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18-0309 Friday “Daily Bugle”

18-0309 Friday “Daily Bugle”

Friday, 9 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. Commerce/Census Updates HTS in AES
  4. DHS/CBP Announces ACE and ACS Production Scheduled Maintenance, 10-11 Mar
  5. DHS/CBP Extends Drawback Focused Trade Support Call on 13 Mar
  6. DHS/CBP Notice on Status of HTS Changes Required to Support Recent Steel and Aluminum Legislation 
  7. DoD/DSS Knowledge Center Continues to Experience Disruptions in Service 
  8. President Adjusts Imports of Aluminum into the U.S.
  9. President Adjusts Imports of Steel into the U.S.
  10. State/DDTC: (No new postings.)
  11. EU Amends Restrictive Measures Concerning ISIL (Da’esh) and Al-Qaida
  12. EU Outlines Plan to Counter U.S. Trade Restrictions on Steel and Aluminum”
  13. UK DIT/EJCU Encourages UK Exporters to Complete EU Survey on Meaning of “Specially Designed for Military Use”
  1. CBC News: “They Thought They Were Downloading Skype. Instead They Got Spyware”
  2. Defense News: “Trump Announces Stiff Trade Tariffs, Unswayed by Warnings”
  3. Forbes: “Did This American Tech Help Turkey Spy in Syria?”
  1. M. Volkov: “Five Questions for Corporate Boards on Oversight of Compliance”
  2. T.G. Ficaretta: “Which Products Are Regulated Under the Federal Explosives Laws?” 
  3. Gary Stanley’s EC Tip of the Day 
  4. R.C. Burns: “The Norky Horror Picture Show: Let’s Do the UNPA Warp Again” 
  1. CORRECTION: ECS Presents “ITAR/EAR Boot Camp,” 10-11 Jul in Long Beach, CA 
  2. List of Approaching Events – 17 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 (5 Mar 2018), 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)
 

* State; NOTICES; Designations as Global Terrorists [Publication Date: 12 March 2018.]:
  – Abdifatah Abubakar Abdi, aka Musa Muhajir 
  – Ahmad Iman Ali, aka Sheikh Ahmed Iman Ali, Shaykh Ahmad Iman Ali, Ahmed Iman Ali, Abu Zinira
 
* State; NOTICES; Waivers of Missile Proliferation Sanctions: Foreign Persons [Publication Date: 12 March 2018.]

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

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

OGS_aa23. Commerce/Census Updates HTS in AES
(Source: census@subscriptions.census.gov, 8 Mar 2018.)
 
Effective immediately, all recent additions to the Harmonized Tariff Schedule (HTS) are now available for use in AES.
 
*Note: There have been no additions to the Schedule B.
 
The ACE AESDirect program has been updated with these new HTS codes.
 
The full 2018 Schedule B and HTS tables are available for downloading here.
 
The current list of HTS codes that are not valid for AES are available here.
 
For further information or questions, contact the U.S. Census Bureau’s International Trade Indicator Micro Analysis Branch.
 
  – Telephone: (800) 549-0595, select option 2 for International Trade Indicator Micro Analysis Branch
  – Email: eid.scheduleb@census.gov
  – Online: www.census.gov/trade
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(Source:
CSMS #18-000208, 9 Mar 2018.)
 
There will be ACE and ACS PRODUCTION Scheduled Maintenance Saturday evening, March 10, 2018 from 2200 ET to 0400 ET Sunday, March 11, 2018 for infrastructure maintenance.
* * * * * * * * * * * * * * * * * * * *

(Source:
CSMS #18-000205, 9 Mar 2018.)
 
CBP’s Drawback focused trade support call will be extended and held on Tuesday, March 13, 2018. This call will focus on Drawback issues only. The call on Tuesday March 13th, from 3:00 PM ET to 4:00 PM ET will be held to answer questions related to Drawback capabilities included in the February 24th deployment.
 
Line 1 (877) 336-1829 / PC 4840827
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(Source:
CSMS #18-000207, 9 Mar 2018.)
 
In light of the two recent Presidential Proclamations regarding steel and aluminum imports, it is our intent to have both our PROD and CERT environments updated with the new HTS records no later than close of business Tuesday, March 13, 2018. Once the records are available, we will confirm with another CSMS message.
 
[Editor’s note: The Presidential Proclamation concerning aluminum can be found in today’s Daily Bugle here. The Presidential Proclamation concerning steel can be found in today’s Daily Bugle here.]
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(Source:
DoD/DSS, 9 Mar 2018.)
 
The DSS Knowledge Center is currently experiencing intermittent disruptions in its service and will possibly be down through the remainder of the day.
 
We apologize for any inconvenience this may cause.
* * * * * * * * * * * * * * * * * * * *

(Source:
White House, 8 Mar 2018.)

On 8 March the President issued a Proclamation concerning the importation of aluminum into the U.S. 

On January 19, 2018, the Secretary of Commerce (Secretary) transmitted to me a report on his investigation into the effect of imports of aluminum on the national security of the United States under section 232 of the Trade Expansion Act of 1962, as amended (19 U.S.C. 1862).
 
The Secretary found and advised me of his opinion that aluminum is being imported into the United States in such quantities and under such circumstances as to threaten to impair the national security of the United States.  The Secretary found that the present quantities of aluminum imports and the circumstances of global excess capacity for producing aluminum are “weakening our internal economy,” leaving the United States “almost totally reliant on foreign producers of primary aluminum” and “at risk of becoming completely reliant on foreign producers of high-purity aluminum that is essential for key military and commercial systems.”  Because of these risks, and the risk that the domestic aluminum industry would become “unable to satisfy existing national security needs or respond to a national security emergency that requires a large increase in domestic production,” and taking into account the close relation of the economic welfare of the Nation to our national security, see 19 U.S.C. 1862(d), the Secretary concluded that the present quantities and circumstances of aluminum imports threaten to impair the national security as defined in section 232 of the Trade Expansion Act of 1962, as amended.
 
In light of this conclusion, the Secretary recommended actions to adjust the imports of aluminum so that such imports will not threaten to impair the national security.  Among those recommendations was a global tariff of 7.7 percent on imports of aluminum articles in order to reduce imports to a level that the Secretary assessed would enable domestic aluminum producers to use approximately 80 percent of existing domestic production capacity and thereby achieve long-term economic viability through increased production.  The Secretary has also recommended that I authorize him, in response to specific requests from affected domestic parties, to exclude from any adopted import restrictions those aluminum articles for which the Secretary determines there is a lack of sufficient U.S. production capacity of comparable products, or to exclude aluminum articles from such restrictions for specific national security-based considerations.
 
I concur in the Secretary’s finding that aluminum articles are being imported into the United States in such quantities and under such circumstances as to threaten to impair the national security of the United States, and I have considered his recommendations.
 
Section 232 of the Trade Expansion Act of 1962, as amended, authorizes the President to adjust the imports of an article and its derivatives that are being imported into the United States in such quantities or under such circumstances as to threaten to impair the national security.
 
Section 604 of the Trade Act of 1974, as amended (19 U.S.C. 2483), authorizes the President to embody in the Harmonized Tariff Schedule of the United States (HTSUS) the substance of acts affecting import treatment, and actions thereunder, including the removal, modification, continuance, or imposition of any rate of duty or other import restriction.
 
In the exercise of these authorities, I have decided to adjust the imports of aluminum articles by imposing a 10 percent ad valorem tariff on aluminum articles, as defined below, imported from all countries except Canada and Mexico.  In my judgment, this tariff is necessary and appropriate in light of the many factors I have considered, including the Secretary’s report, updated import and production numbers for 2017, the failure of countries to agree on measures to reduce global excess capacity, the continued high level of imports since the beginning of the year, and special circumstances that exist with respect to Canada and Mexico.  This relief will help our domestic aluminum industry to revive idled facilities, open closed smelters and mills, preserve necessary skills by hiring new aluminum workers, and maintain or increase production, which will reduce our Nation’s need to rely on foreign producers for aluminum and ensure that domestic producers can continue to supply all the aluminum necessary for critical industries and national defense.  Under current circumstances, this tariff is necessary and appropriate to address the threat that imports of aluminum articles pose to the national security.
 
In adopting this tariff, I recognize that our Nation has important security relationships with some countries whose exports of aluminum to the United States weaken our internal economy and thereby threaten to impair the national security.  I also recognize our shared concern about global excess capacity, a circumstance that is contributing to the threatened impairment of the national security.  Any country with which we have a security relationship is welcome to discuss with the United States alternative ways to address the threatened impairment of the national security caused by imports from that country.  Should the United States and any such country arrive at a satisfactory alternative means to address the threat to the national security such that I determine that imports from that country no longer threaten to impair the national security, I may remove or modify the restriction on aluminum articles imports from that country and, if necessary, make any corresponding adjustments to the tariff as it applies to other countries as our national security interests require.
 
I conclude that Canada and Mexico present a special case.  Given our shared commitment to supporting each other in addressing national security concerns, our shared commitment to addressing global excess capacity for producing aluminum, the physical proximity of our respective industrial bases, the robust economic integration between our countries, the export of aluminum produced in the United States to Canada and Mexico, and the close relation of the economic welfare of the United States to our national security, see 19 U.S.C. 1862(d), I have determined that the necessary and appropriate means to address the threat to the national security posed by imports of aluminum articles from Canada and Mexico is to continue ongoing discussions with these countries and to exempt aluminum articles imports from these countries from the tariff, at least at this time.  I expect that Canada and Mexico will take action to prevent transshipment of aluminum articles through Canada and Mexico to the United States.
 
In the meantime, the tariff imposed by this proclamation is an important first step in ensuring the economic viability of our domestic aluminum industry.  Without this tariff and satisfactory outcomes in ongoing negotiations with Canada and Mexico, the industry will continue to decline, leaving the United States at risk of becoming reliant on foreign producers of aluminum to meet our national security needs – a situation that is fundamentally inconsistent with the safety and security of the American people.  It is my judgment that the tariff imposed by this proclamation is necessary and appropriate to adjust imports of aluminum articles so that such imports will not threaten to impair the national security as defined in section 232 of the Trade Expansion Act of 1962, as amended.
 
Now, Therefore, I, Donald J. Trump, President of the United States of America, by the authority vested in me by the Constitution and the laws of the United States of America, including section 301 of title 3, United States Code, section 604 of the Trade Act of 1974, as amended, and section 232 of the Trade Expansion Act of 1962, as amended, do hereby proclaim as follows:
 
  (1)  For the purposes of this proclamation, “aluminum articles” are defined in the Harmonized Tariff Schedule (HTS) as: (a) unwrought aluminum (HTS 7601); (b) aluminum bars, rods, and profiles (HTS 7604); (c) aluminum wire (HTS 7605); (d) aluminum plate, sheet, strip, and foil (flat rolled products) (HTS 7606 and 7607); (e) aluminum tubes and pipes and tube and pipe fitting (HTS 7608 and 7609); and (f) aluminum castings and forgings (HTS 7616.99.51.60 and 7616.99.51.70), including any subsequent revisions to these HTS classifications.
 
  (2)  In order to establish increases in the duty rate on imports of aluminum articles, subchapter III of chapter 99 of the HTSUS is modified as provided in the Annex to this proclamation.  Except as otherwise provided in this proclamation, or in notices published pursuant to clause 3 of this proclamation, all imports of aluminum articles specified in the Annex shall be subject to an additional 10 percent ad valorem rate of duty with respect to goods entered, or withdrawn from warehouse for consumption, on or after 12:01 a.m. eastern daylight time on March 23, 2018.  This rate of duty, which is in addition to any other duties, fees, exactions, and charges applicable to such imported aluminum articles, shall apply to imports of aluminum articles from all countries except Canada and Mexico.
 
  (3)  The Secretary, in consultation with the Secretary of State, the Secretary of the Treasury, the Secretary of Defense, the United States Trade Representative (USTR), the Assistant to the President for National Security Affairs, the Assistant to the President for Economic Policy, and such other senior Executive Branch officials as the Secretary deems appropriate, is hereby authorized to provide relief from the additional duties set forth in clause 2 of this proclamation for any aluminum article determined not to be produced in the United States in a sufficient and reasonably available amount or of a satisfactory quality and is also authorized to provide such relief based upon specific national security considerations.  Such relief shall be provided for an aluminum article only after a request for exclusion is made by a directly affected party located in the United States.  If the Secretary determines that a particular aluminum article should be excluded, the Secretary shall, upon publishing a notice of such determination in the Federal Register, notify Customs and Border Protection (CBP) of the Department of Homeland Security concerning such article so that it will be excluded from the duties described in clause 2 of this proclamation.  The Secretary shall consult with CBP to determine whether the HTSUS provisions created by the Annex to this proclamation should be modified in order to ensure the proper administration of such exclusion, and, if so, shall make such modification to the HTSUS through a notice in the Federal Register.
 
  (4)  Within 10 days after the date of this proclamation, the Secretary shall issue procedures for the requests for exclusion described in clause 3 of this proclamation.  The issuance of such procedures is exempt from Executive Order 13771 of January 30, 2017 (Reducing Regulation and Controlling Regulatory Costs).
 
  (5) 
    (a)  The modifications to the HTSUS made by the Annex to this proclamation shall be effective with respect to goods entered, or withdrawn from warehouse for consumption, on or after 12:01 a.m. eastern daylight time on March 23, 2018, and shall continue in effect, unless such actions are expressly reduced, modified, or terminated.
    (b)  The Secretary shall continue to monitor imports of aluminum articles and shall, from time to time, in consultation with the Secretary of State, the Secretary of the Treasury, the Secretary of Defense, the USTR, the Assistant to the President for National Security Affairs, the Assistant to the President for Economic Policy, the Director of the Office of Management and Budget, and such other senior Executive Branch officials as the Secretary deems appropriate, review the status of such imports with respect to the national security.  The Secretary shall inform the President of any circumstances that in the Secretary’s opinion might indicate the need for further action by the President under section 232 of the Trade Expansion Act of 1962, as amended.  The Secretary shall also inform the President of any circumstance that in the Secretary’s opinion might indicate that the increase in duty rate provided for in this proclamation is no longer necessary.
 
  (6)  Any provision of previous proclamations and Executive Orders that is inconsistent with the actions taken in this proclamation is superseded to the extent of such inconsistency.
 
IN WITNESS WHEREOF, I have hereunto set my hand this
eighth day of March, in the year of our Lord two thousand eighteen, and of the Independence of the United States of America the two hundred and forty-second.
 
DONALD J. TRUMP
* * * * * * * * * * * * * * * * * * * *

(Source:
White House, 8 Mar 2018.)

On 8 March the President issued a Proclamation concerning the importation of steel into the U.S.  

  

On January 11, 2018, the Secretary of Commerce (Secretary) transmitted to me a report on his investigation into the effect of imports of steel mill articles (steel articles) on the national security of the United States under section 232 of the Trade Expansion Act of 1962, as amended (19 U.S.C. 1862).
 
The Secretary found and advised me of his opinion that steel articles are being imported into the United States in such quantities and under such circumstances as to threaten to impair the national security of the United States. The Secretary found that the present quantities of steel articles imports and the circumstances of global excess capacity for producing steel are “weakening our internal economy,” resulting in the persistent threat of further closures of domestic steel production facilities and the “shrinking [of our] ability to meet national security production requirements in a national emergency.” Because of these risks and the risk that the United States may be unable to “meet [steel] demands for national defense and critical industries in a national emergency,” and taking into account the close relation of the economic welfare of the Nation to our national security, see 19 U.S.C. 1862(d), the Secretary concluded that the present quantities and circumstances of steel articles imports threaten to impair the national security as defined in section 232 of the Trade Expansion Act of 1962, as amended.
 
In reaching this conclusion, the Secretary considered the previous U.S. Government measures and actions on steel articles imports and excess capacity, including actions taken under Presidents Reagan, George H.W. Bush, Clinton, and George W. Bush. The Secretary also considered the Department of Commerce’s narrower investigation of iron ore and semi-finished steel imports in 2001, and found the recommendations in that report to be outdated given the dramatic changes in the steel industry since 2001, including the increased level of global excess capacity, the increased level of imports, the reduction in basic oxygen furnace facilities, the number of idled facilities despite increased demand for steel in critical industries, and the potential impact of further plant closures on capacity needed in a national emergency.
 
In light of this conclusion, the Secretary recommended actions to adjust the imports of steel articles so that such imports will not threaten to impair the national security. Among those recommendations was a global tariff of 24 percent on imports of steel articles in order to reduce imports to a level that the Secretary assessed would enable domestic steel producers to use approximately 80 percent of existing domestic production capacity and thereby achieve long-term economic viability through increased production. The Secretary has also recommended that I authorize him, in response to specific requests from affected domestic parties, to exclude from any adopted import restrictions those steel articles for which the Secretary determines there is a lack of sufficient U.S. production capacity of comparable products, or to exclude steel articles from such restrictions for specific national security-based considerations.
 
I concur in the Secretary’s finding that steel articles are being imported into the United States in such quantities and under such circumstances as to threaten to impair the national security of the United States, and I have considered his recommendations.
 
Section 232 of the Trade Expansion Act of 1962, as amended, authorizes the President to adjust the imports of an article and its derivatives that are being imported into the United States in such quantities or under such circumstances as to threaten to impair the national security.
 
Section 604 of the Trade Act of 1974, as amended (19 U.S.C. 2483), authorizes the President to embody in the Harmonized Tariff Schedule of the United States (HTSUS) the substance of acts affecting import treatment, and actions thereunder, including the removal, modification, continuance, or imposition of any rate of duty or other import restriction.
 
In the exercise of these authorities, I have decided to adjust the imports of steel articles by imposing a 25 percent ad valorem tariff on steel articles, as defined below, imported from all countries except Canada and Mexico. In my judgment, this tariff is necessary and appropriate in light of the many factors I have considered, including the Secretary’s report, updated import and production numbers for 2017, the failure of countries to agree on measures to reduce global excess capacity, the continued high level of imports since the beginning of the year, and special circumstances that exist with respect to Canada and Mexico. This relief will help our domestic steel industry to revive idled facilities, open closed mills, preserve necessary skills by hiring new steel workers, and maintain or increase production, which will reduce our Nation’s need to rely on foreign producers for steel and ensure that domestic producers can continue to supply all the steel necessary for critical industries and national defense. Under current circumstances, this tariff is necessary and appropriate to address the threat that imports of steel articles pose to the national security.
 
In adopting this tariff, I recognize that our Nation has important security relationships with some countries whose exports of steel articles to the United States weaken our internal economy and thereby threaten to impair the national security. I also recognize our shared concern about global excess capacity, a circumstance that is contributing to the threatened impairment of the national security. Any country with which we have a security relationship is welcome to discuss with the United States alternative ways to address the threatened impairment of the national security caused by imports from that country. Should the United States and any such country arrive at a satisfactory alternative means to address the threat to the national security such that I determine that imports from that country no longer threaten to impair the national security, I may remove or modify the restriction on steel articles imports from that country and, if necessary, make any corresponding adjustments to the tariff as it applies to other countries as our national security interests require.
 
I conclude that Canada and Mexico present a special case. Given our shared commitment to supporting each other in addressing national security concerns, our shared commitment to addressing global excess capacity for producing steel, the physical proximity of our respective industrial bases, the robust economic integration between our countries, the export of steel articles produced in the United States to Canada and Mexico, and the close relation of the economic welfare of the United States to our national security, see 19 U.S.C. 1862(d), I have determined that the necessary and appropriate means to address the threat to the national security posed by imports of steel articles from Canada and Mexico is to continue ongoing discussions with these countries and to exempt steel articles imports from these countries from the tariff, at least at this time. I expect that Canada and Mexico will take action to prevent transshipment of steel articles through Canada and Mexico to the United States.
 
In the meantime, the tariff imposed by this proclamation is an important first step in ensuring the economic viability of our domestic steel industry. Without this tariff and satisfactory outcomes in ongoing negotiations with Canada and Mexico, the industry will continue to decline, leaving the United States at risk of becoming reliant on foreign producers of steel to meet our national security needs – a situation that is fundamentally inconsistent with the safety and security of the American people. It is my judgment that the tariff imposed by this proclamation is necessary and appropriate to adjust imports of steel articles so that such imports will not threaten to impair the national security as defined in section 232 of the Trade Expansion Act of 1962, as amended.
 
Now, Therefore, I, Donald J. Trump, President of the United States of America, by the authority vested in me by the Constitution and the laws of the United States of America, including section 301 of title 3, United States Code, section 604 of the Trade Act of 1974, as amended, and section 232 of the Trade Expansion Act of 1962, as amended, do hereby proclaim as follows:
 
  (1) For the purposes of this proclamation, “steel articles” are defined at the Harmonized Tariff Schedule (HTS) 6

digit level as: 7206.10 through 7216.50, 7216.99 through 7301.10, 7302.10, 7302.40 through 7302.90, and 7304.10 through 7306.90, including any subsequent revisions to these HTS classifications.
 
  (2) In order to establish increases in the duty rate on imports of steel articles, subchapter III of chapter 99 of the HTSUS is modified as provided in the Annex to this proclamation. Except as otherwise provided in this proclamation, or in notices published pursuant to clause 3 of this proclamation, all steel articles imports specified in the Annex shall be subject to an additional 25 percent ad valorem rate of duty with respect to goods entered, or withdrawn from warehouse for consumption, on or after 12:01 a.m. eastern daylight time on March 23, 2018. This rate of duty, which is in addition to any other duties, fees, exactions, and charges applicable to such imported steel articles, shall apply to imports of steel articles from all countries except Canada and Mexico.
 
  (3) The Secretary, in consultation with the Secretary of State, the Secretary of the Treasury, the Secretary of Defense, the United States Trade Representative (USTR), the Assistant to the President for National Security Affairs, the Assistant to the President for Economic Policy, and such other senior Executive Branch officials as the Secretary deems appropriate, is hereby authorized to provide relief from the additional duties set forth in clause 2 of this proclamation for any steel article determined not to be produced in the United States in a sufficient and reasonably available amount or of a satisfactory quality and is also authorized to provide such relief based upon specific national security considerations. Such relief shall be provided for a steel article only after a request for exclusion is made by a directly affected party located in the United States. If the Secretary determines that a particular steel article should be excluded, the Secretary shall, upon publishing a notice of such determination in the Federal Register, notify Customs and Border Protection (CBP) of the Department of Homeland Security concerning such article so that it will be excluded from the duties described in clause 2 of this proclamation. The Secretary shall consult with CBP to determine whether the HTSUS provisions created by the Annex to this proclamation should be modified in order to ensure the proper administration of such exclusion, and, if so, shall make such modification to the HTSUS through a notice in the Federal Register.
 
  (4) Within 10 days after the date of this proclamation, the Secretary shall issue procedures for the requests for exclusion described in clause 3 of this proclamation. The issuance of such procedures is exempt from Executive Order 13771 of January 30, 2017 (Reducing Regulation and Controlling Regulatory Costs).
 
  (5)
    (a) The modifications to the HTSUS made by the Annex to this proclamation shall be effective with respect to goods entered, or withdrawn from warehouse for consumption, on or after 12:01 a.m. eastern daylight time on March 23, 2018, and shall continue in effect, unless such actions are expressly reduced, modified, or terminated.
    (b) The Secretary shall continue to monitor imports of steel articles and shall, from time to time, in consultation with the Secretary of State, the Secretary of the Treasury, the Secretary of Defense, the USTR, the Assistant to the President for National Security Affairs, the Assistant to the President for Economic Policy, the Director of the Office of Management and Budget, and such other senior Executive Branch officials as the Secretary deems appropriate, review the status of such imports with respect to the national security. The Secretary shall inform the President of any circumstances that in the Secretary’s opinion might indicate the need for further action by the President under section 232 of the Trade Expansion Act of 1962, as amended. The Secretary shall also inform the President of any circumstance that in the Secretary’s opinion might indicate that the increase in duty rate provided for in this proclamation is no longer necessary.
 
  (6) Any provision of previous proclamations and Executive Orders that is inconsistent with the actions taken in this proclamation is superseded to the extent of such inconsistency.
 
IN WITNESS WHEREOF, I have hereunto set my hand this
 
eighth day of March, in the year of our Lord two thousand eighteen, and of the Independence of the United States of America the two hundred and forty-second.
 
DONALD J. TRUMP
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* Commission Implementing Regulation (EU) 2018/349 of 8 March 2018 amending for the 282nd time Council Regulation (EC) No 881/2002 imposing certain specific restrictive measures directed against certain persons and entities associated with the ISIL (Da’esh) and Al-Qaida organizations.
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(Source:
European Commission, Press Release 7 Mar 2018.)
 
The College of Commissioners discussed today the EU’s response to the possible US import restrictions for steel and aluminum announced on 1 March. The EU stands ready to react proportionately and fully in line with the World Trade Organization (WTO) rules in case the US measures are formalized and affect EU’s economic interests. The College gave its political endorsement to the proposal presented by President Jean-Claude Juncker, Vice-President Jyrki Katainen and Commissioner for Trade Cecilia Malmström.
 
Speaking after the College meeting, Commissioner Malmström said: “We still hope, as a USA security partner, that the EU would be excluded. We also hope to convince the US administration that this is not the right move. As no decision has been taken yet, no formal action has been taken by the European Union. But we have made clear that if a move like this is taken, it will hurt the European Union. It will put thousands of European jobs in jeopardy and it has to be met by firm and proportionate response. Unlike these proposed US duties, our three tracks of work are in line with our obligations in the WTO. They will be carried out by the book. The root cause of the problem in the steel and aluminum sector is global overcapacity. It is rooted in the fact that a lot of steel and aluminum production takes place under massive state subsidies, and under non-market conditions. This can only be addressed by cooperation, getting to the source of the problem and working together. What is clear is that turning inward is not the answer. Protectionism cannot be the answer, it never is.”
 
The EU remains available to continue working on this together with the United States. The EU has been and remains a strong supporter of an open and rules-based global trade system.
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(Source:
UK DIT/EJCU, 9 Mar 2018.)
 
European Union Member States have produced some draft guidance on the meaning of ‘specially designed for military use’, an expression widely used in export control legislation. The guidance is intended to help Member State competent authorities and the European defence industry establish whether a particular item is specially designed for military use. Once finalised, the guidance should help to achieve a common interpretation of this term across the Union.
 
The Commission has invited comments from European industry on this draft guidance via this online survey:
 
 
The Export Control Joint Unit (ECJU) believes that this issue is important to UK exporters. Please respond to the survey so that your views can be taken into account. This survey is open for 3 months from 1 March 2018.
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NWSNEWS

(Source:
CBC News, 9 Mar 2018.) [Excerpts.]
 
Users in Turkey were redirected using network-filtering technology likely sold by a Canadian-founded company.
 
Since last fall, Turkish internet users attempting to download one of a handful of popular apps may have been the unwitting targets of a wide-reaching computer surveillance campaign.
 
And in Egypt, users across the country have, seemingly at random, had their browsing activity mysteriously redirected to online money-making schemes.
 
Internet filtering equipment sold by technology company Sandvine – founded in Waterloo, Ont. – is believed to have played a significant part in both. …
 
  “Dual-use” technologies
 
The report is a stark reminder of how internet filtering equipment designed for legitimate uses – such as managing network capacity – can also be abused.
 
The governments of Both Turkey and Egypt have for years used internet-filtering technology to monitor activity, crackdown on dissent, and restrict free expression online. Such devices are currently exempt from export control laws governing “dual-use” technologies.
 
Global Affairs Canada, which regulates controlled exports, did not respond to a request for comment. The government established a new ombud role in January to “investigate allegations of human rights abuses linked to Canadian corporate activity abroad.”
 
Waterloo, Ont.-based Sandvine was purchased by U.S. private equity firm Francisco Partners last year and merged with another computer networking company, Palo Alto, Calif.-based Procera. The resulting company operates under the Sandvine name.
 
In a statement, Francisco Partners said its companies are mandated to “operate in accordance with applicable law and strict ethics policies and practices, which include the protection of human rights,” and has asked Sandvine to investigate. …
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(Source:
Defense News, 8 Mar 2018.)
 
Unswayed by Republican warnings of a trade war, President Donald Trump ordered steep new tariffs on steel and aluminum imports to the U.S. on Thursday, vowing to fight back against an “assault on our country” by foreign competitors. The president said he would exempt Canada and Mexico while negotiating for changes to the North American Free Trade Agreement.
The new tariffs will take effect in 15 days, with Canada and Mexico indefinitely exempted “to see if we can make the deal,” Trump said. NAFTA talks are expected to resume early next month.
 
  “The American aluminum and steel industry has been ravaged by aggressive foreign trade practices. It’s really an assault on our country. It’s been an assault,” Trump said at the White House. He was joined by steel and aluminum workers holding white hard hats.
 
American steel and aluminum workers have long been betrayed, but “that betrayal is now over,” Trump said. The former real estate developer said politicians had for years lamented the decline in the industries, but nobody was willing to take action.
 
As he has indicated previously, Trump said he would levy tariffs of 25 percent on imported steel and 10 percent on aluminum. But he said during a Cabinet meeting earlier in the day that the penalties would “have a right to go up or down depending on the country and I’ll have a right to drop out countries or add countries. I just want fairness.”
 
Business leaders, meanwhile, have continued to sound the alarm about the potential economic fallout from tariffs, with the president and CEO of the U.S. Chamber of Commerce raising the specter of a global trade war. That scenario, Tom Donohue said, would endanger the economic momentum from the GOP tax cuts and Trump’s rollback of regulations.
 
  “We urge the administration to take this risk seriously,” Donohue said.
 
The president suggested in the meeting with his Cabinet that Australia and “other countries” might also be spared, a shift that could soften the international blow amid threats of retaliation by trading partners.
 
We’re going to be very fair, we’re going to be very flexible but we’re going to protect the American worker as I said I would do in my campaign,” Trump said.
 
People briefed on the plans ahead of the announcement said all countries affected by the tariffs would be invited to negotiate with the administration to be exempted from the tariffs if they can address the threat their exports pose to U.S. manufacturers. The exemptions for Canada and Mexico could be ended if talks to renegotiate NAFTA stall.
 
The process of announcing the penalties has been the subject of an intense debate and chaotic exchanges within the White House, pitting hard-liners against free trade advocates such as outgoing economic adviser Gary Cohn.
 
The fight over tariffs comes amid intense turmoil in the West Wing, which has seen waves of departures and negative news stories that have left Trump increasingly isolated in the Oval Office, according to two senior officials speaking on the condition of anonymity to discuss internal discussions.
 
Congressional Republicans and business groups are bracing for the impact of the tariffs and the departure of Cohn, a former Goldman Sachs executive who has opposed them.
 
House Speaker Paul Ryan, appearing at a session with Home Depot employees in Atlanta, said ahead of Trump’s announcement, “I’m just not a fan of broad-based, across-the-board tariffs.” He pointed to the store’s many products that rely on steel and aluminum.
 
More than 100 House Republicans wrote Trump on Wednesday, asking him to reconsider “the idea of broad tariffs to avoid unintended negative consequences” to the U.S. economy and workers.
 
Arizona Sen. Jeff Flake, a Republican, said he plans to introduce legislation next week to nullify the tariffs though he has acknowledged that finding the votes to stop the president’s actions could be difficult.
 
The president has said the tariffs are needed to reinforce lagging American steel and aluminum industries and protect national security.
* * * * * * * * * * * * * * * * * * * *

(Source:
Forbes, 9 Mar 2018.) [Excerpts.]
 
In late 2016, Forbes learned of a mini uprising at the Swedish branch of major U.S. networking vendor Procera Networks. Multiple staff members threatened to quit, or did in fact leave, over a sale in Turkey of technology capable of supporting the repressive actions of the state, one where surveillance had intensified after a failed coup led to a crackdown by the Recep Erdogan regime. They were nervous about their new owners too: Francisco Partners, a private equity firm that had invested hundreds of millions in surreptitious smartphone surveillance companies. …
 
European member of parliament Schaake said the Procera case should provide impetus for the need for proper export controls. “The use of surveillance systems should be much more closely scrutinized,” she added. “These sales do not seem to violate laws, which is why the laws should change.”
* * * * * * * * * * * * * * * * * * * *

COMMCOMMENTARY

COMM_a1
17. M. Volkov: “Five Questions for Corporate Boards on Oversight of Compliance”

(Source:
Volkov Law Group Blog, 9 Mar 2018. Reprinted by permission.)
 
* Author: Michael Volkov, Esq., Volkov Law Group,
mvolkov@volkovlaw.com, 240-505-1992.
 
Let’s face it – corporate boards are not adept at overseeing a company’s compliance program.  In the absence of a board member who has prior compliance expertise, corporate boards either ignore or struggle to fulfill their compliance oversight responsibilities.
 
Corporate governance performance is suffering from this serious gap between compliance responsibilities and compliance capabilities.  Corporate boards are under increasing pressure to improve their performance, including in the area of compliance.  The Federal Reserve’s recent action against the Wells Fargo’s board set an importance precedent – a board has to maintain an effective system for risk oversight and management, including its compliance program.
 
As a first step, every board should have a former compliance professional as a member.  In today’s risk and activist environment, corporate boards need to address this deficiency as quickly as possible and enlist compliance expertise on the board itself.
 
As a second step, chief compliance officers, with the backing of the CEO and senior management, should “train” the board for at least two hours each year (and preferably more).  When I use the term “train,” I really mean “educate” the board on risks, the law, and the company’s compliance program, and most importantly, how to oversee and monitor the company’s compliance program.
 
In this new era of corporate governance excellence, board members have to become familiar with the key compliance issues facing the company, ensure that there are effective controls to identify, elevate and resolve issues as appropriate.  In carrying out this oversight function, there are five important issues that the board should address:
 
(1) Risk Profile: The board needs to understand exactly the company’s risk profile. This inquiry should not be based just on an annual review of risks but should be a forward-looking perspective on risks for the year and projected risks based on expected business plans and developments.
 
To exercise proper oversight and monitoring, the board should direct management to provide information and data on the identification of risk, monitoring and management of risk and procedures in place to ensure that risk activities are properly addressed at each level.  On a quarterly basis, the CCO should update the company’s risk profile based on compliance monitoring activities.
 
(2) Culture and Compliance Controls: The board has to assist in defining the company’s culture, its values and principles, and take responsibility for the management and oversight of the company’s culture. To that end, the board itself should develop a two-prong strategy: communication and conduct.  The board has to commit itself to communicating and conducting themselves in furtherance of the company’s defined culture.
 
As part of its oversight and monitoring responsibilities, the board has to hold the CEO, senior management and the CCO to the same standard – what communications activities and conduct they plan to perform to further the company’s culture and its values.
 
On the more granular, but equally important level, the board has to ensure that the CCO has put into place appropriate mechanisms to measure, monitor and evaluate the company’s culture.  The board’s expectations should be clear – our culture is our most important asset, and what specifically is the CCO doing to preserve and promote the culture.  It is critical for the board to make clear to the CCO that it expects quarterly reports on issues relating to the company’s culture, whether it be company-wide, or focused on specific high-risk areas or operations, or other appropriate inquiries.
 
(3) Measurement and Performance: With the input of the CEO, senior management and the CCO, the board should develop accurate and appropriate metrics for the compliance program, focusing on the company’s culture and its compliance controls. The board has to demand a new compliance dashboard that includes relevant measurements, not just data that reports on completion of specific compliance tasks (e.g. training sessions held, attendance, certifications).  In this area, the board has to demand measurements that answer the questions of whether management and employees understand the requirements of the code of conduct and the law, whether their behavior is conforming to these requirements, and if not, why not, and understanding of the company’s culture and expectations of the application of value principles to the day-to-day responsibilities.
 
(
4) Gap Analysis and Remediation: The board needs to understand exactly the gap between the company’s risk profile and its compliance program. To the extent these gaps are analyzed, the board has to demand plans by the CEO and the CCO to remediate these gaps and the timetable.  In prioritizing this gap analysis, the board should focus on each gap, the risks created by the gap, and prioritize the remediation based on this analysis.  The CCO has to be held accountable in this area as to specific analysis, and a timetable for remediation.
 
(5) Continuous Functions: As the board understands its oversight and monitoring responsibilities, it has to ask a continuing question – based on the company’s operations, to what extent I the company’s culture and compliance program generating information and data needed to adjust and improve its compliance program.  The board has to ensure that the CCO and the CEO are implementing sufficient controls, generating relevant data, analyzing such data, and presenting the board with insights, opportunities and recommendations to improve and revise the company’s compliance program.

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COMM_a2
18. T.G. Ficaretta: “Which Products Are Regulated Under the Federal Explosives Laws?”

(Source: 
Ficaretta Legal Services LLC, 8 Mar 2018.)
 
*Author: Teresa G. Ficaretta, Esq., 
teresa@ficarettalegal.com, 301-353-3558; Ficaretta Legal Services, LLC.
 
The federal explosives laws in 18 U.S.C. Chapter 40 impose licensing requirements on persons who engage in the business of importing, manufacturing, or dealing in explosive materials.  License requirements also apply to occasional users and hobbyists, as persons who wish to lawfully transport, ship, or receive explosive materials must obtain a user permit from the Bureau of Alcohol, Tobacco, Firearms and Explosives (“ATF”).  Licensees and permittees must maintain records of acquisition and distribution of explosive materials and store them in storage magazines that comply with construction, housekeeping, and tables of distance requirements in ATF regulations. 
 
The starting point for federal regulation is determining whether a particular product fits within the definition of “explosive materials.”  The statutory definition states the term means “explosives, blasting agents, and detonators.”  Those terms are defined in the statute as follows:
 
Explosives: Any chemical compound mixture or device the primary or common purpose of which is to function by explosion.  
 
Blasting agent:  Any material or mixture consisting of fuel and oxidizer intended for blasting not otherwise fitting within the definition of “explosives.”
 
Detonator:  Any device containing a detonating charge that is used for initiating detonation in an explosive; the term includes electric blasting caps of instantaneous and delay types, blasting caps for use with safety fuses and detonating-cord delay connectors.
 
The statutory definition of “explosives” requires ATF to publish and revise at least annually a list of explosives subject to regulation.  This annual list is titled the “List of Explosive Materials” and is published in the Federal Register.  The most recent version (2017 Annual List of Explosive Materials, 82 FR 61589, December 28, 2017) is on the agency’s website in the Publications Library.
 
The annual list of explosive materials should make it relatively straightforward for members of the explosives industry to determine whether a particular product is subject to regulation.  The list is alphabetical and uses terms commonly understood by the industry.  However, some of the compounds listed are generic and do not clearly indicate which products are included.  For example, the 2017 list includes entries for “Explosive gelatins,” “Explosive liquids,” and “Explosive powders.”  Maybe these terms are clear to the ATF personnel who put them on the list, but they may not be clear to company personnel responsible for ensuring compliance with federal law. 
 
Industry members who need to know whether a particular product fits within the definition of “explosive materials” should request a classification from ATF’s Explosives Industry Programs Branch (“EIPB”).  There is no charge for obtaining a classification and a determination generally takes 4-6 months.  Requesters may be required to submit product samples for analysis.  EIPB may be contacted by calling (202)648-7120 or via email at 
eipb@atf.gov.
 
The federal explosives laws and implementing regulations also provide a number of exemptions for products that would otherwise fit within the definitions outlined above.  The exemptions include the following:
 
  – Explosive materials being transported via railroad, water, highway, or air in accordance with safety regulations of the Department of Transportation or the Department of Homeland Security;
  – Explosive materials manufactured or imported for distribution to the U.S. military and other federal, state, or local government agencies;
  – Explosive materials used in medicines and medicinal agents in forms prescribed by the U.S. Pharmacopeia or the National Formulary;
  – Small arms ammunition and components of small arms ammunition (this includes smokeless propellant suitable for use in small arms ammunition and other explosives listed in the definition of “ammunition” in 27 C.F.R. 555.11);
  – Fireworks classified as UN0336, UN0337, UN0431, or UN0432 explosives by the U.S. Department of Transportation and generally known as “consumer fireworks” or “articles pyrotechnic;”
  – Special explosive devices as designated by ATF;
  – Gasoline, fertilizers, propellant actuated devices, and propellant actuated industrial tools;
  – Industrial and laboratory chemicals intended for use as reagents and which are packaged and shipped pursuant to U.S. Department of Transportation regulations;
  – Certain specified model rocket motors; and
  – Commercially manufactured black powder in quantities not to exceed 50 pounds if intended to be used solely for sporting, recreational, or cultural purposes in antique firearms or antique devices
 
Readers are cautioned that the above exemptions are complex and may not exempt products from all requirements of the law and regulations.  For example, manufacturers and importers of smokeless powder must still obtain a license from ATF and import products with a Form 6 import permit; marking requirements apply to explosives manufactured for certain government agencies; and state and local government agencies are required to store explosives in accordance with ATF’s storage regulations.  It is essential that industry members contact ATF for guidance before concluding that explosive materials are exempt from all ATF regulations.
 

Compliance with the federal explosives laws is essential to ensure the safety and security of explosive materials and to avoid violations of the law.  Industry members should become familiar with the statutory definitions and exemptions, as they are the starting point for compliance. 

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

COMM_a319. Gary Stanley’s EC Tip of the Day

(Source: Defense and Export-Import Update, 8 Mar 2018.  Available by subscription from
gstanley@glstrade.com.)
 
* Author: Gary Stanley, Esq., Global Legal Services, PC, (202) 352-3059,
 
When a company located in the United States is no longer in the business of manufacturing, exporting or brokering defense articles or defense services, the company must notify DDTC in writing at least 30 days prior to the expiration of the manufacturer, exporter and/or broker registration. 
 
Click 
here for detailed instructions.

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

COMM_a4
20. R.C. Burns: “The Norky Horror Picture Show: Let’s Do the UNPA Warp Again”

(Source:
Export Law Blog, 8 Mar 2018. Reprinted by permission.)
 
* Author: R. Clifton Burns, Esq., Bryan Cave LLP, Wash DC,
Clif.Burns@bryancave.com, 202-508-6067).
 
On March 5, the Office of Foreign Assets Control (“OFAC”)
released a completely revised and revamped version of the North Korea Sanctions Regulations. The intent of the revision was to catch up with Executive Orders 13687, 13722, and 13810, as well as with the North Korea Sanctions and Policy Enhancement Act of 2016 and Title III of the Countering America’s Adversaries Through Sanctions Act, all of which came into force since the regulations were originally promugated in 2010.
 
Not surprisingly, OFAC continues its war on the Congressionally mandated travel and information exemptions in 50 U.S.C. § 1702(b)(3) and (4), apparently worried that someone might give a copy of the Declaration of Independence or The Federalist Papers to a Nork SDN. Section 510.213 of the new regulations contains the normal travel and informational materials exemptions but
section 510.213(a) says this:
 
(a) United Nations Participation Act. The exemptions described in this section do not apply to transactions involving property or interests in property of persons whose property and interests in property are blocked pursuant to the authority of the United Nations Participation Act, as amended (22 U.S.C. 287c(b)) (UNPA).
 
And the
note to that section says this:
 
Persons whose property and interests in property are blocked pursuant to the authority of the UNPA include those listed on both OFAC’s Specially Designated Nationals and Blocked Persons List (SDN List) and the Consolidated United Nations Security Council Sanctions List (see
https://www.un.org) as well as persons listed on the SDN List for being owned or controlled by, or acting for or on behalf of, such persons.
 
Of course, to add extra unnecessary confusion, the introductory text to the new rules in the Federal Register says
this:
 
The exemptions described in this section do not apply to any transactions involving property or interests in property of certain persons whose property and interests in property are blocked pursuant to the provisions of E.O. 13551, E.O. 13722, or E.O. 13810 and that are blocked pursuant to the authority of the UNPA in addition to IEEPA.
 
This pretty much renders the Note to section 510.213 useless. The list of persons blocked under the UNPA includes everyone designated under those three orders and given program tag listing of DPRK2, DPRK3 and DPRK4. The problem is that is a much bigger list than those on the
Consolidated United Nations Security Council Sanctions List. There are 133 North Korean individuals and entities on the UN List, whereas there are 314 North Korean individuals and entities designated on the SDN List under DPRK2, DPRK3 and DPRK4.
 
The
UNPA gives the President the power “whenever the United States is called upon by the Security Council to apply measures which said Council has decided are to be employed to give effect to its decisions under said Charter” to issue executive orders “to the extent necessary to apply such measures.” Without question, when a Security Council Resolution requires member states to block particular entities and individual, the President has the power to block them under UNPA.  So OFAC can, if it wants, forbid U.S. persons from giving copies of
The Interview, The Bible or John Stuart Mill’s On Liberty to any party on the UN List, no matter how silly and pointless such a restriction would be.
 
But the Security Council Resolutions at issue here under which the Executive Orders were issued do not say block these particular individuals and whoever the heck else you want to block while you’re at it. So individuals blocked by OFAC that aren’t also blocked under UN Security Council Resolutions are not lawfully blocked under the UNPA and the full extent of the travel and informational materials exemptions in section 1702(b) of IEEPA have to be applied by OFAC to those individuals not also on the UN Sanctions List. Don’t bet on that ever happening.

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TEEX/IM TRAINING EVENTS & CONFERENCES

TE_a121
. CORRECTION: ECS Presents “ITAR/EAR Boot Camp,” 10-11 Jul in Long Beach, CA

(Source: Suzanne Palmer, spalmer@exportcompliancesolutions.com)
 
[Editor’s Note: Unlike stated in yesterday’s item, the event is not in Orlando, FL, but in Long Beach, CA.]
 
* What: ITAR/EAR Boot Camp, Long Beach CA
* When: July 10-11, 2018
* Sponsor: Export Compliance Solutions (ECS)
* ECS Speaker Panel:  Suzanne Palmer, Mal Zerden
* Register:
Here
o
r by calling 
866-238-4018 or e-mail spalmer@exportcompliancesolutions.com
* Discount: Daily Bugle subscribers get a 10% discount when they use the coupon code: ECS10PERBUGLE when registering for this event.

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

TE_a3
22.
List of Approaching Events – 17 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 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: Long Beach, CA; ”
The Ins & Outs of ATA Carnets“; Foreign Trade Association
* 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: Webinar; “Classification in the Schedule B“; Foreign Trade Association
* 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

# Mar 28: Webinar; ”
Export Compliance for Sales and Marketing“; Export Compliance Training Institute

#
Apr 2-5: San Diego, CA; “Best Customs Broker Exam Course“; GRVR Attorneys

* 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 23-27: Dallas, Texas; “Best Customs Broker Exam Course“; GRVR Attorneys 
* 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 26: Webinar; “Export Control Reform“; Foreign Trade Association
* 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 14-15: Washington, D.C.; ”
BIS Update 2018 Conference on Export Controls and Policy“; BIS

* 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 5-6: Chicago, IL; ”
EAR Boot Camp“; 
American Conference Institute

# Jun 7: Chicago, IL; “ITAR Boot Camp“; 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: Webinar; “ACE for Importers and Exporters“; Foreign Trade Association
* 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 11-14: Laredo, Texas; “Best Customs Broker Exam Course“; GRVR Attorneys 
* 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
# Jul 19-20: Torrance, CA; “Customs Compliance For Import Personnel“; Foreign Trade Assocaition
* 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 21-24: Detroit, Michigan; “Best Customs Broker Exam Course“; GRVR Attorneys 
* 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 22-26:
 Dallas, Texas; “Best Customs Broker Exam Course“; GRVR Attorneys

* 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 6: Manchester, UK; “Introduction to Export Controls and Licenses“; 
* 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_a123
. Bartlett’s Unfamiliar Quotations

(Source: Editor)
*
Maxwell Maltz (10 Mar 1889 – 7 Apr 1975; was an American cosmetic surgeon and author of Psycho-Cybernetics (1960), which was a system of ideas that he claimed could improve one’s self-image. In turn, the person would lead a more successful and fulfilling life. He wrote several books, among which
Psycho-Cybernetics was a long-time bestseller – influencing many subsequent self-help teachers.)
  
– “Often the difference between a successful man and a failure is not one’s better abilities or ideas, but the courage that one has to bet on his ideas, to take a calculated risk, and to act.” 
  – “The ‘self-image’ is the key to human personality and human behavior. Change the self-image and you change the personality and the behavior.”
 
*
William Cobbett (William Cobbett (9 Mar 1763 – 18 Jun 1835; was an English pamphleteer, farmer, journalist and member of parliament. He wrote many polemics, on subjects from political reform to religion, but is best known for his book from 1830, Rural Rides, which is still in print today.)
  – 
“You never know what you can do ’till you try.”
  – “Men fail more often from want of perseverance than from want of talent.”
 
Friday funnies:
 
Q: What is red and smells like blue paint?
A: Red paint.
 
Q: What do you call bears with no ears?
A: B.
 
*  I went in to a pet shop and said, “I’d like to buy a goldfish.” The guy said, “Do you want an aquarium?”  I said, “I don’t really care what its sign it is.”

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

EN_a224. 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:
5 Mar 2018: 83 FR 9182-9204: North Korea 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_a325
. 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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