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17-1006 Friday “The Daily Bugle”

17-1006 Friday “Daily Bugle”

Friday, 6 October, 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.

  1. Commerce/Census Seeks Comments on Standard and Routed Export Transactions
  1. Ex/Im Items Scheduled for Publication in Future Federal Register Editions 
  2. Commerce/BIS: (No new postings.)
  3. DHS/CBP Announces ACE Production Outage, 7 Oct
  4. State/DDTC: (No new postings.)
  5. Treasury/OFAC Posts New Sudan FAQ and New General License
  6. EU Posts Additional Guidance Following Yesterday’s Dual-Use List Amendment
  1. Expeditors News: “European Commission Issues a New Customs Decisions System”
  2. Reuters: “U.S. Lifts Sudan Sanctions, Wins Commitment against Arms Deals with North Korea”
  3. ST&R Trade Report: “Dates and Deadlines: CBP Operations, Classification, China 301, Export Controls”
  1. M. Schlüter & P. Ende: “Thailand: Export Control of Dual-Use Items Due in 2018”
  2. M. Volkov: “The Delusion of a Barebones Compliance Program”
  3. S. Kohn Ross: “Tips for Traveling With Electronic Devices”
  4. Gary Stanley’s ECR Tip of the Day
  5. R.C. Burns: “OFAC Fines U.S. Paper Company for ‘Discussing’ Exports to Sudan”
  1. Friday List of Approaching Events: 30 New Events Posted This Week
  1. Bartlett’s Unfamiliar Quotations 
  2. Are Your Copies of Regulations Up to Date? Latest Changes: ATF (15 Jan 2016), Customs (28 Sep 2017), DOD/NISPOM (18 May 2016), EAR (3 Oct 2017), FACR/OFAC (16 Jun 2017), FTR (20 Sep 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

 
82 FR 46739-46740: Foreign Trade Regulations (FTR): Request for Public Comments Regarding Standard and Routed Export Transactions
* AGENCY: Bureau of the Census, Commerce Department.
* ACTION: Advance notice of proposed rulemaking.
* SUMMARY: The Bureau of the Census (U.S. Census Bureau) is seeking public comments to perform a review of the requirements governing routed export transactions. In particular, the Census Bureau is interested in comments regarding the definition of a routed export transaction as well as the responsibilities of parties in routed export transactions. Routed export transactions are transactions in which the Foreign Principal Party in Interest (FPPI) controls the movement of the goods out of the country. There are a variety of reasons why the FPPI assumes this responsibility such as the use of a preferred carrier and the desire to not disclose the ultimate consignee to the U.S. Principal Party in Interest (USPPI), although the ultimate consignee is properly identified to the U.S. Government. Because the FPPI controls the movement of the goods in a routed transaction and cannot file Electronic Export Information (EEI), the Census Bureau requires the FPPI to authorize a U.S. authorized agent or the USPPI to file the EEI on its behalf. This ensures that the Census Bureau collects the statistical information.
* DATES: Written comments must be received on or before December 5, 2017. …
* FOR FURTHER INFORMATION CONTACT: Dale C. Kelly, Chief, International Trade Management Division, U.S. Census Bureau, Room 5K158, Washington, DC 20233-6010, by phone (301) 763-6937, by fax (301) 763-8835, or by email dale.c.kelly@census.gov.
* SUPPLEMENTARY INFORMATION: …
  The Census Bureau is soliciting comments on the clarity, usability, and any other matters related to the regulatory requirements for routed transactions. This will include the definition of a routed export transaction found in 15 CFR 30.1 as well as the general responsibilities of parties in routed export transactions as detailed in 15 CFR 30.3. Suggested questions are below; however, any pertinent feedback not captured by these questions is also welcome:
  (1) If you do not think that the definition of a routed export transaction in 15 CFR 30.1 is clearly stated, then what definition of routed export transaction would you suggest?
  (2) Should the Census Bureau modify the list of data elements at 15 CFR 30.3(e)(2) that the U.S. authorized agent is required to provide when filing the electronic export information? If so, what changes would you suggest?
  (3) Should the Census Bureau modify the list of data elements at 15 CFR 30.3(e)(1) that the U.S. Principal Party in Interest is required to provide to the U.S. Authorized agent? If so, what changes would you suggest?
  (4) The carrier’s responsibilities under the FTR are the same in both standard and routed transactions. Does the FTR clearly communicate these responsibilities? If not, what clarification would you suggest?
  (5) The data elements that the USPPI and U.S authorized agent are required to provide are currently located in Section 30.3(e) of the FTR. However, additional data elements are needed to complete the AES filing. Here is a list of data elements that are required to be reported but for which a responsible party is not listed. Please provide comments on which party, the USPPI or the U.S. authorized agent, should report these data elements. …
  (6) Are the responsibilities of parties in a routed export transaction clearly stated? If not, what improvements would you suggest?
  (7) How could we improve the process to authorize filing in a routed export transaction?
  (8) How could the FTR be revised to align with the Bureau of Industry and Security’s Export Administration Regulations on routed export transactions?
  (9) What changes would you suggest in Section 30.3 of the FTR that might improve the parties’ understanding of the requirements of a routed export transaction?
  (10) What changes would you suggest in Section 30.3 of the FTR that might improve the parties’ understanding of their roles in a routed or standard export transaction?
 
  Dated: September 29, 2017.
Ron S. Jarmin, Associate Director for Economic Programs, Performing the Non-Exclusive Functions and Duties of the Director, Bureau of the Census. 

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OGSOTHER GOVERNMENT SOURCES

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

(Source:
Federal Register)
 

* U.S. Customs and Border Protection; NOTICES; Agency Information Collection Activities; Proposals, Submissions, and Approvals [Publication Date: 10 October 2017.]:
  – Cargo Manifest/Declaration, Stow Plan, Container Status Messages and Importer Security Filing
  – Report of Diversion

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

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

(Source:
CSMS #17-000644, 6 Oct 2017.)
 
There will be an ACE PRODUCTION Outage Saturday evening, October 7, 2017 from 2200 ET to 0400 ET Sunday, October 8, 2017 for ACE infrastructure maintenance. 
* * * * * * * * * * * * * * * * * * * *

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

 
The U.S. Government announced on October 6, 2017 that it will revoke certain sanctions with respect to Sudan and the Government of Sudan, effective October 12, 2017, pursuant to Executive Order (E.O.) 13761, as amended by E.O. 13804.  The Office of Foreign Assets Control is publishing new Frequently Asked Questions regarding this revocation, as well as a new general license authorizing certain transactions pursuant to the Trade Sanctions Reform and Export Enhancement Act of 2000.
 
The State Department has issued a statement and a report with respect to this revocation of sanctions.
* * * * * * * * * * * * * * * * * * * *

 
On 26 September 2017, the Commission adopted the annual Delegated Regulation that updates the EU dual-use export control list in Annex I to Regulation (EC) No 428/2009 and brings it in line with the decisions taken within the framework of the international non-proliferation regimes and export control arrangements in 2016.
 
The majority of the changes this year result from amendments that were agreed in the Wassenaar Arrangement, including
 
  – An updated list of acronyms and abbreviations;
  – New definitions for “biological agents” (Category 1), “Monolithic Microwave Integrate Circuit” (MMIC) (Categories 3 and 5) and “authentication” (Category 5 Part 2). The definition of “adapted for use in war” (Category 1) was removed;
  – The restructuring of Category 5 Part 2 into a more positive control list of dual-use information security items continued. Note 4 (decontrol note to Category 5, Part 2) was removed, and is now incorporated in the 5A002.a. control entry; and
  – The addition of new (sub-entry) controls in Category 3 for integrated circuits with analogue-to-digital converters (3A001.a.14.) and for MMIC transmit/receive modules
(3A001.b.12.), and in Category 6 for certain lasers (6A005).
 
The Australia Group in 2016 agreed to remove controls on the Dengue virus (1C351.a.10.), and on verotoxin and Shiga-like ribosome inactivating proteins (1C351.d.9.). Two bacteria and six toxins under 1C351 were renamed. Several controls on biological equipment were reviewed. To be noted, viruses controlled under 1C351.a have not been re-ordered alphabetically in the EU list, as decided by the Australia Group in 2016, as the long term consistency in control entry numbering for pathogenic material was considered more preferential.
 
The Missile Technology Control Regime added a new control for aerothermodynamic test facilities (9B107) and a new sub-entry control for ultra-high temperature ceramics (1C102.f.). The controls for liquid rocket propulsion (9A106) and for propellant tanks systems (9A120) were amended to include gel propellant. A note to the control on flow-forming machines was amended to include missile inter-stages (2B109.b.). A new note to the 9D105 software control was added to highlight that this control includes software specially designed for a manned aircraft converted to operate as an unmanned aerial vehicle.
 
Two new sub-entry controls for plasma torches and electron beam guns were introduced by the Nuclear Suppliers Group in Category 2 (2B227).
 
The Commission Delegated Regulation will enter into force upon its publication 2 month after its adoption, provided that the Council and the European Parliament raise no objections within this period.
 
  – The Comprehensive Change Note Summary 2017 provides a detailed overview of all technical changes compared to the 2016 EU Dual-Use Control List across all 10 categories.
  – The 2017 Commission Delegated Regulation, including Explanatory Memorandum 
* * * * * * * * * * * * * * * * * * * *

NWSNEWS

(Source:
Expeditors News, 5 Oct 2017.)
 
On October 2, 2017, the European Commission announced a new pan-EU electronic Customs Decisions System (CDS).
The CDS “is to be used for all applications and decisions which may have an impact in more than one Member State, and for any subsequent event which may affect the original application or decision.” European Union member states may use the central CDS or will deploy their own system.
 
The new CDS “will increase process efficiency for all parties involved” while also simplifying business in the EU. The Customs Union will continue to modernize to promote job growth through trans-European IT systems.
 
The full notice may be found here.
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(Source:
Reuters, 6 Oct. 2017.)
 
The United States lifted long-standing sanctions against Sudan on Friday, saying it had made progress fighting terrorism and easing humanitarian distress, and also secured Khartoum’s commitment not to pursue arms deals with North Korea.
 
In a move that completes a process begun by former President Barack Obama and which was opposed by human rights groups, President Donald Trump removed a U.S. trade embargo and other penalties that had effectively cut Sudan off from much of the global financial system.
 
The U.S. decision marked a major turnaround for the government of President Omar Hassan al-Bashir, who once played host to Osama bin Laden and is wanted by the International Criminal Court on charges of orchestrating genocide in Darfur.
 
However, Sudan will remain on the U.S. list of state sponsors of terrorism – alongside Iran and Syria – which carries a ban on weapons sales and restrictions on U.S. aid, senior U.S. officials said.
 
Sudanese officials also remain subject to separate sanctions stemming from human rights abuses during the Darfur conflict, the officials told reporters, speaking on condition of anonymity.
 
The lifting of sanctions reflects a U.S. assessment that Sudan has made progress in meeting Washington’s demands, including cooperation on counter-terrorism, working to resolve internal conflicts and allowing more humanitarian aid into Darfur and other rebellious border areas, the officials said.
 
The Trump administration also secured a commitment from Sudan that it would “not pursue arms deals” with North Korea, and Washington will apply “zero tolerance” in ensuring Khartoum’s compliance, one of the officials said.
 
But they said Khartoum’s assurances on North Korea were not a condition for lifting the sanctions, some of which had been in place for 20 years and have hobbled the Sudanese economy.
 
Sudan has long been suspected of military ties with North Korea, which is locked in a tense standoff with Washington over its missiles and nuclear weapons programs. But the official said Khartoum was not believed to have diplomatic relations with Pyongyang and that was not expected to change.
 
Sudan also has recently distanced itself diplomatically from Iran, another U.S. arch-foe.
 
Shortly before leaving office, Obama temporarily eased penalties against the east African nation. In July, the Trump administration postponed for three months a decision on whether to remove the sanctions completely, setting up an Oct. 12 deadline.
 
Human rights groups see the decision to remove sanctions as premature.
 

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Following are highlights of regulatory effective dates and deadlines and federal agency meetings coming up in the next week.
 
  – 9 Oct: effective date of revocation and modification of CBP rulings
  – 10 Oct: deadline for comments to CBP on report of vessel diversion
  – 10 Oct: deadline for comments to USDA on proposal to ease restrictions on imports of swine and pork from Mexico
  – 10 Oct: USTR hearing in Section 301 investigation of China
  – 10 Oct: deadline for comments to BIS on foreign policy-based export controls
  – 10 Oct: deadline for comments to ITC on potential IPR import restrictions on data storage tapes
  – 11 Oct: deadline for comments to USDA on electronic import inspection information collections
  – 12 Oct: effective date of USDA final rule allowing imports of bone-in sheep meat from Uruguay
  – 12 Oct: effective date of USDA final rule allowing imports of fresh persimmon from Japan
  – 12 Oct: deadline for comments to ITC on potential IPR import restrictions on insulated beverage containers, semiconductor devices
  – 13 Oct: deadline for comments to ITC on potential IPR remedial orders on semiconductor devices
* * * * * * * * * * * * * * * * * * * *

COMMCOMMENTARY

COMM_a211
. M. Schlüter & P. Ende: “Thailand: Export Control of Dual-Use Items Due in 2018”

 
* Authors: Markus Schlüter; Esq., markus.schlueter@roedl.pro; and Philip Ende, Esq., philip.ende@roedl.pro. Both of Rödl & Partner.
 
The government in Thailand aims to enforce export controls on goods that have both a commercial and military use, so called dual-use items, with commencement in 2018. The draft law, titled “Trade Controls on Weapons of Mass Destruction Act”, is currently being considered by the Council of State but is expected to pass the legislative process by the end of this year. It will become effective 180 days after it has been published in the Royal Gazette. The initiative is based on a Commerce Ministry notification regarding criteria and licensing requirements issued in October 2015.
 
Requirements for Companies
 
Companies will be required to monitor whether their exports are covered under two lists. List I is the list of Export Control Classification Numbers (ECCN), which is largely based on European Union regulations. The goods on this list require a specific license (on a shipment-by-shipment basis) before they can be exported. It is expected that under the new regulations companies will be allowed to apply for bulk licenses to cover multiple shipments, rather than on a shipment-by-shipment basis under the current notification. Such bulk license applications could be issued to companies proving a proper internal compliance system to manage exports of dual-use items. List II is wider and based on harmonized system (HS) classification codes. Companies exporting goods under list II do not need an export license but must follow certain procedures before exporting. These procedures include:
 
  – registration with the Foreign Trade Department and
  – self-certification that such goods are not eligible for dual-use.
 
Consequences and Impacts
 
Non-compliance with the export control regime may lead to significant penalties and fines, or even imprisonments, delay in shipments, financial loss and reputational damage. The new rules will likely have impact on various industries. Those to be expectedly mostly affected include automotive, chemicals and pharmaceuticals, computers, electronics, medical equipment, semiconductors, steel and telecommunications. In order to avoid sanctions or obstacles in their trading activities companies should start as soon as possible with the checking and verifying whether their products are considered dual-use items under list I and/or are listed as products that require self-certification under list II.

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

(Source:
Volkov Law Group Blog. Reprinted by permission.)
 
* Author: Michael Volkov, Esq., Volkov Law Group, mvolkov@volkovlaw.com, 240-505-1992.
 
Instead of wrestling over the definition of an “effective” ethics and compliance program, let’s take a step back and define what we all agree on is an “ineffective” compliance program. Unfortunately, when you work in the real world, some Chief Compliance Officers, along with senior management and the members of the board of directors are supervising and administering compliance programs that fall far short of the “effectiveness” objective.
 
Again, if you give everyone truth serum, they will admit that their compliance program falls way short of effectiveness. In other cases, the failure to recognize deficiencies in an ethics and compliance program reflects a lack of understanding or education, especially among the CEO, senior executives, and board members. In most cases, they have no clue what an effective compliance program should look like. The responsibility for this lack of education sometimes rests with the CCO who is unwilling or unable to educate and train the board and senior executives.
 
So what does an “ineffective” compliance program look like and why are important stakeholders deluded into thinking that their compliance program is effective?
 
CEOs, senior executives, and board members believe that the company’s compliance program consists of certain minimum elements – a code of conduct, a letter from the CEO supporting the code of conduct, a hotline to report employee concerns, a video statement from the CEO, which may be updated annually, an annual training program and certification of compliance with the code of conduct, and a library of policies and procedures that cover the basic risk factors, including anti-corruption, trade compliance, antitrust and other basic risks.
 
Now, let’s notice what is missing from this skeleton program:
 
  – Evidence of ethical communications or conduct by a board of directors, CEO and senior management;
  – A risk and compliance program assessment or continuous process to update assessments and update ethics and compliance program;
  – An automated due diligence program to screen, monitor and audit third parties, including vendors and suppliers;
  – Robust training program beyond basic code of conduct that is tailored to identified risks;
  – Evidence that compliance program has been operationalized through coordination with legal, human resources, internal audit, finance, security, and security;
  – Operational justice through timely resolution of employee concerns, and even-handed punishment and discipline for offending officers, managers and employees;
  – Regular CCO reporting to senior management and board committee; and
  – Mature audit and monitoring of compliance program, including detailed data collection, analysis and continuous assessment.
 
Many companies are lacking in many of these basic requirements for an effective compliance program. Companies that have been investigated by the government often respond and implement compliance programs. Unfortunately, reactive ethics and compliance programs are often created for the wrong purpose – as a defense against another government investigation. Companies that embrace the value of ethics and compliance programs for long-term sustainable growth are on the right path.
 
Board members, CEOs and CCOs have a responsibility to avoid complacency and to challenge the status quo when a company’s compliance program is deficient. To the extent the board, the CEO and senior executives are deluded in their belief that the company’s ethics and compliance program is adequate, the CCO has a responsibility to inform, educate and notify company and board officials that the company’s ethics and compliance program should be remediated. A CCO who keeps silent to get along with key leaders will eventually come to the point where he/she will question his/her own integrity. In some cases, the CCO will have to make a choice – if he/she cannot bring about change, the CCO may have to leave the company rather than continue to aid the company’s inadequate ethics and compliance program.
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* Author: Susan Kohn Ross, Esq., Mitchell Silberberg & Knupp LLP,
skr@msk.com
, 310-312-3206.
 
In the September 18, 2017 Federal Register notice (see 82 FR 43556), U.S. Citizenship and Immigration made clear it will now routinely require those applying to enter the U.S. to provide social media handles. As such, the obvious starting point for these tips must be a reminder that Customs and Border Protection (“CBP”) officers may require arriving travelers to provide the unlock code to their electronic devices and user names/passwords to gain access to programs, including social media accounts, so make sure all your programs are closed when you cross the border! The contents on your devices can be examined, and that is true whether or not you are a U.S. citizen, and regardless of your profession. If you are selected for such an inspection, you can expect this two page summary may be handed to you.
 
The national security concerns of protecting the homeland allow CBP officers to inspect passengers and their belongings without meeting the Fourth Amendment protections against unreasonable search and seizure. A CBP officer is not required to articulate why he or she directs you to secondary or why you or a particular device is of interest.
 
The 2009 directives (for CBP – see here; for Immigration and Customs Enforcement [“ICE”] see here) provide a specific process only if a traveler identifies him or herself as an attorney (with equal application to U.S. and foreign attorneys). In that case, the officer is to consult with either the agency’s own attorneys or the Dept. of Justice for approval to proceed with the inspection of the relevant materials. Regardless, the device is subject to inspection. In reality, the stories which make the news do not generally involve the inspection of electronic devices belonging to attorneys, but rather those belonging to other travelers.
 
In the recently filed Ghassan Alasaad et al v. Elaine Duke, et al, Mass DC, Case No. 1:17-cv-11730, September 13, 2017, we learn about 11 travelers and their unpleasant experiences, which range from being held in secondary for a few hours to far more upsetting stories. In one example, a family crossed from Canada back into the U.S. with a sick child and was detained about six hours before being permitted to leave, during the course of which their devices were seized for many days before being returned. In another case, father and daughter returned from Canada to the U.S. by bus, were detained at a small U.S. crossing point for about seven hours, the father’s devices were inspected and later, they were permitted to leave, but long after their original bus had departed. Equally perplexing is why some of the individuals were stopped more than once, and the very same electronic devices subjected to searches each time!
 
Lest anyone think only CBP officers at small ports with limited traffic are the culprits, Dallas-Fort Worth and Miami also gave rise to incidents described in the pending case. The focus of the lawsuit is to declare the current procedures unconstitutional given that electronic devices carry so much personal information that they no longer equate to the contents of one’s luggage, which everyone surely concurs is available to be inspected at time of entry.
 
The Supreme Court has repeatedly held that CBP has an unfettered right to inspect anything which accompanies a traveler leaving from or returning to the U.S.. The issue of laptop searches and surrounding privacy rights comes up every few years. The current iteration of the push-pull between protecting the borders and the right to privacy is no longer limited to just laptops.
 
To provide some context, CBP published the following figures:
 
  (1) In 2015, of the 383.2 million travelers, 8,503 searches of electronic devices were conducted;
  (2) In 2016, of the 390.6 million travelers, 19,033 searches of electronic devices were conducted; and
  (3) In the first six months of 2017, there were 14,993 searches of electronic devices conducted out of the 189.6 million travelers.
 
While the numbers of devices searched is still small in comparison to the number of travelers, the number of searches is steadily climbing and, if it is your device which is held, you will likely run out and replace it long before you get your original device back. So, be prepared to spend the money to do so or plan to stick around, even if you miss a connecting flight, assuming CBP or ICE will release your device. Cooperating with authorities does not guarantee the release of your device.
 
In 2009, when the CBP and ICE directives were originally issued, they were woefully inadequate. They did not address all the situations where the law recognizes confidentiality. Yes, the search of attorney devices was marginally carved out, but what about a device belonging to a doctor or priest, or one containing someone’s medical information, or how about the business person who has confidential communications from an attorney? There are also journalists whose sources are typically protected from disclosure.
 
From the CBP side, certainly great flexibility is needed to protect the homeland, no one doubts that. It is also true that sometimes the situation is nothing more than the officer has a well-founded hunch which proves to be right. At the same time, threatening to pull your gun or choking someone to get your hands on a smartphone to inspect it, as alleged in the current lawsuit, would seem to be excessive by any standard!
 
The courts have long held that taking the device, imaging it, and returning it long thereafter does require a search warrant, especially if a criminal case is filed. How is the average traveler to know his or her rights?
 
So, what is a traveler to do?
 
  (1) If you don’t absolutely need the device, don’t take it with you.
  (2) Keep in mind which of your devices has security settings and which does not. The ones which do not could be inspected, no matter the circumstances.
  (3) You can put the data which you later want to access in the cloud with strong password protection (be sure to disable the connection) and carry the equivalent of a burner phone. Otherwise, make sure all your programs are closed.
  (4) Do not keep more data on your device than you are willing to have exposed to CBP or ICE.
  (5) If you have photos on a device, store them in your cloud account and remove them from your device.
  (6) Some have suggested that if the device is in airplane mode, it may discourage any inspection since the device is not connected to the Internet. While CBP did state in June 2017 that its searches are limited to “information that is physically resident on the device,” it is not clear that simply activating airplane mode actually makes a difference.*
  (7) If you do get selected for secondary, you really only have two choices – give them the information they want and make the search process go as quickly as possible** or be prepared to sit around for several hours and, in the end, possibly be forced to leave your device behind to be returned (perhaps) at some later undefined point in time.
  (8) In 2009, both CBP and Immigration and Customs Enforcement issued directives as to how each agency would deal with the inspection of digital devices. They protect no one, not even attorneys!
 
* See here for the full list of questions and answers from the Senate Finance Committee dated June 20, 2017 to the nominee for Commissioner of Customs and Border Protection.
 
**Of course, if you are an attorney or work for a lawyer or law firm, or are in house, you must immediately object to the search of the device so as to have the best argument possible the attorney-client and work product privileges apply, despite what the officers may find on your device.
 
This topic finally takes us to the question of what companies are doing to protect themselves? Just as developing a bring your own device to work policy is necessary, so are ground rules for employees traveling with company-owned devices. Many companies are in highly regulated industries or have employees with access to highly prized information and so already have robust policies in place. If you do not, at least adopt the above recommendations as a starting point to stylize a policy that works best for your individual company’s needs.
* * * * * * * * * * * * * * * * * * * *

 
* Author: Gary Stanley, Esq., Global Legal Services, PC, (202) 352-3059,
gstanley@glstrade.com
.
 
U.S. importers may be requested by their foreign suppliers to furnish them with a certified Form BIS-647P, Delivery Verification Certificate, covering items imported into the United States. These requests are made by foreign governments to assure that strategic items shipped to the United States are not diverted from their intended destination. In these instances, the issuance of an export license by the foreign country is conditioned upon the subsequent receipt of a Delivery Verification Certificate from the U.S. importer. Accordingly, your compliance with your foreign exporter’s request for a Delivery Verification is necessary to ensure your foreign exporter fulfills its government obligations and is able to participate in future transactions with you. Failure to comply may subject your exporter to penalties that may prevent future trade.
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(Source:
Export Law Blog
. Reprinted by permission.)
 
* Author: R. Clifton Burns, Esq., Bryan Cave LLP, Wash DC,
Clif.Burns@bryancave.com
, 202-508-6067).
 
Yesterday the Office of Foreign Assets Control (“OFAC”) announced that it was fining White Birch Paper $372,465 to settle charges arising from exports of $354,602.26 of Canadian-origin paper from a White Birch mill in Canada to a customer in Sudan. Ah, yes, the doctrine of facilitation strikes again, although OFAC has some difficulty explaining that clearly:
 

Various personnel within White Birch USA and its Canadian subsidiary, White Birch Paper Canada Company NSULC (“White Birch Canada”), were
actively involved in discussing, arranging, and executing the export transactions to Sudan. (Emphasis added.)

 
This makes it appear that the violation arises equally from employees of White Birch Canada being involved in the exports, which, of course, was neither illegal nor facilitation.
 
The violation arises, of course, from the U.S. employees, rather than the Canadian employees being involved in the exports, certainly to the extent that the U.S. employees “arranged and executed” the exports.  However, if “discussing” the exports is facilitation, as this also seems to state, OFAC would be expanding the scope of the facilitation doctrine far beyond any prior conception of the scope of that doctrine. That would mean that if a U.S. employee said to the Canadian subsidiary “We can’t be involved in the exports to Sudan,” then that discussion would violate OFAC’s rules. Even if the employee were to stick his/her fingers in his ears and chant “la la la la la” every time a Canadian employee mentioned Sudan, that might still be a discussion as well since “la la la la la” means, of course, “I can’t be involved in these exports.”
 
Of course, it is more likely that this is just sloppy draftsmanship by OFAC – something we’ve seen before – than it is an effort to expand the scope of the facilitation doctrine to any discussion of the transaction whatsoever. Still, OFAC could have avoided this issue if it simply noted that the U.S. employees were actively involved in “arranging and executing” the exports, both of which can clearly constitute facilitation.
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TEEX/IM TRAINING EVENTS & CONFERENCES

TE_a216
. 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
 
# E-Seminars: “ITAR/EAR Awareness;” Export Compliance Solutions; spalmer@exportcompliancesolutions.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:

 

* 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 10-12: Dallas, TX; “
‘Partnering for Compliance™’ West Export/Import Control Training and Education Program
;” Partnering for Compliance
 


*
 Oct 10: Rotterdam, the Netherlands; “
Awareness Training Export Control, Dual-Use, and Sanctions
” day I/3 [in Dutch]; Fenex 

*
Oct 10 & 24: Webinar; “Two Part Webinar Series: Harmonized System Classifications: Learning By Doing;” ECTI; 540-433-3977

* 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 11-12: Detroit, MI;
 
2017 Trade Compliance and Policy Seminar
; C.H. Robinson

* Oct 11: Webinar; ”
Basics of Importation Under the Gun Control Act;” Reeves & Dola LLP; Teresa Ficaretta;
tficaretta@reevesdola.com; 202-715-9183

*
Oct 11: Webinar; “Encryption Export Controls 2017 Update;” ECTI; 540-433-3977

# Oct 12-13; Schöllkrippen, Germany; “
Module Controlled Goods
” (in German); FALEX

* 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 12: Webinar; “OFAC Enforcement Trends: Exporters in the Crosshairs;” ECTI; 540-433-3977

* 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 17 & 26: Webinar; “Two Part Webinar Series: EAR License Exceptions: Learning By Doing;” ECTI; 540-433-3977

* Oct 19: Free Webinar; ”
Duty Drawback;” Citta Brokerage Company

*
 Oct 19: Boston, MA;
 
2017 Trade Compliance and Policy Seminar
; C.H. Robinson

* Oct 19: Boston, MA; ”
Import Documentation and Procedures Seminar;” International Business Training

* Oct 20: Milwaukee, WI;
Import Audit Compliance Seminar; International Business Training

* 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 24-25: Cleveland, OH;
 
2017 Trade Compliance and Policy Seminar
; C.H. Robinson

*
 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 26: Coventry, UK;
Export Control Symposium; Midlands Aerospace Alliance and UK Department of International Trade

* 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 2: Webinar; “DIY Encryption Classification 2017 Edition;” ECTI; 540-433-3977

* 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: London UK; “Control List Classification – Combined Dual Use and Military;” UK Department for International Trade; denise.carter@trade.gsi.gov.uk

* Nov 8: Webinar; “Introduction to the National Firearms Act;” Reeves & Dola LLP; Teresa Ficaretta; tficaretta@reevesdola.com; 202-715-9183

#
Nov 9: London UK; “Making Better Licence Applications;” UK Department for International Trade; denise.carter@trade.gsi.gov.uk

* Nov 9-10: Shanghai, China;ICPA China Conference;” International Compliance Professionals Association; wizard@icpainc.org  
* Nov 9: Tysons Corner, VA; ITAR for the Empowered Official; FD Associates

* Nov 13: San Diego, CA; 
 “
Import Documentation and Procedures Seminar
;” International Business Training

* Nov 13-16: Wash DC; “ITAR Defense Trade Controls / EAR Export Controls Seminar;” ECTI; jessica@learnexportcompliance.com; 540-433-3977

# Nov 14-15; Schöllkrippen, Germany; ”
Fundamentals of Export Controls” (in German); FALEX
# Nov 14-15; Schöllkrippen, Germany; ”
Export Controls Refresher Course” (in German); FALEX
# Nov 16-17; Schöllkrippen, Germany; ”
Workshop Export Controls” (in German); FALEX

* 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 16: Chicago, IL;
 “
Import Documentation and Procedures Seminar
;” International Business Training 
*
 Nov 17: Chicago, IL; “
Import Audit Compliance Seminar
;” International Business Training 

* 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: Webinar; ”
NAFTA Rules of Origin;” International Business Training

* 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: London UK; “Intermediate Seminar;” UK Department for International Trade; denise.carter@trade.gsi.gov.uk

* 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 7: London UK; “Beginners Workshop;” UK Department for International Trade; denise.carter@trade.gsi.gov.uk
#
Dec 7: London UK; “Licences Workshop;” UK Department for International Trade; denise.carter@trade.gsi.gov.uk

* Dec 8: Boston, MA; ”
Export Expo;” Compliance Alliance
* Dec 8: Minneapolis, MN; 

Incoterms 2010: Terms of Sale Seminar
;” International Business Training
* Dec 8: Washington, D.C.; ”
2017 SIA Holiday Party;” Society for International Affairs (SIA)

* Dec 11-13: Sterling, VA; “
Basics of Government Contracting
;” Federal Publications Seminars

#
Dec 12: London UK; “Control List Classification – Combined Dual Use and Military;” UK Department for International Trade; denise.carter@trade.gsi.gov.uk

# Dec 13: Washington, DC; “DDTC In-House Seminar;”

*
 Dec 14: Minneapolis, MN; “
Import Audit Compliance Seminar
;” International Business Training 

* Dec 15: Atlanta, GA; ”
Incoterms 2010: Terms of Sale Seminar;” International Business Training

 
2018
 

#
Jan 17: Bristol UK; “Intermediate Seminar;” UK Department for International Trade; denise.carter@trade.gsi.gov.uk
#
Jan 18: Bristol UK; “Beginners Workshop;” UK Department for International Trade; denise.carter@trade.gsi.gov.uk
#
Jan 18: Bristol UK; “Licences Workshop;” UK Department for International Trade; denise.carter@trade.gsi.gov.uk
#
Jan 18: Bristol UK; “Control List Classification – Combined Dual Use and Military;” UK Department for International Trade; denise.carter@trade.gsi.gov.uk

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


Jan 29-30: Toronto, Canada;
7th Industry Forum on Export and Re-Export Compliance for Canadian Operations;”
American Conference Institute

* Feb 6: Las Vegas, NV;
 “
Import Documentation and Procedures Seminar
;” International Business Training

# Feb 13-14: Orlando FL; “
ITAR/EAR Boot Camp
;” Export Compliance Solutions; 
spalmer@exportcompliancesolutions.com
; 866-238-4018

* Feb 19-22: Huntsville AL; “
ITAR Defense Trade Controls / EAR Export Controls Seminar
;” ECTI; 
jessica@learnexportcompliance.com
; 540-433-3977

#
Feb 21: Newcastle UK; “Intermediate Seminar;” UK Department for International Trade; denise.carter@trade.gsi.gov.uk
#
Feb 22: Newcastle UK; “Beginners Workshop;” UK Department for International Trade; denise.carter@trade.gsi.gov.uk
#
Feb 22: Newcastle UK; “Licences Workshop;” UK Department for International Trade; denise.carter@trade.gsi.gov.uk
#
Feb 22: Newcastle UK; “Control List Classification – Combined Dual Use and Military;” UK Department for International Trade; denise.carter@trade.gsi.gov.uk

* Mar 5-7: Sugar Land, TX; ”
2018 Winter Basics Conference;” Society for International Affairs (SIA)
* 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 
* Mar 11-14: San Diego, CA; “ICPA Annual Conference;” International Compliance Professionals Association; wizard@icpainc.org

# Mar 14-15: Austin, TX; “
Establishing an ITAR/EAR Export Compliance Program
” Export Compliance Solutions;
spalmer@exportcompliancesolutions.com
;
866-238-4018 

#
Mar 14: Birmingham UK; “Intermediate Seminar;” UK Department for International Trade; denise.carter@trade.gsi.gov.uk
#
Mar 15: Birmingham UK; “Beginners Workshop;” UK Department for International Trade; denise.carter@trade.gsi.gov.uk
#
Mar 15: Birmingham UK; “Licences Workshop;” UK Department for International Trade; denise.carter@trade.gsi.gov.uk
#
Mar 15: Birmingham UK; “Control List Classification – Combined Dual Use and Military;” UK Department for International Trade; denise.carter@trade.gsi.gov.uk

* 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

* May 6-8: Toronto, Canada;
2018 ICPA Canadian Conference; ICPA
* May 7-8: Denver, CO; ”
2018 Spring Advanced Conference;” Society for International Affairs (SIA)

# May 16-17: National Harbor, MD; “
ITAR/EAR Compliance: An Industry Perspective
;” Export Compliance Solutions;
spalmer@exportcompliancesolutions.com
;
 866-238-4018 

# Jul 10-11: Long Beach, CA; ”
ITAR/EAR Boot Camp;”  Export Compliance Solutions; 
spalmer@exportcompliancesolutions.com
; 866-238-4018

#
Sep 12-13: Annapolis, MD; “ITAR/EAR Boot Camp;” Export Compliance Solutions; spalmer@exportcompliancesolutions.com; 866-238-4018

*
Oct 22-23; Arlington, VA; “2018 Fall Advanced Conference;” Society for International Affairs (SIA)

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

ENEDITOR’S NOTES

EN_a117
. Bartlett’s Unfamiliar Quotations

(Source: Editor)

 
* James Whitcomb Riley (7 Oct 1849 – 22 Jul 1916; was an American writer, poet, and best-selling author. His famous works include Little Orphan Annie and The Raggedy Man.)
  – “The most essential factor is persistence – the determination never to allow your energy or enthusiasm to be dampened by the discouragement that must inevitably come.”
 
Friday funnies:
 
Q. “Do you have holes in your underwear?” 
A. “No, of course not!” 
Q. “Then how did you get them on?” 
 
Three elderly gentlemen were walking down the street when the first man said, “Dang, it’s windy.” The second man said, “No it’s not – it’s Thursday.” The third man said, “Me too. Let’s stop in this bar and get a drink.”
  — Mary Ellen Dunlap, Lakehills, TX

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

EN_a218. 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 Sep 2017: 82 FR 45366-45408: Changes to the In-Bond Process [Effective Date: 27 Nov 2017.] 
 
DOD NATIONAL INDUSTRIAL SECURITY PROGRAM OPERATING MANUAL (NISPOM): DoD 5220.22-M

  – Last Amendment: 18 May 2016: Change 2
: Implement an insider threat program; reporting requirements for Cleared Defense Contractors; alignment with Federal standards for classified information systems; incorporated and cancelled Supp. 1 to the NISPOM (Summary 
here
.)


EXPORT ADMINISTRATION REGULATIONS (EAR): 15 CFR Subtit. B, Ch. VII, Pts. 730-774 

  – Last Amendment:
3 Oct 2017: 82 FR 4 5959-45962: Updated Statements of Legal Authority for the Export Administration Regulations

  

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: 
20 Sep 2017:
 
82 FR 43842-43844
: Foreign Trade Regulations (FTR): Clarification on Filing Requirements; Correction
  
  – HTS codes that are not valid for AES are available 
here.
  – The latest edition (20 Sep 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: 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.
 

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

EN_a319
. 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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