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17-1212 Tuesday “Daily Bugle”

17-1212 Tuesday “Daily Bugle”

Tuesday, 12 December 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/Census: “Finding Your Schedule B Number”
  3. Commerce/BIS: (No new postings.)
  4. DHS/CBP Announces Submission Period for 2018 Customs Broker Triennial Status Report and Fee, Deadline 28 Feb 2018
  5. DoD/DSCA Publishes Policy Memo 17-51
  6. DoD/DSS Announces Annual NISP Cost Collection Survey
  7. State/DDTC: (No new postings.)
  8. EU Amends Sanctions Against DR Congo, Supports Global Reporting Mechanism Concerning Illicit Trade in Small Arms, Light Weapons, Conventional Weapons, and Ammunition
  9. UK DIT/ECO Publishes Lists of Revoked OGELs
  1. Al Jazeera: “Uncertainty Shrouds Canadian Arms Sales to Saudi Arabia”
  2. Business Insider: “Charges: Turkish Businessman Exported U.S. Goods to Iran”
  3. The New York Times: “U.S. Man Accused of Illegal Gun Exports to Europe, Australia”
  4. Reuters: “EU to Agree Extending Economic Sanctions on Russia Until Mid-2018”
  1. G. Bekmukhanbetova & C. Masters: “Steps to Liberalize Uzbekistan’s Export – Import Regime”
  2. M.A. Gajewski Barnhil: “Export Control Considerations: Beyond the Authorization”
  3. Gary Stanley’s ECR Tip of the Day
  1. Bartlett’s Unfamiliar Quotations 
  2. Are Your Copies of Regulations Up to Date? Latest Changes: ATF (15 Jan 2016), Customs (8 Dec 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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OGS_a22.

Commerce/Census: “Finding Your Schedule B Number”

(Source:
Global Reach Blog, 11 Dec 2017.) [Excerpts.]
 
You are exporting a product to a foreign country and your filer calls you for a Schedule B number. What is that and how do you find it?
 
Schedule B numbers are 10-digit statistical classification codes for all domestic and foreign goods being exported from the United States. With over 9,000 codes, the process can seem overwhelming. Here are the steps to find the appropriate number for your goods using the U.S. Census Bureau’s Schedule B search engine. To find the Schedule B search engine, you should start at census.gov/trade and click on the gray Schedule B tab. The link to the search engine is located in the second red box labeled Schedule B Search.
 
The search engine will ask questions to narrow down the Schedule B options based on key words that you input. Some searches will be easy and take you directly to the code. Other searches may require multiple attempts. The search engine may ask about composition, capacity, power source, end use or function. These key characteristics allow the search engine to hone in on the appropriate Schedule B for your product. Please see Foreign Trade Regulations §30.36-30.40
for additional details on filing exemptions per Schedule B number.
 
For a step-by-step demonstration on Finding a Schedule B Number, click here. … 
 
Finding a Schedule B number can be a complex process, however, the Census Bureau Schedule B search engine can be helpful in narrowing down which number you report for your goods. … 

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OGS_a44.

DHS/CBP Announces Submission Period for 2018 Customs Broker Triennial Status Report and Fee, Deadline 28 Feb 2018

(Source:
DHS/CBP, 1 Dec 2017.)
 
On 1 December 2017, U.S. Customs and Border Protection announced the submission period for the 2018 Customs Broker Triennial Status Report and fee for all licensed customs brokers opens Friday, 15 December 2017.
 
Every licensed broker is required to file a status report with CBP every three years and the deadline for submitting the 2018 Triennial Status Report and fee is Wednesday, 28 February 2018 at 11:59 p.m. EST.
 
Submissions will be collected online via Pay.gov.  Pay.gov accepts credit card, debit card, and digital wallet (i.e. PayPal and Amazon Pay) payments. No additional fees are charged for any payments, and receipts are provided electronically.
 
Each entity holding a broker’s license must file a status report with CBP and pay a processing fee of $100 every three years, in accordance with 19 CFR § 111.30(d). Licensed customs brokers must include an employee list, if applicable, with each status report submitted to CBP in accordance with 19 CFR § 111.28(b). In addition, each individually licensed broker must state whether or not he/she still meets the applicable requirements of 19 CFR § 111.11 and 111.19 and has not engaged in any conduct that could constitute grounds for suspension or revocation under section 111.53. Broker employee lists and any additional detail can be submitted as a PDF file attachment with the Pay.gov online form.
 
Individuals are considered to be “actively engaged” in transacting customs business when they are currently transacting or have recently transacted customs business on behalf of others as a sole proprietor, or when they are employed by a licensed customs broker which is currently transacting or has recently transacted customs business on behalf of others. Those who work for another broker and are not directly involved in any activities which fall under the scope of the definition of customs business may report that they are not actively engaged in customs business.
 
Partnerships, corporations, and associations must also report to customs in a status report whether or not they are actively engaged in customs business. An organization which currently transacts or recently transacted customs business on behalf of others should report that they are “actively engaged” in customs business.
 
Failure to file a Triennial Status Report will result in the customs broker’s license to be revoked by operation of law, without prejudice.
 
CBP encourages all brokers to submit the report and fee electronically via Pay.gov; however, CBP will accept a paper status report and payment at the port that originally delivered the license.
 
For more information, visit www.CBP.gov/Broker-FAQ.

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OGS_a55.

DoD/DSCA Publishes Policy Memo 17-51

(Source:
DoD/DSCA, 12 Dec 2017.)
 
 
– This memorandum adds a new transportation Surcharge Account and identifies the line of accounting that should be used when loading information into shipping and billing systems for the new Building Partnership Capacity (BPC) programs established by the FY17 National Defense Authorization Act (NDAA).

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OGS_a66.

DoD/DSS Announces Annual NISP Cost Collection Survey

(Source:
DoD/DSS, 11 Dec 2017.)
 
As the Executive Agency for the National Industrial Security Program (NISP) under Executive Order 12829, the Department of Defense is required to provide the Information Security Oversight Office (ISOO) with an estimated annual cost to industry of complying with NISP security requirements. We determine the costs by surveying contractors who possess classified information at their cleared facility. Results are forwarded to ISOO and incorporated in an annual report to the President.
 
To meet this requirement, DSS conducts a stratified random sample survey of contractor facilities using a web-based survey and Office of Management and Budget (OMB)-approved survey methodology. Since the sample of cleared facility participants is randomly selected, not all facilities will receive the survey. The survey will be fielded on January 16, 2018, and remain open through COB January 29, 2018. Participation is anonymous. The survey invitation will contain a foresee.net survey link. Verification of the legitimacy of the survey URL can be obtained through your Cognizant Security Office. If you have any questions, please direct them to: dss.ncr.dss.mbx.psiprogram@mail.mil.
 
We appreciate your cooperation and submission of the cost information by January 29, 2018.

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OGS_a88.

EU Amends Sanctions Against DR Congo, Supports Global Reporting Mechanism Concerning Illicit Trade in Small Arms, Light Weapons, Conventional Weapons, and Ammunition

 
Decisions
* Council Decision (CFSP) 2017/2282 of 11 December 2017 amending Decision 2010/788/CFSP concerning restrictive measures against the Democratic Republic of the Congo (DR Congo)
* Council Decision (CFSP) 2017/2283 of 11 December 2017 in support of a global reporting mechanism on illicit small arms and light weapons and other illicit conventional weapons and ammunition to reduce the risk of their illicit trade (‘iTrace III’)

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OGS_a99.

UK DIT/ECO Publishes Lists of Revoked OGELs

(Source:
UK DIT/ECO
, 12 Dec 2017.)
 
The Export Control Organisation (ECO) of the UK Department of International Trade (DIT) has published all previous, revoked versions of the following 18 open general export licenses (OGELs):
 

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NWSNEWS

NWS_a1
10Al Jazeera: “Uncertainty Shrouds Canadian Arms Sales to Saudi Arabia”

(Source: Al Jazeera, 11 Dec 2017.) [Excerpts.]
 
Pressure is mounting on the Canadian government over an “historic” $12bn-arms deal to Saudi Arabia, with legal experts and human rights watchdogs expressing outrage and calling for its cancellation.
 
Signed in 2014 by the previous government, which was then led by the Conservative Party, the deal is meant to send nearly $12bn (15bn Canadian dollars) worth of military vehicles to Saudi Arabia.
 
The light-armored vehicles, known as LAVs, will reportedly be equipped with machine guns and anti-tank cannons. …
 
But rights groups, as well as challenges against the government, have renewed fears that the Canadian equipment may be used by Saudi Arabia to carry out alleged human rights abuses in the kingdom and Yemen. …
 
Since 1986, Canada has adopted measures that restrict the export of arms to countries with serious human rights violations unless it can be proven that there is “no reasonable risk” that they might be used against their own civilians. …
 
In April 2017, Foreign Minister Freeland introduced legislation, known as Bill C-47, in Parliament to “enhance transparency and accountability in Canada’s export controls”.
 
The bill is a proposed amendment to Canada’s Export and Import Permits Act. It sets mandatory considerations for the minister of foreign affairs “to take into account” before issuing any export permits. … 

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NWS_a2
11Business Insider: “Charges: Turkish Businessman Exported U.S. Goods to Iran”

(Source: Business Insider, 11 Dec 2017.) [Excerpts.]
 
Federal prosecutors allege a Turkish businessman helped illegally route Wisconsin-made outboard engines and boat generators to the Iranian navy.
 
Forty-year-old Resit Tavan of Istanbul appeared in U.S. District Court in Milwaukee Monday. Tavan was arrested in Romania in June on an international warrant.
 
Tavan, his Turkish company and a manager there are accused of conspiring to defraud the U.S. and to smuggle American-made products to Iran.
 
The Milwaukee Journal Sentinel reports the indictment alleges they failed to obtain the special licenses needed to get around trade embargoes against Iran in place since 1995. Instead, the defendants allegedly negotiated the export of the engines and generators to Turkey, then re-exported them to Iran.
 
Tavan’s attorney, Nejla Lane, told The Associated Press her client pleaded not guilty and will fight the charges. … 

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NWS_a3
12The New York Times: “U.S. Man Accused of Illegal Gun Exports to Europe, Australia”

(Source: The New York Times, 11 Dec 2017.) [Excerpts.]
 
A fugitive captured in Mexico is due in a U.S. courtroom Tuesday on accusations that he orchestrated an elaborate scheme to export handguns to countries with restrictive gun laws.
 
Eric Daniel Doyle was indicted by a grand jury on federal firearms charges in 2015, but fled before he could be arrested and eluded authorities for more than two years.
 
Authorities allege the 37-year-old Kalispell man used the internet to set up handgun sales to customers in Australia, Norway, Denmark and Sweden. The weapons were shipped through the U.S. Postal Service.
 

Doyle pleaded not guilty during an initial court appearance last week. His attorney, Andrew Nelson, told The Associated Press that he had no comment on the case ahead of Tuesday’s detention hearing in U.S. District Court in Missoula, Montana. … 

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NWS_a4
13Reuters: “EU to Agree Extending Economic Sanctions on Russia Until Mid-2018”

(Source: Reuters, 12 Dec 2017.)
 
European Union leaders will agree on Thursday to prolong for another six months the bloc’s economic sanctions on Russia, imposed over the annexation of Ukraine’s Crimea region and Moscow’s support for rebels in east Ukraine.
 
The main sanctions, which target Russia’s energy, defense and financial sectors, would otherwise be due to expire at the end of January 2018. EU leaders meeting in Brussels on Thursday will agree an extension until mid-2018, officials and diplomats in Brussels said.
 

Moscow says it will never return Crimea, which it annexed in 2014 in a move that has not been recognized internationally. Western countries say Russia has also been providing a lifeline to separatists in eastern Ukraine, where a conflict has killed more than 10,000 people since 2014. 

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COMMCOMMENTARY

COMM_a01
14. G. Bekmukhanbetova & C. Masters: “Steps to Liberalize Uzbekistan’s Export – Import Regime”

(Source: Global Compliance News, 8 Dec 2017.)
 
* Authors: Gulnur Bekmukhanbetova, Esq., Gulnur.Bekmukhanbetova@bakermckenzie.com; and Curtis Masters, Esq. Both of Baker McKenzie, Almaty, Kazakhstan.
 
Two decrees aiming towards the liberalization of Uzbekistan’s import and export regime have been signed by the country’s President. The Decrees represent a further step towards liberalization of Uzbekistan’s economy.
 
The President of Uzbekistan, Shavkat Mirziyoyev has signed two decrees intended to liberalize the country’s export and import regime:
 
  – the Foreign Trade Decree [FN/1] which will become effective 1 December 2017, and
  – the Export-Import Contract Decree [FN/2] which became effective on 10 November 2017 (together, the Decrees).
 
The Decrees represent a further step towards liberalization of Uzbekistan’s economy following the President’s earlier measures to improve the country’s currency regime. [FN/3]
 
The principal provisions of the Decrees are summarized below.
 
Foreign Trade Decree
 
Relief from Payment Security Requirement
 
Uzbek companies wishing to export goods and services previously were required to obtain from the purchaser one of several types of security for payment of the purchase price: an advance payment, a letter of credit, a bank guarantee or an export insurance policy. Failure to obtain such security would subject the Uzbek exporter to investigation by Uzbek authorities under the applicable currency monitoring regulations, resulting in sanctions for any breaches discovered. [FN/4]
 
The Foreign Trade Decree eliminates the payment security requirement for most types of goods and services, provided that the Uzbek exporter has no overdue receivables under previous export operations. The payment security requirement, however, continues to apply to the export of fresh fruits and vegetables and certain other products listed in the Foreign Trade Decree.
 
Export without an Export Contract
 
The Foreign Trade Decree states that Uzbek companies will be entitled to export goods (except fresh produce) and services without an export contract, on the basis of an invoice, provided that the following conditions are met: (i) the export operation is reflected in the Unified Electronic System [FN/5] for currency control purposes, and (ii) 100% prepayment is received in the Uzbek bank account of the exporter. The previous legislation required a contract for all export operations.
 
Unification of Currency Repatriation Period
 
Like most countries of the former Soviet Union, Uzbekistan requires exporters to ensure that proceeds from their export operations be received in Uzbekistan within a certain period of time. Such time period was variable and ranged from 60 days to 180 days, depending on the circumstances of the export operation.
 
The Foreign Trade Decree, while retaining the requirement that exporters must ensure that the export proceeds are repatriated to Uzbekistan, abolishes the variable time periods for repatriation and instead provides for a unified, 120-day term for all export operations, with limited exceptions.
 
Following expiration of the 120-day term an exporter will be deemed to have overdue receivables in which case it may be subject to financial sanctions (generally ranging from 10% to 70% of the export proceeds that were not repatriated to Uzbekistan).
 
The Foreign Trade Decree clarifies that the 120-day period will be suspended in case of force-majeure events. Also, if the exporter receives compensation for any loss under an insurance policy, the amount of overdue receivables will be reduced by the amount of compensation for purposes of calculating the financial sanctions on the exporter.
 
Other Relief for Exporters and Importers
 
The Foreign Trade Decree also provides for the following relief and exemptions in respect of export and import operations:
 
  – re-export of goods previously imported into Uzbekistan under the “temporary import” regime no longer requires permission from the Uzbek customs authorities;
  – importers are no longer obligated to submit to the customs authorities an export cargo customs declaration in order to confirm the customs value of goods imported into Uzbekistan with customs exemptions and benefits; and
  – export customs clearance of products (except types of fresh produce indicated in the decree) may be carried out without obtaining a certificate on payments from the Unified Electronic System; similarly,no certificate from the Unified Electronic System is required for customs clearance of products exported based upon an invoice, without an export contract (see Export without an Export Contract above).
 
Export-Import Contract Decree
 
The Export-Import Contract Decree states that licensing of export and import of certain products (listed in the decree) should be carried out by the Cabinet of Ministers of Uzbekistan. Previously, the Ministry of Foreign Trade licensed such operations.
 
Under the decree, the Ministry of Foreign Trade will be responsible for registration (not licensing) of export contracts (except contracts made on a stock exchange) (a) made pursuant to the decision of the Government of Uzbekistan or intergovernmental treaties, and (b) for goods and services indicated in the decree.
 
In addition, the decree authorizes the State Committee for Investments to carry out an examination of certain import contracts financed out of the proceeds of the state budget or state-controlled companies.
 
———
  [FN/1] Decree of the President of the Republic of Uzbekistan On Measures of Further Liberalization of Foreign Trade Activity and Support of Subjects of Entrepreneurship dated 3 November 2017 (the Foreign Trade Decree).
  [FN/2] Decree of the President of the Republic of Uzbekistan On Measures to Streamline Licensing of Export and Import of Specific Goods and Registration of Export Contracts and Examination of Import Contracts dated 3 November 2017 (the Decree on Export-Import Contracts).
  [FN/3] See Baker McKenzie’s Legal Alert Steps to Liberalize Uzbekistan’s Currency Regime dated 15 September 2017.
  [FN/4] Clause 24 of Regulations On Procedure of Carrying Out Monitoring of Foreign Trade Operations approved by the Cabinet of Ministers of Uzbekistan on 30 September 2003 No. 416.
  [FN/5] The Unified Electronic Information System of Foreign Trade Operations (the Unified Electronic System) is a centralized electronic system used by the Central Bank of Uzbekistan, local commercial banks and Uzbek authorities to monitor foreign trade operations.

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COMM_a215
. M.A. Gajewski Barnhil: “Export Control Considerations: Beyond the Authorization”

(Source: World Trade Controls, 8 Dec 2017.)
 
* Author: Megan A. Gajewski Barnhill, Esq., Bryan Cave, megan.gajewskibarnhill@bryancave.com, +1 202-508-6302.
 
Your compliance obligations do not end once an authorization is in hand.  Determining whether and what authorizations are needed and ensuring that all required authorizations have been obtained are critical first steps in trade compliance, but compliance is a continuing process.
 
Review and Understand the Authorization
 
A critical first step is to review and understand the authorization. What parties are covered by the authorization? Are there restrictions on the employees who can be involved? What activities or items are covered?  What value and quantity limitations apply? For how long is the authorization valid? Are there any provisos or conditions to the authorization?  Ensuring that you understand the scope of the authorization and any restrictions is crucial to avoiding compliance issues down the road.
 
Train Personnel on the Authorization
 
Ensuring that the personnel who are engaging in the covered export activities understand the authorization and its restrictions is even more important. Identify which employee(s) are responsible for compliance with any requirements associated with an authorization, and ensure they are aware of those obligations. Consider providing training to employees who will engage in activities pursuant to an authorization regarding the scope of and requirements under that authorization. Depending on the authorization, it may also be appropriate to develop processes or procedures to track the requirements under an authorization and ensure that all compliance obligations under that authorization are satisfied. Checklists also may be a useful tool to assist with compliance with the conditions of an authorization.
 
Obtain Required Documents
 
Be aware of any additional requirements that must be fulfilled in order to involve certain employees or third parties in the project covered by the export authorization. U.S. ITAR agreements require the non-U.S. party to obtain ITAR Nondisclosure Agreements from third-party sublicensees before any ITAR-controlled technical data or defense articles are transferred to such parties. In addition, ITAR Nondisclosure Agreements are required in some circumstances from dual- and third-country national employees of the foreign licensee and sublicensees prior to such individuals getting access to controlled items. Ensure that any such requirements that apply under your authorization are identified and complied with by the personnel working on the project.
 
Maintain Records
 
Keeping appropriate records is also critical. Know what records are required in connection with your activities; establish who will be responsible for keeping such records and where those records will be kept.  For example, if you rely on substantive contacts screening for transfers to permanent and regular employees pursuant to Section 126.18 of the ITAR or Section 734.20 of the EAR, you must maintain a technology security/clearance plan that includes procedures for screening employees for such substantive contacts, along with records of such screening.
 
Monitor Changes
 
Be vigilant for any changes, including the involvement of new parties, changes to existing parties (such as name or address changes), new end users or end uses, or additional or different activities. Train program personnel and others involved in the exports to communicate those changes early to the compliance team and, ultimately, to the U.S. party.  Such changes may require the submission of an application for a new authorization or an amendment to an existing authorization.  Identifying changes and coordinating with the license holder to submit new authorizations or amendments in advance of the change can help mitigate delays in the business activities while you await a new or amended authorization.
 
Conduct Regular Audits and Reviews of Activities
 
Consider conducting periodic audits of your activities to confirm compliance with U.S. export control provisions and with the specific requirements of the particular authorization. Include as part of any such reviews an assessment of the extent to which personnel are familiar with any compliance programs or procedures that have been created in addition to an evaluation of compliance with any conditions to such authorizations.
 
Compliance obligations do not end when an export authorization has been obtained. Failure to monitor compliance with the requirements of an authorization can be a trap for the unwary. Proper planning can help avoid such traps and ensure all requirements under U.S. export controls and the particular authorization are satisfied.

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

(Source: Defense and Export-Import Update, 11 Dec 2017. Available by subscription via 
gstanley@glstrade.com.
)
 
* Author: Gary Stanley, Esq., Global Legal Services, PC, +1 202-352-3059,
gstanley@glstrade.com
.

The expiration dates on DDTC and BIS licenses and other authorization apply only to the initial export(s), reexport(s), or transfer(s) authorized in the license or other authorization. That is, in the case of items leaving the United States, the export(s) must take place before the expiration date for it to be authorized. The expiration date does not apply to subsequent transactions involving the items at issue to the end users, destinations, and end uses described in the license or other authorization. Such transactions continue to be authorized so long as no condition or proviso to the license or other authorization limits such transactions and the U.S. government has not subsequently imposed additional controls on the end uses, end users, or destinations at issue, such as through the Entity List, the Debarred Parties List, or the Specially Designated Nationals List.

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ENEDITOR’S NOTES


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EN_a318
. 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: 8 Dec 2017: 82 FR 57821-57825: Civil Monetary Penalty Adjustments for Inflation
 
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_a0319
Weekly Highlights of the Daily Bugle Top Stories

(Source: Editor) 

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

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EPEDITORIAL POLICY

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

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

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

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