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17-1128 Tuesday “Daily Bugle”

17-1128 Tuesday “Daily Bugle”

Tuesday, 28 November 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. State Announces Advisory Committee on International Law Meeting on 14 Dec in Wash DC
  1. Items Scheduled for Publication in Future Federal Register Editions 
  2. Commerce/BIS Gives “Know Your Customer” Guidance
  3. Commerce/BIS Modifies TDO Concerning Mahan Airways of Tehran, Iran, and Others, Removes 3 Parties
  4. DHS/CBP Releases Updated ACE Entry Summary Business Process Document
  5. State/DDTC Announces DTAS System Outage on 1 Dec
  6. Treasury/OFAC Issues Ukraine-/Russia-Related General License 1B, Releases Updated and New FAQs
  7. Germany BAFA Announces Export Control Events on 8 Dec 2017 and 22-23 Mar 2018
  1. Global Trade News: “U.S. Customs and Border Protection to Deploy Statements, e214 and MID within ACE on 9 Dec 2017”
  2. ST&R Trade Report: “CBP to Examine Use of Blockchain in Trade Environment”
  3. The Washington Times: “EU Moves to Place Export Controls on Hacking Tools, Surveillance Software”
  1. M.C. Hamilton: “Deemed Exports and You”
  2. SIPRI Releases Report Concerning 3D Printing and Missile Technology Controls
  3. Gary Stanley’s ECR Tip of the Day
  4. R.C. Burns: “Mugabe Leaves, Mnangagwa Arrives, Sanctions Remain”
  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_a11.

State Announces Advisory Committee on International Law Meeting on 14 Dec in Wash DC

(Source:
Federal Register, 28 Nov 2017.)
 
82 FR 56322: Notice of Meeting of Advisory Committee on International Law
 
A meeting of the Department of State’s Advisory Committee on International Law will take place on Thursday, December 14, 2017, from 9:30 a.m. to 5:00 p.m. at the George Washington University Law School, Michael K. Young Faculty Conference Center, 716 20th St. NW, 5th Floor, Washington, D.C. It is anticipated that Acting Legal Adviser Richard C. Visek will chair the meeting, which will be open to the public up to the capacity of the meeting room. It is anticipated that the meeting will include discussions on:
 
  – international law and cyberspace;
  – lethal autonomous weapons systems; and
  – self-determination under international law.
 
Members of the public who wish to attend should contact the Office of the Legal Adviser by December 10 at heathjb@state.gov or 202-776-8315 and provide their name, professional affiliation, address, and phone number. A valid photo ID is required for admission to the meeting. Attendees who require reasonable accommodation should make their requests by December 7. Requests received after that date will be considered but might not be possible to accommodate.
 
  J. Benton Heath, Attorney-Adviser Office of the Legal Adviser, 
Executive Director Advisory Committee on International Law, 
Department of State.
 

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OGSOTHER GOVERNMENT SOURCES

OGS_a12
. Items Scheduled for Publication in Future Federal Register Editions
 

(Source:
Federal Register)
 
* Commerce/BIS; NOTICES; Impact of Implementation of Chemical Weapons Convention on Legitimate Commercial Chemical, Biotechnology, and Pharmaceutical Activities Involving “Schedule 1” Chemicals (including Schedule 1 Chemicals Produced as Intermediates) through Calendar Year 2017 [Publication Date: 29 Nov 2017.]

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OGS_a23.

Commerce/BIS Gives “Know Your Customer” Guidance

(Source:
Commerce/BIS, 28 Nov 2017.) 
 
Certain provisions in the Export Administration Regulations (EAR) require an exporter to submit an individual validated license application if the exporter “knows” that an export that is otherwise exempt from the validated licensing requirements is for end-uses involving nuclear, chemical, and biological weapons (CBW), or related missile delivery systems, in named destinations listed in the EAR.
 
BIS has issued the following guidance on how individuals and firms should act under this knowledge standard. This guidance does not change or revise the EAR.
 
Decide whether there are “
Red Flags
 
Take into account any abnormal circumstances in a transaction that indicate that the export may be destined for an inappropriate end-use, end-user, or destination. Such circumstances are referred to as “Red Flags.” Included among examples of red flags are orders for items which are inconsistent with the needs of the purchaser, a customer’s declining installation and testing when included in the sales price or when normally requested, or requests for equipment configurations which are incompatible with the stated destination (e.g.–120 volts in a country with a standard of 220 volts). BIS has developed lists of such ”
Red Flags” which are not all-inclusive but are intended to illustrate the types of circumstances that should cause reasonable suspicion that a transaction will violate the EAR. You should also review U.S. Government Lists to check to identify parties prohibited or restricted from participating in U.S. export transactions as well as BIS’s Unverified List of parties whose bona fides BIS has been unable to determine in end-use checks.
 
If there are “
Red Flags
 
If there are no “Red Flags” in the information that comes to your firm, you should be able to proceed with a transaction in reliance on information you have received. That is, absent “Red Flags” (or an express requirement in the EAR), there is no affirmative duty upon exporters to inquire, verify, or otherwise “go behind” the customer’s representations. However, when “Red Flags” are raised in the information that comes to your firm, you have a duty to exercise due diligence to inquire regarding the suspicious circumstances and ensure appropriate end-use, end-user, or ultimate country of destination in the transactions you propose to engage in.
 
The duty to check out “Red Flags” is not confined to transactions involving the “know,” “reason to know,” or “is informed” sections of the EAR. Parties engaging in export transactions are required by the EAR to obtain documentary evidence concerning the transaction; misrepresentation or concealment of material facts is prohibited, both in the licensing process and in all export control documents. You can rely upon representations from your customer and repeat them in the documents you file unless “Red Flags” oblige you to take verification steps.
 
Do not self-blind
 
Do not cut off the flow of information that comes to your firm in the normal course of business. For example, do not instruct the sales force to tell potential customers to refrain from discussing the actual end-use, end-user and ultimate country of destination for the product your firm is seeking to sell. Do not put on blinders that prevent the learning of relevant information. An affirmative policy of steps to avoid “bad” information would not insulate a company from liability, and it would usually be considered an aggravating factor in an enforcement proceeding.
 
Employees need to know how to handle “Red Flags.” Knowledge possessed by an employee of a company can be imputed to a firm so as to make the firm liable for a violation. This makes it important for firms to establish clear policies and effective compliance procedures to ensure that such knowledge about transactions can be evaluated by responsible senior officials. Failure to do so could be regarded as a form of self-blinding.
 
Reevaluate all the information after the inquiry
 
The purpose of this inquiry and reevaluation is to determine whether the “Red Flags” can be explained or justified so as to evidence the bona fides of the party and the legitimacy of the transaction. If they can, you may proceed with the transaction. If the “Red Flags” cannot be explained or justified and you proceed, you run the risk of having had “knowledge” that would make your action a violation of the EAR.
 
Refrain from the transaction, disclose the information to BIS and wait
 
If you continue to have reason for concern after your inquiry, then you should either refrain from the transaction or submit all the relevant information to BIS in the form of an application for a validated license or in such other form as BIS may specify.
Industry has an important role to play in preventing exports and reexports contrary to the national security and foreign policy interests of the United States. BIS works in partnership with industry to make this front line of defense effective, while minimizing the regulatory burden on exporters. If you have any question about whether you have encountered a “Red Flag,” you may 
contact BIS’ Office of Export Enforcement or use this 
Confidential Enforcement Lead/Tip Form to submit a confidential tip.
 
N.B. Please note that use of the form will 
not generate any return e-mail to you so that the information you submit will remain confidential.

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OGS_a3
4.

Commerce/BIS Modifies TDO Concerning Mahan Airways of Tehran, Iran, and Others, Removes 3 Parties

(Source:
Commerce/BIS, 28 Nov 2017.) [Excerpts.]
 
* Respondent(s): Mahan Airways of Tehran, Iran, and others.
* Modification: The following parties are removed from the Temporary Denial Order (TDO) issued on 27 June 2017:
  – Ali Eslamian of London UK;
  – Equipco (UK) Ltd. of London, UK; and
  – Skyco (UK) Ltd. of London, UK.
* Findings: Ali Eslamian, Equipco (UK) Ltd., and Skyco (UK) Ltd. should be removed from the TDO. The TDO shall remain in full force and affect as to Mahan Airways and others, until 26 December 2017.
* Date of Order: 16 November 2016.

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OGS_a4
5.

DHS/CBP Releases Updated ACE Entry Summary Business Process Document

(Source:
CSMS# 17-000740, 27 Nov 2017.)
 
An updated version of the EXTERNAL ACE Entry Summary Business Process TRADE document (v8.0b), which was released on Monday November 27th, 2017, has been posted on here.
 
All ACE Entry Summary Business Process document related questions, comments, and suggestions should be emailed to acebusinessrules@cbp.dhs.gov

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OGS_a56
.

State/DDTC Announces DTAS System Outage on 1 Dec

(Source:
State/DDTC, 28 Nov 2017.)
 
The DTAS information systems will be unavailable from 6:00AM-8:00AM Friday, 1 December 2017 for scheduled routine maintenance. The DTAS systems will be available Friday, 1 December 2017 after 8:00AM.
 
Last week, DDTC already announced the following outages:
 
  – From 4:00AM-6:00AM Thursday, 30 November 2017.
 
From 6:00PM-8:00PM Wednesday, 6 December 2017.

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OGS_a67
.

Treasury/OFAC Issues Ukraine-/Russia-Related General License 1B, Releases Updated and New FAQs

(Source:
Treasury/OFAC, 28 Nov 2017.)
 
Today, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) is issuing Ukraine-/Russia-related General License 1B and is publishing updated Ukraine-/Russia-related FAQs and one new Ukraine-/Russia-related FAQ.  These changes relate to the amended Ukraine-/Russia-related Directives 1 and 2 that were issued on September 29, 2017 in accordance with Title II of the Countering America’s Adversaries Through Sanctions Act of 2017 (CAATSA).  Certain CAATSA-related prohibitions in amended Directives 1 and 2 had a delayed effective date of November 28, 2017.  In order to account for the fact that the CAATSA-related prohibitions in amended Directives 1 and 2 have now come into effect, OFAC is issuing General License 1B to address the decrease in the maturity dates for Directive 1 from 30 days to 14 days, and the decrease in the maturity dates for Directive 2 from 90 days to 60 days; in the case of both directives, these new prohibitions relate to debt issued on or after November 28, 2017.  OFAC is also publishing updated Ukraine-/Russia-related FAQs and one new FAQ. 

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OGS_a78.

Germany BAFA Announces Export Control Events on 8 Dec 2017 and 22-23 Mar 2018

(Source:
German BAFA, 28 Nov 2017.)
 
The German Federal Office for Economic Affairs and Export Control (BAFA) announces the following two export control events:
 

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NWSNEWS

NWS_19
.

Global Trade News: “U.S. Customs and Border Protection to Deploy Statements, e214 and MID within ACE on 9 Dec 2017”

(Source:
Integration Point Blog, 28 Nov 2017.) [Excerpts.]
 
United States Customs and Border Protection (CBP) has announced plans to finalize the rollout of Automated Commercial Environment (ACE) in early 2018, with the next release due 9 Dec 2017. On that date, CPB will deploy Statements, e214 (electronic Foreign-Trade Zone (FTZ) admissions), and Manufacturer ID (MID) Creation capabilities within ACE.
 
The final release is scheduled for 24 Feb 2018, and will include Reconciliation, Liquidation and Drawback.
 
The National Association of Foreign-Trade Zones (NAFTZ) President Erik O. Autor responded to CBP’s announced postponement from 16 Sep to 9 Dec. “I am very pleased to report that CBP Acting Commissioner Kevin McAleenan announced…that the planned 16 Sept date for the full transition of the core e214 functionality from ACS into ACE has been postponed until 9 Dec.
 
  “We recognize that a decision to postpone this long-scheduled transition was a difficult one. But we are also convinced that it is the right decision – a decision that also reconfirms our belief that (CBP) understands both our industry and his responsibilities in managing such a complex organization,” Autor said.  
 
Click
Here for the complete schedule. … 

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NWS_a2
10.

ST&R Trade Report: “CBP to Examine Use of Blockchain in Trade Environment”

 
U.S. Customs and Border Protection is moving ahead with an evaluation of the implications and potential application of blockchain technology to trade processing. As part of that effort, CBP’s Commercial Customs Operations Advisory Committee has established a working group to examine this issue.
 
A blockchain essentially functions as a distributed ledger that records transactions in a verifiable and permanent way. Blockchain records are transparent to all who have access to the network but are decentralized across that network, making them virtually incorruptible. This security has made blockchain a promising technology for recording a wide range of activities, including customs and trade-related transactions.
 
Earlier this fall the Department of Homeland Security conducted a two-day workshop on blockchain for COAC’s new emerging technologies working group. On the first day DHS provided an overview of blockchain and how it is currently being used, while on the second day participants discussed various cases where the use of this technology might be feasible.
 
More than a dozen proposed uses were identified, including capturing and keeping track of partner government agency licenses and permits, certificate of origin reporting, free trade agreement product qualification, carnets, and bonded movement tracking. CBP now plans to work with the COAC working group to further evaluate the workflow processes of some of these cases and how blockchain technology could be used, although no specific timeframe has yet been established.
 
According to press reports, companies and organizations in other parts of the world are also testing how blockchain may aid international trade flows, including tracking cargo containers, transferring shipping documents, and confirming cross-border payments.

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NWS_a3
11.

The Washington Times: “EU Moves to Place Export Controls on Hacking Tools, Surveillance Software”

(Source:
The Washington Times, 24 Nov 2017.) [Excerpts.]
 
Lawmakers in the European Union (EU) have advanced plans to subject hacking tools to export controls currently reserved for depleted uranium, human pathogens and other “dual use” products and technologies with both military and civilian applications.
 
The European Parliament’s Trade Committee voted 34-1 Thursday in support of expanding its list of regulated dual use products to cover “cyber-surveillance technology which can be used for the commission of serious violations of human rights or international humanitarian law, or can pose a threat to international security or the essential security interests of the Union and its Member States.”
 
The EU’s existing export controls impose restrictions on dual use products capable of being used to make weapons of mass destruction or otherwise banned by trade embargoes.

But if passed by the EU Parliament’s full House, the draft proposal adopted Thursday would place spyware and other surveillance technologies in the same category as missiles, lasers, toxins and other items prone to being harnessed against civilians. …

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COMMCOMMENTARY

COMM_a112.

M.C. Hamilton: “Deemed Exports and You”

 
* Author: Mark C. Hamilton, Esq., mhamilton@tuckerlaw.com, Tucker Arensberg Attorneys.
 
You may be surprised to learn that you can commit an export control violation without shipping a single product overseas.  This is due to the “deemed export” rule.
 
Simply put, you must obtain an export license from the Bureau of Industry and Commerce before you can legally release controlled technology to a foreign person. This is because the US government considers the sharing of controlled information with foreign nationals to be the functional equivalent of a physical export to the person’s country of origin. See 15 CFR 734.13 (b).
 
It makes sense when you think about it. A physical product can be tracked and recovered. If not, it still has a finite shelf life. For example, a set of night vision goggles will eventually break or simply wear out. Yet the knowledge of how to manufacture or operate night vision goggles does not have an expiration date. In fact, once such technology is disseminated it can no longer be effectively controlled. Depending on the technology concerned, its dissemination to foreign persons can have serious economic and national security implications.
 
So that is the basic rule, but what should you do about it? First, you need to determine whether an export license is necessary. There is definitely a risk if you employ foreign nationals or otherwise share data or other information with foreign persons as part of your business. This is particularly the case in the bio-chemical, medical, computer and defense-related industries.  Universities are also subject to export licensing requirements because foreign students frequently work in a research and development role that involves exposure to controlled technology.
 
So regardless of whether you actually ship products out of the country, if your work concerns defense-related or dual use products, you need to be aware of the “deemed export” rule. A determination of whether an export license is necessary needs to be made before you share controlled information with a foreign person. If there is any doubt, the best practice is to screen any foreign national employees or customers from potentially controlled information until a licensing determination has been made.

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COMM_a2
13.

SIPRI Releases Report Concerning
3D Printing and Missile Technology Controls

(Source:
SIPRI, 28 Nov 2017.)  
 
Stockholm International Peace Institute (SIPRI) is pleased to announce the release of a new Background Paper ‘3D printing and missile technology controls’, originally part of a compendium of research papers compiled by the Missile Technology Control Regime on the occasion of their 30th anniversary.
 
Read the report here.
 
Additive manufacturing (AM), also referred to as ‘3D printing’, is widely characterized as a ‘disruptive technology’. It has been hailed for its potential to revolutionize the manufacturing industry by transforming existing modes of production, sales and transfers of goods and technologies in many industrial sectors. This new report critically examines the state of the technology and the extent to which AM poses a challenge to export controls, especially for missile technology. 
 
The report explores the remaining hurdles of the technology as well as its current applications in missile manufacturing and the wider aerospace industry. It emphasizes that this technology has not yet reached the ‘at the push of a button’ scenario that many envision or fear.
 
One of the key challenges to export controls, states the report, is that the capabilities of AM machines makes it difficult to distinguish between machines that are proliferation-relevant and those that are not.
 
The authors argue that a balance needs to be struck between creating barriers to proliferation and limiting the negative side effects these controls can have on legal trade and promising civilian applications of the technology. A key example of the difficulty of applying controls on the materials used in the AM process is controls on Titanium powders, which are used both to produce dental and other implants, and in the defence and aerospace industry for airplane parts and possibly for missiles.
 
Furthermore, the report explores how the implementation of controls on digital transfer of build files poses a profound challenge to export controls. This constitutes issues for both companies and states, and sheds light on the increasing importance of cybersecurity for AM. Controlling the transfer of build files through audit and record-keeping requirements may, however, be one of the most effective ways to implement AM controls, if properly applied and enforced, states the report.
 
The report discusses the potential to advance controls on AM in three particular areas: (a) controls on the export of AM machines; (b) controls on the materials used in the AM process; and (c) controls on the transfer of build files. By using this case study of AM technology, the report also highlights the challenge intangible transfers of technology pose for export controls, and the need for effective dialogue between states, companies and export control regimes.

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* Author: Gary Stanley, Esq., Global Legal Services, PC, (202) 352-3059,
gstanley@glstrade.com
.
 
Items controlled by the EAR should not be included in the valuation of Technical Assistance Agreement or Manufacturing License Agreements. When it becomes necessary to amend your agreement, the (a)(6) table must reflect USML-associated costs only, and may be “de-valued” accordingly.

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COMM_a4
15.

R.C. Burns: “Mugabe Leaves, Mnangagwa Arrives, Sanctions Remain”

(Source:
Export Law Blog
, 27 Nov 2017. Reprinted by permission.)
 
* Author: R. Clifton Burns, Esq., Bryan Cave LLP, Wash DC,
Clif.Burns@bryancave.com
, 202-508-6067).
 
Last Tuesday, while you were thinking about the upcoming Thanksgiving holiday, Robert Mugabe, who has been dictator of Zimbabwe for the last 37 years, resigned. Then while you were storming the doors of a local brick and mortar on Black Friday to cart off a new 4k flat screen TV, former Zimbabwean First Vice-President Emmerson Mnangagwa was sworn in as the new President, er, dictator of Zimbabwe.
 
So, you ask, whither the U.S. sanctions on numerous persons and companies in  Zimbabwe? Here’s a hint:  Mnangagwa’s nickname is “The Crocodile” and he’s been Mugabe’s right hand man for years until the opportunity to replace Mugabe presented itself and Mnangagwa shoved him aside. Here’s another hint:  Mnangagwa is, like Mugabe, on the SDN list, mostly for himself being knee-deep in everything that got Mugabe on the list and kept him there, including the notorious military massacre of the Ndebeles in Matabeleland.
 
The denial of bail for jailed political opponents of Mnangagwa, Ignatius Chombo and Kudzanai Chipanga, does not give much reason to hope that democratic reforms – a prerequisite to any sanctions reform for Zimbabwe – will occur in the near future.
 
Even though many of the member of Zimbabwe’s ruling class and associated companies and agencies are under sanctions, and will likely remain so for the near future, Zimbabwe is a major recipient of U.S. foreign aid, recently receiving $220 million from the United States. As you probably know, that could change if Mnangagwa is determined to have taken power through a coup. Section 508 of the Foreign Assistance Act, as continued through various subsequent appropriations bills, prohibits foreign aid to countries where a duly elected head of government is deposed by military coup or decree. Whether or not Mugabe was “duly elected” remains, I suppose, open to doubt, but even so State Department spokesman Heather Nauert declined to answer questions as to whether Mnangagwa’s takeover was even a coup. “I’m not going to take that bait,” was what she said to worm out of answering that question.

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ENEDITOR’S NOTES

EN_a116
. Bartlett’s Unfamiliar Quotations

(Source: Editor)

 
* Friedrich Engels (28 Nov 1820 – 5 Aug 1895; was a German philosopher, social scientist, journalist and businessman. Engels founded Marxist theory together with Karl Marx and in 1845 published The Condition of the Working Class in England, based on personal observations and research in Manchester. In 1848, Engels co-authored The Communist Manifesto with Marx and also authored and co-authored (primarily with Marx) many other works. Later, Engels supported Marx financially to do research and write Das Kapital.)
  – “All history has been a history of class struggles between dominated classes at various stages of social development.”
 
* William Blake (28 Nov 1757- 12 Aug 1827; was an English poet, painter, and printmaker. Largely unrecognized during his lifetime, Blake is now considered a seminal figure in the history of the poetry and visual arts of the Romantic Age.)
  – “Think in the morning. Act in the noon. Eat in the evening. Sleep in the night.”

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EN_a217. Are Your Copies of Regulations Up to Date?
(Source: Editor)

The official versions of the following regulations are published annually in the U.S. Code of Federal Regulations (C.F.R.), but are updated as amended in the Federal Register.  Changes to applicable regulations are listed below.
 


ATF ARMS IMPORT REGULATIONS: 27 CFR Part 447-Importation of Arms, Ammunition, and Implements of War
  – Last Amendment: 15 Jan 2016: 
81 FR 2657-2723: Machineguns, Destructive Devices and Certain Other Firearms; Background Checks for Responsible Persons of a Trust or Legal Entity With Respect To Making or Transferring a Firearm. 
 

CUSTOMS REGULATIONS: 19 CFR, Ch. 1, Pts. 0-199
  – 
Last Amendment: 28 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, 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: 20 Oct 2017: 
Harmonized System Update 1707, c
ontaining 
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: 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_a318
. Weekly Highlights of the Daily Bugle Top Stories

(Source: Editor)
 

Review last week’s top Ex/Im stories in “Weekly Highlights of Daily Bugle Top Stories” posted here.

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

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

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

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