;

18-0323 Friday “Daily Bugle”

18-0323 Friday “Daily Bugle”

Friday, 23 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 Announces ACE Production Scheduled Maintenance, 24-25 Mar
  4. DHS/CBP Announces Additional Duty on Imports of Steel and Aluminum Articles under Section 232
  5. State/DDTC: (No new postings.)
  6. President Approves Section 232 Tariff Modifications 
  7. EU Adopts Guidelines on the Framework for Post-Brexit Relations with the UK 
  1. Reuters: “China Urges U.S. Away from ‘Brink’ as Trump Picks Trade Weapons”
  2. ST&R Trade Report: “Dates and Deadlines: Steel Tariffs, Importing Basics, Trade Committee, CPSC Priorities”
  1. D.M. Edelman: “President Trump Announces Section 301 Tariffs on China: What We Know So Far”
  2. L. Béraud-Sudreau: “War in Yemen: European Divisions on Arms-Export Controls” 
  3. M.V. Miller: “President Proposes Additional Duties of 25% on China Goods” 
  1. List of Approaching Events – 10 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 (22 Mar 2018), FACR/OFAC (19 Mar 2018), FTR (20 Sep 2017), HTSUS (14 Mar 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.]

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

OGSOTHER GOVERNMENT SOURCES

OGS_a11
. Items Scheduled for Publication in Future Federal Register Editions
 

(Source:
Federal Register)

[No items of interest noted today.]

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

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OGS_aa23. DHS/CBP Announces ACE Production Scheduled Maintenance, 24-25 Mar
(Source: CSMS #18-000242, 23 Mar 2018.)
 
There will be ACE PRODUCTION Scheduled Maintenance Saturday evening, March 24, 2018 from 2200 ET to 0400 ET Sunday, March 25, 2018.
 
ACE will perform infrastructure maintenance activities and the following ACE Deployments during this time:
 
Foreign Trade Zone (FTZ)
 
  – Logic updated to prevent erroneous “024INVALID SCAC” responses on some FTZ Admissions Data (FT) messages.
* * * * * * * * * * * * * * * * * * * *

(Source:
CSMS #18-000240, 22 Mar 2018.)
 
BACKGROUND:
 
On March 8, 2018, the President issued Proclamations 9704 and 9705 on Adjusting Imports of Steel and Aluminum into the United States, under Section 232 of the Trade Expansion Act of 1962, as amended (19 U.S.C. 1862), providing for additional import duties for steel mill and aluminum articles, effective March 23, 2018. See the Federal Register, 83 FR 11619 and 83 FR 11625, March 15, 2018. On March 22, 2018, the President issued Proclamations on Adjusting Imports of Steel and Aluminum into the United States.
 
These duty requirements are 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.
 
COMMODITY:
 
Steel mill and aluminum articles, as specified in the Presidential Proclamations.
 
COUNTRIES COVERED:
 
March 23, 2018 through April 30, 2018: All countries of origin except Canada, Mexico, Australia, Argentina, South Korea, Brazil and member countries of the European Union (Austria, Belgium, Bulgaria, Croatia, Cyprus, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, Netherlands, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden and the United Kingdom).
 
As of May 1, 2018: All countries of origin.
 
Please note this is based on the country of origin, not the country of export.
 
ENTRY SUMMARY FILING INSTRUCTIONS:
 
Steel Products
 
In addition to reporting the regular Chapters 72 & 73 of the Harmonized Tariff Schedule (HTS) classification for the imported merchandise, importers shall report the following HTS classification for imported merchandise subject to the additional duty:
 
  – 9903.80.01 (25 percent ad valorem additional duty for steel mill products)
 
Aluminum Products
 
In addition to reporting the regular Chapter 76 of the HTS classification for the imported merchandise, importers shall report the following HTS classification for imported merchandise subject to the additional duty:
 
  – 9903.85.01 (10 percent ad valorem additional duty for aluminum products)
 
Importers and filers failing to submit the required Chapter 99 HTS classifications with the entry summary information for imports under the specified Chapter 72, 73, and 76 HTS classifications for the covered countries of origin will receive the following reject messages:
 
  – E1 IQ10 LINE SUBJECT TO QUOTA
  – E1 FQ09 QUOTA NOT ALLOWED FOR ENTRY TYPE
  – E1 FQ05 BANNED IMPORT
  – E1 RF998 TRANSACTION DATA REJECTED
 
Note: Quota is not in effect, but this ACE functionality is being used to validate entry summary transmissions and reject when validations determine the data is missing the required chapter 99 number.
 
Importers or filers receiving one of the reject messages above, who have researched their classification and dates to confirm the entry summaries were incorrectly rejected, should contact their assigned Client Representative with the results of their review.
 
Additional Information
 
Any steel or aluminum article subject to the Section 232 duties that is admitted into U.S. foreign trade zones on or after 12:01 a.m. eastern daylight time on March 23, 2018, must be admitted as “privileged foreign status” as defined in 19 CFR 146.41, and will be subject upon entry for consumption to any ad valorem rates of duty related to the classification under the applicable HTSUS subheading.
 
Any steel or aluminum article that was admitted into U.S. foreign trade zones under “privileged foreign status” as defined in 19 CFR 146.41, prior to 12:01 a.m. eastern daylight time on March 23, 2018, will likewise be subject upon entry for consumption to any ad valorem rates of duty related to the classification under applicable HTSUS subheadings imposed by the Proclamations.
 
The merchandise covered by the additional duties may also be subject to antidumping and countervailing duties.
 
CBP will issue additional guidance on entry requirements for any products excluded from these measures, as soon as information is available. CBP will also issue updated guidance if there are any changes to these measures, including any changes to exempted countries and any new requirements, such as quota requirements.
 
FOR FURTHER INFORMATION:
 
For more information, please refer to the Presidential Proclamations on Adjusting Imports of Steel and Aluminum into the United States, Federal Register, 83 FR 11619 and 83 FR 11625, March 15, 2018; and the March 22, 2018 Presidential Proclamations on Adjusting Imports of Steel and Aluminum into the United States.
 
Questions related to Section 232 entry filing requirements should be emailed to adcvdissues-hq@cbp.dhs.gov. Questions from the importing community concerning ACE rejections should be referred to their Client Representative.
 
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(Source:
The White House, 22 Mar 2018.)
 
Today, based on ongoing dialogues, President Donald J. Trump authorized the modification of the Section 232 tariffs on steel and aluminum imports to suspend the tariffs for certain countries before they take effect. These suspensions are based on factors including ongoing discussions regarding measures to reduce global excess capacity in steel and aluminum production by addressing its root causes.
 
The tariffs on steel and aluminum imports from the following countries are suspended until May 1, 2018, pending discussions of satisfactory long-term alternative means to address the threatened impairment to U.S. national security:
 
  – Argentina;
  – Australia;
  – Brazil;
  – Canada;
  – Mexico;
  – the member countries of the European Union; and
  – South Korea.
 
By May 1, 2018, the President will decide whether to continue to exempt these countries from the tariffs, based on the status of the discussions. The European Union will negotiate on behalf of its member countries.
 
The President retains broad authority to further modify the tariffs, including by removing the suspensions or suspending additional countries. Any country not currently suspended remains welcome to discuss a possible suspension with the United States based on a shared commitment to addressing global excess steel and aluminum capacity and production.
 
The Administration will closely monitor imports of steel and aluminum imports from exempted countries, and the United States Trade Representative, in consultation with the Secretary of Commerce and the Director of the National Economic Council, may advise the President to impose quotas as appropriate. Further action by the President would be needed to implement any quota the President might decide to adopt.
 
The tariffs proclaimed in Presidential Proclamations 9704 and 9705 will go into effect on 12:01 a.m. on Friday, March 23, 2018.
 
The process for directly affected parties to apply for an exclusion for specific steel or aluminum products that they need remains in place, as announced in the two Presidential Proclamations and subsequent Federal Register notices by the U.S. Department of Commerce. Secretary Ross, in consultation with other Administration officials, will evaluate exclusion requests for products, taking into account national security considerations. In that evaluation, the Secretary will consider whether a product is produced in the United States of a satisfactory quality or in a sufficient and reasonably available amount.

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The European Council (Art. 50) on 23 March 2018 adopted guidelines on the framework for post-Brexit relations with the UK.
 
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NWSNEWS

(Source:
Reuters, 23 Mar 2018.)
 
China urged the United States on Friday to “pull back from the brink” as President Donald Trump’s plans for tariffs on up to $60 billion in Chinese goods moved the world’s two largest economies closer to a trade war.
 
The escalating tensions sent shivers through financial markets as investors foresaw dire consequences for the global economy if trade barriers start going up.
 
Trump is planning to impose the tariffs for what he says is misappropriation of U.S. intellectual property. A probe was launched last year under Section 301 of the 1974 U.S. Trade Act.
 
  “China doesn’t hope to be in a trade war, but is not afraid of engaging in one,” the Chinese commerce ministry responded in a statement.  
“China hopes the United States will pull back from the brink, make prudent decisions, and avoid dragging bilateral trade relations to a dangerous place.”
 
In a presidential memorandum signed by Trump on Thursday, there will be a 30-day consultation period that only starts once a list of Chinese goods is published. That effectively creates room for potential talks to address Trump’s allegations on intellectual property theft and forced technology transfers.  …
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Following are highlights of regulatory effective dates and deadlines and federal agency meetings coming up in the next week. …
 
– 26 Mar: deadline for comments to FTZ Board on production requests
– 28 Mar: deadline for nominations to Intergovernmental Policy Advisory Committee on Trade
– 28 Mar: deadline for comments to CPSC on FY 2019/2020 agenda and priorities
– 30 Mar: deadline for comments on USDA information collections on foreign plants
– 30 Mar: deadline for comments to ITC on remedial orders on carbon and alloy steel products
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COMMCOMMENTARY

        
* Author: Doreen M. Edelman, Esq., Baker Donelson LLP, 202-508-3460, dedelman@bakerdonelson.com
.
 
On March 22, 2018, President Trump directed the Office of the U.S. Trade Representative to implement tariffs on approximately $50 billion worth of Chinese products.  The tariffs are a result of the USTR Section 301 investigation and determination regarding China’s policies related to forced technology transfers and the theft of U.S. intellectual property.
 
Reports indicate that the USTR has already identified a potential list of 1,300 products eligible for new tariffs.  A full proposed list of products subject to additional tariffs will be issued within 15 days from the announcement.  The tariffs will target products in the strategic sectors of Xi Jinping’s “Made in China 2025” plan – including robotics, aerospace, maritime, rail equipment, electric vehicles, telecommunication and biopharmaceutical products.  According to the USTR Section 301 Fact Sheet, 25% ad valorem duties could be imposed, and USTR will propose additional tariffs against Chinese products with an annual trade value commensurate to the harm caused to the U.S. economy from China’s unfair policies.
 
The proposed list will be issued in a Federal Register notice for public comment on the proposed tariff action. Comments will then be due 30 days from the list’s publication.  Following a review of the comments by USTR and the interagency Section 301 committee, the tariffs will then likely go into effect 60 days after the public comment process is complete and the final product list is published.
 
In addition, the President directed the USTR to confront China’s technology licensing practices through a World Trade Organization (WTO) dispute.  He also directed the Treasury Department to work with other federal agencies to further restrict Chinese investment practices involving the acquisition of sensitive technologies.  We will provide further updates on the product list when it is issued, but for now, importers of Chinese goods, particularly in the above-mentioned industries, should prepare to review their inventories for which products may be affected by the announcement.
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* Author: Lucie Béraud-Sudreau, Research Fellow for Defence Economics and Procurements, International Institute for Strategic Studies, contact here.
 
On 9 March 2018, the British government signed a memorandum of intent with Saudi Arabia for the sale of 48 additional Eurofighter Typhoon combat aircraft, on top of the 72 Riyadh purchased in 2007. Mindful of its defence-industrial ambitions, the Kingdom may have asked for final assembly of the aircraft to take place in its territory. In addition, the deal highlights the significant differences in European states’ export-control policies.
 
The ongoing negotiation between the United Kingdom and Saudi Arabia occurs at a time when the debate on arms sales to coalition states involved in the war in Yemen is heating up throughout Europe. As noted by the World Peace Foundation and others, an increasing number of European states are debating the appropriateness of arms sales to states participating in the Saudi-led Operation Restoring Hope.
 
Some of the weapons supplied to these states by European countries in previous years are being used in the conflict; for example, the United Arab Emirates’ French-manufactured Leclerc main battle tanks and AMV armoured personnel carriers built in Poland and sold by Finnish Patria in 2016, as well as  Typhoon aircraft jointly produced by four European nations. Coalition member Jordan has deployed to Yemen F-16 combat aircraft sold by the Netherlands in 2013. The coalition states also use European-made munitions, such as the British Paveway-IV precision guided bomb.
 
While these examples relate to arms supplied prior to the outbreak of conflict, today’s debate is about ongoing exports and licensing since April 2015. Looking at the major regional powers involved in the war, Egypt, Saudi Arabia and the UAE, the latest available data on arms exports reveals that the main European suppliers to these countries are France, Germany, Italy, Spain, Sweden and the UK (see Figures 1-3 and Table 1).
 
However, as these arms sales have become increasingly controversial, decisions to stop exporting to coalition states have divided European states on the issue. In February 2016, the European parliament called for the imposition of an arms embargo against Saudi Arabia, stating that arms sales would be in breach of the European Common Position 2008/944/CFSP on such exports. Shortly after, the Dutch parliament voted in March 2016 to ban arms sales to Saudi Arabia. Finnish President Sauli Niinistö, re-elected in January 2018, committed during a campaign debate to ban arms sales to the UAE. In Germany, the coalition agreement between the CDU/CSU and the SPD adopted in February 2018 indicated that, under the new government, Germany would not licence any more arms sales to the coalition states. Norway decided in January 2018 to also suspend arms sales to the UAE and ban new licences. Although Norway is not part of the EU, it has aligned itself with the EU Common Position on arms exports.
 
Meanwhile, Sweden has not made any specific announcements regarding the war in Yemen, but is due to implement new export-control guidelines on 15 April, including for ‘follow-on deliveries’ (for example, spare parts) for existing contracts. The new guidelines include a stricter human-rights threshold, and focus on the democratic status of the recipient state in the export-licence approval criteria. However, foreign- and defence-policy decisions could override such considerations. Sweden has, in particular, a strong arms-trade relationship with the UAE, to whom it exports the Saab Erieye airborne and early-warning aircraft. The first Saab GlobalEye ISR aircraft for the UAE was rolled out on 23 February.
 
However, despite the emergence of domestic debate on the issue, other major European arms suppliers are taking an opposing position and are not considering ceasing arms sales to members of the Saudi-led coalition. In the UK, in December 2016, the chairs of the Commons International Development Select Committee and the Committees on Arms Export Controls recommended that the Foreign and Commonwealth Office suspend export licences for arms that could be used in the Yemen war, after the United States considered halting a sale of Raytheon-manufactured precision-guided munitions to Saudi Arabia. Nevertheless, the British government refused to stop sales of precision-guided Paveway-IV bombs. NGO Campaign Against Arms Trade attempted legal action against UK arms sales to Saudi Arabia, but in July 2017 the High Court ruled that such sales were lawful, dismissing the claim. The latest negotiations for the sale of additional Typhoon combat aircraft reflect the continuity of the UK’s arms-export policy as regards to Saudi Arabia.
 
France sits on the same side as Britain in this European divide. There is usually little discussion in France on its arms-export policy, although the war in Yemen did see the start of a public debate. The minister of the armed forces has been questioned several times by the media, and has justified arms sales to Saudi Arabia on the basis that the weapons ‘were not supposed to be used’. Some divergences in the export-control decision-making process appear to have surfaced, but so far France’s arms-export policy regarding Saudi Arabia and the UAE has been marked by continuity, as observed during the presidencies of both François Hollande and Emmanuel Macron. Similarly, in Italy, where Mk82, Mk83 and Mk84 bombs manufactured in Sardinia were used by Saudi Arabia in Yemen, in September 2017 parliament refused to apply an embargo.
 
These divisions on a key aspect of armaments policy occur at a time when European countries, in particular those within the EU, are trying to deepen their level of cooperation in defence research and development, and in capabilities development and procurement. They also underscore the failure of initiatives over the past two decades to further the harmonisation of European arms-export controls. Indeed, 2018 marks the twentieth anniversary of the Letter of Intent, signed by the six largest arms manufacturers in Europe, and the tenth anniversary of the Common Position on arms exports (which itself succeeded the 1998 Code of Conduct on arms exports). Although differing in scope and intent, these agreements aimed to improve cooperation among European states on arms-export controls. While EU directive 2009/43/EC on intra-European arms transfers might have led to harmonisation in the licensing process, the political aspect of arms exports has not progressed.
 
Indeed, such divergences on export controls put at risk current efforts to deepen and rationalise the defence-industrial landscape in Europe. This is particularly the case for cooperation between France and Germany. As noted before, while Germany calls for further harmonisation of EU export-control guidelines, France stresses its attachment to national export controls. On the back of current initiatives, such as the European Defence Fund, Permanent Structured Cooperation, the Coordinated Annual Review on Defence and the European Intervention Initiative, there is an opportunity to push these discussions forward. But strong political will would be required to find common ground on this subject.
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COMM_a312. M.V. Miller: “President Proposes Additional Duties of 25% on China Goods” 
(Source: Author, 22 Mar 2018.)
 
* Author: Marshall V. Miller, Esq., Miller & Company P.C., 816-561-4999, mmiller@millerco.com.
 
President Trump initiated a Section 301 action on March 22nd which proposes additional duties of 25% on a wide variety of China origin goods.  The list will include aerospace, information and communication technology, and machinery and will be made public by the United States Trade Representative within 15 days.  The proposed list will be published for public comment. 
 
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TEEX/IM TRAINING EVENTS & CONFERENCES

TE_a3
13.
List of Approaching Events – 10 New Events Listed
(Sources: Editor and Event Sponsors)

Published every Friday or last publication day of the week. Please, send event announcements to 
jwbartlett@fullcirclecompliance.eu, composed in the below format:

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

#” New 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)

Online: Customs Broker Exam Prep Course; The Exam Center
 
Training by Date:
 

* Mar 25-28: Frankfurt, Germany; “6th Annual European Compliance & Ethics Institute“; Society of Corporate Compliance and Ethics
* March 26: TaxWatch Webcast; “
The Short and Long Game On Section 232 Tariffs

; KPMG LLP;
rtatum@kpmg.com 
* 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 Essentials 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 5: Tulsa, OK; “35th Annual Oklahoma World Trade Conference“; U.S. Commercial Service
* Apr 5: Westborough, MA; “Fundamentals of International Traffic in Arms Regulations (ITAR)“; Massachusetts Export Center
# Apr 5: Washington, D.C.; “EX/IM Annual Conference – General Data Protection Regulations“; Export-Import Bank of the United States
* Apr 6: Webinar; “Minimizing Risk in Routed Export Transactions“; Massachusetts Export Center
* Apr 9: Toronto, Canada; “Certified Classification Specialist (CCLS)“; Amber Road
* Apr 10: Webinar;Letters of Credit“; U.S. Commercial Service
# Apr 10: Arlington, VA; “SIA Exemptions Workshop;” Society for International Affairs
* 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 13: Webinar; “The Export Control Reform Act of 2018: What You Need to Know“; Massachusetts Export Center
* 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 25-26: Washington, D.C.; ”
11th Conference on Economic Sanctions Enforcement & Compliance“; American Conference Institute
* 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 1: Boston, MA; ”
Blockchain Technologies for the Warfighter“; NDIA

# May 1: Houston, TX; “D
* 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 10: North Reading; “Best Practices for Integrating Export Compliance Operations in a Global Organization“; Massachusetts Export Center

* May 11: Webinar; ”
Customs Valuation and Documentation for Tricky Transactions“; Massachusetts Export Center

* May 14-15: Washington, D.C.; “
BIS Update 2018 Conference on Export Controls and Policy
“; BIS
# May 15: Long Beach, California; “92 Annual World Trade Week & International Delegate Luncheon and Trade Fair“; Foreign Trade Association
* May 15-16: Cleveland, OH; “Complying with US Export Controls“; Bureau of Industry and Security

* May 16: Webinar; ”
Russia Sanctions Update & Complying with the OFAC 50% Rule“; Massachusetts Export Center

* 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 18: Fall River, MA; “Managing Export Operations & Compliance“; Massachusetts Export Center
* May 20-22: Portland, OR; “Spring 2018 Seminar;” National Association of Foreign Trade Zones (NAFTZ)

* Mar 22: Webinar; ”
Brexit Update: Implications for U.S. Exports to the U.K. and E.U. Webinar“; U.S. Commercial Service

* 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: Tewksbury, MA; “DFARS Cybersecurity 2.0: The Year of Continuous Monitoring“; NDIA New England
* 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: Boston, MA; “Export Regulatory Compliance Update“; Massachusetts Export Center
* 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 Association
* 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_a114
. Bartlett’s Unfamiliar Quotations

(Source: Editor)
Erich Fromm (Erich Seligmann Fromm; 23 Mar 1900 – March 18, 1980; was a German-born American social psychologist and psychoanalyst. His first seminal work was Escape from Freedom, viewed as one of the founding works of political psychology. Fromm’s most popular book was The Art of Loving.)
  – “Creativity requires the courage to let go of certainties.”
  – “The only truly affluent are those who do not want more than they have.”

Fannie Farmer (23 Mar 1857-15 Jan 1915; was an American culinary expert whose Boston Cooking-School Cook Book became a widely used culinary text.)

  – “Progress in civilization has been accompanied by progress in cookery.”     

Friday funnies:
 
* If you want to find out who loves you more–your wife or your dog–force them both into the trunk of your car, and drive around for an hour. When you open the trunk, which one is happier to see you?

* Never criticize a tough guy until you have walked a mile in his shoes.  That way, when you criticize him, you’ll be a mile away, and you’ll have his shoes.

* When I die, I want to go like my grandfather, who died peacefully in his sleep.  Not shrieking and waiving my arms like the passengers in his car.

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

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:
22 Mar 2018:
83 FR 12475-12483
: Addition of Certain Persons to the Entity List and Removal of Certain Persons from the Entity List; Correction of License Requirements 

 

FOREIGN ASSETS CONTROL REGULATIONS (OFAC FACR): 31 CFR, Parts 500-599, Embargoes, Sanctions, Executive Orders

  – Last Amendment:
19 Mar 2018: 83 FR 11876-11881: Inflation Adjustment of Civil Monetary Penalties

 

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 (16 March 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 approximately 250 footnotes containing case annotations, practice tips, Census/AES guidance, and explanations of the numerous errors contained in the official text. Subscribers receive revised copies in Microsoft Word 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. Government employees (including military) and employees of universities are eligible for a 50% discount on both publications at www.FullCircleCompiance.eu
 
* 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:
14 Mar 2018: Harmonized System Update 1803, containing 449 ABI records and 92 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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