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18-0302 Friday “Daily Bugle”

18-0302 Friday “Daily Bugle”

Friday, 2 March 2018

TOPThe 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.

[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 Posts Notice on Incomplete Drawback Claims filed in ACS prior to 24 Feb
  4. State/DDTC: (No new postings.)
  5. UK DIT/ECO Releases Export Control Training Bulletin, Mar-Dec 2018
  1. Reuters: “‘Trade Wars Are Good,’ Trump Says, Defying Global Concern over Tariffs”
  2. RFE/RL: “Son of Ex-Kyrgyz Envoy Under House Arrest In U.S. For Arms Smuggling”
  3. ST&R Trade Report: “Dates and Deadlines: Importer Self-Assessment, Apparel Classification, Origin Ruling, Digital Trade”
  4. ST&R Trade Report: “Enforcement, National Security Among Focuses of Trade Policy Agenda”
  1. The Export Compliance Journal: “Seven Best Practices to Prevent Complacency from Creeping into Your Day-To-Day Screening Routine”
  2. M. Lester: “UK Passes North Korea Export Controls Order” 
  3. T.G. Ficaretta: “Offers in Compromise – A Practical Method for Resolving Firearms and Ammunition Excise Tax Liability” 
  1. List of Approaching Events – 41 New Events Listed 
  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 (27 Feb 2018), ITAR (14 Feb 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; Industry and Security Bureau; NOTICES; Decisions and Orders: Trilogy International Associates, Inc.; William Michael Johnson [Publication Date: 5 March 2018.]
 
* State; NOTICES; Determinations Regarding Use of Chemical Weapons by North Korea under the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991 [Publication Date: 5 March 2018.]
 
* Treasury; Foreign Assets Control Office; RULES; North Korea Sanctions Regulations [Publication Date: 5 March 2018.]

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OGS_aa23. DHS/CBP Posts Notice on Incomplete Drawback Claims filed in ACS prior to 24 Feb
(Source: CSMS #18-000190, 2 Mar 2018.)
 
If you filed an ABI drawback claim in ACS prior to the Deployment G, Release 4 cutover on 2/24/18 and the paperwork for claim completeness was not provided to the Drawback Port until after 2/24/18, you must resubmit the drawback claim in ACE with a new claim number. 

If any of the underlying imports will now exceed the timeframe limitations, you must remove them from the drawback claim to get the claim accepted into the system. After it is accepted, please work with the Drawback specialists to backdate the claim date and put the claim into trade control status. When that is done you can add the underlying imports that were previously exceeding the timeframe limitations back onto the drawback claim and resubmit. You must ensure that the transmission date in the A-Record is the back-dated date to preserve your claim filing date. 

Please send any questions to OTDrawback@cbp.dhs.gov.

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(Source:
UK DIT/ECO, 1 Mar 2018.)
 
This bulletin contains details of courses, seminars and workshops from the Export Control Joint Unit to increase your understanding of the UK’s strategic export controls.
 
Events are aimed at exporting and trading individuals or companies of all sizes, as well as government organizations and cater for a wide range of knowledge levels.
 
This issue includes all details, charges and an application form. In addition, it covers new courses from March to December 2018.
 
[Editor’s Note: the UK DIT/ECO training events are also included in the “List of Approaching Events”, published in every Friday edition of the Daily Bugle.]

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NWSNEWS

(Source:
Reuters, 2 Mar 2018.) [Excerpts.]
 
U.S. President Donald Trump struck a defiant tone on Friday, saying trade wars were good and easy to win, after his plan to put tariffs on imports of steel and aluminum triggered global criticism and a slide in stock markets.
 
The European Union raised the possibility of taking countermeasures, France said the duties would be unacceptable and China urged Trump to show restraint. Canada, the biggest supplier of steel and aluminum to the United States, said it would retaliate if hit by U.S. tariffs. …
 
In a later Facebook post, Trump said his aim was to protect U.S. jobs.
 
  “We must protect our country and our workers. Our steel industry is in bad shape. IF YOU DON’T HAVE STEEL, YOU DON’T HAVE A COUNTRY!” he wrote.
 
Many economists say that instead of increasing employment, price increases for consumers of steel and aluminum such as the auto and oil industries will destroy more U.S. jobs than they create.
 
RETALIATION LIKELY
 
The European Commission, the EU’s executive, called the U.S. tariffs a blatant intervention that amounted to protectionism and promised to act “firmly” in response.
 
The EU, which sees itself as a global counterweight to a protectionist-leaning Trump, made no mention of retaliation but spoke of countermeasures that conform with World Trade Organization (WTO) rules.
 
“We don’t see this as a situation where, like in a zero-sum game, one party loses because another party wins. Trade is beneficial for everyone. It needs to take place on the basis of rules and these rules are in place,” a European Commission spokesman said.
 
Safeguard measures, last deployed by Europe in 2002 after then-U.S. President George W. Bush imposed steel import duties, would be designed to guard against steel and aluminum being diverted to Europe from elsewhere if U.S. tariffs come in.

But to conform with WTO rules such measures would have to apply to imports from all countries and could also hit producers including China, India, Russia, South Korea and Turkey.

Officials have not said whether the tariffs would include imports from Canada and Mexico, Washington’s partners in the North American Free Trade Agreement (NAFTA), which is being reworked.
 
U.S. Commerce Secretary Wilbur Ross said on Friday that Trump’s tariffs announcement “seemed” to apply to all countries.
 
  “That’s what the president seemed to announce yesterday,” Ross told CNBC.
 
Canadian Foreign Minister Chrystia Freeland called any trade restrictions”absolutely unacceptable” and said Canada would”take responsive measures to defend its trade interests and workers” if needed.
 
Mining company Rio Tinto, the largest producer of aluminum in Canada, Alcoa Corp and the United Steelworkers union, which represents workers in the United States and Canada, all said Canada should be spared tariffs.
 
PROTECTIONISM
 
Steel has become an important focus for Trump, who said he would restore the U.S. industry and punish what he sees as unfair trade practices, particularly by China.
 
Republican U.S. Senator Ben Sasse, who has been critical of Trump, said there were only losers in trade wars.
 
  “Kooky 18th century protectionism will jack up prices on American families – and will prompt retaliation,” he said in a tweet.”Make no mistake, if the president goes through with this it will kill American jobs.”
 
The United States is the world’s biggest steel importer, buying 35.6 million tonnes in 2017. Canada is the leading supplier, accounting for 16.7 percent, followed by Brazil at 13.2 percent and South Korea at 9.7 percent.
 
Although China accounts for only 2 percent of U.S. steel imports, its massive industry expansion has helped produce a global steel glut that has driven down prices.
 
  “China urges the United States to show restraint in using protective trade measures, respect multilateral trade rules, and make a positive contribution to international trade order,” Chinese Foreign Ministry spokeswoman Hua Chunying said.
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A U.S. court has ordered the son of a former Kyrgyz ambassador to Washington to be placed under house arrest on charges including firearms trafficking and smuggling, Kyrgyzstan’s Foreign Ministry says.
 
In a statement on March 2, the ministry said that 28-year-old Kyrgyz citizen Tengiz Sydykov was placed under house arrest at a court hearing the previous day.
 
Zamira Sydykova, a well-known journalist who was Kyrgyzstan’s ambassador to Washington from 2005-10, said on March 1 that Sydykov is her son and that he lives in the Washington metropolitan area.

U.S. federal prosecutors say that Sydykov and another suspect, Eldar Rezvanov, were arrested on February 27. Describing the men as citizens of Kyrgyzstan residing in Alexandria, Virginia, just outside Washington D.C., the U.S. Attorney’s Office for the Eastern District of Virginia alleged that they bought more than 100 disassembled firearms and attempted to ship them to Russia’s Chechnya region without a license.

 
Sydykov and Rezvanov, 27, were charged with violating the Arms Export Control Act, which regulates foreign military sales and commercial sales of defense articles, conspiracy to smuggle goods from the United States, bank fraud, and money laundering, it said. If convicted, the two face up to 20 years in prison.
 
Sydykova contends that her son has been wrongly accused as the result of a “misunderstanding.”
 
She said that police detained Rezvanov, whom she described as her son’s former roommate, after searching his home.

  “When my son came to the police station to find out why his former roommate was arrested, he was detained as well. I hope that this misunderstanding will be cleared up soon,” Sydykova said.
 
Sydykova said that her son works for an IT company.


She also said that Rezvanov is a Kazakh citizen, contradicting the U.S. Attorney’s Office.

 
A court in Alexandria, Virginia, told RFE/RL on March 1 that Rezvanov remained in a detention facility. 
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Following are highlights of regulatory effective dates and deadlines and federal agency meetings coming up in the next week.
 
  – 6 Mar: ITC hearing on foreign restrictions on digital trade
  – 7 Mar: deadline for requests for judicial review of CBP origin rulings on Ethernet switch products and pharmaceutical products
  – 8 Mar: USTR hearing on intellectual property protection and enforcement
  – 9 Mar: deadline for comments on CBP information collections on duty allowance, penalties
  – 9 Mar: deadline for comments on request for permit for new southwest border crossing
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The Trump administration’s second annual trade policy agenda again takes a tough line, emphasizing “aggressive” enforcement of U.S. trade laws, the role of trade in supporting national security, and limiting the role of the World Trade Organization.

The document is critical of previous administrations for continuing to “passively adhere to outdated and underperforming trade deals and allow[ing] international bureaucracies to undermine U.S. interests,” leaving U.S. workers and businesses “at a disadvantage in global markets as unfair trading practices flourish[ed].” By contrast, the document asserts, Trump has “launched a new era in American trade policy,” one in which the U.S. unabashedly uses its economic power to open foreign markets and obtain “fairer treatment for American workers.” This policy rests on the following principles.
 
Supporting National Security
. The report warns against trade policies that weaken the economy and jeopardize national sovereignty, a reference to World Trade Organization dispute settlement rulings that the administration believes have created “new obligations to which the United States and its elected officials never agreed.” The U.S. will protect national interests against “hostile policies from China, Russia, or any other countries,” the report states, and will “respond to unfair economic competitors by using all available tools to discourage any country from undermining true fair market competition.” On the other hand, the U.S. will be a “true friend and ally” to countries that are “committed to market-based outcomes and willing to provide the United States with reciprocal opportunities in their home markets.”
 
Strengthening the Economy
. This section focuses on the tax reform bill Trump signed into law in December 2017, which reduced the top statutory corporate tax rate from 35 percent to 21 percent and switched the U.S. from a worldwide tax system to a territorial tax system. These changes align the U.S. with its major trading partners, the report states, and allow U.S. businesses and workers to compete on a level playing field.
 
Trade Agreements
. The report emphasizes ongoing efforts to renegotiate NAFTA to “get a better deal for American workers and to improve the U.S. trade balance” and to make improvements to the U.S.-Korea free trade agreement that will “improve U.S. export opportunities and facilitate more balanced, two-way trade,” particularly for motor vehicles and parts.
 
The report mentions plans to negotiate new trade agreements but provides few details, referencing only “ongoing efforts” to pursue a possible post-Brexit deal with the United Kingdom and to prepare for “potential bilateral negotiations in the Indo-Pacific and African regions.” The report also blames the Senate’s delay in confirming several deputy U.S. trade representatives at least in part for the lack of any new negotiations to date. In preparation for future negotiations Trump plans to seek an extension of trade promotion authority through 2021, which would allow any trade agreements negotiated between now and then to receive expedited consideration by Congress.
 
Enforcement
. The report highlights the administration’s use of a variety of trade enforcement tools, including a section 301 investigation of Chinese policies related to technology transfer, intellectual property, and innovation (in which Trump is reportedly considering higher tariffs on a number of Chinese goods), the section 201 safeguards recently imposed on solar panels and washing machines, and the section 232 national security investigations of steel and aluminum imports (in which Trump reportedly announced March 1 plans to levy additional tariffs of 25 percent and 10 percent, respectively, on imports from all countries). The report also touts a 59 percent increase in the number of new antidumping and countervailing duty investigations, including the first such probe self-initiated by the Department of Commerce in more than 25 years.
 
WTO Reform
. The report asserts that the WTO is “an important institution” but is critical of its dispute settlement function, which “has appropriated to itself powers that the WTO members never intended to give it” and is thus “undermining our country’s ability to act in its national interest.” Although the report states that the U.S. is willing to work with other WTO members to address these concerns, press reports indicate that the administration has done little to detail its objections or propose potential solutions.
 
The report states that the WTO’s “highest value should be as a forum for trade negotiations” but criticizes the organization’s “inability to reach agreements needed in a modern global economy,” an apparent reference to the failure of the Doha Round. The report suggest that rather than pursuing broad initiatives such as that one the administration will focus on “building coalitions of like-minded members to use the WTO committee system as vital tool to achieve market-oriented results.”
 
View Document(s):
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COMMCOMMENTARY

COMM_a1
10. The Export Compliance Journal: “Seven Best Practices to Prevent Complacency from Creeping into Your Day-To-Day Screening Routine”
(Source: The Export Compliance Journal, 26 Feb 2018.)
 
You could be missing out on better accuracy and efficiency. For best results, don’t just screen-screen SMARTLY.
 
(1) Search refinement settings are your friends.
 
If you’re using a restricted party screening software tool, you can reduce false positives (who has the time to wade through hundreds of unwanted names?), and also ensure you’re not missing alerts due to typos or names with multiple possible spellings.
 
You can also maximize screening efficiency by understanding what various settings do and determining when you should use them and when it would be more efficient to turn them off. Among your options: grammatical variations on a word (e.g., with “s” or “ed” endings), synonyms or nicknames, or even matches that simply sound like your search term.
 
(2) Mind the three W’s of screening:
 
  (a) Who to screen: International customers may be obvious, but what about domestic customers that re-export internationally? What about your employees? Take a good look at all the parties with whom you connect, and make sure nobody is overlooked.
  (b) When to screen: Initial screening should be done before signing a contract with a new customer or manufacturer with rescreening happening at regular intervals thereafter.
  (c)What to enter in the search fields: Be strategic and select parameters in all possible fields-such as City, State and Company-to increase the quality of matches returned.
 
(3) Audit recording is essential.
 
You can screen until the cows come home, but in an audit, if there’s no record of your restricted party screening activity it’s as though it never happened. Details about who you screened, when you screened and the result of that screening are integral not only to passing your audit but to avoiding internal oversights and miscommunication. Conscientious day-to-day screening keeps your transactions legal, but don’t neglect your responsibility to prove your due diligence. …
 
(4) Rescreen daily.
 
Once you’ve screened and received the all-clear on your party, it’s tempting to high-five your colleagues and add to your “done” pile. But no denied party screening is ever really “done” so long as you’re still doing business with the individual or company in question. Government watch lists change often-even a longtime employee or customer can suddenly appear as a denied party-and regular rescreening is the only way to know your transactions are compliant each and every time.
 
The most effective way to ensure regular rescreening happens is by automating the process altogether, either by integrating screening into your business systems, or subscribing to daily automated rescreening service -or even both.
 
(5) Timeliness is everything.
 
You need access to the most current, up-to-date sanctioned and denied party lists or your screening results simply can’t be trusted. Receiving updates as they are published is your best bet.
 
(6) List selection matters.
 
You may think screening against every list available is wise, but by doing so you’re actually inviting invalid matches. Pare down the number of lists you use by doing some self-examination of your industry, where your customers are located, and the products you export. If, for example, your company does not deal with government contracts of any kind, screening against the General Services Administration (GSA) List is unnecessary.
 
(7) Your escalation process.
 
Smart screeners have an incident management plan in place for when denied party screening yields a match. They ensure decision-makers receive all the details required to investigate and clear transactions with minimal delay (postponing lawful shipments won’t endear you to impatient customers) or, if there’s a true threat of violation, immediately stopping the transaction.
 
Many companies use email alerts as a reliable communication channel to keep the right people in-the-know. Thoroughly detailed notes regarding your incident response activities are a must so that facts are clear and decisions are defensible in case of an audit.
 
There you have it-a solid compliance program demands smart screening practices, like the ones detailed above. …
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COMM_a2
11. M. Lester: “UK Passes North Korea Export Controls Order”
(Source: European Sanctions Blog, 2 Mar 2018.)
 
* Author: Maya Lester, Esq., Brick Court Chambers, maya.lester@brickcourt.co.uk, +44 20 7379 3550.
 
The UK has passed the 
Export Control (North Korea Sanctions) Order 2018
, SI 2018/200, which makes provision for the EU trade restrictions against North Korea, as contained in 
Council Regulation (EU) 2017/1509
 (as amended). The Order will come into force on 14 March 2018.
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COMM_a3
12. T.G. Ficaretta: “Offers in Compromise – A Practical Method for Resolving Firearms and Ammunition Excise Tax Liability”

(Source:  Author, 2 Mar 2018)
 
*
Author:  Teresa G. Ficaretta, Esq., teresa@ficarettalegal.com, 301-353-3558; Ficaretta Legal Services, LLC.
 
Manufacturers and importers of firearms and ammunition incur liability for excise tax on their sale and use of such products.  The tax, imposed by 26 U.S.C. § 4181, is 10 percent of the sale price for pistols and revolvers and 11 percent of the sale price for all other firearms, shells and cartridges.  Tax returns must be filed quarterly with the Alcohol and Tobacco Tax & Trade Bureau (“TTB”), and tax must be paid in full with the return.  Taxpayers who fail to timely file returns and pay tax may be assessed the full amount of any underpayment plus penalties and interest.  
 
Firearms and ammunition excise tax calculation and payment rules are complex.  There are provisions in the law and regulations for exemptions from tax, charges that must be included in the taxable sale price, and charges that may be excluded from the sale price.  There are also provisions for tax-free sales that require taxpayers to jump through a number of hoops to qualify.  Sales of firearms not made at the wholesale level and sales to a related selling company require calculation of a constructive sale price.  Also adding to the complexity is the fact that the definition of “firearm” for purposes of excise tax differs significantly from the definition of “firearm” for purposes of the Gun Control Act.  All of these issues may result in errors in tax calculation and underpayments of tax. 
 
What happens when a TTB tax audit results in an underpayment determination?  Field investigators will report their findings to TTB’s National Revenue Center (“NRC”).  The NRC will then enter an assessment for the unpaid tax, including penalties and interest.  Taxpayers are notified of the underpayment through a written communication titled Notice and Demand of tax.  The Notice and Demand will specifically identify the basis for the underpayment of tax, the amount of tax due, and the amount of penalties and interest.  The document will also demand payment from the taxpayer. 
 
TTB has broad authority to collect unpaid excise tax liability.  The agency may impose liens on property of taxpayers, levy on bank accounts and wages, and seize property to satisfy unpaid tax liability.  Tax assessments must be reported to creditors and may result in an inability to obtain capital for raw materials and business expansion.  It is essential that taxpayers act expeditiously to resolve excise tax liability to avoid negative impacts on your business.  
 
The good news is that TTB frequently enters into agreements with taxpayers called Offers in Compromise (OIC).  OICs give TTB the authority to accept less than the total amount of the taxes, penalties, and interest assessed.   The law and regulations give TTB the authority to accept an offer in compromise when there is (1) doubt as to liability or (2) doubt as to collectability.  Doubt as to liability exists where there is uncertainty as to the fact or amount of tax liability.  Litigation risk is a frequent basis for TTB concluding there is uncertainty as to the fact or amount of tax liability.  Doubt as to collectability exists when financial information indicates payment of the full amount is likely to cause the taxpayer significant financial hardship, which may include bankruptcy. 
 
OICs may be submitted to TTB offering a lump sum payment or a series of periodic or installment payments.  Installment payments made over a period of years will alleviate the hardship on taxpayers and allow them to continue in business while satisfying their tax liability.
 
The bottom line is that an unexpected assessment for firearms and ammunition excise tax is not the death knell for a business.  OICs provide a legal basis for negotiating with TTB to resolve the tax liability in an equitable manner.  TTB personnel are motivated to collect as much of the tax as possible without driving businesses into bankruptcy.  It is in the best interest of the government for taxpayers to continue in business, so they contribute to the economy and pay more taxes.  OICs are a powerful tool to bring about that result.

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TEEX/IM TRAINING EVENTS & CONFERENCES

TE_a3
13.
List of Approaching Events – 41 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 or updated listing this week  

 
Continuously Available Training:
 
* E-Seminars: “US Export Controls” / “Defense Trade Controls“; Export Compliance Training Institute; danielle@learnexportcompliance.com 

# Webinar: ”
Company-Wide US Export Controls Awareness Program“; Export Compliance Training Institute;
danielle@learnexportcompliance.com 

* E-Seminars: “ITAR/EAR Awareness“; Export Compliance Solutions;
spalmer@exportcompliancesolutions.com
* On-Demand Webinar; “Is Your Organization Ready for the Challenges of Global Trade?“; Amber Road 
*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

* Online: ”
Increase Your International Sales – Webinar Archive;” U.S. Commercial Service

* Web Form: “Compliance Snapshot Assessment“; Commonwealth Trading Partners (CTP) 
 
Training by Date:
 

* Mar 5-7: Sugar Land, TX; “2018 Winter Basics Conference“; Society for International Affairs (SIA)

* Mar 6: Tysons Corner, VA; ”
KPMG LLP’s International Trade, Export Compliance, and Customs Update“; 
contact
Amie Ahanchian at aahanchian@kpmg.com or 202-533-3247

Mar 6: Webinar; ”
Legal Aspects of Doing Business in Canada“; U.S. Commercial Service

* Mar 7: Waltham, MA; ”
Important Changes in Export Control Laws in the Trump Era“; National Contract Management Association

* 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: Free Webinar: “AES Response Messages with a Focus on Fatal Errors“; U.S. Census Bureau; Dial-In: 1-(888)-989-6511; Passcode: 4834428
* Mar 8: Webinar; ”
Europe’s GDPR and EU – U.S. Privacy Shield For U.S. Education Sector“; U.S. Commercial Service

* 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

* Mar 12-14: Las Vegas, NV; ”
2018 General Audit Management Conference;” Institute of Internal Auditors
* Mar 13: Hook, UK; ”
General Counsel Connect“; C5 Group
* Mar 13: Webinar; ”
Canada’s Non-Resident Importer Program“; U.S. Commercial Service

* Mar 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: Las Vegas, NV; ”
Women in Internal Audit Leadership“; Institute of Internal Auditors

* Mar 14-15: Austin, TX; “Establishing an ITAR/EAR Export Compliance Program“; Export Compliance Solutions; spalmer@exportcompliancesolutions.com; 866-238-4018

# Mar 14: Birmingham, UK; ”
Intermediate Seminar“; 
UK Department for International Trade

* 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: Geneva, Switzerland;Fraud, Asset Tracking, & Recovery;” C5 Group
* Mar 15-16: McLean, VA; “ITAR Fundamentals“; FD Associates 

Mar 19: Tysons Corner, VA; “
Import 5-Day Boot Camp
“; Global Trade Academy

* Mar 20: London, UK; “Board Engagement for Ethics and Compliance Buy-In“; NAVEX Global
* Mar 20: Webinar; ”
Sending Temporary Workers to Canada“; U.S. Commercial Service
* Mar 20: Webinar; ”
Tax Avoidance in the U.S. – Lessons for Canada“; The Conference Board of Canada

* 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 20-21: San Diego, CA; “ITAR/EAR Beyond the Basics Establishing A Rock Solid Export Compliance Program“; Export Compliance Solutions, spalmer@exportcompliancesolutions.com; 866-238-4018

* Mar 20-21: Nashville, TN;
 “Complying with US Export Controls“; Bureau of Industry and Security
# Mar 21: Webinar; “Regulatory Rollback Under President Trump“; Arent Fox
* Mar 21-22: London, UK; “Women in Compliance Conference“; C5 Group 
* Mar 22: Nashville, TN; “How to Build an Export Compliance Program“; Bureau of Industry and Security

* Mar 22: Free Webinar; “Creating an Effective Export Compliance Program and Actions to Take if an Export Violation Occurs“; U.S. Census Bureau; Dial-In: 1-(800)-369-1749; Passcode: 8836707

* Mar 23; Nashville, TN; “How to Build an Export Compliance Program“; Bureau of Industry and Security
* Mar 25-28: Frankfurt, Germany; “6th Annual European Compliance & Ethics Institute“; Society of Corporate Compliance and Ethics
* Mar 26: East Rutherford, NJ; “Advanced Classification of Plastics and Rubber“; Global Trade Academy

* Mar 27: London, UK; “Brexit – Customs, Sanctions and Export Controls“; TechUK
* Mar 27: Webinar; “The ABCs of Embargoes and Sanctions – Part II“; ECTI;

* Mar 27-28: San Francisco, CA; “
8th Advanced Industry Forum on Global Encryption, Cloud, and Cyber Export Controls
“; American Conference Institute

* Mar 27-28: Brussels, Belgium; ”
Global Customs Compliance Forum“; C5 Group

* Mar 27-28: Santa Clara, CA; “Export Control Forum“; Bureau of Industry and Security
* Apr 
4-5: Des Moines, IA; “
Complying with US Export Controls
“; Bureau of Industry and Security 
* Apr 9: Toronto, Canada; “Certified Classification Specialist (CCLS)“; Amber Road
* 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 16-20: Washington, D.C.; ”
Excellence in Anti-Corruption – ISO Standards 37001 and 19600“; ETHIC Intelligence

* Apr 17-19: Kansas City, MO;
NNSA Export Control Coordinators Org Annual Training; Kimberly.galloway@pnnl.gov; 509-372-6184

Apr 18: Ottowa, Canada; ”
U.S. Ocean Tech Innovation Showcase“; U.S. Embassy in Canada

* Apr 18: Melbourne, Australia; ”
Australia/North Asia FTA Training Session for SMEs: Cultural Awareness – Negotiating Business in South Korea“; Victorian Chamber of Commerce and Industry

* Apr 18-19: Miramar (Miami), FL; “
10th Maritime Logistics Training Course

; ABS Consulting; contact Albert Saphir, 954-218-5285

# Apr 17: London, UK; ”
Intermediate Seminar“; 
UK Department for International Trade
# 
Apr 18: London, UK; ”
Beginner’s Workshop“; 
UK Department for International Trade
# 
Apr 18: London, UK; ”
Licenses Workshop“; 
UK Department for International Trade
# Apr 18: London, UK; ”
Control List Classification – Combined Dual Use and Military“; UK Department for International Trade

* 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
* Apr 30-May 2: Kansas City, MO; “Discover Global Markets“; U.S. Department of Commerce
* May 2-3; Scottsdale, AZ; “Complying with US Export Controls“; Bureau of Industry and Security 

* May 3-4: Milan, Italy; ”
Trade Compliance Southern Europe“; C5 Group

* May 6-8: Toronto, Canada; “2018 ICPA Canadian Conference“; ICPA

* May 6-11: Miami, FL; ”
U.S. Commercial Service Trade Mission to the Carribean Region“; (Additional dates are available for B2B meetings in listed countries.)

* 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: Amsterdam, Netherlands; “Digital Utilities Europe 2018“; American Conference Institute

* May 16-17: National Harbor, MD; “ITAR/EAR Compliance: An Industry Perspective“; Export Compliance Solutions
spalmer@exportcompliancesolutions.com
;
866-238-4018

# May 16: Southampton, UK; ”
Intermediate Seminar“; 
UK Department for International Trade
# 
May 17: Southampton, UK; ”
Beginner’s Workshop“; 
UK Department for International Trade
# 
May 17: Southampton, UK; ”
Licenses Workshop“; 
UK Department for International Trade
# May 17: Southampton, UK; ”
Control List Classification – Combined Dual Use and Military“; UK Department for International Trade


* May 20-22: Portland, OR; “Spring 2018 Seminar;” National Association of Foreign Trade Zones (NAFTZ)
* May 22-23: London, UK; “
Upstream Oil and Gas Legal Forum“; C5 Group

* May 22-24: Las Vegas, NV; ”
Licensing Expo 2018: The Meeting Place for the Global Licensing Industry“; U.S. Commercial Service

# May 23: London, UK; “Control List Classification – Combined Dual Use and Military“; UK Department for International Trade
* May 23-24: Berlin, Germany; ”
12th Annual Exporters’ Forum on Global Economic Sanctions“; C5 Group
#
 May 24: London, UK; “
Making Better License Applications
“; UK Department for International Trade
# May 29-31: Hong Kong; ”
Hong Kong Summit on Economic Sanctions and Compliance Enforcement“; American Conference Institute

* 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 6-7: Munich, Germany; “Pharma Patent Term Extensions“; C5 Group

* Jun 6-8: Baltimore, MD; ”
97th Annual AAEI Conference and Expo“; American Association of Importers and Exporters

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

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

* June 12-13; Stockholm, Sweden; ”
Trade Compliance Nordics“; C5 Group

* Jun 13: San Diego, CA; “Made in America, Buy America, or Buy American: Qualify your Goods and Increase Sales“; Global Trade Academy

# Jun 13: Derby, UK; ”
Intermediate Seminar“; 
UK Department for International Trade
# 
Jun 14: Derby, UK; ”
Beginner’s Workshop“; 
UK Department for International Trade
# 
Jun 14: Derby, UK; ”
Licenses Workshop“; 
UK Department for International Trade
# Jun 14: Derby, UK; ”
Control List Classification – Combined Dual Use and Military“; UK Department for International Trade

* Jun 17-19: Amsterdam, Netherlands; “2018 ICPA European Conference“; International Compliance Professionals Association
* Jun 18: Los Angeles, CA; “Certified Classification Specialist (CCLS)“; Global Trade Academy

# Jun 20-21: McLean, VA; “
ITAR Fundamentals
“; FD Associates

# Jun 27: London, UK; “Control List Classification – Combined Dual Use and Military“; UK Department for International Trade

* Jun 27-28: London, UK; ”
12th Annual Conference on Anti-Corruption“; C5

# Jun 28: London, UK; “Making Better License Applications“; UK Department for International Trade 
# Jul 4: Cambridge, UK; ”
Intermediate Seminar“; 
UK Department for International Trade
# 
Jul 5: Cambridge, UK; ”
Beginner’s Workshop“; 
UK Department for International Trade
# 
Jul 5: Cambridge, UK; ”
Licenses Workshop“; 
UK Department for International Trade
# Jul 5: Cambridge, UK; ”
Control List Classification – Combined Dual Use and Military“; UK Department for International Trade

* 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 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: Springfield, RI; “Complying with US Export Controls“; Bureau of Industry and Security
* Sep 13-17: Galveston, TX (Cruise); “ICPA @ SEA!“; International Compliance Professionals Association (ICPA)
* Sep 16-19: Atlanta, GA; “2018 Annual Conference and Exposition“; National Association of Foreign Trade Zones (NAFTZ)
* Sep 17: Los Angeles, CA; “Import Compliance“; Global Trade Academy
* Sep 17-20: Columbus, OH; “University Export Controls Seminar at The Ohio State University in Columbus“; Export Compliance Training Institute (ECTI); jessica@learnexportcompliance.com; 540-433-3977
* 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 19-20: Rome, Italy; ”
Defense Exports 2018“; SMi

* 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

# Sep 26: McLean, VA; “
EAR Basics
“; FD Associates 

# Sep 26: Oxford, UK; ”
Intermediate Seminar“; 
UK Department for International Trade
# 
Sep 27: Oxford, UK; ”
Beginner’s Workshop“; 
UK Department for International Trade
# 
Sep 27: Oxford, UK; ”
Licenses Workshop“; 
UK Department for International Trade
# Sep 27: Oxford, UK; ”
Control List Classification – Combined Dual Use and Military“; UK Department for International Trade

* Oct 9-11:  Dallas, TX; ”
Partnering for Compliance West Export/Import Control Training and Education Program“; Partnering for Compliance

* Oct 12: Dallas TX; ”
Customs/Import Boot Camp“; Partnering for Compliance

* Oct 18-19: McLean, VA; “ITAR Fundamentals“; FD Associates
* Oct 21-23: Grapevine, TX; “2018 Fall Conference“; ICPA
* Oct 22-23: Arlington, VA; “2018 Fall Advanced Conference
“; Society for International Affairs (SIA)

# Oct 24: Leeds, UK; ”
Intermediate Seminar“; 
UK Department for International Trade
# Oct 25: Leeds, UK; ”
Beginner’s Workshop“; 
UK Department for International Trade
# Oct 25: Leeds, UK; ”
Licenses Workshop“; 
UK Department for International Trade
# Oct 25: Leeds, UK; ”
Control List Classification – Combined Dual Use and Military“; UK Department for International Trade

* Oct 29 – Nov 1: Phoenix, AZITAR Defense Trade Controls / EAR Export Controls Seminar“; ECTIjessica@learnexportcompliance.com; 540-433-3977
* 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 12-15: Washington, D.C.; “ITAR Defense Trade Controls / EAR Export Controls Seminar“; ECTIjessica@learnexportcompliance.com; 540-433-3977
* Nov 13: Tysons Corner, VA; “Made in America, Buy America, or Buy American: Qualify your Goods and Increase Sales“; Global Trade Academy

# Nov 14: Manchester, UK; ”
Intermediate Seminar“; 
UK Department for International Trade
# Nov 15: Manchester, UK; ”
Beginner’s Workshop“; 
UK Department for International Trade
# Nov 15: Manchester, UK; ”
Licenses Workshop“; 
UK Department for International Trade
# Nov 15: Manchester, UK; ”
Control List Classification – Combined Dual Use and Military“; UK Department for International Trade

* Nov 14-15: London, UK; “Economic Sanctions & Financial Crime“; C5 Group
* 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 4-5: Frankfurt, Germany; ”
US Defence Contracting and DFARS Compliance in Europe;” C5 Group
# Dec 5: London, UK; ”
Intermediate Seminar“; 
UK Department for International Trade
# Dec 5: London, UK; ”
Beginner’s Workshop“; 
UK Department for International Trade
# Dec 6: London, UK; ”
Licenses Workshop“; 
UK Department for International Trade
# Dec 6: London, UK; ”
Control List Classification – Combined Dual Use and Military“; UK Department for International Trade

* 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
 
2019
 
* May 5-7: Savannah, GA; ”
2019 Spring Seminar
; National Association of Foreign Trade Zones (NAFTZ)
* Sep 8-11: Chicago, IL; “2019 Annual Conference and Exposition“; National Association of Foreign Trade Zones (NAFTZ)

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

ENEDITOR’S NOTES

EN_a114
. Bartlett’s Unfamiliar Quotations

(Source: Editor)
* Dr. Seuss (Theodor Seuss Geisel, 2 Mar 1904 – 24 Sep 1991, was an American writer, cartoonist, animator, book publisher, and artist best known for authoring children’s books, including The Cat in the Hat (1957), How the Grinch Stole Christmas! (1957), and Green Eggs and Ham (1960) under the pen name Dr. Seuss. His work includes several of the most popular children’s books of all time, selling over 600 million copies and being translated into more than 20 languages by the time of his death.)
  – “You’re never too old, too wacky, too wild, to pick up a book and read to a child.”
  – “Today you are you! That is truer than true! There is no one alive who is you-er than you!”
 
* Knute Rockne (Knute Kenneth Rockne.
4 Mar 1888 – 31 Mar 1931, was a Norwegian-American football player and coach at the University of Notre Dame. Rockne is regarded as one of the greatest coaches in college football history.)
  – “Drink the first. Sip the second slowly. Skip the third.”
 
Friday Funnies:
 
* A snail, telling other snails what it was like being passed by a turtle:  “I can’t really say — it all happened so fast!”
 
* Teacher: “The first student who answers my next question can go home early.”
  While the teacher’s back was turned, one boy throws his pencil at the teacher. 
  Teacher: “Who just threw that pencil?”
  Boy: “I did, and I’m going home now!”

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

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.  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, 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: 27 Feb 2018:
Harmonized System Update 1802
, containing 164 ABI records and 38 harmonized tariff records.

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

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

  – Last Amendment: 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_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, 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 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.

* BACK ISSUES: An archive of Daily Bugle publications from 2005 to present is available HERE.

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