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18-0413 Friday “Daily Bugle”

18-0413 Friday “Daily Bugle”

Friday, 13 April 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 Releases Updates Concerning ACE Statements Reports
  4. DoD/DSCA Releases 2 New Policy Memos, Updates Security Assistance Management Manual
  5. State/DDTC: (No new postings.)
  6. EU Amends Sanctions Against Iran and Democratic Republic of the Congo
  1. Expeditors News: “Update: U.S. – Israel Free Trade Agreement Shipments Will no Longer Require the Certificate of Origin”
  2. Newsweek: “Florida Gunmaker May Have Violated Russia Sanctions in Getting AK-47 Parts, Congressman Alleges”
  3. Reuters: “Russia Lawmakers Draft List of U.S. Imports that Could be Banned”
  4. ST&R Trade Report: “Dates and Deadlines: GSP, Export Regulations, Marking and Labeling, Tariffs, Supply Chains”
  5. WorldECR: “Bahraini Government Audit Reveals Bank Aided Evasion of Iran Sanctions”
  1. The Export Compliance Journal: “Understanding the EU Classification Regime”
  2. L. Gant: “With Additional Tariffs, Will Your Import Bond be Sufficient?” 
  3. M. Volkov: “OFAC Hits Russia with New Sanctions”
  4. Steptoe & Johnson Publishes Report Concerning FCPA/Anti-Corruption Developments in 2017 and 2018
  1. ECTI Presents “Mastering ITAR/EAR Challenges” in Annaplois, Maryland on May 22-23
  2. List of Approaching Events – 9 New Events Listed
  1. Bartlett’s Unfamiliar Quotations 
  2. Are Your Copies of Regulations Up to Date? Latest Amendments: ATF (15 Jan 2016), Customs (12 Apr 2018), DOD/NISPOM (18 May 2016), EAR (5 Apr 2018), FACR/OFAC (19 Mar 2018), FTR (20 Sep 2017), HTSUS (30 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.]

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OGSOTHER GOVERNMENT SOURCES

OGS_a11
. Items Scheduled for Publication in Future Federal Register Editions
 

(Source:
Federal Register)

* Commerce/BIS; NOTICES; Export Privileges; Denials; 
  – Earl Henry Richmond; 
  – Peter Steve Plesinger; and
  – Stephen Edward Smith [Included in the Daily Bugle of 11 Apr 2018. Publication Dates: 16 Apr 2018.] 

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OGS_aa23. 
DHS/CBP Releases Updates Concerning ACE Statements Reports

(Source: 
CSMS# 18-000283, 13 Apr 2018.)

Based on feedback from the trade community, CBP has simplified the Revenue data universe and has condensed the five statements (REV) reports into three reports (REV-101, REV-102, and REV-103). The names and brief descriptions of each of these reports are listed below.  

  – REV-101: Monthly Statement Overview – provides monthly statement data, and the monthly statement payment status defaults to “not paid.” 

  – REV-102: Daily Statement Overview – provides daily statement data (both periodic and regular), and the daily statement payment status defaults to “not paid” or “authorized.”

  – REV-103: Daily Statement Entry Summary List – provides daily statement data at the entry summary level, and the daily statement payment status defaults to “not paid” or “authorized.” This report now also displays actual amounts, as opposed to estimated amounts.

Each of these reports have separate views for brokers and importers, making them more similar to the AR-007 report format.

Please update any customized reports (based on the former REV reports) by removing data elements indicating “estimated amount” and including those representing “total” or “grant total” amounts. Please e-mail 
ace.reports@cbp.dhs.gov with any questions. 

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OGS_a3
4. 
DoD/DSCA Releases 2 New Policy Memos, Updates Security Assistance Management Manual

(Source: 
DoD/DSCA, 13 Apr 2018.) 
 

  This memorandum adds a new transportation surcharge account, L709, and identifies the line of accounting that should be used when loading information into shipping and billing systems for the new Counter-ISIL Equipment Fund (CTEF) programs established by the FY17 National Defense Authorizations Act (NDAA).

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5.

State/DDTC: (No new postings.)

(Source: 
State/DDTC)

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OGS_a5
6.

EU Amends Sanctions Against Iran and Democratic Republic of the Congo

(Source: 
Official Journal of the European Union, 13 Apr 2018.)
 
Regulations
 

Council Implementing Regulation (EU) 2018/565 of 12 April 2018 implementing Regulation (EU) No 359/2011 concerning restrictive measures directed against certain persons, entities and bodies in view of the situation in Iran

Council Implementing Regulation (EU) 2018/566 of 12 April 2018 implementing Article 9 of Regulation (EC) No 1183/2005 imposing certain specific restrictive measures directed against persons acting in violation of the arms embargo with regard to the Democratic Republic of the Congo
 
Decisions
 

Council Decision (CFSP) 2018/568 of 12 April 2018 amending Decision 2011/235/CFSP concerning restrictive measures directed against certain persons and entities in view of the situation in Iran

Council Implementing Decision (CFSP) 2018/569 of 12 April 2018 implementing Decision 2010/788/CFSP concerning restrictive measures against the Democratic Republic of the Congo

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NWSNEWS

(Source: 
Expeditors News, 11 Apr 2018.) 
 
On April 6, 2018, U.S. Customs and Border Protection (CBP) announced the phase out for the U.S.-Israel Free Trade Agreement certificate of origin.
 
The phase out of the certificate of origin will end June 30, 2018. Before this date, U.S. exporters may present the “Form A” certificate of origin, or the exporter may state on the commercial invoice, “I, the undersigned, hereby declare that unless otherwise indicated, the goods covered by this document fully comply with the rules of origin and the other provisions of the Agreement on the Establishment of a Free Trade Area between the Government of Israel and the Government of the United States of America.” 
 
After June 30, 2018, Israel will only accept a signed statement on the commercial invoice. There is no change for imports into the U.S. from Israel as CBP replaced the “Form A” requirement for imports with a signed affidavit from the importer on May 20, 1994.
 
The date of the initial signed agreement eliminating the certificate of origin for U.S. exports to Israel took place on May 10, 2017. The original agreement may be found 
here.

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(Source: 
Newsweek, 12 Apr 2018.) [Excerpts.] 
 
A United States congressman from Florida is questioning whether an American manufacturer of AK-47-style guns violated Russian sanctions, and he is asking for more information.
 
In a letter to the Department of the Treasury on Wednesday, Representative Ted Deutch, a Democrat, asked for information about Kalashnikov USA. The Florida-based company started as an importer of firearms from Kalashnikov Concern, a Russian company. After the U.S. imposed sanctions on the Russian company in 2014, Kalashnikov USA began manufacturing its own firearms.
 
But Deutch believes that the American manufacturer still has ties to the Russian entity and is violating the Russian sanctions.
 
  “Kalashnikov USA is reportedly using a web of shell companies to hide its relationship to the sanctioned Russian Kalashnikov company,” he 
wrote in the letter. The congressman pointed to 
news reports saying that in 2015, after the sanctions were in place, the company still stated on an application for tax incentives that it was receiving parts and components from Russia. … 

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NWS_a3
9. 
Reuters: “Russia Lawmakers Draft List of U.S. Imports that Could be Banned”
(Source: 
Reuters, 13 Apr 2018.) [Excerpts.] 
 
Russia’s lower house of parliament is to consider draft legislation that would give the Kremlin powers to ban or restrict a list of U.S. imports, reacting to new U.S. sanctions on a group of Russian tycoons and officials.
 
Senior lawmakers in the State Duma, which is dominated by Kremlin loyalists, said they had prepared the list ranging from food and alcohol to medicine and consulting services in response to Washington’s move last week. … 
 
The sectors listed in the draft which could be subject to bans or restrictions include U.S.-made software and farm goods, U.S. medicines that can be sourced elsewhere, and tobacco and alcohol.
 
It gives the government the power to ban cooperation with the United States on atomic power, rocket engines and aircraft making, and to bar U.S. firms from taking part in Russian privatization deals.  
 

The provision of auditing, legal and consulting services by U.S. firms could also be subject to bans or restrictions, and curbs could be imposed on U.S. citizens working in Russia. …   

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NWS_a4
10. 
ST&R Trade Report: “Dates and Deadlines: GSP, Export Regulations, Marking and Labeling, Tariffs, Supply Chains” 

(Source: 
Sandler, Travis & Rosenberg Trade Report, 13 Apr 2018.)
 
Following are highlights of regulatory effective dates and deadlines and federal agency meetings coming up in the next week.
 
  April 16 – deadline for petitions to 
change GSP coverage
  April 16 – effective date of USDA final rule allowing 
imports of bellflowers from Denmark
  April 16 – deadline for comments to USTR on 
export subsidies in India
  April 17 – deadline for comments to FTZ Board on proposed 
expansion of production authority at motor vehicle facility
  April 18 – effective date of USDA final rule restructuring regulations on 
imports of plants for planting
  April 18 – meeting of President’s Advisory Council on 
Doing Business in Africa
  April 19 – meeting of Advisory Committee on 
Supply Chain Competitiveness
  April 19 – deadline for comments to ITC on 
IPR infringement petition on dermatological treatment devices

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NWS_a5
11. 
WorldECR: “Bahraini Government Audit Reveals Bank Aided Evasion of Iran Sanctions”

(Source: 
WorldECR News, April 2018.) [Excerpts.] 
 
A Bahraini government audit has revealed that a Persian Gulf bank helped Iran to evade sanctions for over a decade. Future Bank – a joint venture between Iranian and Bahraini banks – allegedly hid around $7bn worth of transactions between 2004 and 2015, at a time when sanctions prohibited Iranian banks from accessing the international financial markets.
 
Bahraini regulators closed Future Bank in 2015, prompting two Iranian shareholders to file a complaint in The Hague against Bahrain for ‘improperly’ closing down the bank. They also sought the recovery of frozen assets. … 
 
Future Bank was added to the US Department of the Treasury’s Office of Foreign Assets Control (‘OFAC’)’s Specially Designated Nationals (SDN) List in 2008 for being controlled by Iran’s Bank Melli and was also sanctioned by the EU in 2010. It was removed from both lists in 2016 as part of the Joint Comprehensive Plan of Action (‘JCPOA’), but US parties were still prohibited from dealing with it as part of the government of Iran.

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COMMCOMMENTARY

 
The export of controlled goods is highly regulated in the European Union, as they are in the United States, for both defense-related and “dual-use” (civilian products that have military applications) items.
 
Goods for import and export are classified for tariffs and trade statistics using the Harmonized Tariff System (HTS). Controlled goods have an additional independent classification, either as a military or dual-use item.
 
Each country (or economic union or consortium of countries) develops national schedules for their concessions based on an international standard. For HTS, that standard is the World Trade Organization Brussels tariff nomenclature. For controlled goods, the international standard is The Wassenaar Arrangement. Established in 1996, The Wassenaar Arrangement is a voluntary export control regime, whose 42 member-countries exchange information on transfers of conventional weapons and dual-use goods and technologies, and produce the base classification tables for both Dual-Use and Munitions List items.
 
The United States has improvised on Wassenaar dual-use classifications more than any other country, layering a license determination system over the classifications (based on Reasons for Control to specific destinations defined on a Country Chart), a license exceptions scheme, and also adding many items in designated optional spots in the numbering scheme (for instance the “600 series” items for U.S. Export Control Reform). For Military List items, the U.S. developed the Wassenaar Guidelines into its United States Munitions List (USML). None of these U.S. innovations apply to other countries, which have their own schedules adapted from Wassenaar, and different license determination systems, usually with General Authorizations for exceptions to specific destinations.
 
In the Wassenaar Arrangement 
Guidelines and Procedures the list of restricted technology classification items is in two parts: the “List of Dual-Use Goods and Technologies” (also known as the Basic List) and the “Munitions List.” The Basic List is composed of ten categories, as follows:
 
Category 1 – Special Materials and Related Equipment
Category 2 – Materials Processing
Category 3 – Electronics
Category 4 – Computers
Category 5 – Part 1 – Telecommunications
Category 5 – Part 2 – Information Security
Category 6 – Sensors and Lasers
Category 7 – Navigation and Avionics
Category 8 – Marine
Category 9 – Aerospace and Propulsion

 
The Basic List has two nested subsections-Sensitive and Very Sensitive. Items on the Very Sensitive List include materials for stealth technology, such as equipment that could be used for submarine detection, advanced radar, and jet engine technologies.
 
The Munitions List has 22 categories, which are not labeled.
As mentioned, and as can be seen by the headings, the United States adopted the Wassenaar dual-use categories for the U.S. Commerce Control List, along with the Munitions List categories for the United States Munitions List (USML). Other countries participating in The Wassenaar Arrangement also adopt these structures and classification items, including Canada and the countries of the European Union.
 
In the European Union, the Wassenaar classification schedules are annexes in the respective EU Council regulations enacted for the control of dual-use and military goods.
 
The current EU base regulation for dual-use is Annex I to the 
COUNCIL REGULATION (EC) No 428/2009 of 5 May 2009 setting up a Community regime for the control of exports, transfer, brokering and transit of dual-use items.[FN/1] This 2009 regulation is revised and amended regularly, the latest full edition being Nr. 1969/2016.
 
Annex II in the Regulation is the 
Community General Export Authorization NoEU001. Annexes IIIa and IIIb are models for individual or global export authorization forms and brokering services authorization forms.
 
Annex IV, very significantly, contains details of classification items where an “authorization shall be required for intra-Community transfers of dual-use items …. Items listed in Part 2 of Annex IV shall not be covered by a general authorization.” These include Items of stealth technology, Community strategic control and cryptography, Missile Technology Control Regime (MTCR) technology, Chemical Weapons Convention (CWC) items, and Nuclear Suppliers Group (NSG) technologies. A classification item appearing in Annex IV overrides any other consideration for purposes of EU export licensing.
 
The dual-use Annex I in the main Regulations is sometimes supplemented by National Controls implemented by individual countries within the EU, applying to that jurisdiction only – in particular U.K., Germany, France, and Italy.
 
The current EU base regulation for military items is the 
COMMON MILITARY LIST OF THE EUROPEAN UNION (equipment covered by Council Common Position 2008/944/CFSP defining common rules governing the control of exports of military technology and equipment), originally published as Nr. 944/2008, revised 9.4.2014.
 
An important thing to understand about these regulations is that the EU classifications for dual-use and national amendments are the classifications used for export declarations and for the use of General Authorizations. The classifications in the EU Common Military List are 
not the classifications used for the export of defense articles. Although based on the EU Common Military List, military goods and technologies are classified using the National Controls implemented by the respective countries. The munitions schedules published by EU countries generally only contain classifications for goods known to be manufactured or produced in that country, or a country will have no Military List at all if it does not produce any munitions articles for export. Dual-use goods [listed on Annex I] travel freely between countries within the European Union. [Dual-Use Goods listed on Annex IV, however, require a license or authorization.] In general, military goods require a license or authorization for exports to other EU countries as well as abroad.
 
The classification of dual-use goods in the EU is usually undertaken as a comparison of sources made in parallel-or at least this is a helpful and assuring approach. Accurate technical detail is essential in the classification of controlled goods, which are often decided, and also found exempt-or-not (“EAR99” in the United States), on the basis of the fine detail of engineering specifications.
 
The classification sources entailed for EU are the Wassenaar Basic List, the U.S. Commerce Control List (ECCN), the EU dual-use Council Regulation Annex I, and any additional National items for the country from which you are exporting.
 
These are the main points about effective EU controlled goods classification, with a reminder that effective classification is in the details. Accurate technical detail on the basis of up-to-date product specifications is essential.
 
———
  [FN/1] Information regarding Annexes sourced from the 
Official Journal of the European Union. Available 
here. Accessed April 11, 2018.

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(Source: 
Shap Talk, Issue 192, April 2018.)
 
* Author: Liz Gant, Corporate Regulatory Compliance Analyst, Shapiro. Contact details available 
here.
 
When President Trump announced the additional duties on steel (25%) and aluminum (10%), did you think about how this may impact your import bond?
 
At this point, we don’t know how long these additional duties will be in effect, but please don’t lose sight of how additional duties can and will impact your import bond limit. Customs uses duties, taxes and fees based on the previous 12 months to evaluate the sufficiency of your bond. All duties must be considered to calculate your bond limit. [
Here] is an example of how the import bond limit may increase for an importer of steel valued at $10 Million for a 12-month period.
  
A $300,000.00 bond may require a new bond application, indemnity and financial records for the surety to review.
 
While the additional tariffs are in place, bond sufficiency should be monitored by the importer closely. An importer does not want to be surprised if Customs deems their bond insufficient and a shipment is delayed while the importer gathers the information required for the surety. This will definitely cause more headache and cost for importers on top of the additional tariffs. Importers must be proactive and review their bond amount for sufficiency. Reach out to Shapiro or your surety for guidance with your specific situation.

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(Source: 
Volkov Law Group Blog, 11 Apr 2018. Reprinted by permission.) 
 
* Author: Michael Volkov, Esq., Volkov Law Group, 
mvolkov@volkovlaw.com, 240-505-1992. 
 
On April 6, 2018, OFAC announced a new round of sanctions against Russian individuals and companies.  (For Press Release 
Here; new FAQs 
Here; and new General Licenses 12
Here and 13 
Here).  Relying on its authority under existing executive orders, OFAC designated seven Russian oligarchs and 12 companies they own or control, 17 senior Russian government officials and a state-owned weapons trading company, and its subsidiary, a Russian bank.  In announcing the new sanctions, the US government cited Russia’s continue occupation of Crimea, its instigation of violence in eastern Ukraine, supplying the Assad regime with materials and weapons, attempting to subvert Western democracies, and malicious cyber-attacks.
The seven oligarchs include:
 
  – Vladimir Bogdanov, the Director General and Vice Chairman of the Board of Directors of Surgutneftegaz, a vertically integrated oil company operating in Russia.
  – Oleg Deripaska has been investigated for money laundering, and has been accused of threatening the lives of business rivals, illegally wiretapping a government official, and taking part in extortion and racketeering.
  – Suleiman Kerimov is a member of the Russian Federation Council.  On November 20, 2017, Kerimov was detained in France and held for two days. He is alleged to have brought hundreds of millions of euros into France – transporting as much as 20 million euros at a time in suitcases, in addition to conducting more conventional funds transfers – without reporting the money to French tax authorities.
  – Igor Rotenberg acquired significant assets including Russian oil and gas drilling company Gaqzprom Burenie from his father, Arkady Rotenberg, after OFAC designated Arkady in March 2014.
  – Kirill Shamalov married Vladimir Putin’s daughter Katerina Tikhonova in February 2013 and shortly thereafter, he acquired a large portion of shares of Sibur, a Russia-based company involved in oil and gas exploration, production, processing, and refining.  A year later, he was able to borrow more than one $1 billion through a loan from Gazprombank.
  – Andrei Skoch is being designated for being an official of the Government of the Russian Federation.  Skoch is a deputy of the Russian Federation’s State Duma.  Skoch has longstanding ties to Russian organized criminal groups, including time spent leading one such enterprise.
  – Viktor Vekselberg is the founder and Chairman of the Board of Directors of the Renova Group, an asset management and investment company.  Vekesberg has been accused of bribing top government officials in Russia.
 
OFAC also issued new General Licenses 12 and 13.
General License 12 authorizes US persons and company to conduct transactions, until June 5, 2018, which are ordinarily incident to continuity of operations or to facilitate wind-down of a business relationship, including salary payments, pension payments or other benefits by the blocked entities listed in General License 12.  US persons are prohibited from continuing employment with any designated company or sitting on the board of any blocked entity.
 
General License 13 authorizes certain divestment transactions and transfer activities related to debt, equity or other holdings in the blocked entities for a period of time ending May 7, 2018.
 
The new sanctions raise compliance issues relating to application of OFAC’s 50 percent rule.  For example, if a blocked person/oligarch holds less than a 50 percent interest in a U.S. company, the U.S. company is not itself blocked but the U.S. company has to block all property and interests in property in which the blocked person has an interest.  In such a scenario, the company may be able to continue operating, but the company may not be able to pay the blocked person/oligarch any required payments, dividends or disbursements of profits.
 
As always, companies have to be vigilant in reviewing proposed transactions involving Russian business interests, and in particular, identify beneficial owners of companies that may be owned, directly or indirectly, by a Russian blocked government official or oligarch.
 
Foreign companies may be subject to OFAC’s Russia sanctions depending on the nature of the transaction, their knowledge relating the transaction itself and the participants.  General Licenses 12 and 13, coupled with prior OFAC Guidance, may permit certain transactions otherwise prohibited so long as the transactions are not structured in a deceptive manner.

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(Source: 
Steptoe & Johnson LLP
, 12 Apr 2018.)

 
2017 was a year of transition for US enforcement of the Foreign Corrupt Practices Act (FCPA) and saw a significant increase in global anti-corruption enforcement. As noted in our 
2017 FCPA Mid-Year Review, last year began with a flurry of FCPA enforcement at the end of the Obama Administration, followed by a prolonged lull as the Trump Administration reviewed enforcement policies and filled key positions at the US Department of Justice (DOJ) and Securities and Exchange Commission (SEC). FCPA enforcement resumed in earnest in the third and fourth quarters of the year, putting 2017 well within the typical range of reported corporate and individual prosecutions for the last five years. Those enforcement trends continued in the first quarter of 2018, with both the DOJ and SEC inking corporate resolutions. 
 
After the transition of administrations, the DOJ, under President Trump, avoided public changes to pre-existing enforcement policies. In November 2017, the DOJ formalized, with certain amendments, the FCPA Pilot Program by incorporating a new FCPA Corporate Enforcement Policy into the US Attorneys’ Manual. The program creates a presumption, absent aggravating circumstances, that a company will receive a declination if it self-discloses, cooperates in the government’s investigation, and remediates, but the payment of disgorgement and/or forfeiture remains a requirement of such a declination. Even where aggravating circumstances exist and declination is unavailable, companies meeting the disclosure, cooperation, and remediation expectations will be eligible to receive a 50% discount off the fines calculated under the US Sentencing Guidelines (USSG), consistent with the Pilot Program. Although the Yates Memorandum is currently under review, Deputy Attorney General Rosenstein has publicly asserted that the DOJ is committed to the “common themes” put forward in that Memorandum and remains committed to pursuing criminal resolutions against individuals.[FN/1]
 The number and range of individual prosecutions in 2017 appears to confirm that approach, as does the settlement in Transportation Logistics International, Inc. in the first quarter of 2018, which justified a dramatically reduced penalty based on, among other reasons, the prosecution of the executives who allegedly directed the scheme. 
 
The SEC under President Trump and Chairman Clayton also appears committed to enforcing the FCPA and holding individuals accountable for misconduct. Chairman Clayton and Steven Peikin, Co-Director of the Enforcement Division, have commented on the importance of the SEC’s anti-corruption enforcement,[FN/2] and the SEC’s enforcement record to date appears to corroborate these public comments. Settlements with Halliburton and Alere suggest the SEC will continue to pursue civil enforcement actions against issuers for violations of the FCPA’s accounting provisions, and settlements with Mondelēz and Kinross show continued commitment to enforce violations of the FCPA arising from mergers and acquisitions (M&A). The SEC continues, however, to face headwinds in the courts. The Supreme Court’s decision in 
Kokesh v. SEC, 137 S. Ct. 1635 (2017), that disgorgement penalties are subject to the federal five-year statute of limitations, may hinder the SEC’s ability to complete large multi-year investigations.
 
In perhaps the most important trend in anti-corruption enforcement, the recent trend of multilateral anti-corruption cooperation and enforcement between US FCPA enforcement authorities and their counterparts abroad further accelerated. 2017 began in an interlude between two landmark multilateral enforcement actions: Odebrecht (Brazil, US, and Switzerland) and Rolls-Royce (UK, US, and Brazil). The trend continued in the third and fourth quarters of 2017 with large, multi-jurisdictional settlements involving Telia (US, Sweden, and the Netherlands) and Keppel Offshore (US, Brazil, and Singapore). Penalties for these multilateral settlements were orders of magnitude larger than some settlements before only the DOJ or SEC, suggesting that the largest and most serious cases continue to garner attention from enforcement authorities across the globe. Also notable is that the largest portion of those penalties went not to the US Treasury, but to the coffers of non-US enforcement authorities. 
 
Consistent with this growing global crackdown on corruption, the past year also saw a steady increase in anti-corruption legal and enforcement developments around the world, including investigation and prosecution of matters that had no FCPA enforcement component. In December 2017, the United Kingdom published its Anti-Corruption Strategy 2017­2022, calling for the establishment of a National Economic Crime Centre, and the French Anti-Corruption Agency published guidelines for compliance with the Law on Transparency, the Fight against Corruption and Modernization of Economic Life, nicknamed “Sapin II.” In Latin America, Brazil continues to aggressively pursue anti-corruption enforcement, most notably through Operation Car Wash, and anti-corruption laws in both Argentina and Peru became effective in the first quarter of 2018. In Asia-Pacific, China, Korea, India, and Australia are all in the midst of legislative changes related to anti-corruption laws, and domestic enforcement of graft and corruption laws continues to rise. While the World Bank Sanctions Board issued several significant decisions, the number of negotiated resolutions reached by contractors and consultants with the Integrity Vice Presidency continues to rise, obviating the need for a sanctions referral.  
While it is still too early to see the fruits of investigations initiated during the current administration, from what is publicly known about the current pipeline, we anticipate that these trends will continue in 2018.
 
Please click 
here to view the full report, 
FCPA/Anti-Corruption Developments: 2017 Year in Review & Q1 2018 Preview.
 
——— 
   [FN/1] See Rod J. Rosenstein, Keynote Address, NYU Program on Corporate Compliance & Enforcement, at *4 (Oct. 6, 2017) (noting “any changes will reflect our resolve to hold individuals accountable for corporate wrongdoing”), available here.
   [FN/2] See Steven R. Peikin, Reflections on the Past, Present, and Future of the SEC’s Enforcement of the Foreign Corrupt Practices Act, N.Y.U. Sch. of Law (Nov. 9, 2017), available here.

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TEEX/IM TRAINING EVENTS & CONFERENCES

TE_a3
16.
ECTI Presents “Mastering ITAR/EAR Challenges” in Annapolis, Maryland on May 22-23
(Sources: Suzanne Palmer, 
spalmer@exportcompliancesolutions.com)

*
What: Mastering ITAR
/
EAR Challenges, Annapolis, MD
* When:
May 22-23, 2018
* Sponsor: Export Compliance Solutions (ECS)
* ECS Speaker Panel:  Suzanne Palmer; Lisa Bencivenga; Timothy Mooney, Commerce/BIS; Matt Doyle, Lockheed; Matt McGrath, McGrath Law, Debi Davis, Esterline
* Register here 
or by calling 
866-238-4018 or e-mail
spalmer@exportcompliancesolutions.com

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TE_a3
17.
List of Approaching Events 
(Sources: Editor and Event Sponsors)

Published every Friday or last publication day of the week. Please, send event announcements to John Bartlett, Events & Jobs Editor (email: 
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
*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:

* Apr 16: Commodity Webinar; “April Series: Chemical Industry Waste“; National Commodity Specialist Division (NCSD) 
* 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: Washington, D.C.;
RPTAC; Commerce/BIS

* Apr 17: London, UK; “Intermediate Seminar“; UK Department for International Trade
* 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 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: Kissimmee, FL; “BIS Meeting Notice – Sensors and Instrumentation Technical Advisory Committee“; Bureau of Industry and Security

* Apr 19: Webinar: “The Modernization of the EU Export Control System“; Amber Road
* Apr 19: Commodity Webinar; “April Series: Dairy Products”; National Commodity Specialist Division (NCSD) 
* Apr 19: McLean, VA; “ITAR for the Empowered Official“; FD Associates
* Apr 23: Commodity Webinar; “April Series: Aircraft and Aircraft Parts”; National Commodity Specialist Division (NCSD) 
* 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: Commodity Webinar; “April Series: Organic Chemicals”; National Commodity Specialist Division (NCSD) 
* 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: Webinar; “Understanding Classification“; NAFTZ
* Apr 25: Commodity Webinar; “April Series: Articles Designed for Demonstrational Purposes“; National Commodity Specialist Division (NCSD) 
* Apr 25-26: Berlin, Gernamy; “Global Anti-Bribery In-House Network (GAIN)“; TRACE Anti-Bribery Compliance Solutions
# Apr 25-26: West Middlesex, PA; “Export Compliance Conference“; Ohio-Pennsylvania Export Initiative
* 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: Commodity Webinar; “April Series: Role of Material in Classification“; National Commodity Specialist Division (NCSD) 
* Apr 30-May 2: Kansas City, MO; “Discover Global Markets“; U.S. Department of Commerce
* May 1: Commodity Webinar; ” May Series: Blouses and Other Garments of Heading 6211“; National Commodity Specialist Division (NCSD) 
* May 1: Boston, MA; “
Blockchain Technologies for the Warfighter
“; NDIA
* May 2-3: Scottsdale, AZ; “Complying with US Export Controls“; Bureau of Industry and Security 

# May 3: ”
Sanctions & Export Controls: Focus on Medical Devices“; Winston & Strawn LLP

* 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: Commodity Webinar; “May Series: ‘Textile Articles: Basket Provision’“; National Commodity Specialist Division (NCSD) 
* May 7-8: Denver, CO; “2018 Spring Advanced Conference“; Society for International Affairs (SIA)
May 8: New York, NY; “Advanced Classification – Textiles“; Amber Road
May 8: Commodity Webinar; “May Series: Monumental and Building Stone“; National Commodity Specialist Division (NCSD)
* 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 9: Commodity Webinar; “
May Series: Festive Articles
“; National Commodity Specialist Division (NCSD)
 
May 10: Commodity Webinar; “May Series: Inorganic Chemicals, Fertilizers, and Surfactants“; National Commodity Specialist Division (NCSD) 
* 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: Commodity Webinar; “May Series: Ribbons and Trimmings“; National Commodity Specialist Division (NCSD) 
* May 14-15: Washington, D.C.; “
BIS Update 2018 Conference on Export Controls and Policy
“; BIS
May 15: Commodity Webinar; “May Series: Hair Accessories of Heading 9615“; National Commodity Specialist Division (NCSD) 
* May 15: Long Beach, California; “
92 Annual World Trade Week & International Delegate Luncheon and Trade Fair
“; Foreign Trade Association
May 15: San Diego, CA; “Export Controls Specialist – Certification“; Amber Road
* May 15-16: Cleveland, OH; “Complying with US Export Controls“; Bureau of Industry and Security
May 16: Commodity Webinar; “May Series: Pharmaceutical Products“; National Commodity Specialist Division (NCSD) 
* 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
* 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)
May 22: Commodity Webinar; “May Series: Sweaters and Articles of Heading 6110“; National Commodity Specialist Division (NCSD) 
* 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: Miami, FL; “Export Compliance Seminar and Workshop“; 
South Florida District Export Council / U.S. Commercial Service, at University of Miami
* May 22-23: Annapolis, MD; ”
May 2018 Seminar Level III-Mastering ITAR/EAR Challenges“; Export Compliance Solutions

* 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: Commodity Webinar; “May Series: Coated and Down Garments“; National Commodity Specialist Division (NCSD) 
* 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: Commodity Webinar; “May Series: Plywood, Veneered Panels, and Similar Laminated Wood“; National Commodity Specialist Division (NCSD) 
* 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: Commodity Webinar; “May Series: Cameras of Subheading 8525.80“; National Commodity Specialist Division (NCSD) 
* May 29-31: Hong Kong; “Hong Kong Summit on Economic Sanctions and Compliance Enforcement“; American Conference Institute
May 30: Commodity Webinar; “May Series: Bitcoin Miners“; National Commodity Specialist Division (NCSD) 
May 31: Commodity Webinar; “May Series: Women’s Knit Tank Tops“; National Commodity Specialist Division (NCSD) 
Jun 4: Commodity Webinar; “June Series: Wafers, Transformers, and PCBAs“; National Commodity Specialist Division (NCSD) 
Jun 5: Commodity Webinar; “June Series: Alcoholic Beverages“; National Commodity Specialist Division (NCSD) 
* Jun 5-6: Chicago, IL; “EAR Boot Camp“; American Conference Institute
Jun 6: Commodity Webinar; “June Series: Self-Adhesives of Heading 3919“; National Commodity Specialist Division (NCSD) 
* Jun 7: Chicago, IL; “ITAR Boot Camp“; American Conference Institute
* Jun 7: Webinar; “Resource Guide on Trade Actions“; NAFTZ
* 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: Commodity Webinar; “June Series: Glass Containers: Headings 7010 and 7013“; National Commodity Specialist Division (NCSD) 
* Jun 12: Webinar; “Duty Drawback and Refunds“; U.S. Commercial Service
* June 12-13; Stockholm, Sweden; “Trade Compliance Nordics“; C5 Group
Jun 13: Commodity Webinar; “June Series: Ornaments, Boxes, and Furniture of Heading 4420“; National Commodity Specialist Division (NCSD) 
* 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: Commodity Webinar; “June Series: Medical Instruments and Appliances“; National Commodity Specialist Division (NCSD) 
* 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: Commodity Webinar; “June Series: Heating and Cooling Treatment Facilities“; National Commodity Specialist Division (NCSD) 
* Jun 18: Los Angeles, CA; “Certified Classification Specialist (CCLS)“; Global Trade Academy
Jun 19: Commodity Webinar; “June Series: Sanitary Ware of Iron or Steel“; National Commodity Specialist Division (NCSD) 
Jun 20: Commodity Webinar; “June Series: Polymer Basics“; National Commodity Specialist Division (NCSD) 
* Jun 20-21: McLean, VA; “ITAR Fundamentals“; FD Associates
Jun 21: Commodity Webinar; “June Series: Antidumping on Diamond Sawblades“; National Commodity Specialist Division (NCSD) 
Jun 25: Commodity Webinar; “June Series: Gloves“; National Commodity Specialist Division (NCSD) 
Jun 26: Commodity Webinar; “June Series: Bed Linens“; National Commodity Specialist Division (NCSD) 
Jun 27: Commodity Webinar; “June Series: Fundamentals of Footwear“; National Commodity Specialist Division (NCSD) 
* 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 7: Commodity Webinar; “July Series: What’s a Toy?“; National Commodity Specialist Division (NCSD) 
* Jul 10: Chicago, IL; “Duty Drawback Specialist – Certification“; Global Trade Academy
Jul 10: Commodity Webinar; “July Series: Food Incorporating Alcohol“; National Commodity Specialist Division (NCSD) 
* Jul 10-11: Columbia, SC; “Complying with US Export Controls“; Bureau of Industry and Security
* July 10-12: Chicago, IL; “Duty Drawback Specialist – Certification“; Amber Road 
* Jul 11-14: Laredo, Texas; “Best Customs Broker Exam Course“; GRVR Attorneys 
* Jul 12: Commodity Webinar; “July Series: Understanding Types of Woven Fabric“; National Commodity Specialist Division (NCSD) 
* Jul 16: Commodity Webinar; “July Series: Electromechanical Domestic Appliances“; National Commodity Specialist Division (NCSD) 
* Jul 16-18: National Harbor, Maryland; “2018 Summer Basics Conference“; Society for International Affairs
* Jul 17: Commodity Webinar; “July Series: Other Articles of Steel“; National Commodity Specialist Division (NCSD) 
* Jul 17: Los Angeles, CA; “Advanced Classification of Plastics and Rubber“; Global Trade Academy
* Jul 19: Commodity Webinar; “July Series: Tubes and Pipes of Iron or Steel“; National Commodity Specialist Division (NCSD) 
* 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 16-18: Dallas, TX; “Partnering for Compliance West Export/Import Control Training and Education Program“; Partnering for Compliance 
* Oct 18-19: McLean, VA; “ITAR Fundamentals“; FD Associates
* Oct 19: Dallas TX; “
Customs/Import Boot Camp
“; Partnering for Compliance
* 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, AZ; ITAR Defense Trade Controls / EAR Export Controls Seminar“; ECTI; jessica@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“; ECTI; jessica@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
 

* Jan 6-7: Long Beach, CA; ”
Fundamentals of FTZ Seminar“;

* 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_a118
. Bartlett’s Unfamiliar Quotations

(Source: Editor)


Thomas Jefferson 
(13 April 1743 – 4 Jul 1826; was an American Founding Father who was the principal author of the Declaration of Independence and later served as the third President of the United States from 1801 to 1809. Previously, he was elected the second Vice President of the United States, serving under John Adams from 1797 to 1801.)


  – “
Do you want to know who you are? Don’t ask. Act! Action will delineate and define you.”
 

Roger de Rabutin 
(13 April 1618 – 9 April 1693; was a French memoirist. He was the cousin and frequent correspondent of Madame de Sévigné.)
 – “Absence is to love what wind is to fire; it extinguishes the small, it enkindles the great.”
 
Friday Funnies:
* I hope my children will never find out why I say “Oooops!” so often when I vacuum their rooms.

* Sometimes I tuck my knees into my chest and lean forward.  That’s just how I roll.

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

EN_a219. 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: 
12 Apr 2018: 
83 FR 15736-15740
: CBP Decision No. 18-04; Definition of Importer Security Filing Importer
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(s): 2 Apr 2018:
83 FR 13849-13862
: Implementation of the February 2017 Australia Group (AG) Intersessional Decisions and the June 2017 AG Plenary Understandings; Addition of India to the AG [Amendment of EAR Parts 738, 740, 745, and 774.]
; and 5 Apr 2018:
83 FR 14580-14583
: Reclassification of Targets for the Production of Tritium and Related Development and Production Technology Initially Classified Under the 0Y521 Series [Imposes License Requirements on Transfers of Specified Target Assemblies and Components for the Production of Tritium, and Related “Development” and “Production” Technology.] 

 

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: 30 Mar 2018:
Harmonized System Update 1804, containing 710 ABI records and 166 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_a320
. 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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