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18-0105 Friday “Daily Bugle”

18-0105 Friday “Daily Bugle”

Friday, 5 January 2018

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.

[No items of interest noted today.] 

  1. Items Scheduled for Publication in Future Federal Register Editions 
  2. Commerce/BIS: (No new postings.)
  3. DHS/CBP Extends In-bond Regulation Enforcement Dates
  4. DHS/CBP Posts Reminder Concerning Statements Deployment, 6 Jan 
  5. State/DDTC: (No new postings.)
  1. ST&R Trade Report: “Dates and Deadlines: CBP Priorities, Forced Labor, Supply Chains, FTZs”
  1. D.M. Edelman: “New Sanctions Imposed for Human Rights Abuses and Corruption – a Harbinger for Business in 2018?”
  2. M. Volkov: “2018 FCPA Predictions (Part II of II)”
  3. Gary Stanley’s ECR Tip of the Day
  4. R.C. Burns: “Kadyrov’s Cat, Like Schrödinger’s, Is Both Dead and Alive”
  1. Full Circle Compliance and the Netherlands Defense Academy Will Present “Winter School at the Castle”, 5-9 Feb 2018 in Breda, the Netherlands
  2. International Compliance Professionals Association Offers Free Membership
  3. List of Approaching Events – 10 New Events Listed
  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 (28 Dec 2017), FTR (20 Sep 2017), HTSUS (1 Jan 2018), ITAR (3 Jan 2018)
  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)
 
* Commerce; RULES; Civil Monetary Penalty Adjustments for Inflation [Publication Date: 8 January 2018.]
 
* Commerce/BIS; RULES; Revisions, Clarifications, and Technical Corrections to Export Administration Regulations; Correction [Publication Date: 8 January 2018.]
 
* Treasury; NOTICES; List of Countries Requiring Cooperation with International Boycott [Publication Date: 8 January 2018.]
 
* U.S. Customs and Border Protection; NOTICES; Agency Information Collection Activities; Proposals, Submissions, and Approvals [Publication Date: 8 January 2018.]:
  – Application for Allowance in Duties
  – Declaration for Free Entry of Returned American Products
  – Petition for Remission or Mitigation of Forfeitures and Penalties Incurred

 

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OGS_a3
3. DHS/CBP Extends In-bond Regulation Enforcement Dates

(Source: CSMS #18-000013, 4 Jan 2018.)
 
CBP will extend the time frame for initial implementation of these regulatory changes for all participants for six months. CBP Officers will continue to accept paper CBP Form 7512 and input the data on the trade’s behalf until July 2, 2018. On that date, paper forms will no longer be accepted for input into the ACE system by CBP Officers. The new implementation schedule will be as follows:
 
* July 2, 2018 – Paper CBP Form 7512 will no longer be accepted by CBP for input into ACE. Electronic filing of new in-bond transactions will be the responsibility of the trade. Paper forms or other paper alternatives (screen prints or plain paper documents etc.) will be accepted as part of enforcement processes at the border or verification/audit operations such as warehouse withdrawals, FTZ exports and transfers or vessel/aircraft supply operations where additional information is required on paper forms that is not provided for electronically.
 
* August 6, 2018 – Electronic reporting of all transactions will be mandatory; CBP will no longer accept paper copies of the CBPF 7512 to perform arrival and export functionality. These functions will be the requirement of the carrier. Electronic reporting will be mandatory. In addition, electronic reporting of diversion to a port other than reported on the original in-bond will be required. An ACE edit will reject arrival if not performed. Electronic reporting of bonded cargo location (FIRMS code) will be required. An ACE edit will reject arrival if not provided.
 
* At this time, no date is set for implementation of the provision requiring the 6 -digit Harmonized Tariff Schedule number requirement for Immediate Transportation movements.
 
The Frequently Asked Questions Document posted online is being updated to reflect the changes.
 
  – Related CSMS No. 17-000736

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OGS_a4
4. DHS/CBP Posts Reminder Concerning Statements Deployment, 6 Jan

(Source: CSMS #18-000015, 5 Jan 2018.)
 
On January 6, 2018, CBP will deliver ACE Deployment G, Release 3B. At this point, ACE will become the system of record for all statements with the exception of Reconciliation statements. CBP will deliver Statements for Reconciliations as part of ACE Deployment G, Release 4 on February 24, 2018.
 
No later than January 13, 2018, CBP will deploy ACE Statements reports with the Statements universe, which replaces the Account Revenue universe. The new ACE Statements reports will be available under the Statements tab found in the applicable trade account workspace. In addition, two existing “quickview” reports for brokers and importers (AR-007) will remain available in ACE.
 
CBP will work with filers to address any issues related to this deployment of Statements in ACE, and will provide support as necessary.
 
Deployment G, Release 3B Support Calls:
 
CBP will host a series of calls to communicate the status of the statements deployment from Sunday, January 7 through Friday, January 12.
 
SUNDAY, January 7, 2018, 1:00 PM ET – On this call, CBP will communicate the status of the statements deployment.
 
MONDAY, January 8, 2018 through FRIDAY, January 12, 2018, 2:00PM ET to 3:00PM ET – On these calls, CBP will provide a short deployment status followed by an open question and answer session
 
For the January 7 through January 12 calls, please use the following conference line: (877) 336-1828 / PC: 6124214.
 
Deployment G Resources:
 
More information may be found in the Information Notices posted to CBP.gov at the links below.
 

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NWSNEWS

NWS_aa1
6. ST&R Trade Report: “Dates and Deadlines: CBP Priorities, Forced Labor, Supply Chains, FTZs”

 
Following are highlights of regulatory effective dates and deadlines and federal agency meetings coming up in the next week.
 
  – 8 Jan: deadline for comments to ATF on application for permanent exportation of firearms
  – 8 Jan: deadline for comments to FTZ Board on production and subzone requests
  – 12 Jan: deadline for comments on child and forced labor lists and reports
  – 12 Jan: deadline for nominations for Advisory Committee on Supply Chain Competitiveness

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

COMMCOMMENTARY

COMM_a1
7. D.M. Edelman: “New Sanctions Imposed for Human Rights Abuses and Corruption – a Harbinger for Business in 2018?”

(Source: Export Compliance Matters, 5 Jan 2018.)
        
* Author: Doreen M. Edelman, Esq., Baker Donelson LLP, 202-508-3460, dedelman@bakerdonelson.com
.
 
On December 21, the U.S. Treasury Department announced the implementation of a new global sanctions regime under the Magnitsky Human Rights Accountability Act (the “Global Magnitsky Act”).  President Trump issued an Executive Order declaring a national emergency with respect to human rights abuses and global corruption, targeting individuals and entities spanning nations across the world, including Russia, Ukraine, Uzbekistan, Pakistan, Nicaragua, and elsewhere.
 
The Global Magnitsky Act is an expansion of the 2012 Magnitsky bill named for Russian whistleblower Sergei Magnitsky, an accountant who died in a Moscow prison in 2009 under mysterious circumstances after exposing a tax fraud scheme allegedly involving high-level Russian officials. Unlike the traditional country-by-country sanction programs implemented by the Treasury Department’s Office of Foreign Assets Control (OFAC), the Magnitsky Act authorizes the President and OFAC to impose visa bans and strict sanctions on individuals anywhere in the world who have committed human rights violations or severe acts of corruption.
 
Key Figures Sanctioned and Impact for U.S. Businesses
 
Several powerful international political figures were included in the most recent bout of sanctions, such as the former President of the Gambia Yahya Jammeh, the President of Nicaragua’s Supreme Electoral Council Roberto Jose Rivas Reyes, the former chief of the Burmese Army’s Western command Maung Maung Soe, and Gulnara Karimova, the daughter of former Uzbek president Islam Karimov.  The range of human rights abuses and corrupt misconduct the sanctions target are varied in scope and are described in further detail here, including alleged ethnic cleansing in Myanmar’s Rakhine State, arms dealing in the Balkans, misallocation of government funds, electoral fraud, and even the trafficking of human organs.
 
For U.S. businesses, the implementation of the first major global Magnitsky sanctions is a harbinger of things to come.  As we recently blogged here, global sanctions programs are only becoming more complex and it is critical to screen all parties, and related parties under some programs, before doing business.  This is arguably the broadest sanctions regime implemented by the U.S. to date, and there are no black-letter definitions promulgated for key terms like “corruption” and “bribery.”  Dozens of entities related to the sanctioned individuals were targeted by OFAC in this announcement, and as the U.S. blacklist grows larger, so do the perils and complications of doing business in high-risk regions.  Multi-national businesses should take note that several countries, including the U.K., have passed similar versions of Magnitsky sanction regimes targeting human rights abusers from any country. Due diligence and compliance training is becoming more and more important as economic sanctions are increasingly used as a foreign policy tool to deter grave misconduct, hold bad actors accountable, and cut off financing for those perpetuating human rights abuses and corruption.

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COMM_a2
8. M. Volkov: “2018 FCPA Predictions (Part II of II)”

(Source: Volkov Law Group Blog, 3 Jan 2018.) Reprinted by permission.)
 
* Author: Michael Volkov, Esq., Volkov Law Group, mvolkov@volkovlaw.com, 240-505-1992.
 
[Editor’s Note: Part I in this series was included in yesterday’s, 4 Jan 2018, Daily Bugle.]
 
I always take a deep breath when starting this posting – not that I am the kiss of death, but sometimes my predictions come true and most times they do not. But with that caveat, I am brave enough to venture into 2018 and offer some predictions.
 
First, and this may not be so surprising, individual FCPA criminal prosecutions will continue to increase. In fact, I will go out on a limb and predict that in 2018 there will be at least 25 individual criminal prosecutions, approximately double the number in 2017. What is not clear is whether the Justice Department will bring criminal cases against individuals based on cooperation from companies that settled FCPA cases in 2016 and 2017, akin to the Rolls Royce case. I do not expect the Justice Department to go very far back in time to identify culpable individuals for prosecution. However, I predict that the Justice Department will bring more individual cases at the same time or close to the time when corporations enter into FCPA settlements.
 
Second, the Serious Fraud Office will continue to coordinate closely with the Justice Department on corporate investigations and individual criminal prosecutions. The SFO brought several criminal cases against individuals arising from the Rolls Royce investigation, and the SFO and the Justice Department will continue to carve defendants to each other in joint investigations.
 
Third, the Justice Department will bring more FCPA cases that include Title III wiretaps. The Joseph Batiste case is the first criminal prosecution that relied on Title III wiretaps, and I expect there will be more.
 
Fourth, the number of companies taking advantage of the declination-disgorgement reward will increase as a result of the new FCPA Corporate Enforcement Policy. The Justice Department’s new policy will encourage companies who experience FCPA violations to voluntarily disclose, cooperate and remediate in hopes of earning a declination. Companies that risk falling into one of the aggravating factors may hold back from a voluntary disclosure depending on the specific circumstances surrounding the aggravating factor, despite the benefit of a 50 percent reduction in the fine from the low end of the US Sentencing Guideline range and escaping the appointment of corporate monitor.
 
Fifth, the Justice Department only appointed one two-year corporate monitor this year, and I do not expect new monitors to be appointed except in extraordinary circumstances. The Telia and SBM Offshore cases did not include a corporate monitor, and they are lucky to have dodged that bullet.
 
As to particular corporate investigations and cases, I expect that 2018 will bring an end to some long-pending investigations:
 
Wal-Mart
: This is an easy prediction given the recent reports indicating that a final resolution may finally be reached, although the final penalty amount appears to be less than $250 million. A final settlement will probably be announced in the first quarter of 2018.
 
Panasonic Avionics
: This appears to be a blockbuster case with potential violations stretching across Asia and the Middle East. The amount of the fine could be high, and individual criminal prosecutions could follow, given this year’s announcement that senior executives departed the company.
 
Microsoft
: This enforcement investigation has been under the radar for years and there is little public information on the status of the investigation and possible resolution. Whenever it ends, the amount is sure to be large given the nature and extent of the violations, and the breadth of risks involved in Microsoft’s distribution chain in Asia and other high-risk countries.
 
Juniper Networks
: This enforcement action has been close to resolution for years but has been delayed while the company continues to negotiate a final resolution. This case should finish up toward the middle to low range of FCPA resolutions.

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COMM_a3
9.

Gary Stanley’s ECR Tip of the Day

 
* Author: Gary Stanley, Esq., Global Legal Services, PC, (202) 352-3059,
 gstanley@glstrade.com
.
 
ITAR § 120.11(a)(7) provides that “public domain” means information which is published and which is generally accessible or available to the public through public release (i.e., unlimited distribution) in any form (e.g., not necessarily in published form) after approval by the cognizant U.S. government department or agency. This is further covered in the ITAR § 125.4(b)(13) exemption. One of the agencies that qualifies as a “cognizant U.S. government department or agency is the U.S. Department of Defense’s Defense Office of Prepublication and Security Review (DOPSR). DOPSR derives its authority from DoD Directive 5230.09 Clearance of DoD Information for Public Release and DoD Instruction 5230.29 Security and Policy Review of DoD Information for Public Release. 

(Editor’s Note: ITAR
§ 
125.4(b)(13) incorrectly refers to the Defense Office of Prepublication and Security Review (
 
DOPSR) as the “
Office of Freedom of Information and Security Review”, even though that office was renamed to its current name 
in 2014.) 

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(Source:
Export Law Blog
, 4 Jan 2018. Reprinted by permission.)
 
* Author: R. Clifton Burns, Esq., Bryan Cave LLP, Wash DC,
Clif.Burns@bryancave.com
, 202-508-6067).
 
Ramzan Kadyrov, head of the Chechen Republic, Putin toady, serial human rights violator, cat aficionado,* fashion victim, and blocked person on the OFAC SDN List is upset that his Facebook account has been deleted. A spokesman at Facebook said this to the New York Times:
 
We became aware and have now confirmed that the accounts appear to be maintained by or on behalf of parties who appear on the U.S. Specially Designated Nationals List and thus subject to U.S. trade sanctions. … For this reason, Facebook has a legal obligation to disable these accounts.
 
Er, no.  Kadyrov was sanctioned under the Magnitsky Sanctions, and the rules governing those sanctions, set forth an informational materials exception. Section 584.206(b) of the Magnitsky Sanctions Regulations states:
 
The prohibitions contained in this part do not apply to the importation from any country and the exportation to any country of any information or informational materials, as defined in §584.304, whether commercial or otherwise, regardless of format or medium of transmission
 
Moreover, if Facebook really believed, as its spokesperson asserted, that it has to disable accounts maintained by SDNs, why does Bashar Al-Assad still have an active account? Or Nicolás Maduro?
 
Something else is clearly going on here. So, as they say, don’t believe everything you read on Facebook.
——–
*
Click this link to get the backstory on Ramzan and his kitty cat.
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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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TEC_a112. International Compliance Professionals Association Offers Free Membership

(Source: ICPA Membership Chair, membership@members.icpainc.org)
 
To celebrate the new-year, the International Compliance Professionals Association (ICPA) is offering first-time regular members (non-service providers) an introductory first-year ICPA membership FREE! That’s right, NO COST! The renewal next year will be at the regular price. So go get your friends and colleagues who have “resisted” our charm until now and sign them up! Just click on www.icpainc.org and click on JOIN/RENEW and look for the new member special!
 
[Editor’s Note: As a regular speaker and former U.S. General Counsel of ICPA, I encourage all export/import professionals to join ICPA and attend their excellent, huge conferences. Great seminars and networking! – Jim Bartlett.]

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TE_a213
. List of Approaching Events – 10 New Events Listed
(Sources: Editor and Event Sponsors) 
 
Published every Friday or last publication day of the week. Please, send event announcements to
jwbartlett@fullcirclecompliance.eu
, composed in the below format:

# DATE: LOCATION; “EVENT TITLE;” SPONSOR; WEBLINK; CONTACT (email and phone number)


#” New listing this week  

 
Continuously Available Training:
 
* E-Seminars: “US Export Controls” / “Defense Trade Controls“; Export Compliance Training Institute; danielle@learnexportcompliance.com 
* E-Seminars: “ITAR/EAR Awareness“; Export Compliance Solutions;
 
spalmer@exportcompliancesolutions.com 
* Online: “Simplified Network Application Process Redesign (SNAP-R)“; Commerce/BIS; 202-482-2227
* E-Seminars: “Webinars On-Demand Library“; Sandler, Travis & Rosenberg, P.A.

* Online: ”
International Trade Webinars“; Global Training Center

*
 
Online: “On-Demand Webinars“; “General Training“; Center for Development of Security Excellence; Defense Security Service (DSS)

* Online: ”
ACE Reports Training and User Guide“; DHS/CBP

 
Training by Date:
 

# Jan 9: Webinar; ”
2017 FCPA Year in Review“; Volkov Law Group

# Jan 11: Webinar; ”
ITAR Primer for Federal Defense Contractors“; Torres Law, PLLC
* Jan 11: E-Seminar; ”
Export Competitively and Increase Your Sales with Government Support“; U.S. Export/Import Bank

* Jan 17: Melbourne, FL; “Global Challenges: A Conversation with James Clapper“; Indialantic Rotary Club; info@partneringforcompliance.org; 321-952-2978
* Jan 17: Bristol UK; “Intermediate Seminar“; UK Department for International Trade; denise.carter@trade.gsi.gov.uk 
* Jan 17: Dusseldorf, Germany; “Recent Developments in U.S., E.U., and German Export Control: Promoting Global Trade in Challenging Times;” (Event will be held in English); U.S. Commercial Service
* Jan 18: Bristol UK; “Beginners Workshop“; UK Department for International Trade; denise.carter@trade.gsi.gov.uk 
* Jan 18: Bristol UK; “Licences Workshop“; UK Department for International Trade; denise.carter@trade.gsi.gov.uk 
* Jan 18: Bristol UK; “Control List Classification – Combined Dual Use and Military“; UK Department for International Trade;  denise.carter@trade.gsi.gov.uk 

* Jan 18: Webinar/Lunch; San Jose, CA; ”
Compliance Audit: An Executive Tool for 2018“; PAEI

* Jan 22-23: San Diego, CA; “ITAR Defense Trade Controls“; ECTI; jessica@learnexportcompliance.com; 540-433-3977

* Jan 22-23: Frankfurt, Germany; ”
U.S. Export Controls and Sanctions – 2018 Update“; Aussenwirtschafts Akademie; Contact  
Kristina.Brueffer@awa-seminare.de to register.

* Jan 23: London, UK; “International Documentations and Customs Compliance“; Institute of Export and International Trade
* Jan 23-24: Houston, TX; “Complying with US Export Controls“; Bureau of Industry and Security
# Jan 23-24: Houston, TX; “12th Annual Forum on the Foreign Corrupt Practices Act;” American Conference Institute (ACI)

* Jan 24: Frankfurt, Germany; “International Compliance, Legal Risks & Corporate Integrity“; TRACE Anti-Bribery Compliance Solutions
* Jan 24: London, UK; “An Introduction to Exporting – Physical Goods“; IOEx 
* Jan 24-25: San Diego, CA: “EAR and OFAC Controls“; ECTI; 

# Jan 25: Houston, TX; ”
Africa Anti-Corruption Roundtable“; ACI
* Jan 25: Hong Kong, China; ”
Anti-Bribery Roundtable“; TRACE Anti-Bribery Compliance Solutions

* Jan 25: Houston TX; “Technology Controls“; Bureau of Industry and Security

* Jan 25: Webinar; ”
Roadmap to a Successful Voluntary Disclosure“; Census Bureau

* Jan 25: London, UK; “International Documentation & Customs Compliance“; IOEx
* Jan 29-30: Toronto, Canada;
 “7th Industry Forum on Export and Re-Export Compliance for Canadian Operations“;
 American Conference Institute
* Jan 30: Miami, FL; “Duty Drawback Specialist – Certification“; Global Trade Academy 
* Jan 31: Webinar; “Fundamentals of US Reexport Controls“; ECTI; 540-433-3977
* Jan 31: Washington, D.C.; “4th National Forum on CFIUS and Team Telecom“; American Conference Institute
* Feb 1: Birmingham, UK; International Documentation & Customs Compliance“; IOEx
* Feb 5-8: Orlando FL; “
ITAR Defense Trade Controls / EAR Export Controls Seminar
“; ECTI; 
jessica@learnexportcompliance.com
;
 540-433-3977
* Feb 6: Las Vegas, NV; “Import Documentation and Procedures Seminar“; International Business Training
* Feb 6: Birmingham, UK; “An Introduction to Exporting – Physical Goods“; IOEx
* Feb 6-7: San Diego, CA; “Complying with US Export Controls“; Bureau of Industry and Security
* Feb 7-8: Munich, Germany; “Export Compliance in Europe, 2018“;
* Feb 8: McLean, VA; “EAR Basics“; FD Associates

# Feb 13: 
Webinar; “
Exporting Mechanics Webinar Series: Export Licenses
“; NCBFAA

* Feb 13-14: Miami, FL; “Complying with US Export Controls“; Bureau of Industry and Security 
* Feb 13-14: Orlando FL; “
ITAR/EAR Boot Camp
“; Export Compliance Solutions; 
spalmer@exportcompliancesolutions.com
; 866-238-4018
* Feb 13-16: London, UK; “Certified Authorized Economic Operator (AEO) Specialist“; Global Trade Academy

* Feb 14: ”
Wednesday Webinar: Temporary Imports of NFA Firearms“; Reeves & Dola LLP

* Feb 14: London, UK; “Post-Brexit Planning Workshop“; IOEx
* Feb 19: Tysons Corner, VA; “Export Compliance and Controls 101“; Global Trade Academy
* Feb 19-21: Tysons Corner, VA; “Export Controls Specialist – Certification“; Global Trade Academy
* Feb 19-22: Huntsville AL; “
ITAR Defense Trade Controls / EAR Export Controls Seminar
“; ECTI;
 
jessica@learnexportcompliance.com
; 540-433-3977
* Feb 21: Newcastle UK; “Intermediate Seminar“; UK Department for International Trade; denise.carter@trade.gsi.gov.uk 
* Feb 22: Newcastle UK; “Beginners Workshop“; UK Department for International Trade; denise.carter@trade.gsi.gov.uk 
* Feb 22: Newcastle UK; “Licences Workshop“; UK Department for International Trade; denise.carter@trade.gsi.gov.uk 
* Feb 22: Newcastle UK; “Control List Classification – Combined Dual Use and Military“; UK Department for International Trade; denise.carter@trade.gsi.gov.uk 
*
 
Feb 27: London, UK; “International Documentation & Customs Compliance“; IOEx
* Feb 28-Mar 1: Dubai, UAE; “GESS Dubai 2018“; Global Educational Supplies and Solutions
* Mar 1: Manchester, UK; “An Introduction to Exporting – Physical Goods“; IOEx
* Mar 1: Dubai, UAE; “Anti-Bribery Workshop“; TRACE Anti-Bribery Compliance Solutions
* Mar 5-7: Sugar Land, TX; “2018 Winter Basics Conference“; Society for International Affairs (SIA)
* Mar 7: London, UK; “Operations and Maintenance for Offshore Wind“; ACI 
* Mar 7-8: Portland, OR; “Complying with US Export Controls“; Bureau of Industry and Security
* Mar 8: Manchester, UK; “International Documentation & Customs Compliance“; IOEx

* Mar 8-9: Washington, D.C.; ”
14th Annual TRACE Forum“; TRACE Anti-Bribery Compliance Solutions

* Mar 9: Orlando, FL; “Customs/Import Boot Camp“; Partnering for Compliance

* Mar 9: Webinar; ”
ECCN Classification Numbers“; U.S. Commercial Service

* Mar 11-14: San Diego, CA; “
ICPA Annual Conference“; International Compliance Professionals Association; wizard@icpainc.org
* March 13: London, UK; “International Documentation & Customs Compliance“; IOEx

* Mar 14: ”
Wednesday Webinar: Due Diligence for Exports;” Reeves & Dola LLP

* Mar 14; London, UK; “Letters of Credit“; IOEx
* Mar 14: Birmingham UK; “Intermediate Seminar“; UK Department for International Trade; denise.carter@trade.gsi.gov.uk 
* Mar 14-15: Austin, TX; “Establishing an ITAR/EAR Export Compliance Program“; Export Compliance Solutions;  spalmer@exportcompliancesolutions.com;  866-238-4018 
* Mar 15: Birmingham UK; “Beginners Workshop“; UK Department for International Trade; denise.carter@trade.gsi.gov.uk 
* Mar 15: Birmingham UK; “Licences Workshop“; UK Department for International Trade; denise.carter@trade.gsi.gov.uk 
* Mar 15: Birmingham UK; “Control List Classification – Combined Dual Use and Military“; UK Department for International Trade; denise.carter@trade.gsi.gov.uk 
* Mar 15-16: McLean, VA; “ITAR Fundamentals“; FD Associates
* Mar 20: Zurich, Switzerland; “Anti-Corruption in Switzerland“; TRACE Anti-Bribery Compliance Solutions
* Mar 20: London, UK; “An Introduction to Importing“; IOEx
* Mar 20: London, UK; “UK & US Export Controls: A Basic Understanding“; IOEx
* Mar 20-22: Nashville, TN; “Complying with US Export Controls“; Bureau of Industry and Security
* Mar 23; Nashville, TN; “How to Build an Export Compliance Program“; Bureau of Industry and Security
* Mar 26: East Rutherford, NJ; “Advanced Classification of Plastics and Rubber“; Global Trade Academy 
* Mar 27-28: Santa Clara, CA; “Export Control Forum“; Bureau of Industry and Security
* Apr 5-6: Des Moines, IA; “Complying with US Export Controls“; Bureau of Industry and Security 
* Apr 10: Webinar; “Letters of Credit“; U.S. Commercial Service

* Apr 11: ”
Wednesday Webinar: Anatomy of a Compliance Program;” Reeves & Dola LLP

* Apr 11-12: Denver, CO; “Complying with US Export Controls“; Bureau of Industry and Security
# Apr 16-17: Los Angeles, CA; “APBO Conference, 2018“; Asia Pacific Business Outlook
* Apr 16-19: Las Vegas NV; “ITAR Defense Trade Controls / EAR Export Controls Seminar“; ECTI;
 
jessica@learnexportcompliance.com; 540-433-3977
* Apr 19: McLean, VA; “ITAR for the Empowered Official“; FD Associates
* Apr 23: Copenhagen, Denmark; “Anti-Bribery Roundtable“; TRACE Anti-Bribery Compliance Solutions
* Apr 24: Los Angeles, CA; “Duty Drawback Specialist – Certification“; Global Trade Academy
* Apr 24-25: Dubai, UAE; “Trade Compliance in the Middle East“; NeilsonSmith
* Apr 25-26: Berlin, Gernamy; “Global Anti-Bribery In-House Network (GAIN)“; TRACE Anti-Bribery Compliance Solutions
* Apr 25-26: Costa Mesa, CA; “Complying with US Export Controls“; Bureau of Industry and Security
* May 2-3; Scottsdale, AZ; “Complying with US Export Controls“; Bureau of Industry and Security 
* May 6-8: Toronto, Canada; “2018 ICPA Canadian Conference“; ICPA
* May 7-8: Denver, CO; “2018 Spring Advanced Conference“; Society for International Affairs (SIA)

* May 8: Webinar; “U.S. Harmonized Tariff Classification Numbers“; U.S. Commercial Service
* May 8: Mexico City, Mexico; “Anti-Bribery Workshop“; TRACE Anti-Bribery Compliance Solutions
* May 9: ”
Wednesday Webinar: Demonstrations and Plant Visits“; Reeves & Dola LLP

* May 9: London, UK; “Advanced Financing of International Trade“; IOEx
* May 15-16; Cleveland, OH; “Complying with US Export Controls“; Bureau of Industry and Security
* May 16-17: National Harbor, MD; “ITAR/EAR Compliance: An Industry Perspective“; Export Compliance Solutions; spalmer@exportcompliancesolutions.com
;
 866-238-4018 

* Jun 5-9: Baltimore, MD; ”
AAEI Annual Conference“; AAEI

* Jun 6-7: Seattle, WA; “Complying with US Export Controls“; Bureau of Industry and Security
* Jun 6-7: Munich, Germany; “US Trade Controls Compliance in Europe“; NielsonSmith

* Jun 8: Stafford, VA; ”
Spring Golf Outing;” Society for International Affairs;

* Jun 12: Webinar; “Duty Drawback and Refunds“; U.S. Commercial Service

* Jun 13: San Diego, CA; “Made in America, Buy America, or Buy American: Qualify your Goods and Increase Sales“; Global Trade Academy
* Jun 13-14: McLean, VA; “ITAR Fundamentals“; FD Associates
* Jun 18: Los Angeles, CA; “Certified Classification Specialist (CCLS)“; Global Trade Academy
* Jul 10: Chicago, IL; “Duty Drawback Specialist – Certification“; Global Trade Academy
* Jul 10-11: Columbia, SC; “Complying with US Export Controls“; Bureau of Industry and Security
* Jul 10-11: Long Beach, CA; “ITAR/EAR Boot Camp“;  Export Compliance Solutions; spalmer@exportcompliancesolutions.com; 866-238-4018

* Jul 16-18: National Harbor, Maryland; ”
2018 Summer Basics Conference“; Society for International Affairs

* Jul 17: Los Angeles, CA; “Advanced Classification of Plastics and Rubber“; Global Trade Academy
* Jul 19: McLean, VA; “ITAR for the Empowered Official“; FD Associates
* Aug 1-3: Washington, D.C.; “NSSF and Fair Trade Import/Export Conference“; NSSF
* Aug 6: Detroit, MI; “Export Compliance and Controls“; Global Trade Academy
* Aug 7-9: Detroit, MI; “Export Controls Specialist – Certification“; Global Trade Academy
* Aug 14-15: Milpitas, CA; “Complying with US Export Controls“; Bureau of Industry and Security
* Aug 16: Milpitas, CA; “Encryption Controls“; Bureau of Industry and Security
* Sep 12-13: Annapolis, MD; “
ITAR/EAR Boot Camp
“; Export Compliance Solutions; 
spalmer@exportcompliancesolutions.com
; 866-238-4018
* Sep 12-13: Springfield, RI; “Complying with US Export Controls“; Bureau of Industry and Security
* Sep 13: McLean, VA; “EAR Basics“; FD Associates
* Sep 17: Los Angeles, CA; “Import Compliance“; Global Trade Academy

* Sep 17-20: Columbus, OH; ”
3rd Annual University Export Controls Conference“; Export Compliance Training Institute (ECTI)

* Sep 17-21: Los Angeles, CA; “Import 5-Day Boot Camp“; Global Trade Academy  
* Sep 18: Los Angeles, CA; “Tariff Classification for Importers and Exporters“; Global Trade Academy 
* Sep 19: Los Angeles, CA; “NAFTA and Trade Agreements“; Global Trade Academy
* Sep 20: Los Angeles, CA; “Country and Rules of Origin“; Global Trade Academy
* Sep 21: Los Angeles, CA; “Customs Valuation – The Essentials“; Global Trade Academy
* Oct 18-19: McLean, VA; “ITAR Fundamentals“; FD Associates
* Oct 22-23: Arlington, VA; “2018 Fall Advanced Conference“; Society for International Affairs (SIA)
* Oct 30 – Nov 1: Seattle, WA; “Export Controls Specialist – Certification“; Global Trade Academy
* Nov 6: Detroit, MI; “Classification: How to Classify Parts“; Global Trade Academy
* Nov 7-9: London, UK; “TRACE European Forum, 2018“; TRACE Anti-Bribery Compliance Solutions
* Nov 7-9: Detroit, MI; “Advanced Classification for Machinery & Electronics“; Global Trade Academy
* Nov 13: Tysons Corner, VA; “Made in America, Buy America, or Buy American: Qualify your Goods and Increase Sales“; Global Trade Academy
* Nov 15: McLean, VA; “ITAR For the Empowered Official“; FD Associates
* Nov 27: Houston, TX; “Duty Drawback Specialist – Certification“; Global Trade Academy
* Dec 3-7: Tysons Corner, VA; “Certified Classification Specialist“; Global Trade Academy
* Dec 6: London, UK; “International Documentation and Customs Compliance“; Institute of Export and International Trade
* Dec 11: Manchester, UK; “International Documentation and Customs Compliance“; Institute of Export and International Trade

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

ENEDITOR’S NOTES

EN_a114
. Bartlett’s Unfamiliar Quotations

(Source: Editor)
 

* Deepika Padukone (
Born 5 Jan 1986; is an Indian film actress. As of 2017, she is the highest-paid actresses in India, and is the recipient of 
several awards
, including three 
Filmfare Awards
. She features in listings of the nation’s most popular personalities.)

  – “I like statement earrings.” 



* Paramahansa Yogananda (

5 Jan 1893 – 7 Mar 1952, born Mukunda Lal Ghosh, was an Indian 
yogi
 and 
guru
 who introduced millions of Indians and westerners to the teachings of 
meditation
 and 
Kriya Yoga
. His book, Autobiography of a Yogi, is considered a spiritual masterpiece, and was included in the HarperCollins list of the 100 best spiritual books of the 21st century.)
 
  – “Remain calm, serene, always in command of yourself. You will then find out how easy it is to get along.”
 
* Thomas Dewar
 (
Thomas Robert “Tommy” Dewar, 1st Baron Dewar; 6 Jan 1864 – 11 Apr 1930; was a Scottish 
whisky
 distiller who, along with his brother 
John Dewar
, built their family label, 
Dewar’s
, into an international success. They blended their whisky to make it more appealing to the international palate, and Dewar demonstrated skill in marketing, travelling the world to find new markets, and promote his product, exploiting romantic images of Scotland and tartan in his advertising.)

  – “The only thing that hurts more than paying an income tax is not having to pay an income tax.”
  – “No wife can endure a gambling husband; unless he is a steady winner.” 
  – “Judge not a man by his clothes, but by his wife’s clothes.” 
 

Friday funnies:
 
Q. Johnny, do you think I’m a bad mother?
A. Mother, my name is Paul.

Father: “Son, you were adopted.” 
Son: “What?! I knew it! I want to meet my biological parents!”
Father: “We are your biological parents. Now pack up. Your new parents will pick you up in 20 minutes.”

Judge: “Why did you steal that car?”
Defendant: “I had to get to work.”
Judge: “Why didn’t you take the bus?”
Defendant: “I don’t have a license to drive a bus.”
 

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

EN_a215. 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: 28 Dec 2017: 
82 FR 61450-61451: Iraq Stabilization and Insurgency 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 (1 Jan 2018) 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 2018: 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: 1 Jan 2018: Updated HTS for 2018.
  – 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: 3 Jan 2018: 83 FR 234-237: Department of State 2018 Civil Monetary Penalties Inflationary Adjustment
  – The only available fully updated copy (latest edition: 3 Jan 2018) of the ITAR with all amendments is contained in Bartlett’s Annotated ITAR
(“BITAR”), by James E. Bartlett III. The BITAR contains all ITAR amendments to date, plus a large Index, over 800 footnotes containing amendment histories, case annotations, practice tips, DDTC guidance, and explanations of errors in the official ITAR text. Subscribers receive updated copies of the BITAR in Word by email, usually revised within 24 hours after every ITAR amendment.
 The BITAR is available by annual subscription from the Full Circle Compliance 
website
. BAFTR subscribers receive a 25% discount on subscriptions to the BITAR, please
contact us
to receive your discount code.
 

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

EN_a316
. Weekly Highlights of the Daily Bugle Top Stories

(Source: Editor)
 

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

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

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

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

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

* SUBSCRIPTIONS: Subscriptions are free.  Subscribe by completing the request form on the Full Circle Compliance website.

* TO UNSUBSCRIBE: Use the Safe Unsubscribe link below.

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