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17-1121 Tuesday “Daily Bugle”

17-1121 Tuesday “Daily Bugle”

Tuesday, 21 November 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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[No items of interest noted today.] 

  1. Items Scheduled for Publication in Future Federal Register Editions
  2. Commerce/BIS: (No new postings.)
  3. Commerce/Census: “Tips on How to Resolve AES Fatal Errors”
  4. DHS/CBP Announces ACE-Certification Final Statement Testing
  5. State/DDTC Posts Name and Address Change Announcements for 5 Entities
  6. EU Amends Restrictive Measures Concerning Ukraine, Adds “Governor of Sevastapol” to DPL
  7. Singapore Customs Announces TradeNet Downtime on 26 Nov
  1. ST&R Trade Report: “USTR Updates NAFTA Negotiating Objectives”
  2. Xinhua: “Israel Nods at Cyber-Security Exports in Defense-Related Reforms”
  1. L. Lyons: “USA Import Fees Cheat Sheet”
  2. M. Volkov: “Putting Ethics Back Into Compliance (Part IV of IV)”
  3. Gary Stanley’s ECR Tip of the Day
  1. ECTI Presents “Risk Based Self-Assessment as a Critical Element to Measure Risk, Performance, and Improvement,” Webinar, 14 Dec
  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 (9 Nov 2017), FACR/OFAC (13 Nov 2017), FTR (20 Sep 2017), HTSUS (20 Oct 2017), ITAR (30 Aug 2017) 
  3. Weekly Highlights of the Daily Bugle Top Stories 

EXIMITEMS FROM TODAY’S FEDERAL REGISTER

EXIM_a1

 
[No items of interest noted today.]

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OGSOTHER GOVERNMENT SOURCES

OGS_a11. Items Scheduled for Publication in Future Federal Register Editions
(Source: Federal Register

[No items of interest noted today.]

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When a shipment is filed to the AES, a system response message is generated and indicates whether the shipment has been accepted or rejected. If the shipment is accepted, the AES filer receives an Internal Transaction Number (ITN) as confirmation. However, if the shipment is rejected, a Fatal Error notification is received.
 
To help you resolve AES Fatal Errors, here are some tips on how to correct the most frequent errors that were generated in AES for this month.
 
Fatal Error Response Code: 331
 
  – Narrative: Ultimate Consignee Country Unknown
  – Reason: The Ultimate Consignee Country code reported is not valid in AES.
  – Resolution: The Ultimate Consignee Country code must be a valid ISO Country code found in Appendix C – ISO Country Codes.
  – Verify Ultimate Consignee Country code, correct the shipment and resubmit.
 
Fatal Error Response Code: 626
 
  – Narrative: 1st UOM Code Missing
  – Reason: The Schedule B/HTS Number reported requires a Unit of Measure (1) and Unit of Measure (1) is missing.
  – Resolution: The Schedule B/HTS Number reported requires the Units for 1st Quantity to be reported.
  – Verify the Unit of Measure for the 1st Quantity, correct the shipment and resubmit.
 
For a complete list of Fatal Error Response Codes, their reasons, and resolutions, see Appendix A – Commodity Filing Response Messages.
 
It is important that AES filers correct Fatal Errors as soon as they are received in order to comply with the Foreign Trade Regulations. These errors must be corrected prior to export for shipments filed predeparture and as soon as possible for shipments filed postdeparture but not later than five calendar days after departure.
 
For further information or questions, contact the U.S. Census Bureau’s Data Collection Branch.
 
  – Telephone: (800) 549-0595, select option 1 for AES
  – Email: askaes@census.gov
  – Online:
www.census.gov/trade

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(Source:
CSMS #17-000730, 21 Nov 2017.)
 
ACE-CERTIFICATION Final Statement testing is now available to vendors and self-programmers to further test their ACE Statement programs. The testing will be limited in the number of preliminary statements targeted for a Final Daily statement generation, and testing will be handled by a limited number of client representatives.
 
Vendors and self-programmers may request testing for Final Daily Statements by sending an email to their assigned client representative. The email must contain one recent preliminary statement number, statement date and amount received from the ACE Certification environment. The participant should include the DPSITE and Processing Port/Filer codes listed on the Preliminary statement. The supporting client representatives will supply further testing steps to complete the test.
 
When necessary, CBP may request an additional preliminary statement for resolving issues that may occur.
 
Should you have questions, please contact your assigned client representative.

  

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OGS_a55. State/DDTC Posts Name and Address Change Announcements for 5 Entities

(Source: State/DDTC, 21 Nov 2017.) [Excerpts.]
 
Effective immediately, HENSOLDT Sensors GmbH and HENSOLDT Optronics GmbH has changed as follows: HENSOLDT Holding Germany GmbH. 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. …
 
 
Effective immediately, HS Wroclaw Sp. z o.o. has changed as follows: UTC Aerospace Systems Wroclaw Sp. z o.o. 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. …
 
 
Effective immediately, KMWE Precise Eindhoven B.V. has changed as follows: KMWE Precision B.V. 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. ,,,
 
 
Effective immediately , Thales Alenia Space UK Ltd., 20 Dashwood Lang Road, The Bourne Business Park, Addlestone, Weybridge, Surrey, United Kingdom, KT15 2NX will change as follows: Thales Alenia Space UK Ltd., 350 Longwater Avenue, Green Park, Reading, Berkshire, United Kingdom, RG2 6GF . 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. …
 
 
Effective January 1, 2018, Thales will change as follows:
 
Old Name
New Name
Thales Training & Simulation SAS
Thales AVS France SAS
Thales Avionics LCD SAS
Thales AVS France SAS
Thales Electron Devices SAS
Thales AVS France SAS
Thales Underwater Systems SAS
Thales DMS France SAS
Thales Microelectronics SAS
Thales DMS France SAS
Thales Angenieux SAS
Thales LAS France SAS
TDA Armements SAS
Thales LAS France SAS
Thales Air Operations SAS
Thales LAS France SAS
Thales Cryogenie SAS
Thales LAS France SAS
Thales Optronique SAS
Thales LAS France SAS
Thales LAS France SAS, 3 Avenue Charles Lindbergh, Rungis, Department Val – de – Marne, France 94150
Thales LAS France SAS, 2 Avenue Gay Lussac , Elancourt, Department Yvelines, France 78990
 
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_a66
. EU Amends Restrictive Measures Concerning Ukraine, Adds “Governor of Sevastapol” to DPL

(Source: Official Journal of the European Union, 21 Nov 2017.)
 
Regulations:
  – Council Implementing Regulation (EU) 2017/2153 of 20 November 2017 implementing Regulation (EU) No 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine
 
Decisions:
  – Council Decision (CFSP) 2017/2163 of 20 November 2017 amending Decision 2014/145/CFSP concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine
 
N.B. To read more about the restrictive measures concerning Ukraine, please read the following press release.

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OGS_a77
. Singapore Customs Announces TradeNet Downtime on 26 Nov

(Source: Singapore Customs Notice No. 16/2017, 20 Nov 2017.
 
In addition to the usual housekeeping time for TradeNet on Sundays from 0400 hours to 0800 hours, we wish to inform you that Singapore Customs will be performing system maintenance work which will affect TradeNet from 0400 hours to 1200 hours on 26 November 2017.
 
As a result of the above maintenance work, applications submitted via TradeNet will not be processed during the above mentioned period. Processing of these applications will resume in TradeNet after 1200 hours on 26 November 2017.
 
Please bring the contents of this Notice to the attention of your staff. Kindly plan in advance and submit applications before the downtime, to minimize disruptions to your business operations. We apologize for any inconvenience caused.

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NWSNEWS

NWS_a1
8. ST&R Trade Report: “USTR Updates NAFTA Negotiating Objectives”

 
The Office of the U.S. Trade Representative has updated the U.S. objectives for the renegotiation of the North American Free Trade Agreement that were originally announced July 17. According to a USTR press release, the updated objectives reflect the goals of text proposals tabled by the U.S. in the ongoing NAFTA talks. They include increased market access for agriculture, new transparency and administrative measures, expanded investment and intellectual property rights objectives, and completed negotiations of the chapters on competition and small- and medium-sized enterprises. The objectives retain the first-ever USTR objective for trade deficit reduction, in addition to trade distortion prevention measures.
 
New or modified objectives in the area of trade in goods include, among others:
 
  – increase transparency in import and export licensing procedures;
  – discipline import and export monopolies to prevent trade distortions;
  – expand market access for remanufactured goods exports by ensuring that they are not classified as used goods that are restricted or banned;
– promote greater regulatory compatibility with respect to key goods sectors, including pharmaceuticals, medical devices, cosmetics, information and communication technology equipment, motor vehicles, and chemicals, and on issues such as energy efficiency, to reduce burdens associated with unnecessary differences in regulation, including through regulatory cooperation where appropriate;
  – expand competitive market opportunities for U.S. agricultural goods in NAFTA countries, substantially equivalent to the competitive opportunities afforded to foreign exports into the U.S. market, including by eliminating remaining Canadian tariffs on imports of U.S. dairy, poultry, and egg products;
  – seek to eliminate and prevent non-tariff barriers to U.S. agricultural exports such as restrictive administration of tariff rate quotas, as well as discriminatory barriers and unjustified technical barriers, including to U.S. grain and alcohol beverages;
  – seek to eliminate unjustified measures that unfairly limit access to Canada’s markets and unfairly decrease market access opportunities in third countries for U.S. dairy products, such as cross subsidization, price discrimination, and price undercutting; and
  – establish specific commitments for trade in products developed through agricultural biotechnologies, including on transparency, cooperation, and managing low level presence issues, and a mechanism for exchange of information and enhanced cooperation on agricultural biotechnologies.

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NWS_a2
9. Xinhua: “Israel Nods at Cyber-Security Exports in Defense-Related Reforms”

(Source: Xinhua, 21 Nov 2017.) [Excerpts.]
 
The Israeli Defense Ministry has announced a reform in its defense exports controls, clearing the path for businesses in an ever-expanding market.
 
The changes will take effect in the coming months. From now on there will be a longer list of products cleared for export and a longer list of countries that are permitted for export by Israeli authorities. Additional reforms are also included.
 
In recent years, Israel has become a focal point of cyber-security technology with experts believing it to be only second to the United States in the industry. …
 
In a statement announcing the reforms, the Israeli Defense Export Control Agency (DECA) which is a part of the country’s defense ministry, said they “took quite a few calculated risks,” in the new policy.
 
Opening such a strategic market to more export could expose Israel to more dangers.
 
“The government understands that the cooperation between nations is extremely important and collaboration of data is extremely important,” Gazit told Xinhua.
 
Cyber security technology can be a grey area, defensive software for one party can sometimes easily be turned into offensive software for a hostile entity. Such technology has what is called “dual use.” …

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COMMCOMMENTARY

COMM_a01
10. L. Lyons: “USA Import Fees Cheat Sheet”

(Source: Laura Lyons, Laura.Lyons@efi.com, 21 Nov 2017.)
 
HARBOR MAINTENANCE FEE (HMF)
(Pub. L. 99-662 – for Army Engineering Corps)
   Assessed on value of commercial cargo loaded on or unloaded from a commercial vessel at a US or Puerto Rican port.
 
Exemptions – HMF does NOT apply to:
  – Informal entries (under $2500.00)
  – Shipments from Guam, American Samoa and other US possessions
  – Shipments from Alaska & Hawaii to US mainland
  – Cargo entering the US under bond for direct exportation
 
HMF on FTZ shipments is paid quarterly, due upon FTZ entry, regardless of ultimate disposition. HMF on imports is paid at time of entry – there is NO MAXIMUM $$$ per shipment.
 
HMF on exports WAS paid quarterly within 31 days of end of quarter (CF349) by shipper named on SED (must have had min. of $10,000/quarter in exports or was de minimis).
  – The export HMF was declared unconstitutional and TERMINATED in early 1998.
 
Began 1 Apr 87 at .0004 ad valorem, increased 31 Dec 90 to .00125 (current level).
 
MERCHANDISE PROCESSING FEE
(MPF) (19 USC 58c)
  Assessed on value of imports when ANY line-item on an entry is subject to the fee.
  – Began on 12/1/86 @ .0022  
  – Reduced on 10/1/87 to .0017  
  – Increased on 10/1/92 to .0019
  – Increased on 1/1/95 to .0021  
  – Increased on 10/1/11 to .003464 (current level)
 
NAFTA Rates
(initially effective 1/1/95)
  Mexico origin .0019   Canada origin 0.00
 
**** As of 7/1/99   MPF for Mexico NAFTA products WAS TERMINATED.
 
MAXIMUM $$ per import entry
  – Formal non-NAFTA   = $485.00 (including for weekly FTZ filings)
  – Increased 1/1/2018 = $497.99
  – Formal NAFTA         = $400.00 (terminated 7/1/99)
MINIMUM per import entry
  – Formal     Non-NAFTA = $25.00
  – Increased 1/1/2018   = $25.67
  – Informal   Non-NAFTA = $2
  – Increased 1/1/2018   = $2.05
  – Informal   NAFTA       = $21.00 (terminated 7/1/99)
 
Fees on Other Types of Entries:
  – HTS Chapter 98 – No MPF (except partial on HTS 9802).
  – TIB, LDDC, CBI and insular possessions imports – No MPF.
  – FTZ – MPF paid at time of extraction for consumption.
 
ENTRY LIMITS
 
USA
  Informal – Increased July 1998 from $1250 to $2000
                  Increased 7 Jan 2013 to $2500 Current level
  Section 321 – Under $200 – no duties due
                      Increased 3/7 Mar 16 to $800 Current level – 1 per day, some  
                      exceptions

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COMM_a2
11. M. Volkov: “Putting Ethics Back Into Compliance (Part IV of IV)”

(Source: Volkov Law Group Blog, 16 Nov 2017. Reprinted by permission.)
 
* Author: Michael Volkov, Esq., Volkov Law Group, mvolkov@volkovlaw.com, 240-505-1992.
 
[Editor’s Note: Parts 1, 2, and were included in the Daily Bugles of 16, 17, and 20 November, respectively.]
 
My final posting in this ethics series is a call to action for all compliance professionals. Every compliance officer should insist on and embrace a title – “Chief Ethics and Compliance Officer.” Some larger organizations have a separate ethics officer, and I am not suggesting to merge the positions. Every company should have a chief ethics officer, either as a separate function or as part of the compliance function. In mid-size and smaller organizations, the chief compliance officer should be responsible as the chief ethics and compliance officer for both the company’s ethical culture and compliance with the law and the code of conduct.
 
Compliance is much more than just compliance with the law and the company’s code of conduct. A company has to define, maintain and promote its ethical culture. And a chief compliance officer has to recognize the importance of the company’s ethical culture. As I often say, an ethical culture is the most effective control that a company can implement.
 
CCOs have to avoid a narrow focus on the intricacies of compliance controls to the detriment of the company’s culture.   A company’s culture is reflected in its controls and overall compliance with the law and code of conduct. Too often, chief compliance officers carry ethics around as an afterthought to the company’s compliance program. The legal intricacies and day-to-day management of compliance controls can be overwhelming when you consider the scale and monitoring, oversight, review and continuous improvement responsibilities.
 
If you assume that the company’s ethical culture is a valuable intangible assets and an effective compliance control, it is easy to conclude that CCOs need to refocus their efforts and attend to the company’s culture.
 
To do so, CCOs have to assume responsibility for the company’s culture, assuming the company already has defined its values and principles. A values statement is essential, and must be concise and to the point.
 
A company’s culture, once defined, has to be communicated and embedded in the workforce. On a number of occasions, I have observed employees who ask a very specific question – how does the company’s ethical culture and values apply to my job? CCOs have to anticipate this question and address the meaning of the company’s values mission in real and concrete terms.
 
This is when the CEO and senior management have to communicate in words and in conduct how they live by the company’s values, as reflected in the values statement and the company’s code of conduct. Without this support and effort, the company’s attempt to embed its culture will fail.
 
To reinforce this message, the CCO has to conduct training on the company’s culture as part of the code of conduct training, provide concrete examples tailored to the specific audience, and make sure managers and supervisors repeat the message.
 
One of the more important strategies a CCO has to use to train and enlist the support of managers and supervisors to promote, reinforce and communicate brief daily ethics messages to immediate employees. These ethics reminders are critical. This is ethics on the frontlines and in the trenches, where it counts.
 
A CCO has to measure and monitor the company’s
 
culture by partnering with human resources. Periodic measurements of discrete functions, divisions, product lines, geographic units should be conducted on a rotating and rolling basis so that the CCO and HR can collect data on whether the company’s culture is being embraced, how to fine tune its operations and whether remediation may be required. Focus groups and targeted interviews provide additional data points.
 
With this active culture program, CCOs have an obligation to educate and report to the board, the CEO and management on the company’s culture. If necessary, additional efforts may be needed to address specific deficiencies in the company’s culture.
 
There is much more to this effort that has to be done but these are just some of the basic requirements for defining and maintaining an active culture compliance program. Companies have developed creative strategies and maximize opportunities to reinforce culture messaging and conduct – it is the lifeblood of every company, and should be part of every CCO’s lifeblood.
 

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COMM_a3
12. Gary Stanley’s ECR Tip of the Day

(Source: Defense and Export-Import Update; available by subscription from
gstanley@glstrade.com
)
 
* Author: Gary Stanley, Esq., Global Legal Services, PC, +1 202-352-3059,
gstanley@glstrade.com
.
 
License Exception STA authorizes certain exports, reexports and transfers (in-country). The most likely scenario for use of License Exception STA to transfer (in-country) would be to comply with the terms of a license. In this scenario, the original export was authorized under a Commerce license to a Country Group A:5 country or the export was authorized under an ITAR license or other approval as a USML paragraph (x) item under the section 120.5(b) process, such as to a defense contractor (Defense Contractor A), and subsequently the defense contractor needed to go outside the scope of the original Commerce license or State license or other approval, such as by selling the “600 series” item to another defense contractor (Defense Contractor B) in that same Country Group A:5 country who was not authorized under the original export license. In this example, Defense Contractor B was not listed on the original license as an authorized end user, and therefore an EAR authorization is required to transfer to Defense Contractor B. If Defense Contractor B will use the “600 series” item for manufacturing a military item for the Country Group A:5 military, then the transfer (in-country) could most likely be authorized under License Exception STA. (Note that you must also then obtain a prior consignee statement from Defense Contractor B, along with satisfying any other applicable requirements of License Exception STA, before you can permit Defense Contractor A to transfer the “600 series” item to Defense Contractor B in reliance on License Exception STA).  

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TECEX/IM TRAINING EVENTS & CONFERENCES

TEC_a113. ECTI Presents “Risk Based Self-Assessment as a Critical Element to Measure Risk, Performance, and Improvement,” Webinar, 14 Dec

(Source: Danielle McClellan, danielle@learnexportcompliance.com)
 
* What: Risk Based Self-Assessment as a Critical Element to Measure Risk, Performance, and Improvement
* When: December 14, 2017; 1:00 p.m. (EST)
* Where: Webinar
* Sponsor: Export Compliance Training Institute (ECTI)
* ECTI Speaker: Randall Cook & Rosanne Giambalvo
* Register: Here or Danielle McClellan, 540-433-3977, danielle@learnexportcompliance.com.
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ENEDITOR’S NOTES

 

* Voltaire (François-Marie Arouet; 21 Nov 1694 – 30 May 1778; was a French writer, historian, and philosopher famous for his wit, his attacks on the established Church, and his advocacy of freedom of religion, freedom of speech, and separation of church and state. Voltaire was a prolific writer, producing works in almost every literary form, including plays, poems, novels, essays, and historical and scientific works. He wrote more than 20,000 letters and more than 2,000 books and pamphlets.)
  – It is difficult to free fools from the chains they revere.
  – In general, the art of government consists of taking as much money as possible from one class of citizens to give to another.”

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EN_a315
. 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: 9 Nov 2017: 82 FR 51983-51986: Amendments to Implement United States Policy Toward Cuba

  
*
FOREIGN ASSETS CONTROL REGULATIONS (OFAC FACR)
: 31 CFR, Parts 500-599, Embargoes, Sanctions, Executive Orders
  – Last Amendment: 13 Nov 2017: 82 FR 52209-52210: Removal of Côte d’Ivoire 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, 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: 20 Oct 2017: Harmonized System Update 1707, containing 27,291 ABI records and 5,164 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: 19 Nov 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_a0316. 
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.

* 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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