk posed by the transaction relates to, among other things, the potential transfer of intellectual property to the foreign acquirer, the Chinese government’s role in supporting this transaction, the importance of semiconductor supply chain integrity to the U.S. government, and the use of Lattice products by the U.S. government.”
 
  – Investors are likely to continue to seek transaction structures that potentially minimize CFIUS risk. It has been reported that the investment structure for the Lattice acquisition was intended to minimize CFIUS risk. Despite this effort, CFIUS found the transaction to be subject to its jurisdiction and ultimately determined it presented unresolvable national security concerns. CFIUS interprets its jurisdiction broadly and undoubtedly will continue to do so. In our experience, investors are becoming increasingly open to considering transaction structures that can help minimize CFIUS risk. Since CFIUS does not issue advisory opinions, including about whether a particular transaction is subject to CFIUS’s jurisdiction, only a formal notification of the transaction will solicit CFIUS’s binding feedback.
 
  – Presidential reviews may become more frequent. Presidential decisions are historically quite rare. There have only been four presidential blocks since Congress gave the President the power to prohibit transactions on national security grounds when it originally passed the CFIUS statute in 1988. That said, three of the blocks have been in the past five years-and two in the past ten months alone. While parties may be more inclined to risk presidential review going forward, this strategy might well be abandoned quickly if the President consistently defers to CFIUS and blocks transactions at its recommendation. There have also been discussions about potential legislative changes that could empower CFIUS to directly prohibit transactions, which would avoid the potential political fallout of presidential decisions. Notably, under the current CFIUS statute, the President is required to publicly announce the decision whether to suspend or prohibit a transaction, whereas the entire CFIUS process is otherwise confidential.
 
  – The United States remains open to foreign investment, but the CFIUS atmosphere and process are evolving. CFIUS is reviewing a record number of transactions and is currently on track to review well over 200 this year-the largest amount in the modern CFIUS era. Given the combination of the intense caseload and current vacancies in political positions in CFIUS member agencies, the CFIUS review process is taking longer, and CFIUS appears to be acting somewhat more conservatively in adjudicating transactions. CFIUS is generally taking more time to comment on draft prefilings and to accept filings and formally begin reviews, increasing the time on the front end of the CFIUS process. There have also recently been a number of reviews that have been withdrawn and resubmitted, which is an approach often taken when CFIUS needs more time to complete its review than the statutorily mandated 30- and 45-calendar-day periods (the refiling restarts the statutory review period). Particularly for complex transactions, parties should now factor in the possibility of CFIUS reviews taking longer. In addition to these issues, the Trump Administration has indicated that it is considering policy adjustments, which could impact how cases-particularly those involving more sensitive target companies and acquirers from rival countries-are reviewed and adjudicated.
 
Legislation aimed at updating the CFIUS process may also be introduced this year. The anticipated leading bill is being sponsored by John Cornyn, the Senate Majority Whip. Senator Cornyn has indicated that the bill will be designed to modernize (rather than overhaul) the CFIUS process, including applying special requirements for transactions involving sensitive technologies and investors from countries of concern. While Senator Cornyn has stated his bill will not change either the US policy of being open to foreign direct investment or CFIUS’s exclusive focus on national security issues, other rumored CFIUS bills may seek to expand CFIUS’s scope to consider economic factors relating to deals, including whether a transaction will present a “net benefit” to the United States. Although it is too early to know whether and how the CFIUS statute may be updated, it appears that Congress is set to start working on the first statutory updates to the CFIUS process in a decade. Such efforts are likely to target, at least in part, widespread concerns about foreign investment in sensitive technology areas, including semiconductors.
 
As the atmosphere around CFIUS continues to evolve, it is more critical than ever to develop a comprehensive CFIUS strategy as early as possible in a transaction.

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COMM_a2
18. M. Lester: “UK Government Says UK and EU Will Be ‘Stronger Acting Together’ on Sanctions and Foreign Policy Post-Brexit”

 
* Author: Maya Lester, Esq., Brick Court Chambers,
maya.lester@brickcourt.co.uk, +44 20 7379 3550.
 
The UK Department for Exiting the European Union has published a position paper [Tuesday] (one of a number of its Brexit position papers) entitled Foreign policy, defence and development: a future partnership paper in which it “discusses options for foreign policy, defence and development collaboration in the future partnership”.  The paper is available here. Key points in the paper are that:
 
(1) The UK has been central to EU foreign policy, including as regards sanctions where the UK:
  – “has been the most active Member State in proposing autonomous EU sanctions as a foreign policy tool”;
  – “has also been able to encourage cooperation between the EU and like-minded partners, including the United States, increasing the reach and impact of agreed measures”; and
  – many of the asset freezes applied to terrorist organizations by the EU are based on UK national proscriptions or asset freezes.
 
(2) “The UK and EU will be stronger acting together.” “Given the shared threats and challenges we face, and the UK’s deep commitment to European values, it is in the interests of both the UK and the EU to continue to work together to meet the challenges of the day, including by “upholding the rules-based international order through aligning sanctions regimes”. “The UK and the EU should remain close partners in foreign policy issues.”
 
(3) The UK “is establishing its own national legal framework for sanctions” (see previous blog) “but continues to see a strong mutual interest in cooperation and collaboration with European partners.” This could be done through “regular dialogue and specific cooperation. The UK and the EU should have regular close consultations on foreign and security policy issues, with the option to agree joint positions on foreign policy issues. This could include cooperation on sanctions listings, including by sharing information and aligning policy where appropriate.”

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COMM_a3
19. 
R.C. Burns: “Beware the Smiley Face!”

(Source:
Export Law Blog
. Reprinted by permission.)
 
* Author: R. Clifton Burns, Esq., Bryan Cave LLP, Wash DC,
Clif.Burns@bryancave.com
, 202-508-6067).
 
A recently unsealed criminal complaint alleges that Parisa Mohamadi, an Iranian-born U.S. citizen, was responsible for exports of approximately $3 million of goods from the United States to Iran between 2010 and 2012. The fact pattern alleged in the indictment is a familiar one: the items, requested by Iranian buyers, were purchased by Mohamadi in the United States and shipped to a free zone company she incorporated in Dubai and then were transshipped to Iran from there.
 
Of course, there is no criminal violation without criminal intent. And in these transshipment fact patterns, where the shipment from the U.S. to Dubai would not require a license (if considered alone) and the shipment from Dubai to Iran was also one that was legal under UAE law, it is conceivable (indeed fairly likely) that the exporter may think that this shipment route is legal. (Remember we live in a country where 7 percent of the population believes that chocolate milk comes from brown cows.)
 
The criminal complaint understands this issue and tries to forward proof of Ms. Mohamadi’s criminal intent.  Truth be told, the government’s proof of criminal intent by Ms. Mohamadi can only be described as, well, completely whack-a-doodle.
 
The first “proof” cited by the complaint is this statement made by Mohamadi in an email:
 
I KNOW WHICH COUNTRIES ARE EMBARGO AND SANCTION AND WHICH COUNTRY WILL BE EMBARGO AND SANCTION, I AM AS SHIP OWNER, SO I KNOW HOW IS SHIPPING WORKS TO FIXED THE SHIPMENTS IN ADVANCE THUS DO NOT WORRY FOR THIS DELIVERY SCHEDULE, I NEVER SHOOT MY SELF.
 
The complaint adds a snarky footnote pointing out that the spelling mistakes and grammatical errors are those of Ms. Mohamadi alone and not an indication of any illiteracy on the part of the investigating DHS agent who signed the affidavit. This snark might have been justified but for the agent’s reference elsewhere in the complaint to an “I-Phone” (for iPhone) and multiple references to “U.S. Principal Party of Interest” (instead of “U.S. Principal Party in Interest”). Of course, nothing in this difficult-to-parse statement is inconsistent with a belief that the shipment was legal if it went through Dubai first.  As Ms. Mohamadi tried to make clear, she never shoots herself.
 
But the agent saved the best “proof” for last (with my bold and italics added):
 

Similarly, on November 1, 2011, Individual D from Iranian Business A emailed MOHAMADI: “How are you. I am at the sanction solution and money transfer conference in the university. So far I we doing it like no one does, very happy to be here, of course I am the youngest here, and and we do it like no one. That’s what separate us from the others.” MOHAMADI responded: “Good to hear that we are the best but off course in knew that already.”
This was followed by three smiley faces.

 
The best I can tell the agent believes that the smiley faces are proof of criminal intent because nothing else in Mohamadi’s quoted statement about “being the best” even comes close. You might recall that FBI agents get specific training in smiley faces and their meaning, so I suppose DHS agents get that training as well.
 
And that’s it. That’s what the criminal complaint cites to prove that the defendant knew that shipping items from the U.S through a foreign company in Dubai to Iran was illegal:  three smiley faces and a desire not to shoot herself.  Maybe that’s why Ms. Mohamadi doesn’t have much of a smiley face in her mug shot.

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TECEX/IM TRAINING EVENTS & CONFERENCES

TEC_a120.

ECTI Presents “OFAC Enforcement Trends: Exporters in the Crosshairs Webinar,” 12 Oct


 
* What: OFAC Enforcement Trends: Exporters in the Crosshairs Webinar
* When: October 12, 2017; 1:00 p.m. (EDT)
* Where: Webinar
* Sponsor: Export Compliance Training Institute (ECTI)
* ECTI Speaker: Sean Kane
* Register: Here or Danielle McClellan, 540-433-3977, danielle@learnexportcompliance.com.

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TE_a221.

NAITA Presents 2017 Export Control Update (ITAR/EAR/OFAC) on 18-19 Sep in Huntsville, AL

 
* What: NAITA 2017 Export Control Update (ITAR/EAR/OFAC).
* When: 18-19 Sept 2017.
* Where: The Westin Huntsville; 6800 Governors West, Huntsville, AL 35806.
* Sponsor: North Alabama International Trade Association (NAITA) and Maynard Cooper & Gale PC.
* Speakers Include: Alan Ensalen, Jim Bartlett, Candace Goforth, Kevin Wolf, Michael Rithmire (BIS), Doreen Edelman, Doug Whitlow, Chrystal Morgan, MAJ Patrick Reimnitz (DDTC), Michael Laychak (DTSA), Dan Cook (DDTC), Larry Chamness (DASA DE&C), Andy Obler, and Ariel Leinwand (OEE).
* Credits: Approved by the Mandatory Continuing Legal Education Commission of the Alabama State Bar for 12.5 CLEs.
* Register: Click here for details & registration link or contact Amanda Berkey/NAITA at 256-532-3505, apberkey@madisoncountyal.gov or naita@naita.org.

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ENEDITOR’S NOTES

* Constance Baker Motley (14 Sep 1921 – 28 Sep 2005; was a civil rights activist, lawyer, judge, state senator, and Borough President of Manhattan, New York City. She was the first African-American woman appointed to the federal judiciary by Lyndon B. Johnson. She was an assistant counsel to Thurgood Marshall arguing the case Brown v. Board of Education.)
  – “Lack of encouragement never deterred me. I was the kind of person who would not be put down.”
 
* Sydney J. Harris (14 Sep 1917 – 7 Dec 1986; was an American journalist for the Chicago Daily News and, later, the Chicago Sun-Times. He wrote eleven books, and his weekday column, “Strictly Personal,” was syndicated in over 200 newspapers in the U.S. and Canada.)
  – “The time to relax is when you don’t have time for it.”

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EN_a323
. 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 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.
 
*
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 1706, containing 834 ABI records and 157 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: 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: 12 Sep 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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EN_a0324. 
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 
here

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EPEDITORIAL POLICY

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

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

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

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