18-0621 Thursday “Daily Bugle”

18-0621 Thursday “Daily Bugle”

Thursday, 21 June 2018

The Daily Bugle is a free daily newsletter from Full Circle Compliance, containing changes to export/import regulations (ATF, DOE/NRC, Customs, NISPOM, EAR, FACR/OFAC, FAR/DFARS, FTR/AES, HTSUS, and ITAR), plus news and events.  Subscribe 
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  1. Commerce Extends Comment Period Concerning Section 232 National Security Investigation Until 29 Jun 
  1. Items Scheduled for Publication in Future Federal Register Editions
  2. Commerce/BIS: (No new postings.)
  3. State/DDTC: (No new postings.)
  4. EU Implements Policy Measures Concerning Certain Products of U.S. Origin
  1. Ammoland: “Foreign Partners Collaboration Will be Easier After Gun Export Control Reform”
  2. Handelsblatt Global: “Arms Exports Booming, Triggering Debate”
  3. South China Morning Post: “U.S. Commerce Secretary to Assess ZTE Espionage Threat at Senator’s Urging”
  4. ST&R Trade Report: “EU Retaliatory Tariffs Moved Up to June 22”
  5. WorldECR: “Canada Considers Changing Export Laws to Promote Human Rights”
  1. M. Volkov: “Welcome! You Are the New Chief Compliance Officer: Five Basic Steps to Get Started”
  2. O. Torres & J. Creek: “Tariffs: The Never-Ending Saga”
  3. The Export Compliance Journal: “Iceland Wins the 2018 World Cup! (Export Compliance Edition)”
  1. Bartlett’s Unfamiliar Quotations 
  2. Are Your Copies of Regulations Up to Date? Latest Amendments: ATF (15 Jan 2016), Customs (12 Jun 2018), DOD/NISPOM (18 May 2016), EAR (6 Jun 2018), FACR/OFAC (19 Jun 2018), FTR (24 Apr 2018), HTSUS (8 Jun 2018), ITAR (14 Feb 2018) 
  3. Weekly Highlights of the Daily Bugle Top Stories 



Federal Register, 21 Jun 2018.) [Excerpts.] 
83 FR 28801: Public Comments and Public Hearing on Section 232 National Security Investigation of Imports of Automobiles, including Cars, SUVs, Vans and Light Trucks, and Automotive Parts; Extension of Comment Period
* AGENCY: U.S. Department of Commerce.
* ACTION: Notice of request for public comments and public hearing; extension of comment period.
* SUMMARY: In response to requests for additional time, the Department of Commerce is extending the comment period for the notice of request for public comments and public hearing that was published in the Federal Register on May 30, 2018. In the notice, the Department requested written comments, data, analyses, or other information pertinent to the investigation to determine the effects on the national security of imports of automobiles, including cars, SUVs, vans and light trucks, and automotive parts. Through this notice, the Department extends the comment period to June 29, 2018 and the rebuttal period to July 13, 2018. Requests to appear at the hearings are also now due June 29, 2018.
* DATES: The due date for filing comments, for requests to appear at the public hearing, and for submissions of a summary of expected testimony at the public hearing is June 29, 2018.
* The due date is July 13, 2018 for rebuttal comments submitted in response to any comments filed on or before June 29, 2018.
 The public hearings will be held on July 19 and 20, 2018. The hearings will begin at 8:30 a.m. local time and conclude at 5:00 p.m. local time, each day.
* ADDRESSES: Written comments: All written submissions must be in English and must be addressed to Section 232 Automobile and Automotive Parts Imports Investigation, and filed through the Federal eRulemaking Portal. To submit comments via www.regulations.gov, enter docket number DOC-2018-0002 on the home page and click “search.” The site will provide a search results page listing all documents associated with this docket. Find a reference to this notice and click on the link entitled “Comment Now!” … 
* FOR FURTHER INFORMATION CONTACT: Sahra Park-Su, U.S. Department of Commerce (202) 482-2811. For more information about the section 232 program, including the regulations and the text of previous investigations, see www.bis.doc.gov/232. … 
Wilbur L. Ross, Secretary of Commerce.

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

* Commerce/BIS; NOTICES; Meetings: 
Information Systems Technical Advisory Committee [Publication Date: 22 Jun 2018.]
* Defense; NOTICES; Violations of Arms Control Treaties or Agreements with the United States [Publication Date: 22 Jun 2018.]

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Commission Implementing Regulation (EU) 2018/886 of 20 June 2018 on certain commercial policy measures concerning certain products originating in the United States of America and amending Implementing Regulation (EU) 2018/724

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Ammoland, 20 Jun 2018.) [Excerpts.] 
Firearms and ammunition companies that share technical data or defense services controlled by the International Traffic in Arms Regulations (ITAR) with foreign partners will be big beneficiaries of Export Control Reform (ECR).
Your company is among the beneficiaries if it engages in any of the following activities with regard to non-automatic or semi-automatic firearms:
  – Exchange of firearm- or ammunition-related technical data or defense services with foreign parent companies or affiliates;
  – Sourcing parts or tools from offshore vendors;
  – Joint design and development of firearm or ammunition products with foreign partners.
Quite a few U.S. companies in the firearms and ammunition industry are owned by non-U.S. parent companies. When the U.S. company and the foreign parent want to collaborate on designing new products or modifying existing products, the ITAR get in the way. An ITAR Technical Assistance Agreement (TAA) or Manufacturing License Agreement (MLA) generally must be approved by the Department of State, Directorate of Defense Trade Controls (DDTC) before the collaboration can begin. … 

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Handelsblatt Global, 21 Jun 2018.) [Excerpts.] 
German weapons exports remained high last year despite plans to reduce sales to countries outside the EU and NATO. Arms manufacturers say such deals have been vital to them due to sluggish European spending.
The value of German arms exports fell by 9 percent to €6.24 billion ($7.24 billion) in 2017 but that was still the third-highest total ever, and it conflicts with Berlin’s policy of 
becoming more restrictive on sales. In their coalition agreement for the new government formed in March, Chancellor Angela Merkel’s conservatives and the center-left Social Democrats said they would reduce arms exports to countries that aren’t members of NATO or the EU. … 
The arms industry says restrictive export rules are hampering a planned European defense cooperation, especially with France, and has called on EU members to adopt common regulations. “Without a harmonization of export control regulations, European and especially German-French cooperation plans are barely feasible over the long term,” the managing director of German defense industry federation BDSV, Hans Atzpodien, told Handelsblatt.

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South China Morning Post, 20 Jun 2018.) [Excerpts.] 
Commerce Secretary Wilbur Ross has been urged by a U.S. senator to address whether his department believes that Chinese telecoms giant ZTE poses an espionage threat to the United States.
Senator Ron Wyden, Democrat of Oregon, posed the question at a Senate Finance Committee hearing on Wednesday concerning the recent deal by the Trump administration that saved ZTE from the brink of collapse and requested a written answer within a week from the commerce department to clarify its position on national security concerns.

Wyden said that keeping ZTE alive – as the administration had done when President Donald Trump ordered an end to a seven-year ban on US suppliers selling their components to ZTE – was in conflict with what William Evanina, the director of the National Counterintelligence and Security Centre, said in testimony in May, when he declared that ZTE had been an espionage threat for years. … 

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ST&R Trade Report: “EU Retaliatory Tariffs Moved Up to June 22” 
Sandler, Travis & Rosenberg Trade Report, 21 Jun 2018.) 
The European Commission adopted June 20 the regulation to implement the European Union’s “rebalancing measures” in response to a June 1 increase in U.S. tariffs on steel and aluminum from EU and other countries. As a result, starting June 22 the EU will impose an additional 25 percent tariffs on 
a list of products worth €2.8 billion. Affected products include textile, apparel, and footwear items, rice, orange juice, bourbon whiskey, tobacco products, cosmetic products, steel and aluminum products, playing cards, sailboats, and motorcycles.
Trade Commissioner Cecilia Malmström said that the EU “did not want to be in this position” but that “the rules of international trade, which we have developed over the years hand in hand with our American partners, cannot be violated without a reaction from our side.” Malmström defended the EU tariffs as “measured, proportionate, and fully in line with WTO rules” and said they would be removed if the U.S. removes its tariffs.
The Commission notes that the retaliatory tariffs are part of a three-pronged EU response that also includes the June 1 launch of a World Trade Organization case and the March 26 initiation of a safeguard investigation meant to protect the European market from disruptions caused by the diversion of steel from the U.S. market. The EU has also warned that tariffs on another €3.6 billion worth of U.S. goods could be increased by 10 to 50 percent in March 2021 (or sooner, if the WTO case is decided against the U.S. before then) if the U.S. has not rescinded its steel and aluminum tariffs by that time. 

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WorldECR: “Canada Considers Changing Export Laws to Promote Human Rights”
WorldECR News, 21 June 2018.) 
Canada’s Senate Committee on Human Rights has published a report on how human rights can be promoted in its export sector, recommending that the Export and Imports Permits Act 1947 be updated. It also advises that the focus of any new controls should be on end uses and end-users.
The report was commissioned after it emerged that the Canadian government had granted export permits for the sale of light armored vehicles to Saudi Arabia. Footage was then disseminated allegedly showing Saudi security forces using Canadian vehicles against their own citizens.
The committee considered how Canada could use its economic leverage to create a better environment for human rights worldwide. At present, the Export and Import Permits Act gives the Minister of Foreign Affairs (currently Chrystia Freeland) discretion to weigh the risk of potential human rights violations against foreign policy, defense and economic interests. The report concludes that the Canadian government’s ‘actions on exports are not always consistent with its stated support for human rights’. It also expresses concern that the current export regime does not fully cover new or emerging technology such as surveillance tools that can be used to control or monitor internet access, and restrict free speech and the flow of ideas. Evidence was heard that a Canadian company aided by a Crown corporation (a state-owned enterprise) exported technology to Bahrain, which was used to ‘to filter content including critical political speech, news websites, human rights content, websites of oppositional political groups, and Shia-related content.’
The report recommends that Crown corporations should take ‘additional steps’ to make sure business practice complies with the United Nations Guiding Principles on Business and Human Rights.
  – For a copy of the report click 

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M. Volkov: “Welcome! You Are the New Chief Compliance Officer: Five Basic Steps to Get Started”

Volkov Law Group Blog, 20 Jun 2018. Reprinted by permission.) 
* Author: Michael Volkov, Esq., Volkov Law Group, 
mvolkov@volkovlaw.com, 240-505-1992. 
Congratulations on your new position as the chief compliance officer.  You successfully interviewed with the company, met the senior executive team and the audit committee chair, and negotiated a nice compensation package. You are feeling “pretty, pretty good” (ala Larry David) about your new job and looking forward to starting your new position.
So, now, what do you do?
My first question for you is did you negotiate and secure confirmation of important issues and mechanics necessary for you to carry out your responsibilities?
Here is a laundry list of questions you should have resolved before accepting the position.
  – To whom do you report and how often?
  – Are you part of the C-Suite?
  – What is your reporting relationship to the board committee with oversight responsibility and how often?
  – How committed is the company to its ethics and compliance program?
  – How many staff members do you have and where are they located?
  – What is your budget?
  – Where is your office located? (Hopefully not where 
Melvin in Office Space was eventually moved)
Assuming all of the above-listed issues have been confirmed in your favor and the company is truly committed to its ethics and compliance program, you show up for your first day of work, plough through the human resources portion of the day and process, and you are ready to go.  What do you do?
First, you meet with your compliance team.  This is a chance to meet your staff, learn about each of them, find out activities and responsibilities.  You can then begin to tentatively visualize and prioritize assignments and responsibilities.  Each of your staff members will have strengths and weaknesses.  Your priority is to assess the capabilities, strengths and weaknesses of your compliance staff.
Second, you need to meet with your “operational” partners, meaning your natural partners and supporters in the compliance space – human resources, legal, internal audit, controller, chief financial officer, security (if the company has an office), and information technology.  In each meeting, your task is to listen and learn and find out how exactly compliance has been interacting with each function and the strengths and weaknesses of each relationship.
If the company has an ethics and compliance committee, you need to meet with each member, assess the operation of the committee and each constituent.
What types of operations and programs has compliance established to operationalize the ethics and compliance program?
Third, you need to meet with business leaders and key managers.  This is a critical task — to learn and understand as much as possible about the company’s business.
  – How has the business and compliance interacted?
  – How effective is the working relationship?
  – What is the business leaders’ perception of compliance and vice versa?
This is an important opportunity to learn about the business, how to develop a strong working relationship and to begin to lay the foundation for a strong message of cooperation and support.
Fourth, you need to develop a tentative game plan.  I mean tentative from an operational stand point.  You are still missing one key ingredient – senior leadership and the audit committee.  Before you meet with them, however, you need to assess where the program is, what needs to be done and a multi-year picture of where you envision leading the program. A tentative view, which is developed based on objective evidence and your expertise, is critical because you need to be ready to answer senior leadership and audit committee questions on the state of the company’s compliance program and where you want to take the program.  As the leader of the compliance program, you need to develop a vision for the program and the steps needed to reach your objectives.
Fifth and finally, you need to bring your vision to senior leadership and the audit committee.  This is a chance to test your reality, to determine exactly whether the promises and representations made to you prior to accepting the position are in fact true.  In other words, this is when you will gain insight into exactly how much you will be able to accomplish, what roadblocks may develop at the senior level of the company, and the challenges you will face.
At the conclusion of this process, a CCO will know whether he or she will be facing an internal political struggle that will complicate his or her assignment or whether the challenges can be overcome with the support of senior leadership.  Nothing is easy in compliance and no one ever thinks the job will be easy, but CCOs can develop a quick sense of the path towards success.  For some, early in this process they will know that the job may be extremely difficult, or they will know that there is a path forward but it will require commitment and hard work.

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O. Torres & J. Creek: “Tariffs: The Never-Ending Saga”

Torres Law PLLC, 18 Jun 2018.)
* Authors: Olga Torres, Esq; and Jonathan Creek, Esq. Contact information: 214-593-7120, 
On June 15, 2018, the Trump Administration took the next step in escalating trade tensions with China by imposing additional 25% tariffs on imports of more than 800 products under Section 301 of the Trade Act of 1974. [FN/1] This announcement comes after the Administration imposed additional tariffs on imports of steel (25%) and aluminum (10%) products from nearly all countries under Section 232 of the Trade Expansion Act of 1962.
The Trump Administration has made tariffs a key element of its trade agenda. While there has been significant back and forth on which countries and industries will be subject to tariffs or may be a target of future announcements, the Administration appears poised to continue using tariffs as both a bargaining tool and a weapon. This article provides an update on the most recent tariff related developments.
Section 301 Tariff List Announced
On June 15, 2018, the Office of the United States Trade Representative (“USTR”) released a list of Chinese goods that will be subject to an additional 25% tariff. [FN/2] The product list covers approximately $50 billion worth of Chinese imports. The final announcement pares back the previously proposed list of 1,333 products following a period of public comments and hearings. These punitive tariffs were issued in response to what the USTR called China’s unfair trade practices and the forced transfer of American technology and intellectual property. The tariffs are intended to target Chinese imports involving industrially significant technologies, including those identified in China’s “Made in China 2025” policy.
The June 15 announcement included two sets of products. The 
first list contains 818 tariff lines covering approximately $34 billion worth of imports from China. These 818 product types will be subject to a 25% duty rate. U.S. Customs and Border Protection (“CBP”) will begin to collect the additional duties on July 6, 2018.

second list of 284 products covering approximately $16 billion worth of imports from China will be subject to a second public review and comment process, including a public hearing. After the completion of this process, USTR will issue a final list of products based on these 284 proposed tariff lines. The final list will also be subject to a 25% tariff rate.
Companies impacted by these tariffs will be allowed to apply for the exclusion of particular products from the tariffs. USTR has not yet announced how this process will work. However, USTR will publish a notice in the Federal Register detailing the exclusion process in the next few weeks.
Canada, Mexico, and the EU are No Longer Exempt
On May 31, 2018, President Trump issued two new Presidential Proclamations [FN/3] related to the tariffs on steel and aluminum. Most notably, these Proclamations provide that Canada, Mexico, and the EU are no longer exempt from the steel and aluminum tariffs. In his previous Proclamations from March 22, 2018, [FN/4] President Trump had granted exemptions from the 232 tariffs to Australia, Argentina, Brazil, and the EU. Canada and Mexico had been exempted pursuant to the initial steel and aluminum tariff announcement on March 8. [FN/5]
With regards to steel, the 25% tariff is now applicable to imports of steel from, among others, Canada, Mexico, and the EU. The duty does not apply to imports of steel from Argentina, Brazil, or Australia. These countries join South Korea who was previously granted an exemption. For aluminum, the 10% tariff is now applicable to imports of aluminum from Canada, Mexico, Brazil, and the EU. Imports of aluminum from Argentina and Australia will remain exempt from the tariffs.
The 232 tariffs have been met with hostility by U.S. allies. Canada and the EU have promised to impose retaliatory tariffs. Additionally, Mexico has already imposed tariffs targeting certain U.S. products, including pork, apples, potatoes, bourbon, and cheese. The 232 announcement is also worth monitoring for its potentially negative impact on ongoing NAFTA negotiations.
Section 232 Investigation into Automobile Imports Initiated
On May 23, 2018, Secretary of Commerce Wilbur Ross announced that, at the direction of President Trump, the Department of Commerce (“DOC”) would initiate an investigation under Section 232 into the impact of auto imports on U.S. national security. The investigation will focus on whether automobiles, including SUVs, vans and light trucks, and automotive parts imported into the U.S. threaten to impair the national security of the U.S. such that retaliatory measures are warranted. In announcing the investigation, the DOC noted imports of passenger vehicles into the U.S. has grown from 32% of the cars sold in the U.S. to 48% in the last 20 years. In this same time, employment in motor vehicle production declined by 22%.
This process is still in the early stages, so whether or not any tariffs will be implemented is still unknown. However, interested parties will be able to submit comments, data, analyses, or other information pertinent to the investigation by June 22, 2018. [FN/6] Rebuttal comments will be due by July 6, 2018. The DOC will then hold a public hearing on the investigation on July 19 and 20, 2018 in Washington, D.C.
Tariffs have proven to be a constantly evolving situation. As such, companies should keep a close eye on tariff developments. Torres Law will continue to closely monitor all tariff related developments. Please do not hesitate to contact us if you have any questions or require any assistance.
  [FN/1] Section 301 of the Trade Act of 1974 authorizes the President to take action to obtain the removal of any act, policy, or practice of a foreign government that violates an international trade agreement or is unjustified, unreasonable, or discriminatory, and that burdens or restricts U.S. commerce.
  [FN/2] Office of the United States Trade Representative, 
USTR Issues Tariffs on Chinese Products in Response to Unfair Trade Practices, available 
here (last visited June 15, 2016).
  [FN/3] Whitehouse.gov, 
Presidential Proclamation Adjusting Imports of Steel into the united States, available 
here (last visited June 15, 2018); Whitehouse.gov, 
Presidential Proclamation Adjusting Imports of Aluminum into the United States, available 
here (last visited June 15, 2018).
  [FN/4] For more information, please see our previous article: 
Tariff Updates: New Exemptions, Deals Made to Avoid Tariffs, and New China Tariffs Incoming. This article can be found 
  [FN/5] For more information, please see our previous article: 
Tariffs on Steel, A Sign of Trade Wars on the Horizon. This article can be found 
  [FN/6] Comments and rebuttal comments can be made at 
www.regulations.gov. Comments should be made under docket DOC-2018-002.

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The Export Compliance Journal: “Iceland Wins the 2018 World Cup! (Export Compliance Edition)”

The Export Compliance Journal, 21 Jun 2018.)
The FIFA World Cup is upon us once again, and football fans around the world are on the edge of their seats, desperate for their team to defeat the odds and walk away with the top prize.
With many of this year’s qualifying teams in the media for reasons other than sports-rather reasons related to export, trade and financial (OFAC) sanctions violations — we here at eCustoms wondered:
Who would win the 2018 World Cup-if the tournament winner was the country with the fewest number of individuals and business entities on the multitude of U.S. and International screening watch lists?
So, we did just that! Below you’ll find out just how the 2018 World Cup would play out if governed by the rules of export, trade, and OFAC compliance.

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Reinhold Niebuhr (Karl Paul Reinhold Niebuhr; 21 Jun 1892 – 1 June 1971; was an American theologian, ethicist, commentator on politics and public affairs, and professor at Union Theological Seminary for more than 30 years. Historian Arthur Schlesinger Jr. described Niebuhr as “the most influential American theologian of the 20th century.”)
  – “Forgiveness is the final form of love.”

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. 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.
: 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. 
: 19 CFR, Ch. 1, Pts. 0-199
  – Last Amendment: 12 Jun 2018: 83 FR 27380-27407: Air Cargo Advance Screening (ACAS)

  – 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 

: 15 CFR Subtit. B, Ch. VII, Pts. 730-774

  – Last Amendment: 6 Jun 2018: 83 FR 26204-26205: Unverified List (UVL); Correction

: 31 CFR, Parts 500-599, Embargoes, Sanctions, Executive Orders

  – Last Amendment: 
19 Jun 2018: 
83 FR 28370-28375
: Rough Diamonds Control Regulations 

: 15 CFR Part 30
  – Last Amendment: 24 Apr 2018: 3 FR 17749-17751: Foreign Trade Regulations (FTR): Clarification on the Collection and Confidentiality of Kimberley Process Certificates
  – HTS codes that are not valid for AES are available
  – The latest edition (30 Apr 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 websiteBITAR 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.  
, 1 Jan 2018: 19 USC 1202 Annex. (“HTS” and “HTSA” are often seen as abbreviations for the Harmonized Tariff Schedule of the United States Annotated, shortened versions of “HTSUSA”.)
  – Last Amendment:
8 Jun 2018: Harmonized System Update 1809, containing 901 ABI records and 192 harmonized tariff records. 

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

  – 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: 25 Apr 2018) of the ITAR with all amendments is contained in Bartlett’s Annotated 

, 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
. BAFTR subscribers receive a 25% discount on subscriptions to the BITAR, please
contact us 
to receive your discount code.

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Weekly Highlights of the Daily Bugle Top Stories

(Source: Editor) 

Review last week’s top Ex/Im stories in “Weekly Highlights of the Daily Bugle Top Stories” published on the
Full Circle Compliance website

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* The Ex/Im Daily Update is a publication of FCC Advisory B.V., compiled by: Editor, James E. Bartlett III; Assistant Editors, Alexander P. Bosch and Vincent J.A. Goossen; and Events & Jobs Editor, John Bartlett. The Ex/Im Daily Update is emailed every business day to approximately 8,000 readers of changes to defense and high-tech trade laws and regulations. We check the following sources daily: Federal Register, Congressional Record, Commerce/AES, Commerce/BIS, DHS/CBP, DOE/NRC, DOJ/ATF, DoD/DSS, DoD/DTSA, FAR/DFARS, State/DDTC, Treasury/OFAC, White House, and similar websites of Australia, Canada, U.K., and other countries and international organizations.  Due to space limitations, we do not post Arms Sales notifications, Denied Party listings, or Customs AD/CVD items.

* RIGHTS & RESTRICTIONS: This email contains no proprietary, classified, or export-controlled information. All items are obtained from public sources or are published with permission of private contributors, and may be freely circulated without further permission, provided attribution is given to “The Export/Import Daily Bugle of (date)”. Any further use of contributors’ material, however, must comply with applicable copyright laws.

* CAVEAT: The contents of this newsletter cannot be relied upon as legal or expert advice.  Consult your own legal counsel or compliance specialists before taking actions based upon news items or opinions from this or other unofficial sources.  If any U.S. federal tax issue is discussed in this communication, it was not intended or written by the author or sender for tax or legal advice, and cannot be used for the purpose of avoiding penalties under the Internal Revenue Code or promoting, marketing, or recommending to another party any transaction or tax-related matter.

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