18-0208 Thursday “Daily Bugle”

18-0208 Thursday “Daily Bugle”

Thursday, 8 February 2018

The Daily Bugle is a free daily newsletter from Full Circle Compliance, containing changes to export/import regulations (ATF, DOE/NRC, Customs, NISPOM, EAR, FACR/OFAC, FAR/DFARS, FTR/AES, HTSUS, and ITAR), plus news and events.  Subscribe 
here for free subscription. Contact us
for advertising inquiries and rates

  1. USTR Amends HTSUS, Makes Technical Modifications to Subchapter III of Chapter 99 
  1. Items Scheduled for Publication in Future Federal Register Editions 
  2. Commerce/BIS: (No new postings.) 
  3. State/DDTC: (No new postings.) 
  1. Expeditors News: “U.S.-Israel Free Trade Agreement Shipments Will no Longer Require the Certificate of Origin” 
  2. The Globe and the Mail: “Ottawa Orders Review of Deal to Sell Helicopters to Philippine Military”
  3. The Guardian: “UK Sold Spyware to Honduras Just Before Crackdown on Election Protesters”
  4. Reuters: “Anti-China Bill Being Softened After U.S. Companies Complain”
  5. ST&R Trade Report: “Vessels Prohibited from Transferring Cargo in U.S.”
  1. D. Scavuzzo: “Brexit Consequences in the Import/Export Industry”
  2. M. Volkov: “Challenges in Global Compliance Operations: Structure and Responsibilities (Part I of II)”
  3. R. Levick: “Regulatory Labyrinth Can Trap Foreign Companies Doing Business in U.S.”
  4. T.G. Ficaretta: “ATF Completes eRegulations Project: A Powerful Research Tool for Industry Members”
  1. ECS Will Present “ITAR/EAR Boot Camp” on 13-14 Feb in Orlando, FL
  2. ECTI Presents “United States Export Control (ITAR/EAR/OFAC) Seminar Series” 16-18 Apr in Las Vegas, NV
  1. Bartlett’s Unfamiliar Quotations 
  2. Are Your Copies of Regulations Up to Date? Latest Amendments: ATF (15 Jan 2016), Customs (8 Dec 2017), DOD/NISPOM (18 May 2016), EAR (26 Jan 2018), FACR/OFAC (28 Dec 2017), FTR (20 Sep 2017), HTSUS (8 Feb 2018), ITAR (19 Jan 2018) 
  3. Weekly Highlights of the Daily Bugle Top Stories 



USTR Amends HTSUS, Makes Technical Modifications to Subchapter III of Chapter 99

Federal Register, 8 Feb 2018.) [Excerpts.]
83 FR 5674: Technical Corrections to the Harmonized Tariff Schedule of the United States
* AGENCY: Office of the United States Trade Representative.
* ACTION: Notice.
* SUMMARY: The United States Trade Representative (USTR) is making technical modifications to subchapter III of chapter 99 of the Harmonized Tariff Schedule of the United States (HTSUS) to correct errors and omissions in the Annex to a Presidential Proclamation issued on January 23, 2018, concerning imports of large residential washers and covered parts.
* DATES: The modifications and corrections are effective with respect to articles entered or withdrawn from warehouse for consumption, on or after the dates set forth in each item in the annex to this notice. …
* SUPPLEMENTARY INFORMATION: … Effective with respect to articles entered or withdrawn from warehouse for consumption, on or after 12:01 a.m., eastern standard time, on February 7, 2018, U.S. Note 17(f) to subchapter III of chapter 99 of the Harmonized Tariff Schedule of the United States is modified:
  (1) By deleting the phrase “, the foregoing which incorporate, at a minimum, (A) a side wrapper, (B) a base and (C) a drive hub” in subdivision (1);
  (2) by deleting the word “and” at the end of subdivision (2);
  (3) by renumbering subdivision (3) as subdivision (4); and
  (4) by inserting the following new subdivision (3) in numerical order: “(3) all assembled baskets provided for in subheading 8450.90.60 and designed for use in the washing machines defined in subdivision (c) of this note, which incorporate, at a minimum: (A) a side wrapper, (B) a base and (C) a drive hub; and”.
  Jamieson Greer, Chief of Staff, Office of the United States Trade Representative.

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


OGS_a12. Items Scheduled for Publication in Future Federal Register Editions
(Source: Federal Register


[No items of interest noted today.]

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

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

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


5. Expeditors News: “U.S.-Israel Free Trade Agreement Shipments Will no Longer Require the Certificate of Origin”

(Source: Expeditors News, 7 Feb 2018.)
On May 10, 2017, the Governments of U.S. and Israel signed an agreement indicating that certificates of origin would no longer be required in order to claim duty preference under the U.S. – Israel Free Trade Agreement. According to this agreement, which was published by the Office of the United States Trade Representative (USTR), a written declaration would be “completed by the producer or export on the invoice, delivery note, or any other commercial document.” According to the America-Israel Chamber of Commerce website, these changes will become effective on March 31, 2018.
  – The USTR document can be found here.
  – Additional information can be found here.

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

NWS_a26. The Globe and the Mail: “Ottawa Orders Review of Deal to Sell Helicopters to Philippine Military”

(Source: The Globe and the Mail, 8 Feb 2018.) [Excerpts.]
The [Canadian] federal government has ordered a review of Canada’s deal to sell helicopters to the Philippine military amid rising concerns about supplying armed forces that have been accused of unlawful killings in the Asian country.
Foreign Affairs Minister Chrystia Freeland said she is prepared to block the export of the aircraft if necessary, and expressed serious misgivings about human-rights violations under the Duterte government in the Philippines.
International Trade Minister François-Philippe Champagne told reporters the review was prompted by comments from a Filipino military officer regarding the intended use of these equipment.
Philippines Brigadier-General Restituto Padilla, military chief of plans, told media on Tuesday, the day that news of the deal was released, that the helicopters “will be used for the military’s internal security operations.” …
The Philippine military has said the ‘copters might also be used for these humanitarian purposes. The Liberal government was on the defensive earlier this week over why Ottawa would allow a deal with the Philippines’ armed forces after Prime Minister Justin Trudeau voiced concerns over human-rights abuses by the country’s security forces. …
No export permits yet have been issued in the Philippines deal. …

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

NWS_a37. The Guardian: “UK Sold Spyware to Honduras Just Before Crackdown on Election Protesters”

(Source: The Guardian, 8 Feb 2018.) [Excerpts.]
The interception equipment was used by the country’s law enforcement agencies which have a dismal human rights track record.
The British government sanctioned sales of spy equipment to Honduras shortly before a disputed general election led to a violent crackdown on opposition protesters and activists in the Central American country.
Telecommunications interception equipment worth at least £300,000, sophisticated spy technology which can be used to intercept, monitor and track emails, mobile phones, and online messaging services such as WhatsApp was sold to Honduras for use by its law enforcement agencies which have a dismal human rights track record of kidnap, torture and extrajudicial killings.
The government also approved two open export licenses between December 2016 and September 2017, according to the latest available information from the Department of International Trade (DIT).
These open licenses permit recurrent exports of a wide range of military and telecoms parts such as cables and software systems “sensitive to eavesdropping”, but the DIT is not obliged to reveal what, if anything, is sold.
Honduras, the second poorest and most unequal country in the Americas, has been plagued by a deadly mix of violence, impunity and corruption since a July 2009 coup ushered the National party into power, where it has remained despite allegations of state sponsored killings, electoral fraud and links to organized crime. …
The 2008 British Export Control Act prohibits the sale of arms to countries where there is a clear risk that they will be used to repress their own people.
Nevertheless, the government has sanctioned the sale of spyware to authoritarian states including Saudi Arabia, Bahrain, Turkey, Egypt and now Honduras, despite evidence of surveillance technology being used to target activists and opponents. …

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

NWS_a48. Reuters: “Anti-China Bill Being Softened After U.S. Companies Complain”

(Source: Reuters, 8 Feb 2018.) [Excerpts.]
Proposed legislation in Congress aimed at preventing China from acquiring sensitive technology is being softened after protests by big U.S. companies who fear a loss in sales, four people with knowledge of the matter said this week.
Two bills in the House of Representatives and Senate would broaden the powers of the inter-agency Committee on Foreign Investment in the United States (CFIUS) in hopes of stopping Chinese efforts to acquire sophisticated U.S. technology. The bipartisan legislation has the support of President Donald Trump’s administration.
  “We are concerned that it vastly expands the scope and jurisdiction (of CFIUS),” said Nancy McLernon, chief executive of the Organization for International Investment, a group that represents global companies with U.S. operations.
Given the alarm that the legislation has caused, Senator John Cornyn’s staff is drafting changes to address industry concerns, according to three sources. Cornyn’s office did not respond to a request for comment. … 
Two potential fixes are that lawmakers could either identify the “critical technologies” in the bill to narrow the number of companies whose sales would go before CFIUS. Or those paragraphs could be removed and the technologies at issue be monitored instead by U.S. government agencies that enforce export control rules.
The bills, introduced in November by Republicans Cornyn and Representative Robert Pittenger, have Republican and Democratic co-sponsors.
Companies affected by the legislation did not see the language of the bills until they were introduced and, in any case, were focusing their lobbying efforts on tax reform before moving to the CFIUS legislation.
The legislation would expand CFIUS’ reach to allow it to review, and potentially reject, smaller investments and add new national security factors for CFIUS to consider. Those factors include whether information about Americans, such as Social Security numbers, would be exposed as part of the transaction or whether the deal would facilitate fraud.

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

NWS_a59. ST&R Trade Report: “Vessels Prohibited from Transferring Cargo in U.S.”

The Coast Guard has posted to its website a list of vessels that are generally prohibited from entering the navigable waters of the U.S. or transferring cargo in the U.S. under a law designed to tighten sanctions against North Korea and those countries that support it.
The Countering America’s Adversaries Through Sanctions Act amended the Ports and Waterways Safety Act to require the Coast Guard to maintain timely information on the registrations of all foreign vessels over 300 gross tons that are known to be owned and operated by or on behalf of the following.
  – The government of North Korea or a North Korean person;
  – Any country identified by the president as a country that has not complied with the applicable United Nations Security Council resolutions (affecting North Korea);
  – Any country in which a sea port is located, the operator of which the president has identified in his most recent report on countries and ports that knowingly do any of the following:
   (a) significantly fail to implement or enforce regulations to inspect ships, aircraft, cargo, or conveyances in transit to or from North Korea, as required by applicable UNSC resolutions;
   (b) facilitate the transfer, transshipment, or conveyance of significant types or quantities of cargo, vessels, or aircraft owned or controlled by persons designated under applicable UNSC resolutions; or
   (c) facilitate any of the activities described in section 104(a) of the North Korea Sanctions and Policy Enhancement Act of 2016.
The Coast Guard is required to publish and periodically update a list of such vessels. Upon receiving an advance notice of arrival from a vessel on this list the Coast Guard will notify the vessel master that the vessel may not enter or operate in the navigable waters of the U.S. or transfer cargo in any port or place under U.S. jurisdiction unless otherwise allowed by law.

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


* Author: Davide Scavuzzo, Esq.,
dejalex@dejalex.com, Di Berti Jacchia, Milan.  
In the context of the ongoing Brexit negotiations, the European Commission is informing all interested parties of the possible consequences of a hard Brexit. On 25 January 2018, the Commission published two notices to stakeholders aimed at making them aware of the consequences of Brexit in the field of
import/export licenses for certain goods and in the field of
customs and indirect taxation.
The Commission reminds the operators that, without a sector-specific agreement or a transitional agreement, from 30 March 2019 the United Kingdom will become a Third Country. This means that businesses, in particular those active in the import/export sector, should take all necessary measures to stand ready to face the exit of the United Kingdom from the European Union.
The import/export of certain goods from the EU to the UK and vice versa will require a mandatory authorization/approval/shipment notification, contrary to the present situation where in most cases such licenses are not required for intra-Union shipments. Moreover, as of the withdrawal date, import/export licenses issued by the United Kingdom as an EU Member State on the basis of Union law will no longer be valid for shipments to the EU-27 from third countries or vice versa.
Goods that require an import/export license include: “dual use goods” (Council Regulation (EC) No 428/2009), cultural goods (Council Regulation (EC) No 116/2009), waste (Regulation (EC) No 1013/2006), firearms and ammunition (Regulation (EU) No 258/2012) and military technology and equipment (Council Common Position 2008/944/CFSP).
With regard to customs, the Commission recalls that goods which are brought into the customs territory of the EU from the United Kingdom or from the EU to the United Kingdom, will be subject to customs supervision and to customs controls in accordance with the Union Customs Code (Regulation (EU) No 952/2013). Goods which are brought into the customs territory of the EU from the United Kingdom will be subject to the relevant custom duties according to Council Regulation (EEC) No 2658/87 on the tariff and statistical nomenclature and the Common Customs Tariff.
Certain goods which enter the EU from the United Kingdom or are leaving the EU to the United Kingdom will be subject to prohibitions or restrictions on grounds of public policy or public security, the protection of health and life of humans, animals or plants, or the protection of national treasures.
The status of Authorized Economic Operator (AEO) issued by the customs Authorities of the United Kingdom will no longer be valid in the customs territory of the Union.
In the field of indirect taxation, the Commission pointed out that goods which enter the VAT territory of the EU from the United Kingdom or are dispatched or transported from the VAT territory of the EU to the United Kingdom will be treated as importations or exportations of goods respectively in accordance with Council Directive 2006/112/EC on the common system of value added tax. This will imply charging VAT on importation, while exports will remain exempt from VAT.
Taxable persons established in the United Kingdom purchasing goods and services or importing goods subject to VAT in a Member State of the EU who wish to claim refund of that VAT may no longer file their applications electronically in accordance with Council Directive 2008/9/EC and will need to claim that VAT in accordance with Council Directive 86/560/EEC.
A company established in the United Kingdom carrying out taxable transactions in a Member State of the EU may be required by that Member State to designate a tax representative as the person liable for payment of VAT in accordance with Directive 2006/112/EC.
Finally, the Commission points out that the movement of goods from the EU to the United Kingdom and vice versa will be treated as an importation or exportation of excise-liable goods respectively in accordance with Council Directive 2008/118/EC on general arrangements for excise duty. This implies, inter alia, that the Excise Movement and Control System (EMCS) will no longer be applicable to movements of excise-liable goods under suspension from the EU into the United Kingdom, and will be treated as exports, where excise supervision ends at the place of exit from the EU. Movements of excise-liable goods to the United Kingdom will therefore require an export declaration as well as an electronic administrative document (e-AD). Movements of excise goods from the United Kingdom to the EU will need to be released from customs formalities before a movement under EMCS can begin.

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

Volkov Law Group Blog, 7 Feb 2018. Reprinted by permission.)
* Author: Michael Volkov, Esq., Volkov Law Group,
mvolkov@volkovlaw.com, 240-505-1992.
Global companies face ever-increasing challenges when building and implementing global ethics and compliance programs.  From my vantage point, the set of challenges can be different depending on the industry.  Global regulated companies, such as pharmaceutical, medical device or financial institutions, face a different constellation of challenges than a global manufacturing company.
Notwithstanding the risk and compliance differences among the specific industries, there are a number of common challenges in any global ethics and compliance operation.
Structure: Global ethics and compliance organizations should mirror the company’s business operations.  In other words, if the company is divided among headquarters, regional and local business operations, the compliance structure should resemble the business operation.  This rule, however, is less applicable to manufacturing operations, unless the manufacturing company is heavily regulated.
In this three-tiered system, the responsibilities have to be divided among headquarters, regional and local offices.  These responsibilities will differ for each level.  Each component will be responsible for interfacing with the business at the headquarters (board and senior management), regional (board and business management), and local (business manager).
Headquarters: For efficiency reasons, some functions should be managed at the headquarters level, including ethics and compliance policy management, design and enforcement of compliance controls, risk and compliance program assessments, auditing, internal investigations and design of a training program.  Some issues may bubble up from the local compliance office to the regional office, and ultimately to the headquarters level.  Most issues, however, that arise from the local level will be resolved at either the local or regional level.
The headquarters office should bring together the compliance organization for an annual meeting to share best practices, plan for the upcoming year and reinforce the operation of the ethics and compliance program as a global, unified team.
Regional: A strong regional team depends on an effective regional leader who, in turn, reports to headquarters senior compliance executives.  The regional leader, in turn, has to be supported by a relatively small team of effective ethics and compliance professionals.  The effectiveness of a compliance program, in reality, depends on the dual role of the regional leader and team, and their ability to maintain efficient relationships with headquarters and local compliance professionals.
A regional ethics and compliance team has to provide prompt support to local compliance officers.  When an issue arises that they need to address, regional compliance officers have to prioritize a prompt resolution of such issues to ensure that the business is well served.  A local compliance officer’s relationship with the business in a country depends on the transparency, honesty and support they provide to the business. In this regard, regional compliance officers are critical in supporting local compliance officer efforts.
Local: The rubber meets the road when it comes to the performance and relationship of local compliance officers (assigned to a specific country).  The local compliance officer’s effectiveness is proportional to his/her proactive efforts to engage and support business staff.  This does not mean that they should agree to everything the business wants to do but local compliance officers have to engage the business, find win-win strategies to promote both the business and compliance, and facilitate the business’s overall compliance with relevant policies and procedures.

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

12. R. Levick: “Regulatory Labyrinth Can Trap Foreign Companies Doing Business in U.S.”

Forbes, 6 Feb 2018.) [Excerpts.]
* Author: Richard Levick, Chairman and CEO of LEVICK.
This is the second in a five-part series on the special challenges facing foreign-based companies seeking to do business in the U.S. and for U.S.-based companies looking to expand their presence in foreign markets. The first three columns will explore the often-formidable obstacles that confront foreign-based companies as they operate in the U.S. The final two columns will break down the hurdles that face U.S.-based companies looking to do greater business abroad.
My first column in this
series described the murky litigation waters that threaten to drown foreign-based companies seeking to expand their operations in the U.S. This article addresses the U.S. regulatory labyrinth that can bedevil foreign companies.
International companies that don’t prepare for America’s regulatory challenges could find themselves lost in a maze, fated never to realize their U.S. potential. Not only are many of the regulations facing foreign companies difficult, but their erratic enforcement by federal, state, and municipal officials can be scary, too. The uneven application of U.S. trade rules and sanctions, moreover – from the
Foreign Corrupt Practices Act (FCPA) and
export controls to ”
antidumping” and ”
countervailing measures” – has long been a source of frustration for foreign companies. …
[Editor’s Note: Due to copyright restrictions, we are not authorized to republish the entire article. Please, click on the source link below the item title to read the remaining sections.] 

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

13. T.G. Ficaretta: “ATF Completes eRegulations Project:

A Powerful Research Tool for Industry Members”
(Source: Author, 7 Feb 2018.)
* Author: Teresa G. Ficaretta, Esq.,
teresa@ficarettalegal.com, +1 301-358-3553, Ficaretta Legal Services, LLC.
The Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) recently completed its eRegulations project, an electronic research tool of tremendous value for members of the firearms and explosives industries.  The eRegulations page, available
here, provides a wealth of information on regulations implementing the federal firearms and explosives laws, including the Arms Export Control Act, Gun Control Act, National Firearms Act, and federal explosives laws. 
The eRegulations project is the brainchild of Andrew Lange, the Chief of ATF’s Office of Regulatory Affairs.  Mr. Lange is trained as a lawyer and recognized the importance of an online source of information that links the law, regulations, ATF rulings, and other research materials all in one place.  In 2015 Mr. Lange obtained funding for eRegulations and partnered with ATF’s Digital Media Division to begin.  ATF personnel obtained assistance with technical aspects of the project from Technology Transformation Services, part of the General Services Administration (GSA).  By September 2015 the framework for eRegulations was completed with the text of all the ATF regulations online.  As more funding became available additional content was added to the site.  By the summer of 2017 the last of the related documents were uploaded. 
Using the eRegulations portal is a snap.  The opening page lists Parts 447, 478, 479, 555, and 646 of the regulations in Title 27 of the Code of Federal Regulations.  Clicking on one of the Parts brings up a complete list of the regulations on the left side of the screen and the law from which the regulations are derived on the right.  Clicking on the law takes you to the full text of the statute and clicking on a particular regulation brings up its full text.  Defined terms in the regulation are underlined and clicking on the term brings up its definition on the right side of the screen.  If you wish to search for a particular term in the regulations there is a magnifying glass icon to perform that function.  Users may also view previous versions of the regulations and compare regulatory language by clicking on the “regulation timeline” icon. 
The most useful aspect of the tool is the related materials listed on the right side of the screen for each regulation.  Related documents include ATF rulings, Open Letters, Industry Circulars, and other ATF guidance documents.  For example, clicking on 27 C.F.R. § 478.11 (definition of terms from the Gun Control Act) shows 20 ATF rulings, 6 Open Letters, 2 guides (generally information from other ATF publications or the website), and 8 FFL Newsletters.  Each of these documents can be accessed with a click. 
ATF officials have made a commitment to keep eRegulations up-to-date as new regulations, rulings and other guidance documents are issued.  The agency is to be commended for creating this comprehensive and easy-to-use system and making it available free of charge to industry members.  Federal firearms licensees, federal explosives licensees/permittees, and experts who support them should always start their research at ATF’s eRegulations site.

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



ECS Will Present “ITAR/EAR
Boot Camp” on 13-14 Feb in Orlando, FL


* What: ITAR/EAR
Boot Camp, Orlando, FL
* When:
13-14 Feb
* Sponsor: Export Compliance Solutions (ECS)
* ECS Speaker Panel:  Suzanne Palmer, Mal Zerden
* Register
or by calling
866-238-4018 or e-mail

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

* What: United States Export Control (ITAR/EAR/OFAC) Seminar Series in Las Vegas, NV
* When: ITAR Seminar: April 16-17, 2018; EAR/OFAC Seminar: April 18-19, 2018
* Where: Las Vegas: Westin Las Vegas
* Sponsor: Export Compliance Training Institute (ECTI)
* ECTI Speaker Panel: John Black, Scott Gearity, Greg Creeser, Marc Binder and Melissa Proctor
* Register: Here or Jessica Lemon, 540-433-3977, jessica@learnexportcompliance.com

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


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

. 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.  The latest amendments to applicable regulations are listed below.
: 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. 
: 19 CFR, Ch. 1, Pts. 0-199
  – Last Amendment: 8 Dec 2017: 82 FR 57821-57825: Civil Monetary Penalty Adjustments for Inflation

  – 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 

: 15 CFR Subtit. B, Ch. VII, Pts. 730-774

  – Last Amendment: 26 Jan 2018: 83 FR 3577-3583: Addition of Certain Entities; Removal of Certain Entities; and Revisions of Entries on the Entity List

: 31 CFR, Parts 500-599, Embargoes, Sanctions, Executive Orders
  – Last Amendment: 28 Dec 2017: 
82 FR 61450-61451: Iraq Stabilization and Insurgency Sanctions Regulations

: 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
  – 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, 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.
, 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: 8 Feb 2018:
83 FR 5674: Technical Corrections to the Harmonized Tariff Schedule of the United States [Concerns HTSUS Chapter 99, Subchapter III].

  – HTS codes for AES are available here.
  – HTS codes that are not valid for AES are available here.

  – Last Amendment: 19 Jan 2018: 83 FR 2738: Department of State 2018 Civil Monetary Penalties Inflationary Adjustment; Correction
  – The only available fully updated copy (latest edition: 19 Jan 2018) of the ITAR with all amendments is contained in Bartlett’s Annotated 

, 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
. BAFTR subscribers receive a 25% discount on subscriptions to the BITAR, please
contact us
to receive your discount code.

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

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 

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


* 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, DOE/NRC, DOJ/ATF, DoD/DSS, DoD/DTSA, FAR/DFARS, 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, provided attribution is given to “The Export/Import Daily Bugle of (date)”. 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.

Scroll to Top