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17-1227 Wednesday “Daily Bugle”

17-1227 Wednesday “Daily Bugle”

Wednesday, 27 December 2017

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The Daily Bugle is a free daily newsletter from Full Circle Compliance, containing changes to export/import regulations (ATF, Customs, NISPOM, EAR, FACR/OFAC, FTR/AES, HTSUS, and ITAR), plus news and events.  Subscribe 
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  1. Commerce/BIS Corrects EAR, Parts 732, 734, 738, 740, 746, and 774 
  2. Justice/ATF Seeks Comments on Records and Supporting Data: Importation, Receipt, Storage, and Disposition by Explosives Importers, Manufacturers, Dealers, and Users 
  1. Items Scheduled for Publication in Future Federal Register Editions
  2. Commerce/BIS: (No new postings.)
  3. DHS/CBP Announces Ace Production FTZ Deployment, 28 Dec
  4. State/DDTC Announces Retirement of Brian Nilsson
  5. Treasury/OFAC Announces Iraq Sanctions Amendment
  1. ST&R Trade Report: “Trade Preferences Restored for Three Countries, Suspended for One”
  1. Gary Stanley’s ECR Tip of the Day
  1. Full Circle Compliance and the Netherlands Defense Academy Will Present “Winter School at the Castle”, 5-9 Feb 2018, in Breda, the Netherlands
  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 (27 Dec 2017), FACR/OFAC (21 Dec 2017), FTR (20 Sep 2017), HTSUS (26 Dec 2017), ITAR (30 Aug 2017) 
  3. Weekly Highlights of the Daily Bugle Top Stories 

EXIMITEMS FROM TODAY’S FEDERAL REGISTER

EXIM_a1

1. Commerce/BIS Corrects EAR, Parts 732, 734, 738, 740, 746, and 774
(Source: Federal Register, 27 Dec 2017.) [Excerpts.]
 
82 FR 61153-61162: Revisions, Clarifications, and Technical Corrections to the Export Administration Regulations
* AGENCY: Bureau of Industry and Security, Commerce.
* ACTION: Final rule; correcting amendments.
* SUMMARY: In this final rule, the Bureau of Industry and Security corrects certain provisions in the Export Administration Regulations (EAR) to provide accurate references and fix typographical errors, and amend several Export Control Classification Numbers (ECCNs) to enhance consistency with the other ECCNs on the Commerce Control List (CCL). The corrections are editorial in nature and do not affect license requirements.
* DATES: This rule is effective December 27, 2017.
* FOR FURTHER INFORMATION CONTACT: Ivan Mogensen, Office of Exporter Services, Bureau of Industry and Security, by telephone: (202) 482-2440 or email: Ivan.Mogensen@bis.doc.gov.
* SUPPLEMENTARY INFORMATION:
  This final rule updates six parts of the EAR to correct typographical errors, clarify inaccurate or unclear internal references, and correct inconsistencies in certain entries on the Commerce Control List (CCL).
 
Part 732
  Section 732.4(b) discusses steps to be taken when reviewing license exceptions for exports and reexports. In Sec. 732.4(b)(7)(ii), there is a reference to Sec. 740.20(g) listing ECCNs that may be eligible for subsequent export or reexport under license exception STA, following submission of a license application. However, only ECCN 9A610.a is listed in Sec. 732.4(b)(7)(ii), while ECCNs 0A606.a, 8A609.a, 8A620.a, 8A620.b, “spacecraft” in ECCN subparagraphs 9A515.a.1, a.2, a.3, a.4, 9A515.g, and 9E515.b, .d, .e, and .f (which also now appear in Sec. 740.20(g)), are inadvertently omitted. This correction adds the omitted items listed in Sec. 740.20(g) to Sec. 732.4(b)(7)(ii). Additionally, because these items include both commodities and technology, the term “aircraft” in the reference to 9A610.a is replaced with “item.”
  This rule also clarifies and corrects the Export Control Decision Tree diagram in supplement No. 1 to part 732 that was last revised in a final rule published February 6, 2004 (69 FR 5686 (Feb. 6, 2004)). Several of the decision “blocks” in the flowchart contain references that are unclear or incorrect. This rule provides clarity by changing references to the general prohibitions to citations of specific sections of the EAR, and correcting improper citations to ensure that the citations contained in all decision blocks coincide with the appropriate sections of the EAR. Specifically, the changes are as follows: In the block which begins “Is your item classified under an ECCN on the CCL,” a direct citation to Sec. 736.2(b)(1) through (3) replaces a reference to General Prohibitions 1 through 3, which did not inform the reader where the prohibitions could be found in the EAR; in the block which begins “Is there an `X’ in the box,” the EAR citations now directly follow references to the Commerce Country Chart and the CCL, respectively; and, in the block which begins “Use License Exception,” the citation to Sec. 740.1, which is an introduction, is replaced with a reference to the whole of part 740. Additionally, several grammatical errors are addressed, and the section symbol (“Sec. “) is added wherever a section of the EAR is referenced in the decision blocks for clarity. Finally, this final rule changes the supplement’s name from “Decision Tree” to “Export Control Decision Tree” to match the title of the diagram, and the duplicative parenthetical in the graphic title reading “(Supp. No. 1 to Part 732)” is deleted.
 
Part 734
  Section 734.18 was created in the rule Revisions to Definitions in the Export Administration Regulations (81 FR 35586 (June 3, 2016)) and discusses activities that are not exports, reexports, or transfers. The note following the end of Sec. 734.18(a)(5)(iv) discusses data in transit via the internet, but the note is incorrectly described as the note to paragraph (a)(4)(iv). This rule changes the note to refer to Sec. 734.18(a)(5)(iv).
 
Part 738
  In Sec. 738.2(d)(1), Composition of an entry, there is a description of the meaning attached to each alphanumeric character making up an Export Control Classification Number. This paragraph currently explains that the second “digit” in an ECCN indicates the “Reason for Control.” However, in paragraph (d)(1)(i) of this section, the paragraph refers to the Reason for Control as the third “digit.” This final rule amends Sec. 738.2(d)(1)(i) to replace the word “digit” with “alphanumeric character” in order to maintain consistency and prevent confusion.
  Additionally, in Sec. 738.2, this final rule makes a correction in Sec. 738.2(d)(2)(iv)(C)(2). The text of this paragraph uses ECCN 2B992 as an example when providing an overview of how to read an ECCN heading on the Commerce Control List (CCL). However, in the latter part of the section, the text erroneously references ECCN 2B999 instead of 2B992. This rule replaces the reference to ECCN 2B999 with 2B992 in this section to correct the ECCN reference.
 
Part 740
  Section 740.20(g)(1) lists 9×515 and “600 series” ECCNs that are eligible for license exception Strategic Trade Authorization. This includes ECCNs 9A515.a.1, .a.2, .a.3, .a.4, and .g, 9A610.a, and technology ECCNs 9E515.b, .d, .e, and .f. In the final rule Revisions to the Export Administration Regulations (EAR): Control of Spacecraft Systems and Related Items the President Determines No Longer Warrant Control under the United States Munitions List (USML) (82 FR 2875 (Jan. 10, 2017)), the phrase “that provide space-based logistics, assembly or servicing of any spacecraft (e.g., refueling)” following the list of ECCN 9A515 items paragraphs was intended to be removed since it is only applicable to 9A515.a.4 and not to the other ECCNs. Since the phrase was not removed, this rule removes the phrase to prevent confusion by users.
 
Part 746
  This rule amends Sec. 746.9(a) by removing an outdated reference to Sec. 734.2(b) for the definitions of “deemed export” and “deemed reexport,” as that section is currently reserved, and replacing it with references to Sec. Sec. 734.13(b) and 734.14(b), because the relevant definitions for deemed “export” and deemed “reexport” has been found in those two sections of the EAR since the publication of the final rule Revisions to Definitions in the Export Administration Regulations (81 FR 35586). Additionally, consistent with the guidance in Sec. 774.1(d), the double quotes around deemed export and deemed reexport in Sec. 746.9 are removed as these terms do not appear in Sec. 772.1.
 
Part 774
  This rule makes corrections to six ECCNs in supplement No. 1 to part 774, “Commerce Control List,” by correcting misspellings and creating conforming changes. The corrections are as follows:
  ECCNs 0A606, 8A609, and 9A610: This final rule amends these ECCNs to correct the title of Sec. 740.20(g) that is referenced in paragraph (1) in the Special Conditions for STA section of the ECCN entries. Currently, these sections refer to Sec. 740.20(g) as License Exception STA eligibility requests for “600 series” end items, when the current title for this section is License Exception STA eligibility requests for 9×515 and “600 series” items. The title of Sec. 740.20(g) was changed in the rule Revisions to the Export Administration Regulations (EAR): Control of Spacecraft Systems and Related Items the President Determines No Longer Warrant Control Under the United States Munitions List (USML); (79 FR 27417 (May 13, 2014)), but the change was not made to the corresponding ECCNs. This rule amends the title reference in these ECCNs to match the current title of Sec. 740.20(g).
  ECCNs 0D606.a and 0E606.a: This final rule amends ECCN subparagraphs 0D606.a and 0E606.a to include references to ECCNs 0B606 and 0C606. The headings of both 0D606 and 0E606 refer to 0B606 and 0C606 but these references do not appear in Items paragraph .a of the List of Items Controlled section. This inconsistency has generated confusion as to whether 0D606.a software “specially designed” for the “development,” “production,” operation or maintenance of the items controlled under ECCNs 0B606 and 0C606 or 0E606.a technology required for the “development,” “production,” operation or maintenance of the items controlled under ECCNs 0B606 and 0C606 is controlled or not. This edit removes this confusion by clarifying that such software is controlled under ECCN 0D606.a and such technology is controlled under ECCN 0E606.a.
  ECCN 2B352: This final rule corrects ECCN 2B352 by revising, in the List of Items Controlled section, Items paragraphs g.1, i.1, i.2 and i.3 and the Technical Notes at the end of the Items paragraphs. The corrections are as follows: The word “dependant” is replaced with the American spelling of the word “dependent” in Items paragraph g.1; double quotes are added around the term “aircraft” in Items paragraphs i.1 and i.2, and in Technical Notes 1 and 3 because “aircraft” is a defined term in the EAR; double quotes are added around the term “laser” in Technical Notes 3.a and .b for the same reason; double quotes are replaced with single quotes around the term `VMD’ in Items paragraphs i.1 and i.2 and the term is clarified in Technical Note 3; single quotes are added to the term `aerosol generating units’ in Items paragraphs i.2 and i.3 and Technical Note 1.
  ECCN 8A609: This final rule revises Related Control paragraph (3) under the List of Items Controlled section in ECCN 8A609 to add a reference to Category VI of the International Traffic in Arms Regulations (ITAR). This is done to indicate that certain diesel engines and electric motors for both EAR surface vessels of war and ITAR surface vessels of war are controlled under ECCN 8A992.g. Additionally, double quotes are added around the term “subject to the EAR” because it is a defined term in the EAR. …
 
  Dated: December 18, 2017.
Richard E. Ashooh, Assistant Secretary for Export Administration.

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EXIM_a2

2
. Justice/ATF Seeks Comments on Records and Supporting Data: Importation, Receipt, Storage, and Disposition by Explosives Importers, Manufacturers, Dealers, and Users

(Source: Federal Register, 27 Dec 2017.) [Excerpts.]
 
82 FR 61326-61327: Agency Information Collection Activities; Proposed eCollection eComments Requested; Records and Supporting Data: Importation, Receipt, Storage, and Disposition by Explosives Importers, Manufacturers, Dealers, and Users
* AGENCY: Bureau of Alcohol, Tobacco, Firearms and Explosives, Department of Justice.
* ACTION: 30-Day notice. …
* DATES: Comments are encouraged and will be accepted for an additional 30 days until January 26, 2018.
* FOR FURTHER INFORMATION CONTACT: If you have additional comments, particularly with respect to the estimated public burden or associated response time, have suggestions, need a copy of the proposed information collection instrument with instructions, or desire any other additional information, please contact Anita Scheddel, Program Analyst, Explosives Industry Programs Branch, either by mail 99 New York Ave. NE, Washington, DC 20226, by email at Anita.Scheddel@atf.gov, or by telephone at (202)-648-7158. Written comments and/or suggestions can also be directed to the Office of Management and Budget, Office of Information and Regulatory Affairs, Attention Department of Justice Desk Officer, Washington, DC 20503 or sent to OIRA_submissions@omb.eop.gov.
* SUPPLEMENTARY INFORMATION: …
  – The Title of the Form/Collection: Records and Supporting Data:
Importation, Receipt, Storage, and Disposition by Explosives Importers,
Manufacturers, Dealers, and Users Licensed Under Title 18 U.S.C.
Chapter 40 Explosives. …
  – Form number: None.
  – Component: Bureau of Alcohol, Tobacco, Firearms and Explosives, U.S. Department of Justice. …
  – Abstract: The records show daily activities in the importation, manufacture, receipt, storage, and disposition of all explosive materials covered under 18 U.S.C. Chapter 40 Explosives. The records are used to show where and to whom explosive materials are sent, thereby ensuring that any diversions will be readily apparent, and if lost or stolen, ATF will be immediately notified. …
  If additional information is required contact: Melody Braswell, Department Clearance Officer, United States Department of Justice, Justice Management Division, Policy and Planning Staff, Two Constitution Square, 145 N Street NE, 3E.405A, Washington, DC 20530.
 
  Dated: December 21, 2017.
Melody Braswell, Department Clearance Officer for PRA, U.S. Department of Justice.

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OGSOTHER GOVERNMENT SOURCES

OGS_a13. Items Scheduled for Publication in Future Federal Register Editions
(Source: Federal Register

* Commerce/BIS; NOTICES; Export Privileges; Denials [Publication Date: 28 December 2017.]:
  – Gerardo Trevino-Moncivais
  – Hunter Perry
  – Joseph Esequiel-Gonzalez
  – Papa Faal
 
* Commerce/BIS; NOTICES; Orders; Saeid Yahya Charkhian and Caspian Industrial Machinery Supply, LLC [Publication Date: 28 December 2017.]
 
[Editor’s Note: The four notices on expert privileges denials where included in the 21 December Daily Bugle.  The Order was included in the 22 December Daily Bugle. Therefore, none of the above items will be included in tomorrow’s Daily Bugle.]
 
* Defense Acquisition Regulations System; RULES; Trade Agreement Thresholds [Publication Date: 28 December 2017.]

* Justice/ATF; NOTICES; Commerce in Explosives: 2017 Annual List of Explosive Materials [Publication Date: 28 December 2017.]
 
* Treasury/OFAC; RULES; Iraq Stabilization and Insurgency Sanctions Regulations [Publication Date: 28 December 2017.]
 
* Treasury/OFAC; NOTICES; Blocking or Unblocking of Persons and Properties [Publication Date: 28 December 2017.]
 

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(Source:
CSMS #17-000805, 27 Dec 2017.)
 
There will be an ACE PRODUCTION FTZ deployment on Thursday morning, December 28, 2017, during the 0500 – 0700 ET window.
 
To be deployed will be resolution to the following item:
 – Update NF transmission messages to trade to accommodate variations in House Bill Number

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(Source:
State/DDTC, 26 Dec 2017.)
 
Deputy Assistant Secretary Brian Nilsson is retiring after a distinguished career of 31 years. Effective December 23, 2017, Mr. Mike Miller will temporarily assume the duties of Acting Deputy Assistant Secretary for Defense Trade Controls. Mr. Miller, a career member of the Senior Executive Service, is currently the Director for Regional Security and Arms Transfers (RSAT) within the Bureau of Political-Military Affairs and is already well known in the defense trade sector.
 
As a reminder, the following DDTC Acting positions are still effective:
 
  – Anthony Dearth, Acting Chief of Staff, Directorate of Defense Trade Controls Front Office.
  – Sarah Heidema, Acting Director of Defense Trade Controls Policy.
  – Terry Davis, Acting Director of Defense Trade Controls Licensing.
  – The Director of Defense Trade Controls Compliance position is vacant. As announced December 10, 2017, the leadership responsibilities are being shared by the team chiefs during the transition period until a new Director is identified.

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OGS_a57
. Treasury/OFAC Announces Iraq Sanctions Amendment

(Source:
Treasury/OFAC, 27 Dec 2017.)
 
The Department of the Treasury’s Office of Foreign Assets Control (OFAC) is amending the Iraq Stabilization and Insurgency Sanctions Regulations, to implement Executive Order 13668 of May 27, 2014 (“Ending Immunities Granted to the Development Fund for Iraq and Certain Other Iraqi Property and Interests in Property Pursuant to Executive Order 13303, as Amended.”).  The amendments also implement certain technical and conforming changes.  This amendment will take effect upon publication in the Federal Register on Thursday, December 28, 2017.

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NWSNEWS

NWS_a1
8. ST&R Trade Report: “Trade Preferences Restored for Three Countries, Suspended for One”

 
President Trump has issued a proclamation restoring or suspending trade preferences under the Generalized System of Preferences and the African Growth and Opportunity Act. The GSP changes will have little immediate practical effect because GSP itself expires Dec. 31, 2017.
 
The proclamation restores GSP eligibility for Argentina, which was suspended in 2012, as of Jan. 1, 2018. A press release from the Office of the U.S. Trade Representative explains that Argentina has resolved certain arbitral disputes with U.S. companies, made new commitments to improve market access for U.S. agricultural products, and improved its protection and enforcement of intellectual property rights. However, due to certain remaining IPR issues, GSP benefits for Argentina will not be restored for all eligible products.
 
The proclamation also restores the eligibility of The Gambia and Swaziland for AGOA, which will remain in effect through Sept. 30, 2025, despite the lapse of GSP. The Gambia lost its AGOA eligibility in 2015 due to human rights abuses and the deterioration of the rule of law, but USTR states that following democratic elections in December 2016 the country has made progress in strengthening the rule of law, improving human rights, and supporting political pluralism. Swaziland lost AGOA eligibility in 2015 due to concerns over restrictions on the freedoms of peaceful assembly, association, and expression, but USTR states that in November 2017 the country met the last in a series of benchmarks the U.S. set on these issues.
 
Finally, the proclamation will suspend GSP eligibility for Ukraine, which USTR states is due to Ukraine’s “failure to provide adequate and effective protection of intellectual property rights despite years of encouragement and assistance from the U.S. government.” However, the proclamation gives 120 days’ notice of this suspension because the government of Ukraine “has a viable path to remedy the situation, including improving the current legal regime governing royalty reimbursement to right holders’ organizations.”

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COMMCOMMENTARY

COMM_a01
9. 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, (202) 352-3059,
gstanley@glstrade.com
.
 
Under the EAR, information on the basic function or purpose of an item does not constitute “technology.”

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TEEX/IM TRAINING EVENTS & CONFERENCES

(Source: Editor)
 
The Netherlands Defense Academy presents a winter seminar, “Compliance and Integrity in International Military Trade,” 5-9 February 2018, in the charming town of Breda, the Netherlands, an hour’s drive south of Amsterdam. Many hotels and restaurants are within walking distance of the Defense Academy, which is the Dutch equivalent of the U.S. military academies. The course is designed for NATO+ military officers, government employees, and employees of NATO+ defense contractors. Participants will receive certificates of completion from the Academy.
* Course contents:
  – Day 1: International Trade in Defense Markets and Relevance of Trade Compliance.
  – Day 2: U.S. Export Control Regulations (International Traffic in Arms Regulations), and the EU Perspective.
  – Day 3: U.S. Export Control Regulations (Export Administration Regulations), and EU Export Control Regulations (Military and Dual-Use).
  – Day 4: Compliance & Integrity / Ethics, and Setting up an Internal Compliance Program.
  – Day 5: Setting up an Internal Compliance Program
* When: 5-9 February 2018.
* Where: the Netherlands Defense Academy (“The Castle”), Breda, the Netherlands.
* Event Sponsors: Full Circle Compliance & the Netherlands Defense Academy, Faculty of Military Sciences.
* Speakers include: Prof. dr. J.M. Beeres; Col. Dr. Robert M.M. Bertrand, RA RC RO; Drs. Ghislaine C.Y. Gillessen, RA; James E. Bartlett III, JD, LL.M; Michael E. Farrell; and Drs. Alexander P. Bosch.

  
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ENEDITOR’S NOTES

 

Louis Pasteur (27 Dec 1822 – 28 Sep 1895; was a French biologist, microbiologist, and chemist, remembered for his remarkable breakthroughs in the causes and prevention of diseases. His medical discoveries provided direct support for the germ theory of disease and its application in clinical medicine. He is best known for his invention of the technique of treating milk and wine to stop bacterial contamination, a process now called pasteurization.)
  – “Let me tell you the secret that has led me to my goal. My strength lies solely in my tenacity.”
  – “Fortune favors the prepared mind.”
 
Johannes Kepler (27 Dec 1571 – 15 Nov 1630; was a German  mathematician, astronomer, and astrologer. Kepler was a key figure in the 17th-century scientific revolution, best known for his laws of planetary motion, based on his works Astronomia novaHarmonices Mundi, and Epitome of Copernican Astronomy. These works also provided one of the foundations for Isaac Newton’s theory of universal gravitation.)
  – “I much prefer the sharpest criticism of a single intelligent man to the thoughtless approval of the masses.”

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EN_a312
. 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: 27 Dec 2017: 82 FR 61153-61162: Revisions, Clarifications, and Technical Corrections to the Export Administration Regulations

  
*
FOREIGN ASSETS CONTROL REGULATIONS (OFAC FACR)
: 31 CFR, Parts 500-599, Embargoes, Sanctions, Executive Orders
  – Last Amendment: 21 Dec 2017: 82 FR 60507-60517: Magnitsky Act 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: 26 Dec 2017: Harmonized System Update 1709, containing 2,415 ABI records and 489 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_a0313
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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