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18-0226 Monday “Daily Bugle”

18-0226 Monday “Daily Bugle”

Monday, 26 February 2018

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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 
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  1. State/DDTC Seeks Comments on DSP-5, DSP-6, DSP-61, DSP-62, DSP-73, DSP-74, DSP-83, and DSP-85 
  1. Items Scheduled for Publication in Future Federal Register Editions
  2. Commerce/BIS: (No new postings.)
  3. DHS/CBP Posts Updated Drawback CATAIR and Error Dictionary
  4. DoD/DSCA Releases Policy Memo 18-05
  5. State/DDTC Reminder: DTrade Super Users Need to Update their Email Address in the System
  6. EU Amends Sanctions Concerning Syria, ISIL (Da’esh) and Al-Qaeda; Sanctions Include 2 Syrian Ministers
  7. UK DIT/ECO Releases Notice Concerning Updates to Controls on “Information Security” Products Using Cryptography
  1. CNBC: “Department of Defense Says Unfair Steel and Aluminum Imports are a Risk to U.S. National Security”
  2. Popular Mechanics: “America’s Starmen Are Selling Space, But Who’s Buying?”
  3. Reuters: “Exclusive: U.S. Prepares High-Seas Crackdown on North Korea Sanctions Evaders – Sources”
  1. M. Lester: “EU Renews Sanctions on Belarus”
  2. Gary Stanley’s ECR Tip of the Day
  3. R.C. Burns: “OFAC Sends “SOS” to Norks: Sanctions on Ships”
  1. Monday List of Ex/Im Job Openings: 158 Jobs Posted, Including 17 New Jobs
  1. Bartlett’s Unfamiliar Quotations 
  2. Are Your Copies of Regulations Up to Date? Latest Amendments: ATF (15 Jan 2016), Customs (22 Feb 2018), DOD/NISPOM (18 May 2016), EAR (16 Feb 2018), FACR/OFAC (28 Dec 2017), FTR (20 Sep 2017), HTSUS (8 Feb 2018), ITAR (14 Feb 2018) 
  3. Weekly Highlights of the Daily Bugle Top Stories 

EXIMITEMS FROM TODAY’S FEDERAL REGISTER

EXIM_a1

1. 
State/DDTC Seeks Comments on DSP-5, DSP-6, DSP-61, DSP-62, DSP-73, DSP-74, DSP-83, and DSP-85

(Source:
Federal Register, 26 Feb 2018.) [Excerpts.]
 
83 FR 8312-8314: 60-Day Notice of Proposed Information Collection: Six DDTC Information Collections
 
* ACTION: Notice of request for public comments.
* SUMMARY: The Department of State is seeking Office of Management and Budget (OMB) approval for the information collections described below. In accordance with the Paperwork Reduction Act of 1995, we are requesting comments on these collections from all interested individuals and organizations. The purpose of this notice is to allow 60 days for public comment preceding submission of the collections to OMB.
* DATES: The Department will accept comments from the public
up to April 27, 2018.
* ADDRESSES: You may submit comments by any of the following methods:
 – Web: Persons with access to the internet may comment on this notice by going to
www.Regulations.gov. You can search for the document by entering “Docket Number: DOS-2017-0047” in the Search field. Then click the “Comment Now” button and complete the comment form.
 – Regular Mail: Send written comments to: Andrea Battista, SA-1, 12th Floor, Directorate of Defense Trade Controls, Bureau of Political Military Affairs, U.S. Department of State, Washington, DC 20522-0112.
  You must include the DS form number (if applicable), information collection title, and the OMB control number in any correspondence. …
 
* SUPPLEMENTARY INFORMATION:
 
     Title of Information Collection: Application/License for Permanent Export of Unclassified Defense Articles and Related Unclassified Technical Data.
     OMB Control Number: 1405-0003.
     Type of Request: Extension of a Currently Approved Collection.
     Originating Office: Bureau of Political-Military Affairs, Directorate of Defense Trade Controls, PM/DDTC.
     Form Number: DSP-5. … 
 
     Title of Information Collection: Application/License for Temporary Import of Unclassified Defense Articles.
     OMB Control Number: 1405-0013.
     Type of Request: Extension of Currently Approved Collection.
     Originating Office: Bureau of Political-Military Affairs, Directorate of Defense Trade Controls, PM/DDTC.
     Form Number: DSP-61. … 
 
     Title of Information Collection: Application/License for Permanent/Temporary Export or Temporary Import of Classified Defense Articles and Related Classified Technical Data.
     OMB Control Number: 1405-0022.
     Type of Request: Extension of Currently Approved Collection.
     Originating Office: Bureau of Political-Military Affairs, Directorate of Defense Trade Controls, PM/DDTC.
     Form Number: DSP-85. …
 
     Title of Information Collection: Application/License for Temporary Export of Unclassified Defense Articles.
     OMB Control Number: 1405-0023.
     Type of Request: Extension of Currently Approved Collection.
     Originating Office: Bureau of Political-Military Affairs, Directorate of Defense Trade Controls, PM/DDTC.
     Form Number: DSP-73. … 
 
     Title of Information Collection: Application for Amendment to License for Export or Import of Classified or Unclassified Defense Articles and Related Classified Technical Data.
     OMB Control Number: 1405-0092.
     Type of Request: Extension of Currently Approved Collection.
     Originating Office: Bureau of Political-Military Affairs, Directorate of Defense Trade Controls, PM/DDTC.
     Form Number: DSP-6; DSP-62; DSP-74. … 
 
     Title of Information Collection: Nontransfer and Use Certificate.
     OMB Control Number: 1405-0021.
     Type of Request: Extension of Currently Approved Collection.
     Originating Office: Bureau of Political-Military Affairs, Directorate of Defense Trade Controls, PM/DDTC.
     Form Number: DSP-83. …
Abstract of Proposed Collections
 
  The export, temporary import, and brokering of defense articles, including technical data, and defense services are authorized by The Department of State, Directorate of Defense Trade Controls (DDTC) in accordance with the International Traffic in Arms Regulations (“ITAR,” 22 CFR parts 120-130) and section 38 of the Arms Export Control Act. Those who manufacture, broker, export, or temporarily import defense articles, including technical data, or defense services must register with the Department of State and obtain a decision from the Department as to whether it is in the interests of U.S. foreign policy and national security to approve covered transactions. Also, registered brokers must submit annual reports regarding all brokering activity that was transacted, and registered manufacturers and exporter must maintain records of defense trade activities for five years.
  – 1405-0003 (DSP-5), Application/License for Permanent Export of
Unclassified Defense Articles and Related Unclassified Technical Data: In accordance with part 123 of the ITAR, any person who intends to permanently export unclassified defense articles or unclassified technical data must obtain authorization from DDTC prior to export. “Application/License for Permanent Export of Unclassified Defense Articles and Related Unclassified Technical Data” (Form DSP-5) is the licensing vehicle typically used to obtain permission for the permanent export of unclassified defense articles, including unclassified technical data, enumerated on the USML. This form is an application that, when completed and approved by PM/DDTC, Department of State, constitutes the official record and authorization for the permanent commercial export of unclassified U.S. Munitions List articles, pursuant to the Arms Export Control Act and the International Traffic in Arms Regulations.
  – 1405-0013 (
DSP-61), Application/License for Temporary Import of Unclassified Defense Articles: In accordance with part 123 of the ITAR, any person who intends to temporarily import unclassified defense articles must obtain DDTC authorization prior to import. “Application/License for Temporary Import of Unclassified Defense Articles” (Form DSP-61) is the licensing vehicle typically used to obtain permission for the temporary import of unclassified defense articles covered by USML. This form is an application that, when completed and approved by PM/DDTC, Department of State, constitutes the official record and authorization for the temporary commercial import of unclassified U.S. Munitions List articles, pursuant to the Arms Export Control Act and the International Traffic in Arms Regulations.
  – 1405-0022 (DSP-85), Application/License for Permanent/Temporary Export or Temporary Import of Classified Defense Articles and Related Classified Technical Data: In accordance with part 123 of the ITAR, any person who intends to permanently export, temporarily export, or temporarily import classified defense articles, including classified technical data must first obtain DDTC authorization. “Application/License for Permanent/Temporary Export or Temporary Import of Classified Defense Articles and Related Classified Technical Data” (Form DSP-85) is used to obtain permission for the permanent export, temporary export, or temporary import of classified defense articles, including classified technical data, covered by the USML. This form is an application that, when completed and approved by PM/DDTC, Department of State, constitutes the official record and authorization for all classified commercial defense trade transactions, pursuant to the Arms Export Control Act and the International Traffic in Arms Regulations.
  – 1405-0023 (DSP-73), Application/License for Temporary Export of Unclassified Defense Articles: In accordance with part 123 of the ITAR, any person who intends to temporarily export unclassified defense articles must DDTC authorization prior to export. “Application/License for Temporary Export of Unclassified Defense Articles” (Form DSP-73) is the licensing vehicle typically used to obtain permission for the temporary export of unclassified defense articles covered by the USML. This form is an application that, when completed and approved by PM/DDTC, Department of State, constitutes the official record and authorization for the temporary commercial export of unclassified U.S. Munitions List articles, pursuant to the Arms Export Control Act and the International Traffic in Arms Regulations.
  – 1405-0092 (
DSP-6; DSP-62; DSP-74), Application for Amendment to License for Export or Import of Classified or Unclassified Defense Articles and Related Classified Technical Data: In accordance with part 123 of the ITAR, any person who intends to permanently export, temporarily import, or temporarily export unclassified or classified defense articles or related technical data must obtain DDTC authorization. “Application for Amendment to License for Export or Import of Classified or Unclassified Defense Articles and Related Classified Technical Data” is used to obtain permission for certain changes to previously approved licenses. This form is an application that, when completed and approved by PM/DDTC, Department of State, constitutes the official record and authorization for all requests to amend existing defense trade authorizations made pursuant to the Arms Export Control Act and the International Traffic in Arms Regulations.
  – 1405-0021 (DSP-83), Nontransfer and Use Certificate: Pursuant to Sec.  123.10 of the ITAR, a completed Nontransfer and Use Certificate” (Form DSP-83) must accompany an export license application to export significant military equipment and classified articles and technical data. Pursuant to Sec.  124.10 of the ITAR, a completed “Nontransfer and Use Certificate” must be submitted with any request for a manufacturing license agreement or technical assistance agreement that relates to significant military equipment or classified defense articles and technical data. The foreign consignee (if applicable), foreign end-user, and applicant execute this form. By signing the certificate the foreign end-user certifies that they will not, except as specifically authorized by prior written approval of the Department of State, re-export, resell or otherwise dispose of the defense articles enumerated in the application (1) outside the foreign country named as the country of ultimate destination; or (2) to any other person. With respect to agreements that involve classified articles or classified technical data, an authorized representative of the foreign government must also sign the form. …
 
  Anthony M. Dearth, Directorate of Defense Trade Controls, Bureau of Political-Military Affairs, U.S. Department of State.

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

OGSOTHER GOVERNMENT SOURCES

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

* State; NOTICES; Agency Information Collection Activities; Proposals, Submissions, and Approvals:

  – Maintenance of Records by Registrants; and
  – Request for Approval of Manufacturing License Agreements, Technical Assistance Agreements, and Other Agreements [Publication Dates: 27 Feb 2018.]

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

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

OGS_a34.

DHS/CBP Posts Updated Drawback CATAIR and Error Dictionary

(Source:
CSMS# 18-000164, 26 Feb 2018.)
 
Updated versions of the ACE Drawback CATAIR and Drawback Error Dictionary are now available on
CBP.gov/ACE. They can be found on the
CATAIR page or at the links below:
 

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

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

OGS_a5
6. State/DDTC Reminder: DTrade Super Users Need to Update their Email Address in the System

(Source: 
State/DDTC, 20 Feb 2018.)
 
DTrade Super users should ensure their email address in DTrade is accurate and correct. Please log in to DTrade and verify your email address. To change or update your DTrade email address, follow these instructions: 
Update Your DTrade Email Address Instruction Form.
 

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

OGS_a6
7.

EU Amends Sanctions Concerning Syria, ISIL (Da’esh) and Al-Qaeda; Sanctions Include 2 Syrian Ministers

 
Regulations
 
*
Council Implementing Regulation (EU) 2018/281 of 26 February 2018 implementing Regulation (EU) 2016/1686 imposing additional restrictive measures directed against ISIL (Da’esh) and Al-Qaeda and natural and legal persons, entities or bodies associated with them
*
Council Implementing Regulation (EU) 2018/282 of 26 February 2018 implementing Regulation (EU) No 36/2012 concerning restrictive measures in view of the situation in Syria
 
Decisions
 
*
Council Decision (CFSP) 2018/283 of 26 February 2018 amending Decision (CFSP) 2016/1693 concerning restrictive measures against ISIL (Da’esh) and Al-Qaeda and persons, groups, undertakings and entities associated with them
*
Council Implementing Decision (CFSP) 2018/284 of 26 February 2018 implementing Decision 2013/255/CFSP concerning restrictive measures against Syria 

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

OGS_a7
8.

UK DIT/ECO Releases Notice Concerning Updates to Controls on “Information Security” Products Using Cryptography  

(Source:
UK DIT/ECO
, 26 Feb 2018.)
 
The Export Control Organisation (ECO) of the UK Department of International Trade (DIT) has released
notice to exporters 2018/03: updates to controls on ‘information security’ products using cryptography.  The notice is included below.
 
Controls on “information security” products, notably those using cryptography, are contained in Category 5 Part 2 “Information Security” of the
consolidated list of strategic export controls.
 
With the use of cryptography becoming more widespread, there has been an increase in the number of items controlled in this category. Simultaneously, there are also more products using cryptography that are excluded from control, both by longstanding “decontrol” notes, listed at the start of Part 2 (such as Note 3, the cryptography note) and by more recent additions to the text.
 
It has been recognized that “information security” in general is a complex section of controls. Following 2 years of multilateral negotiation between the
Wassenaar Arrangement participating states, changes to the text were agreed at the end of 2016 and appeared in the Annex I to Council Regulation (EC) No. 428/2009 (as last amended by Regulation (EU) No. 2268/2017) in late 2017.
 
Some amendments to the regulation were made in 2016 in preparation for the further 2017 changes detailed in 0.1 below:
 
  – a new general ‘information security’ note incorporating the content of Note 1, which described the control status of information security equipment – Note 1 was subsequently deleted
  – new sections of control, 5A003 (non-cryptographic information security) and 5A004 (systems … for defeating, weakening or bypassing “information security”), have been broken out from the previous 5A002
  – renumbering and deletion of many sub-controls
  – deletion of 5A002.a.7 – “non-cryptographic information and communications technology (ICT) security systems and devices that have been evaluated and certified by a national authority to exceed class EAL-6 (evaluation assurance level) of the Common Criteria (CC) or equivalent”
 
(1) Purpose of 2017 changes
 
Category 5 Part 2, “Information Security”, has been restructured to create a set of “positive” controls, to improve ease of use and clarity. The broad intent of the restructure was to maintain the scope of Category 5 Part 2, so the new text should not change the control status of most items.
 
The changes below are listed in the order in which they occur in the control text.
 
(2) Change to Note 3 (the cryptography note)
 
Note 3 has been amended to clarify that it does not apply to 5A003 or 5A004.
 
(3) Removal of Note 4 – relevant text incorporated in 5A002a
 
Note 4 excluded items with ancillary cryptography from control. Roughly speaking these are items that use cryptography but the primary function of the item is not information security, networking, sending, receiving or storing information, or computing. The cryptography is only used in support of the item’s primary function. An example of an item that was previously decontrolled by Note 4 is a vending machine that communicates using standard wifi encryption to report that it has run out of soft drinks.
 
Note 4 was written in the negative, excluding an item from control if the primary function was not listed. In an effort to help clear up confusion among exporters, Note 4 is being replaced with positive text in 5A002a that specifies the items subject to control.
 
(4) Changes to 5A002a
 
Scope of control in relation to items and their “primary function”
 
This section now defines the scope of 5A002a as only applying to items:
 
  – designed or modified to use “cryptography for data confidentiality”
  – having a symmetric key length in excess of 56 bits of, or equivalent
  – whose cryptographic capability can be used without being activated, or has been activated
 
In addition, these items must have a primary function that is:
 
  – information security
  – digital communication, networking, computers or other information storage or processing functions
 
If the primary function of the item is not listed above, but the cryptography supports a non-primary function and the component (or other incorporated equipment or software) that performs the cryptographic function would in its own right be controlled under 5A002a, then 5A002a still applies.
 
For most items previously classified as 5A002a1a or 5A002a1b, these classifications are now simplified to 5A002a.
 
Taking an example of an item that was previously decontrolled by Note 4, let’s apply the new control text to the vending machine that communicates stock levels using standard wifi encryption. The vending machine has a primary function of supplying drinks. To support this primary function, the machine performs other tasks such as taking payment, and managing stock levels. Taking the new text in 5A002a1-3, the vending machine’s primary function is not “information security”. It’s not a digital communication or networking system and it does not have information storage or processing as a primary function.
 
Taking 5A002a4, the machine would use cryptography with a key size over 56 bits (or equivalent) but this cryptography supports the primary function of supplying drinks. Assuming that the wifi connectivity is conducted by a standard COTS (commercial off-the-shelf) wifi chip, then this component would almost certainly not be controlled by Category 5 Part 2 because it would meet the decontrol conditions of Note 3.
 
The changes to 5A002a are explained in more detail below.
 
Introducing the concept of “cryptography for data confidentiality”
 
5A002a now specifies that cryptography is only controlled when used for confidentiality. As with other changes made as part of the restructure, this is intended to maintain current control scope. A list of cryptographic functions that are not considered to be confidentiality functions is provided, including:
 
  – authentication
  – digital signing
  – non-repudiation
  – digital rights management
 
Most of these exclusions were explicit in the previous control text. For example, authentication and digital signature functions were previously excluded in 5A002a1 text, whereas digital rights management was excluded at the item level by former Note 4.
 
New local definition of “in excess of 56 bits of symmetric key length, or equivalent”
 
Previously, separate control entries existed for “symmetric algorithms” (5A002a1a) and “asymmetric algorithms” (5A002a1b). The new text specifies that 5A002a controls “systems, equipment and components … designed or modified to use “cryptography for data confidentiality”, having “in excess of 56 bits of symmetric key length, or equivalent'”.
 
The definition of “in excess of 56 bits of symmetric key length, or equivalent” is now provided separately in technical Note 2 and gives examples of equivalent asymmetric algorithms, key sizes and parameters.
 
Addition of Note 1 to 5A002a
 
A new Note 1 to 5A002a has been added to incorporate the condition: “When necessary as determined by the appropriate authority … details of items must be accessible and provided to the authority upon request…”, which was in the (now deleted) Note 4 and in Note g. to 5A002a.
 
New Note 2 to 5A002a
 
The new Note 2 incorporates the previous 5A002a decontrol notes a-j. Unless mentioned below, the wording of these decontrol notes remains the same, but their numbering changes to 2.a-2.i.
 
Introduction of Note 2.a. to 5A002a (smart cards and smart card readers/writers)
 
Note 2.a. to 5A002a replaces the previous Note a to 5A002a. Paragraph 1 of the previous text has been substantially rewritten to improve clarity, but the intended scope is identical.
 
Removal of Note g. to 5A002a (inactive or dormant cryptography)
 
In keeping with the move to a positive set of controls, Note g has been removed. The scope of the control text is preserved by adding new wording to the first paragraph of 5A002a: “… where that cryptographic capability is usable without “cryptographic activation” or has been activated…”
 
As a result of the removal of Note g, former Notes h, i and j are renumbered as 2.g, 2.h and 2.i.
 
(5) Changes to 5D002
 
As indicated above, in 2016 distinct categories of 5A002, 5A003 and 5A004 were created.
 
5D002 has now been adapted to better reflect these categories, so that software performing information security functions can be more clearly classified. 5D002a and 5D002c each now have 3 subcategories (5D002a1, 5D002a2, 5D002a3 and 5D002c1, 5D002c2, 5D002c3) which relate to software with the characteristics of equipment in 5A002, 5A003 and 5A004 respectively.
 
Separately, 5D002d has become 5D002b, with the previous text in 5D002b being removed.
 
(6) New global definition of “authentication”
 
The following definition has been added to the Definitions section of the text:
 
“Authentication”
 
Verifying the identity of a user, process or device, often as a prerequisite to allowing access to resources in an information system. This includes verifying the origin or content of a message or other information, and all aspects of access control where there is no encryption of files or text except as directly related to the protection of passwords, personal identification numbers (PINs) or similar data to prevent unauthorized access.

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NWSNEWS

NWS_a1
9. CNBC: “Department of Defense Says Unfair Steel and Aluminum Imports are a Risk to U.S. National Security”

(Source:
CNBC, 22 Feb 2018.) [Excerpts.]
 
A
Department of Defense memo to Commerce Secretary
Wilbur Ross
supports the findings from Ross that steel and aluminum imports impair U.S. national security.
 
In the memo, Defense Secretary Jim Mattis said that the DoD did have some concern that recommendations could negatively impact allies, but that it agreed with the Department of Commerce’s conclusion that imports of foreign steel and aluminum based on unfair trading practices were a threat to national security
 
Earlier this month, the Commerce Department recommended imposing heavy tariffs or quotas on foreign producers of steel and aluminum in the interest of national security, following a trade investigation of imports.
 

  “DoD continues to be concerned about the negative impact on our key allies regarding the recommended options in the report,” he said. … 

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NWS_a210. Popular Mechanics: “America’s Starmen Are Selling Space, But Who’s Buying?”

(Source:
Popular Mechanics, 23 Feb 2018.) [Excerpts.]
 
The emerging U.S. commercial manned spaceflight market may depend on foreign customers-which is a problem, given the way our laws are written.
 
Robert Bigelow, back of inflatable space hotels, has announced the formation of a new company to build and market space stations in Earth’s orbit, called
Bigelow Space Ops.
 
During his announcement, the company’s founder made a point to paint a picture of a thriving U.S. industry: American-made hardware launching from American spaceports, leading the way into the orbital future. But what
Bigelow and other space barons’ business plans really want are for customers from other nations to emerge. “What we’ve always anticipated and expected is that we would be very involved in helping foreign countries to establish their human space programs,”
Bigelow told reporters. …
 
Another event last week-the meeting of the reformed Space Council-will have a direct bearing on Americans selling space services abroad. “The Council is looking into how reforming export controls plays into all of this,” Lodgson says.
 
At issue is the International Traffic in Arms Regulations (ITAR). Space rockets and military missiles have a lot in common, and for that reason, access to manufacturing facilities and launchpads is limited to citizens and U.S.-based companies. This makes sense for national security reasons, but it also could limit the marketing of space services. For example, a spaceplane landing at an international airport could be subject to ITAR restrictions. A company bringing rockets to another nation clearly would. … 

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NWS_a311. Reuters: “Exclusive: U.S. Prepares High-Seas Crackdown on North Korea Sanctions Evaders – Sources”

(Source:
Reuters, 24 Feb 2018.) [Excerpts.]
 
The Trump administration and key Asian allies are preparing to expand interceptions of ships suspected of violating sanctions on North Korea, a plan that could include deploying U.S. Coast Guard forces to stop and search vessels in Asia-Pacific waters, senior U.S. officials said.
 
Washington has been talking to regional partners, including Japan, South Korea, Australia and Singapore, about coordinating a stepped-up crackdown that would go further than ever before in an attempt to squeeze Pyongyang’s use of seagoing trade to feed its nuclear missile program, several officials told Reuters.
 
While suspect ships have been intercepted before, the emerging strategy would expand the scope of such operations but stop short of imposing a naval blockade on North Korea. Pyongyang has warned it would consider a blockade an act of war.
 
The strategy calls for closer tracking and possible seizure of ships suspected of carrying banned weapons components and other prohibited cargo to or from North Korea, according to the officials, who spoke on condition of anonymity. Depending on the scale of the campaign, the United States could consider beefing up the naval and air power of its Pacific Command, they said. …
 
The effort could target vessels on the high seas or in the territorial waters of countries that choose to cooperate. It was unclear, however, to what extent the campaign might extend beyond Asia.
 
Washington on Friday slapped sanctions on dozens more companies and vessels linked to North Korean shipping trade and urged the United Nations to blacklist a list of entities, a move it said was aimed at shutting down North Korea’s illicit maritime smuggling activities to obtain oil and sell coal. … 

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COMMCOMMENTARY

COMM_a01
12. M. Lester: “EU Renews Sanctions on Belarus”

(Source:
European Sanctions Blog, 23 Feb 2018.)
 
* Author: Maya Lester, Esq., Brick Court Chambers,
maya.lester@brickcourt.co.uk,  +44 20 7379 3550.
The EU has extended its sanctions on Belarus until
28 February 2019, which consist of an arms embargo and targeted asset freezes and travel bans against 4 people. The 4 people are suspected of being involved in the unresolved disappearances of 2 opposition politicians, 1 businessman, and 1 journalist in 1999 and 2000. It has also prolonged a derogation allowing the export of biathlon equipment to Belarus, such as sporting rifles, subject to prior authorization.
 

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COMM_a213.

Gary Stanley’s ECR Tip of the Day

 
* Author: Gary Stanley, Esq., Global Legal Services, PC, (202) 352-3059,
gstanley@glstrade.com.
 
U.S. Munitions List categories are organized by paragraphs and subparagraphs identified alphanumerically. They usually start by enumerating or otherwise describing end-items, followed by major systems and equipment; parts, components, accessories, and attachments; and technical data and defense services directly related to the defense articles of that USML category.

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COMM_a3
14
R.C. Burns: “OFAC Sends “SOS” to Norks: Sanctions On Ships”

(Source:
Export Law Blog, 23 Feb 2018. Reprinted by permission.)
 
* Author: R. Clifton Burns, Esq., Bryan Cave LLP, Wash DC,
Clif.Burns@bryancave.com, 202-508-6067).
 
Today (Friday, 23 February), OFAC 
designated one individual, 27 shipping companies and 28 ships that it asserts have been involved in circumventing sanctions against North Korea, principally by engaging in ship-to-ship transfers where prohibited goods are transferred in mid-ocean to North Korean vessels which then carry those goods to North Korean ports. The picture on the right (available
here), released by Treasury today, shows such a ship-to-ship transfer.
 
The President 
characterized these as the “largest ever” imposed on North Korea, a reference, I suppose, to the number of entities sanctioned rather than the likely actual impact of these sanctions. 
Executive Order 13570, issued in 2011 by the previous administration, forbids all imports from North Korea. As a result, since 2011, North Korean ships, including those designated today and those still undesignated, cannot call in U.S. ports. Thus, it’s not clear what impact designating a bunch of Nork ships will have.
 
Moreover, the designation does not prohibit non-U.S. companies — such as those from Russia, which escaped any designations today — from dealing with these newly designated ships. Of course, if detected, such non-U.S. vessels and shippers might themselves be sanctioned, so there may be some deterrent effect. But it’s hard to say how significant that deterrent effect will be. After all, the 11 non-Nork shipping companies caught up today in OFAC’s new designations certainly knew that they were running that risk when they decided to offload cargo to North Korean vessels in mid-ocean or otherwise try to skirt sanctions on North Korea. Moreover, they did so despite 
UN Security Council Resolution 2375, section 11 of which prohibits ship-to-ship transfers of goods bound for North Korea.  And the 16 North Korean shipping companies singled out in OFAC’s announcement, which could not deal with the United States even before the designation, are unlikely to be affected by their new status as SDNs.
 
So, while I certainly applaud these designations, I don’t think their impact should be oversold.

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MSEX/IM MOVERS & SHAKERS

MS_a218. Monday List of Ex/Im Job Openings; 158 Jobs Posted This Week, Including 17 New Jobs

(Source: Editor)  
 

Published every Monday or first business day of the week. Please, send job openings in the following format to 
jobs@fullcirclecompliance.eu.

 
* COMPANY; LOCATION; POSITION TITLE (WEBLINK); CONTACT INFORMATION; REQUISITION ID
 

#
” New or amended listing this week (
17 New Jobs
)

* Aerojet Rocketdyne; Huntsville, AL, or Camden, AR; 
Senior International Trade and Compliance Analyst
; Requisition ID: 12620

*
AJC Logistics; Atlanta, GA; NVOCC Export Specialist;

* Allports Forwarding Inc.; Portland, OR;
Import Entry Specialist

* Arent Fox LLP; Washington, D.C.; International Trade Associate;

* Arent Fox LLP; Los Angeles, CA;
International Trade Associate;

* BAE Systems; Los Angeles, CA; 
Program Manager, International and Offset; Requisition ID: 33778BR


Boeing; Multiple Locations;
Trade Control Specialist
; Requisition ID: 
1700011280

*
 
Boeing; St Louis, MO; 
Trade Control Specialist
; Requisition ID: 1700011280 

* Boeing; St. Louis, MO; Trade Control Specialist – Mid Career; Requisition ID: 1700022214

* Boeing; Melbourne, Australia;
Trade Control Specialist; Requisition ID: 
1700015249

* BMW North America; Woodcliff Lake, NJ;
Senior Analyst, Trade Compliance; Requisition ID: 170004RD
 * Buehler; Lake Bluff, IL;
Manager, Compliance and Logistics; Requisition ID: 2018-004

Carl Zeiss, Inc.; Thornwood, NY;
Trade Compliance Specialist
; Internal Number: 13309

* Crane ChemPharma & Energy; Long Beach, CA;
Import Export Compliance Specialist;
#
Crown Corporation; New Bremen, Ohio; Trade Compliance Specialist; Requisition ID: 45311

* CSRA; San Diego, CA;
Mid-Level FMS Case Analyst; Requisition ID: RQ 3035

* CSRA; San Diego, CA;
Mid-level Case Analyst for MIDS FMS Program; Requisition ID: RQ6975
 

*
 CSRA; San Diego, CA; 
Senior Case Analyst for MIDS FMS Program
; RQ6763 

* CSRA; San Diego, CA;
Senior FMS Case Analyst; Requisition ID: 3004

* CSRA; San Diego, CA; 
Senior FMS Financial Analyst; Requisition ID: 
RQ3010

* Danaher Science and Technology; United States; Senior Global Trade Compliance ManagerJob ID: COR000942

* Danaher Science and Technology; Brea, CA; Senior Coordinator Regulatory Affairs – Trade ComplianceJob ID: BEC009263 

* Danaher Science and Technology;
Biberach an der Riß, Germany;
European Trade Compliance Specialist
Job ID: KAV001714 

* Danaher Science and Technology; Nationwide, India; Manager, International Regulatory Affairs
Job ID: CEP000339

*
 DynCorp International; Tampa, FL; Foreign Disclosure Officer; Requisition ID: PR1701977

* Eaton; Syracuse, NY;
Global Logistics Manager; Requisition ID: 036620

* Eaton; Shanghai Shi, China;
Global Ethics and Compliance Director, APAC; Requisition ID: 039260

* Elbit Systems of America; Merrimack, NH or Fort Worth, TX; 
Trade Specialist I (Export); Requisition ID 5869
* Elbit Systems of America; Merrimack, NH or Fort Worth, TX;  
Trade Specialist I (Import); Requisition ID 5869

Elbit Systems of America; Fort Worth, TX; 
Trade Specialist II
; Requisition ID 5862
# EMD Serono; Milan, Italy; Trade Compliance Associate Internship;
EMD Serono; Shanghai, China; Trade Compliance Specialist;

EMD Serono; Shanghai, China; Import Export Supervisor;
EMD Serono; St. Louis, MO; Trade Compliance Specialist;

# Emerson; Bloomington, Minnesota; Project Manager, Trade Compliance;

* EoTech Technologies; Ann Arbor, MI;
Trade Compliance Manager; Requisition ID: 092335

* Expeditors; Portland, OR;
US Export Compliance Consultant;

* Expeditors; Sunnyvale, CA;
Customs Compliance Supervisor;


* Expeditors; Krefeld, Germany; 
Sachbearbeiter Import/ Export;
* Expeditors; Bedfont, United Kingdom;
Customs Brokerage Clerk;
* Expeditors; Birmingham, UK;
Customs Brokerage Agent;

* Expeditors; Düsseldorf, Germany;
Sachbearbeiter Luftfracht Import;


* Export Solutions Inc.; Melbourne FL; 
Trade Compliance Specialist;
info@exportsolutionsinc.com

* EY; Belgium; 
Senior Consultant, Global Trade; Requisition ID: BEL000PT

* FD Associates; Tysons Corner, VA; 
Senior Export Compliance Associate;
 Send 
resume to and salary requirements to 
jobs@fdassociates.net 

* FLIR; Billerica, MA;
Global Trade Compliance Analyst,Traffic;
*
 FLIR; Wilsonville, OR; 
Global Trade Compliance Analyst,Traffic
;

*
 FLIR; Elkridge, MD; 
Global Trade Compliance Analyst,Traffic
;

*
FLIR; Arlington, VA;
Senior Analyst, Licensing
* FLIR; Billerica, MA;
Senior Analyst, Licensing
;

# Full Circle Compliance; Bruchem, Netherlands; Legal Analyst, Manager
* Garmin; Olathe, Kansas; International Trade Compliance Specialist; Requisition ID: 1800006
*
 
General Atomics; San Diego, CA; Sr. Director of Import/Export Compliance; Job ID: 13892BR

* General Atomics; San Diego, CA;
Internship, Import/Export, Summer 2018; Requisition ID: 15729BR
*
 General Atomics; San Diego, CA; 
Internship, Import/Export, Summer 2018
; Requisition ID: 15731BR 

* Georgia-Pacific; Atlanta, GA; 
Sr. Analyst, International Trade
; Requisition ID: 052010

* GHY International; Manitoba, Canada; Trade Analyst;
* GHY International; Pembina, ND (or remote); Ocean & Air Import Coordinator
* Henderson Group Unlimited; Inc; Washington, DC; 
Process Improvement Mgr

* Henderson Group Unlimited; Inc; Washington, DC; 
Defense Control Analyst

* Henderson Group Unlimited, Inc; Washington, DC; 
Compliance Analyst;

* Honda of America Manufacturing; Marysvile, OH;
Import Specialist

* Huntington Ingalls Industries – TSD (Camber Corporation); Fairfax, VA; Export Control Analyst; Job ID: #16405

* Infineon Technologies; Milpitas, CA;
Senior Export Compliance Specialist; Requisition ID: 21326

* Infineon Technologies; Munich, Germany;
Experte Export Control (w/m); Requisition ID: 22825

* InteliTrac Global Solutions; Herndon, VA; 
ITAR Compliance Official / Deputy Facility Security Officer;

* InteliTrac Global Solutions; Herndon, VA;
ITAR Compliance Official;

# International Trade Compliance Group; Pompano Beach, FL; Trade Compliance Specialist
# JABIL; St. Petersburg, FL;
Trade Compliance Manager; Requisition ID: 207029
# JABIL; St. Petersburg, FL;
Trade Compliance Specialist; Requisition ID: 206581
# JABIL; Guadalajara, Mexico;
Classification & Export Licensing Analyst; Requisition ID: 207594
* Johnson and Johnson; Skillman, NJ; 
Senior Trade Compliance Customs Analyst, CLS North America
; Requisition ID: 4380171108
* Koch Industries; Tulsa, OK;
Global Trade Compliance & Logistics Director; Requisition ID: 052013
* Koch Industries; Tulsa, OK;
Import/Export Compliance Specialist; Job ID: 052017
* Koch Industries – Invista; Wilmington, DE;
Compliance Program Manager / Apparel and Advanced Textiles
; Job ID: 051793
* Koch Industries; Houston, TX;
Business Compliance Leader; Job ID: 052094

# KPMG U.S.; San Francisco, CA; Associate, Trade & Customs;
* Lockheed Martin; Sunnyvale, CA;
Licensing Analyst (Early Career); Requisition ID: 415037BR_1

*
 Lockheed Martin; Littleton, CO; 
Licensing Analyst (Early Career)
; Requisition ID: 415037BR

* Lockheed Martin; Littleton, CO;
International Licensing Analyst; Requisition ID: 412863BR

* Lockheed Martin; Manassas, VA;
International Licensing Analyst; Requisition ID: 399617BR
* Lockheed Martin; Stratford, CT;
International Trade Compliance Technology Specialist; Requisition ID: 415922BR
* Lockheed Martin; Ft Worth, TX;
International Trade Compliance Analyst; Requisition ID: 416747BR

* Lockheed Martin; Ft Worth, TX; 
Senior Regulatory Compliance Analyst; Requisition ID: 
406664BR

* Lockheed Martin; Arlington, VA; Export Licensing Staff
Requisition ID 419903BR
* Lockheed Martin; Arlington, VA; Export Licensing Staff
Requisition ID 418603BR
* Lockheed Martin; Arlington, VA; International Trade Compliance Staff; Requisition ID 418761BR

* L-3 LINK Division; Tulsa, OK; 
Contracts Administrator 1; Requisition ID: 091686
* L-3 ALST; Orlando, FL;
Contracts Manager / Empowered Official; Requisition ID: 093069
* L-3 Warrior Sensor Systems; Middle East;
International Business Development Manager – Middle East Region; Requisition ID: 093343
* Maersk/DAMCO; Agent de transit IMPORT – EXPORT; Job Ref.: DC-164022
* Medtronic; Heerlen, The Netherlands;
Trade Compliance Analyst; Requisition ID: 16000DYY
* Medtronic; Wash DC;
Global Trade Lawyer;
stacy.m.johnson@medtronic.com; Requisition ID: 170002ON

* Moog Inc.; Blacksburg, VA; 
Trade Compliance Specialist
; Requisition ID: 174447

* Nortek Security & Control; Carlsbad, CA;
Global Logistics & Trade Compliance Analyst; Requisition ID: GLOBA01150
* Northrop Grumman; Herndon, VA;
Manager, International Trade Compliance 2
Requisition ID
:
 
17022803
* Northrup Grumman; Rolling Meadows, IL; International Trade Compliance Analyst 3; Requisition ID: 17028134

* Northrop Grumman; Herndon, VA;
Manager, International Trade Compliance 2; Requisition ID: 17022805
*
Northrop Grumman; Huntsville, AL;
International Trade Compliance 3
; Requisition ID: 17026172

* OneWeb; Arlington, VA;
Export Compliance Specialist;

* Orbital ATK; Fort Worth, TX;
Customs Compliance Analyst; Requisition ID: 
JAY20182301-43349
* Oracle; United States;
Senior Customs Compliance Specialist; Job ID: 170018FJ

* Oracle; United States;
Customs Compliance Specialist; Job ID: 17001CBG

* Oracle; Bejing, China;
Senior Customs Compliance Specialist – APAC; Job ID: 17001CBI

* Oracle; Singapore;
Trade Compliance Specialist; Job ID: 17001ESC

* Raytheon SAS; McKinney, TX;
Senior Regulatory Compliance Analyst; Requisition ID: 
107180BR
* Raytheon IIS; Orlando, FL;
 
Global Trade Licensing Analyst II; Requisition ID: 104036BR
* Raytheon IIS; Dulles, VA;
Global Trade Licensing Analyst II
Requisition ID: 104036BR

* Rolls-Royce; Indianapolis, IN;
 
Export Control Specialist; Req ID:
 

JR6025484 

* SABIC; Houston TX; 
Senior Analyst, Trade Compliance
;
Danielle.Cannata@sabic.com
; Requisition ID: 8411BR

* SAFRAN Group; United Kingdom;
Trade Compliance Specialist;

# Sig Sauer; Newington, New Hampshire; Trade Compliance Manager
* The Spaceship Company; Mojave, CA; Export Compliance Officer;
* Spirent; San Jose, CA;
Global Trade Compliance Specialist; Requisition ID: 4088

# TE Connectivity; Middletown, PA; Manager II, Global Trade Compliance; Requisition ID: 17361
* Teledyne Geophysical; Houston, TX; Trade Compliance Specialist; Requisition ID: 2017-5459
* Teledyne Microwave Solutions; Mountain View, CA; Trade Compliance Administrator II; Requisition ID: 2018-6089
* Teledyne Imaging; Waterloo, Ontario, Canada;
Director of International Trade Compliance; Requisition ID: TC0617

* Teledyne Imaging; Chestnut Ridge, NY; 
Director of International Trade Compliance; Requisition ID: 2017-5558
*
 Teledyne Imaging; Billerica, MA; Director of International Trade Compliance; Requisition ID: 2017-5558 

* Teledyne Imaging; Tarrytown, NY; 
Director of International Trade Compliance; Requisition ID: 2017-5558
* Teledyne Imaging; Kiln, MS; 
Director of International Trade Compliance; Requisition ID: 2017-5558
*
 Teledyne Imaging; Fredricton, NB; 
Director of International Trade Compliance
; Requisition ID: 2017-5558 

* Textron; Hunt Valley, MD;
2018 Intern – Export Import Analyst;

* Textron; Hunt Valley, MD;
Manager – Export Compliance;

* Textron; Hunt Valley, MD;
Senior Manager – Export Compliance;

*
Thermo Fisher Scientific; Waltham, MA;
Director, Global Trade Compliance
;

* Thermo Fisher Scientific; Yokohama, Japan; 
Compliance Specialist
; Job ID: 53213BR

* Thermo Fisher Scientific; Shanghai, China; 
Trade Compliance Specialist
; Job ID: 57953BR 

* Thermo Fisher Scientific; Franklin, MA; 
Trade Compliance Specialist; Job ID: 
61435BR

* Thermo Fisher Scientific; Carlsbad, CA; 
Compliance Specialist II; Job ID: 
60951BR

* Thermo Fisher Scientific; Suwanee, GA;
Export Compliance Specialist III; Job ID:
60224BR

* Thermo Fisher Scientific; Suwanee, GA;
Senior Director and GM, Global Export and Developing Regions; Job ID: 
56334BR

* TLR; San Fransisco, CA;
Import CSR; Requisition ID: 1040

*
Tradewin; Portland, OR;
U.S. Export Compliance Consultant

* Trek; Waterloo, WI; Global Trade & Logistics Specialist;
* Ultra Electronics; Loudwater, United Kingdom;
International Trade Manager;

* United Technologies Corporation, UTC Aerospace Systems; Birmingham, UK; 
International Trade Compliance Manager;
Requisition ID: 39257
* United Technologies Corporation, UTC Aerospace Systems; Chula Vista, CA; 
Supply Chain International Trade and Compliance Focal
; Requisition ID: 53794BR
* United Technologies Corporation, UTC Aerospace Systems; Chula Vista, CA; 
Sr. Associate, ITC Digital Solutions
; Requisition ID: 59662BR
* United Technologies Corporation, UTC Aerospace Systems; Chula Vista, CA

Supply Chain Specialist- ITC/Regulatory
; Requisition ID: 53794BR
* United Technologies Corporation, UTC Aerospace Systems; Hood River, OR;
International Trade Compliance Specialist
; Requisition ID: 60584BR
* United Technologies Corporation, UTC Aerospace Systems; Phoenix, AZ;

* 
University of Colorado, LASP; Boulder CO; 
Export Compliance Administrator

hrads@lasp.colorado.edu
; Requisition ID: 12298
# 
Varian Medical Systems; Belgium, Switzerland, Netherlands, UK; Senior Manager Trade Compliance; Requisition ID: 12301BR; Contact 
Gavin Tickner at 
Gavin.Tickner@varian.com
 
# 
Varian Medical Systems; Paolo Alto, CA; Senior Trade Compliance Analyst; Requisition ID: 12735BR; Contact 
Uyen Tran at
Uyen.Tran@varian.com
# Varian Medical Systems; Beijing, China;
Trade Compliance Analyst; Requisition ID: 
12297BR; Contact 
Susan Lin at
 WeiZhen.Lin@varian.com
* Vigilant; Negotiable Location, USA;
Global Trade Compliance Analyst;

* Virgin Galactic; Mojave, CA; Export Compliance Officer; Requisition ID: 2018-3440
* Virgin Galactic; Las Cruces, NM; Export Compliance Officer; Requisition ID: 2018-3558
* Virgin Galactic; Las Cruces, NM; Director of Trade Compliance; Requisition ID: 2018-3349
* Virgin Galactic; Washington, D.C.; Director of Trade Compliance; Requisition ID: 2018-3349 

* Xilinx; San Jose, CA;
Global Trade Compliance Manager; Requisition ID: 154441

*
 Xilinx; San Jose, CA; Global Trade Compliance Program Manager; Requisition ID: 154442 

*
Xylem, Inc.; Any Location, United States;
Manager, Global Ethics & Compliance

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

ENEDITOR’S NOTES

 
*
Victor Hugo (Victor Marie Hugo; 26 Feb 1802 – 22 May 1885; was a French poet, novelist, and dramatist of the Romantic movement. Hugo is considered to be one of the greatest and best-known French writers. Outside of France, his most famous works are the novels
Les Misérables and
The Hunchback of Notre-Dame.)
  – “He, who every morning plans the transactions of the day, and follows that plan, carries a thread that will guide him through a labyrinth of the most busy life.”
 
*
Christopher Marlowe (26 Feb 1564 – 30 May 1593; was an English playwright, poet and translator of the Elizabethan era. Marlowe was the foremost Elizabethan tragedian of his day.  He greatly influenced William Shakespeare, who was born in the same year as Marlowe and who rose to become the pre-eminent Elizabethan playwright after Marlowe’s mysterious early death. Marlowe’s plays are known for the use of blank verse and their overreaching protagonists.)
  – “Come live with me and be my love, And we will all the pleasures prove, That valleys, groves, hills, and fields, Woods, or steepy mountain yields.”
 
Monday is Punday:
 
* I submitted 10 puns to a joke-writing competition to see if any of them made the finals.  Sadly, no pun in ten did.
 
*  I can’t take my dog to the park because the ducks keep trying to bite him.  I guess that’s what I get for buying a pure bread dog.
 
* Q: What happens to a frog’s car when it breaks down?
   A:  It gets toad away.

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

EN_a317
. 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.
 
*
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: 22 Feb 2018: 83 FR 7608-7610: Technical Amendment to List of User Fee Airports: Name Changes of Several Airports and the Addition of Five Airports
 
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: 
16 Feb 2018:
83 FR 6949-6956
: Russian Sanctions: Addition of Certain Entities to the Entity List [Addition of 21 Entities to Entity List.]

  
*
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, 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 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.

 
INTERNATIONAL TRAFFIC IN ARMS REGULATIONS (ITAR): 22 C.F.R. Ch. I, Subch. M, Pts. 120-130.

  – Last Amendment: 14 Feb 2018: 83 FR 6457-6458: Amendment to the International Traffic in Arms Regulations: Addition of South Sudan [Amends ITAR Part 126.] 

  – The only available fully updated copy (latest edition: 14 Feb 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_a0318
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

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

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, 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.

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