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18-0622 Friday “Daily Bugle”

18-0622 Friday “Daily Bugle”

Friday, 22 June 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
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  1. Commerce/BIS Announces ISTAC Meeting on 25-26 Jul in San  
  2. DOD, GSA, NASA Seek Comments on FAR, Violations of Arms Control Treaties or Agreements with the U.S. 
  1. Items Scheduled for Publication in Future Federal Register Editions 
  2. Commerce/BIS: (No new postings.)
  3. DoD/DSS Releases Details Concerning DISS Deployment
  4. Justice: “Chinese National Arrested for Conspiring to Illegally Export U.S. Origin Goods Used in Anti-Submarine Warfare to China”
  5. Justice: “Newly Unsealed Federal Indictment Charges Iranian Businessman with Illegally Exporting Nuclear Nonproliferation-Controlled Materials from Illinois”
  6. State/DDTC: (No new postings.)
  7. UK ECJU Reintroduces Control List Classification Advisory Service
  1. Abacus News: “ZTE Says it Can’t Fix a Toilet Without Violating Sanctions”
  2. Law360: “Policy Is Changing for Technology Transfers”
  3. ST&R Trade Report: “New Export Controls on China Anticipated Soon”
  4. A. Dier: “Mexico’s World Cup Captain Blacklisted by US”
  1. M. Volkov: “When Your CEO Just Does Not Get It”
  2. T. Murphy: “EU Retaliatory Tariffs Enter Into Force Today”
  1. DDTC is Hiring
  1. List of Approaching Events: 12 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 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 

EXIMITEMS FROM TODAY’S FEDERAL REGISTER

EXIM_a1

1.
Commerce/BIS Announces ISTAC Meeting on 25-26 Jul in San Diego


(Source: Federal Register, 22 Jun 2018.) [Excerpts.]
 
83 FR 29088: Information Systems Technical Advisory Committee; Notice of Partially Closed Meeting
 
The Information Systems Technical Advisory Committee (ISTAC) will meet on July 25 and 26, 2018, 9:00 a.m., at Qualcomm Incorporated, 5665 Morehouse Drive, QRC Building, San Diego, California 92121. The Committee advises the Office of the Assistant Secretary for Export Administration on technical questions that affect the level of export controls applicable to information systems equipment and technology.
 
Wednesday, July 25 — Open Session
 
  (1) Welcome and Introductions
  (2) Working Group Reports
  (3) Old Business
  (4) Intro to hacking? Trends? Tools?
  (5) Update on Practitioner’s Guide to APP
  (6) Update on Top 500
  (7) Digital TV? Implications for 5G video?
  (8) Industry Wassenaar Proposals for 2019
  (9) Clash between GDPR (EU) and 5A1j (WA)
 
Thursday, July 26 — Closed Session
 
  (10) Discussion of matters determined to be exempt from the provisions relating to public meetings found in 5 U.S.C. app. 2 §§
10(a)(1) and 10(a)(3).
  
The open session will be accessible via teleconference to 20 participants on a first come, first serve basis. To join the conference, submit inquiries to Ms. Yvette Springer at 
Yvette.Springer@bis.doc.gov
, no later than July 18, 2018.
   
A limited number of seats will be available for the public session. Reservations are not accepted. If attending in person, forward your Name (to appear on badge), Title, Citizenship, Organization name, Organization address, Email, and Phone to Ms. Springer. To the extent time permits, members of the public may present oral statements to the Committee. The public may submit written statements at any time before or after the meeting. However, to facilitate distribution of public presentation materials to Committee members, the Committee suggests that public presentation materials or comments be forwarded before the meeting to Ms. Springer. … 
 
For more information, call Yvette Springer at (202) 482-2813.
 
Yvette Springer, Committee Liaison Officer.

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EXIM_a2

2.
DOD, GSA, NASA Seek Comments on FAR, Violations of Arms Control Treaties or Agreements with the U.S.


(Source: Federal Register, 22 Jun 2018.) [Excerpts.] 
 
83 FR 29117-29118: Information Collection; Violations of Arms Control Treaties or Agreements with the United States
 
* AGENCY: 
Department of Defense (DOD), General Services Administration (GSA), and National Aeronautics and Space Administration (NASA).
* ACTION: 
Notice of request for public comments regarding an extension to an existing OMB clearance. … 
* DATES: 
Submit comments on or before August 21, 2018.
* ADDRESSES: 
Submit comments identified by Information Collection 9000-0198; Violations of Arms Control Treaties or Agreements with the United States, by any of the following methods:
  – Regulations.gov:
 http://www.regulations.gov. Submit comments Start via the Federal eRulemaking portal by searching for the OMB Control number 9000-0198. Select the link “Comment Now” that corresponds with “Information Collection 9000-0198; Violations of Arms Control Treaties or Agreements with the United States.” Follow the instructions on the screen. Please include your name, company name (if any), and “Information Collection 9000-0198; Violations of Arms Control Treaties or Agreements with the United States.”
  – Mail: General Services Administration, Regulatory Secretariat Division (MVCB), 1800 F Street NW, Washington, DC 20405-0001. ATTN: Ms. Mandell/IC 9000-0198; Violations of Arms Control Treaties or Agreements with the United States. 
Instructions:
 Please submit comments only and cite Information Collection 9000-0198; Violations of Arms Control Treaties or Agreements with the United States, in all correspondence related to this collection. Comments received generally will be posted without change to
http://www.regulations.gov
including any personal and/or business confidential information provided. To confirm receipt of your comment(s), please check 
www.regulations.gov,
 approximately two-to-three days after submission to verify posting (except allow 30 days for posting of comments submitted by mail).
* SUPPLEMENTARY INFORMATION: … 
Section 1290 of Public Law 114-328 (codified at 22 U.S.C. 2593e) went into effect on December 23, 2016. The implementation of this FAR case will protect against doing business with entities that engage in any activity that contributed to or is a significant factor in a country’s failure to comply with arms control treaties or agreements with the United States. This action is necessary because of statutory requirements relating to a national security function of the United States.
  A notice was published in the Federal Register at 83 FR 28145, on June 15, 2018, as a part of a interim rule under FAR Case 2017-018, Violations of Arms Control Treaties or Agreements with the United States. … 
  Public comments are particularly invited on:
 Whether this collection of information is necessary for the proper performance of functions of the FAR, and will have practical utility; whether the estimate of the public burden of this collection of information is accurate, and based on valid assumptions and methodology; ways to enhance the quality, utility, and clarity of the information to be collected; and ways to minimize the burden of the collection of information on those entities who will respond, through the use of appropriate technological collection techniques or other forms of information technology. … 
 
  Dated: June 18, 2018.
 
William F. Clark, Director, Office of Governmentwide Acquisition Policy, Office of Acquisition Policy, Office of Governmentwide Policy.

[Excerpts of 83 FR 28145 were included in the Daily Bugle of 15 June 2018.]

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OGSOTHER GOVERNMENT SOURCES

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. Items Scheduled for Publication in Future Federal Register Editions
 

(Source:
Federal Register)
* President; ADMINISTRATIVE ORDERS: 
  – North Korea; Continuation of National Emergency (Notice of June 22, 2018); and
  – Western Balkans; Continuation of National Emergency (Notice of June 22, 2018) [Publication Dates: 25 Jun 2018.]
 
* Commerce; NOTICES; Agency Information Collection Activities; Proposals, Submissions, and Approvals [Concerning Statement by Ultimate Consignee and Purchaser; Publication Date: 25 Jun 2018.]
 
* Commerce/BIS; NOTICES; Orders Denying Export Privileges: Fuyi Sun [Included in the Daily Bugle of 18 Jun 2018; Publication Date: 25 Jun 2018.]
 
* State/DDTC; NOTICES; Agency Information Collection Activities; Proposals, Submissions, and Approvals:
  – Maintenance of Records by DDTC Registrants; and 
  – Request for Approval of Manufacturing License Agreements, Technical Assistance Agreements, and Other Agreements [Publication Dates: 25 Jun 2018.]
 
* Treasury/OFAC; NOTICES; Blocking or Unblocking of Persons and Properties [3 Items; Publication Date: 25 Jun 2018.]

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OGS_a24
Commerce/BIS: (No new postings.)
(Source: Commerce/BIS)

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OGS_3
5
DoD/DSS Releases Details Concerning DISS Deployment

(Source: DoD/DSS, 21 Jun 2018.)

On June 25, 2018, the Defense Information System for Security (DISS) will deploy to Industry, but given ongoing DISS provisioning efforts, the following guidance is being provided to define what deployment means. Industry users that have been provisioned in DISS should begin using DISS to submit Customer Service Requests (CSRs) and SF-312s.

Industry users not yet provisioned in DISS may continue to submit JPAS RRUs and fax/mail SF-312s while awaiting the provisioning of their DISS account. For communication originating from the Personnel Security Management Office for Industry (PSMO-I) or the DoD Consolidated Adjudications Facility (CAF) that is being sent to facility security officers, PSMO-I/DoD CAF will transmit all communications via both DISS and JPAS. This is a temporary measure during the interim time period where user provisioning is an ongoing effort, and will be re-evaluated every 30 days.

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OGS_a46

Justice: “Chinese National Arrested for Conspiring to Illegally Export U.S. Origin Goods Used in Anti-Submarine Warfare to China”

(Source: Justice, 21 Jun 2018.) [Excerpts.] 
 
Defendant allegedly illegally exported devices used to detect and monitor sound underwater.
 
A Chinese national was arrested today and charged in connection with violating export laws by conspiring with employees of an entity affiliated with the People’s Liberation Army (PLA) to illegally export U.S. origin goods to China, as well as making false statements to obtain a visa to enter the United States and to become a lawful permanent resident under the EB-5 Immigrant Investor Visa Program.
 
Shuren Qin, 41, a Chinese national residing in Wellesley, Mass., was charged in a criminal complaint with one count of visa fraud and one count of conspiring to commit violations of U.S. export regulations. Qin was arrested today and will appear in federal court in Boston on June 22, 2018.
 
According to charging documents, Qin was born in the People’s Republic of China and became a lawful permanent resident of the United States in 2014. Qin operates several companies in China, which purport to import U.S. and European goods with applications in underwater or marine technologies into China.  It is alleged that Qin was in communication with and/or receiving taskings from entities affiliated with the PLA, including the Northwestern Polytechnical University (NWPU), a Chinese military research institute, to obtain items used for anti-submarine warfare.
 
In 2001, the Department of Commerce designated NWPU on its Entity List because of the national security risks it poses to the U.S. NWPU has worked closely with the PLA on the advancement of its military capabilities. From at least July 2015 to December 2016, Qin allegedly exported approximately 78 hydrophones (devices used to detect and monitor sound underwater) from the United States to NWPU without obtaining the required export licenses from the Department of Commerce, in violation of U.S. export laws. Qin did so by concealing from the U.S. supplier that NWPU was the end-user and causing false information to be filed with the United States Government.
 
As alleged in court documents, in 2014, Qin made false statements on his visa application. Specifically, he falsely certified that he had never “engaged in export control violations or other unlawful activity.” However, it is alleged that Qin engaged in numerous violations of U.S. export laws since 2012. In his petition to become a legal permanent resident of the U.S., Qin again falsely certified that he had never committed any crime. Furthermore, during a November 2017, interview with Customs and Board Patrol Officers, Qin stated that he “only” exported instruments that attach to a buoy. However, Qin had allegedly exported remotely-operated side scan sonar systems, unmanned underwater vehicles, unmanned surface vehicles, robotic boats, and hydrophones. These items have military applications and can be used for weapon delivery systems, anti-submarine warfare, mine counter-measures as well as intelligence, surveillance and reconnaissance activities.
 
The charge of conspiring to violate U.S. export laws provides for a sentence of no greater than 20 years in prison, three years of supervised release and a fine of $1 million. The charge of visa fraud provides for a sentence of no greater than 10 years in prison, three years of supervised release and a fine of $250,000. Sentences are imposed by a federal district court judge based upon the U.S. Sentencing Guidelines and other statutory factors. … 
 
The details contained in the indictment are allegations. The defendant is presumed to be innocent unless and until proven guilty beyond a reasonable doubt in a court of law.

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OGS_77

Justice: “Newly Unsealed Federal Indictment Charges Iranian Businessman with Illegally Exporting Nuclear Nonproliferation-Controlled Materials from Illinois”

(Source: Justice, 21 Jun 2018.) [Excerpts.] 
 
An Iranian businessman schemed with the owner of a European company to illegally export nuclear nonproliferation-controlled materials to Iran from Illinois, according to a newly unsealed federal indictment.
 
Saeed Valadbaigi, also known as “Saeed Valad” and “Saeed Baigi,” plotted in 2011 to illegally export U.S.-origin 7075 T6 Aluminum tubing from Illinois to Iran by way of Belgium and Malaysia, the indictment states.  The size and type of the aluminum was used in the missile and aerospace industry and was subject to U.S. regulations for nuclear nonproliferation purposes, the indictment states.  Valadbaigi’s smuggling plan was part of an effort to evade U.S. laws and export-control regulations, according to the charges.
 
The eight-count indictment was returned in 2016 in U.S. District Court in Chicago and ordered unsealed Wednesday.  It charges Valadbaigi with three counts of wire fraud, two counts of attempting to violate the International Emergency Economic Powers Act, one count of conspiracy to defraud the United States, one count of illegally exporting articles from the United States, and one count of making false statements on a U.S. export form.
 
Valadbaigi, 56, of Iran, is considered a fugitive.  A warrant for his arrest was issued in 2016 and remains outstanding. … 
 
In addition to the 7075 Aluminum tubing, the newly unsealed indictment accuses Valadbaigi of illegally exporting titanium sheets from a company in northern Illinois, to Iran, by way of the Republic of Georgia, the United Arab Emirates and Malaysia.  At the time of that deal in 2009, Valadbaigi controlled various companies in all three of those countries, the indictment states.  The charges further allege that Valadbaigi in 2012 ordered acrylic sheets from a company in Connecticut, and falsely claimed that the sheets would be used only in Hong Kong.  He later allegedly arranged for the acrylic sheets to be transshipped to Iran.
 
The public is reminded that an indictment is not evidence of guilt.  The defendant is presumed innocent and entitled to a fair trial at which the government has the burden of proving guilt beyond a reasonable doubt.  Each count of wire fraud and attempting to violate the IEEPA carries a maximum sentence of 20 years in prison.  The illegal export charge is punishable by up to ten years in prison, while the conspiracy and false statement counts are each punishable by up to five years.  If convicted, the Court must impose a reasonable sentence under federal statutes and the advisory U.S. Sentencing Guidelines.
 
The charges against Valadbaigi are part of an investigation that previously resulted in the conviction of NICHOLAS KAIGA, who managed and later owned the Belgium company that did business with Valadbaigi.  Kaiga admitted in a plea agreement that he knew the 7075 Aluminum was subject to U.S. export controls and that it could not be exported to Malaysia without a license from the U.S. Department of Commerce, which neither he nor Valadbaigi possessed.  Kaiga admitted that he nonetheless used his company, Industrial Metals and Commodities, as an intermediary to export the 7075 Aluminum tubing from a company in northern Illinois, to Belgium and then to Malaysia, on behalf of Valadbaigi.  Kaiga pleaded guilty to violating U.S. export-control regulations and was sentenced in 2015 to two years and three months in a U.S. prison.

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OGS_88. 
State/DDTC: (No new postings.)

(Source: State/DDTC)

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OGS_99. 
UK ECJU Reintroduces Control List Classification Advisory Service

(Source: UK ECJU, Notice to Exporters 2018/15, 21 Jun 2018.) [Excerpts.] 
 
The export control joint unit (ECJU) will reintroduce the control list classification advisory service at 9:30am on 25 June 2018. The service has been suspended since June 2014 for operational reasons.
 
This advisory service is for the assessment of goods and technology against the UK strategic export control lists, and will be available through the SPIRE online processing system.
 
Action for Exporters
 
Please limit each enquiry to a maximum of 4 items and do not submit multiple enquiries. We want to allow all enquirers equal access to the service.
 
We recommend you carefully consider the items against export control legislation before submitting an enquiry. Try to self-assess using the resources available on GOV.UK.
 
If after such research, our assistance through this SPIRE service is still required, please provide details of any analysis that you have made of whether or not your items are listed on the control lists. Please also provide all relevant technical details. The efficiency of the service depends on the accuracy of the information you provide.
 
Update to the Service
 
Assessments against goods within sanction lists will not be available. So, if you wish to export to a country with restrictive measures (sanctions) legislation in force, please consider the legislation carefully, seeking independent legal advice as required.
 
Please note that any guidance from the control list classification advisory service is based solely on the information presented as part of the enquiry. No further research is conducted by our advisers.
 
Use of the control list classification service does not absolve exporters from their legal obligations under the UK’s export control legislation.
 
  – Read guidance on the SPIRE online system.
  – Read general guidance on exporting military and dual-use goods.

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NWSNEWS

NWS_a0110. 
Abacus News: “ZTE Says it Can’t Fix a Toilet Without Violating Sanctions”
(Source: Abacus News, 22 June 2018.) [Excerpts.] 
 
When the U.S. banned ZTE from buying any American products for seven years, it was expected to have a crippling impact on the company — with some even fearing it would have to close down entirely.
 
The U.S. and Chinese governments have since worked out a deal that could keep the company afloat, but until it’s official, the ban is still in place. And it’s still being felt in one very weird place: The men’s toilet.
 
A photo of a broken urinal
 has been circulating online, with a sign above it explaining that it can’t be fixed without American parts — parts the company cannot buy without violating the ban.
 

It reads: “Our company is now subject to the export ban posed by the U.S. government. Since this bathroom appliance is a product of American Standard, we can’t procure the spare parts for repair due to the export ban. When the export ban is lifted, we promise to get the parts, repair it, and resume operation at once. We regret any inconvenience this may have caused.” … 

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NWS_a2
11
Law360: “Policy Is Changing for Technology Transfers”
(Source: Law360, 20 Jun 2018.) [Excerpts; subscription required.]
 
The Trump administration and Congress are tightening investment restrictions and export controls to address technology transfer concerns. These measures initially focus on China, but will have broader effects on investments in the United States and transfers of emerging technologies.
 
The White House issued a statement on May 29, 2018, indicating that the Trump administration intends to proceed with new investment restrictions and “enhanced export controls” targeting China as a result of a review conducted pursuant to Section 301 of the Trade Act of 1974. … 

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NWS_ax
12.
ST&R Trade Report: “New Export Controls on China Anticipated Soon” 
(Source: Sandler, Travis & Rosenberg Trade Report, 22 Jun 2018.)
 
President Trump could issue in the next few days an executive order imposing new China-focused export controls on a number of emerging high-tech sectors. A recent White House report asserts that U.S. national and economic security is threatened by China’s use of “economic aggression” to “capture” these industries, including through its “Made in China 2025” industrial policy.
 
The report from the White House’s Office of Trade and Manufacturing Policy asserts that China is aggressively seeking to acquire technology and intellectual property from around the world through (1) state-sponsored IP theft, including physical theft, cyber-enabled espionage and theft, evasion of export control laws, and counterfeiting and piracy; (2) coercive and intrusive regulatory gambits to force technology transfer from foreign companies; (3) economic coercion through export restraints on critical raw materials; (4) methods of information harvesting that include placing non-traditional information collectors at U.S. universities, national laboratories, and other centers of innovation as well as talent recruitment of business, finance, science, and technology experts; and (5) state-backed, technology-seeking foreign direct investment.
 

Steven Brotherton, who heads Sandler, Travis & Rosenberg’s export controls practice, said that in light of this report the anticipated executive order could impose export controls on sectors such as artificial intelligence, aerospace, augmented and virtual reality, high-speed rail and shipping, and new energy vehicles. The end result, Brotherton said, could be a new export license requirement for many activities in these sectors involving China, including manufacturing, technological exchanges with Chinese companies, and the employment of Chinese nationals in the U.S.
 

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NWS_ax1
13.
A. Dier: “Mexico’s World Cup Captain Blacklisted by U.S.” 
(Source: Newser, 19 Jun 2018.)
 
    The captain of Mexico’s World Cup squad became one of only three athletes to play in five World Cup tournaments on Sunday. But Rafael “Rafa” Marquez’s substitution in a 1-0 win over defending champions Germany, per 
ESPN, wasn’t to be applauded by all onlookers, including in his home country. “It is incredible that the authorities are allowing a person who is accused of money laundering to go and play a World Cup as if nothing happened,” a Mexico City resident tells the 
Los Angeles Times, referring to accusations that Marquez held assets for a Mexican drug trafficker, which prompted the US Treasury to freeze his bank accounts and block US companies from doing business with him last August. “That impunity only happens in Mexico. If you or someone who is not famous had cheated, they would put you in jail.”

    Marquez, who has not been formally charged, is about as far from a jail cell as you can get. Two weeks before taking to Russia’s open soccer pitches, Marquez visited Mexican President Enrique Peña Nieto at the presidential palace. As one fan tells the 
Times, “Rafa is the soul of the national team, and if he is in trouble with the United States, we don’t care.” Still, the 39-year-old defender agreed not to be paid for his role with the team, where he’s the only member forced to avoid gear featuring logos of sponsors including Coca-Cola, per the 
New York Times. He also had to miss a warm-up match in California. If any of that is a distraction, Marquez isn’t showing it. “I feel in great shape for the rest of the tournament,” he said after Sunday’s win. “Back home no one thought that we could pull this off.”

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COMMCOMMENTARY

COMM_a1
14.
M. Volkov: “When Your CEO Just Does Not Get It”
(Source: Volkov Law Group Blog, 21 Jun 2018. Reprinted by permission.) 
 
* Author: Michael Volkov, Esq., Volkov Law Group, mvolkov@volkovlaw.com, 240-505-1992. 
 
There are a lot of talented CEOs.  Some remarkable leaders, innovators and eloquent spokespeople for their companies.  In several recent experiences, I have been befuddled by some CEOs.
 
When a CEO addresses a global ethics and compliance staff or has the opportunity to address a large staff or division meeting, the CEO should take the opportunity to reinforce the company’s culture and compliance program message.  CEOs spend a lot of time speaking to groups, meeting with stakeholders and representing the company.
 
What happens, however, when a CEO misses the mark in explaining a company’s ethics and compliance program.  Too often I hear about CEOs who will make statements about the importance of ethics and compliance by narrowly defining the purpose of an ethics and compliance program.
 
What do I mean by this?  As an example, a CEO who explains to a company group that the purpose of an ethics and compliance staff is “to keep the company compliant.”
 
I am not being nitpicky here – the CEO has missed the point – the purpose of a company’s ethics and compliance program is to promote the company’s culture and ensure compliance with the laws and the company’s code of conduct.  There is a big difference between the two statements.  A CEO who defines an ethics and compliance program as narrowly focused on compliance with the laws is selling the company short, including its compliance staff.
 
The questions are: who is responsible for these misstatements? And what are the implications of such a viewpoint? 

It is very easy to blame the CEO.  Of course, every CEO in knows about the importance of corporate culture and should be aware of the role of ethics and compliance programs in promoting such culture.  CEO’s also should be aware of the importance of a company’s culture to a company’s financial sustainability and overall performance.  Given this state of the business world, how could a CEO ignore the connection between compliance and a company’s culture?
 
A chief compliance officer has an important task (of many) and that is to educate the company’s board and senior leadership.  A key part of this education and training is the importance of a company’s culture and its overall compliance with the law.

If a CCO fails to correct the CEO (which can be done delicately), the CCO has to bear some responsibility, unless the CEO somehow ignores the message and the CCO’s education efforts.  A CCO has to take stock of what a CEO knows and what a CEO does not know.  The CCO has a job which is to fill in the educational gaps.
 
A CCO cannot ignore this responsibility.  The importance of educating the CEO so that the CEO understands the role of ethics and compliance is critical.  A CCO depends on the CEO for support and resources – if the CEO does not understand the linkage of all of these issues, then the CCO has to redouble his or her efforts.
 
A CEO who speaks to stakeholders, leads a company and its employees and fails to accurately articulate the message behind compliance, is a leader who is suffering from a serious blinding of vision.  A CEO who is riddled with missed opportunities, in the end, will be a leader who does not achieve his or her full potential.  CEOs have to understand and commit themselves to a company’s culture – a company’s performance (and possibly its future) may depend on it.

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COMM_a2
15. 
T. Murphy: “EU Retaliatory Tariffs Enter Into Force Today”
(Source: Author, 22 June 2018.) 
 
* Author: Ted Murphy, Esq., ted.murphy@bakermckenzie.com, +1 202 452 7000, Baker & McKenzie LLP. 
 
As you may have heard, the EU has formally decided to impose retaliatory tariffs on certain products originating in the United States.  This is in response to President Trump’s decision to impose additional tariffs on EU steel and aluminium products.
 
The new additional tariffs will come into effect today, June 22nd.  
 
List of Affected Items
 
The full list of affected EU tariff codes is set out in Annex I to Commission Implementing Regulation (EU) 2018/886, available here.  In almost all cases, products are subject to an additional duty of 25%.
 
The new tariffs affect all goods of US origin falling within the affected tariff codes that are imported into the EU from June 22nd, except for:
 
  – goods already exported from the US before 22 June (for which the importer must provide proof); and
  
– 
goods for which an import licence exempting or reducing duty on the goods (e.g., by use of tariff quotas) has been obtained before 22 June.
 
As a result, if your goods have been shipped out of the US prior to the 22nd of June or if they are currently “on the water” or if they are held under bond in the EU prior to the 22nd of June, they will not be affected by the additional tariffs.
 
The legislation also provides for additional tariffs on other product lines, which will take effect from the earlier of (i) 1 June 2021 or (ii) from the fifth day following a WTO ruling that the US is in violation of the WTO Agreement.  These products and tariff rates are listed in Annex II to the Regulation linked above.
 
Recommended Actions
 
We suggest that you:
 
  – review the tariff codes for any products imported into the EU and identify those caught by these measures;
  – verify that none of those would qualify as “originating in the US”. 
We
 note that products that are manufactured in another country but have a high US content may qualify as ‘US-origin’ goods if the local manufacturing / processing is not sufficient to confer origin. You should therefore carefully review the origin of products caught by the additional duties that have US content.
 
The situation remains fast-moving, and we note in particular recent news reports that suggest that the EU may offer to reduce its tariffs on automobile imports in exchange for relief from the new US measures.  If the US agrees, then the EU will drop its retaliatory measures.

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TEEX/IM TRAINING EVENTS & CONFERENCES

EXMS_a1
16. 
DDTC Is Hiring
(Source: Editor, 22 June 2018.) 
 
DDTC has several jobs available for compliance specialists and classification analysts to be hired by a civilian contractor. See the job offers HERE (Compliance) and HERE (CJs).

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TEEX/IM TRAINING EVENTS & CONFERENCES

TE_a3
17. 
List of Approaching Events – 12 New Events Listed
(Sources: Editor and Event Sponsors)

Published every Friday or last publication day of the week, o
ur overview of Approaching Events is organized to list c
ontinuously available training, training events, s
eminars & conferences, and 
webinars. 
 
Please, submit your event announcement to John Bartlett, Events & Jobs Editor (email: 
jwbartlett@fullcirclecompliance.eu
), composed in the below format:
 
# DATE: LOCATION; “EVENT TITLE”; EVENT SPONSOR; WEBLINK; CONTACT DETAILS (email and/or phone number)
 

#” = New or updated listing  

 
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
 
Seminars and Conferences
 

*
 Jun 26: Waltham, MA; “
U.S. Trade with Canada
“; Coalition Of New England Companies for Trade (CONECT)
* Jun 26: Lansing, MI; “Export Documentation and Procedures Seminar“; International Business Training 

* Jun 26-27: Tysons Corner, VA; ”
Conducting an Internal Audit for Your Import and Export Transactions; Global Trade Academy

* 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: Lansing, MI
; “
Import Documentation and Procedures Seminar
“; International Business Training

* Jun 28: London, UK; “
Making Better License Applications
“; UK Department for International Trade
 

* Jun 28-29: London, UK; ”
The WorldECR Export Controls & Sanctions Forum 2018“; World ECR

* Jul 2-6: Paris, France; “Training On ISO 19600 & ISO 37001 In Paris“;
* Jul 4: Cambridge, UK; “Intermediate Seminar“; UK Department for International Trade
* Jul 5: Cambridge, UK; “Beginner’s Workshop“; UK Department for International Trade
* Jul 5: Cambridge, UK; “Licenses Workshop“; UK Department for International Trade
* Jul 5: Cambridge, UK; “Control List Classification – Combined Dual Use and Military“; UK Department for International Trade
* Jul 10: Chicago, IL; “Duty Drawback Specialist – Certification“; Global Trade Academy
* Jul 10-11: Columbia, SC; “Complying with US Export Controls“; Bureau of Industry and Security

* Jul 10-11: Long Beach, CA; ”
ITAR/EAR Boot Camp: Achieving ITAR/EAR Compliance”;  Export Compliance Solutions;   
spalmer@exportcompliancesolutions.com; 866-238-4018

* Jul 10-12: Chicago, IL; “Duty Drawback Specialist – Certification“; Amber Road 
* Jul 11-14: Laredo, Texas; “Best Customs Broker Exam Course“; GRVR Attorneys  
* Jul 16-18: National Harbor, Maryland; “2018 Summer Basics Conference“; Society for International Affairs
* Jul 16: Atlanta, GA; “Export Documentation and Procedures Seminar“; International Business Training
* Jul 17: Los Angeles, CA; “Advanced Classification of Plastics and Rubber“; Global Trade Academy
 
* Jul 18-20: Raleigh, NC; “Export Controls Specialist Certification“; Global Trade Academy
* Jul 19: Atlanta, GA; “Import Documentation and Procedures Seminar“; International Business Training 
* Jul 19: Chicago, IL; “Import Documentation and Procedures Seminar“; International Business Training 
* Jul 19: McLean, VA; “ITAR for the Empowered Official“; FD Associates
* Jul 19-20: Torrance, CA; “
Customs Compliance For Import Personnel
“; Foreign Trade Association
* Jul 24: Charlotte, NC; “Export Documentation and Procedures Seminar“; International Business Training

* Jul 25-26: Seattle WA; ”
2018 Pacific Northwest Export Controls Conference;” Dept. of Commerce/U.S. Commercial Service, Dept. of Homeland Security/Homeland Security Investigations, Seattle University, Dorsey & Whitney LLP

* Jul 26: Chicago, IL; “Export Documentation and Procedures Seminar“; International Business Training 
* Jul 26-29: Chicago, IL; “Customs Broker 4-Day Bootcamp“; Global Trade Academy
* Jul 26-29: Princeton, NJ; “Customs Broker 4-Day Bootcamp“; Global Trade Academy

# Jul 27: Charlotte, NC; 

Incoterms 2010: Terms of Sale Seminar“; International Business Training
# Jul 27: Chicago, IL; Incoterms 2010: Terms of Sale Seminar“; International Business Training

* Jul 30-31: Dallas, TX; “GTEC – Global Trade Educational Conference 2018“; Foreign Trade Association/ National Customs Broker & Freight Forwarder Association of America (NCBFAA)

* 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: Orlando, FL
; “
Import Documentation and Procedures Seminar
“; International Business Training

* Aug 7: Detroit, MI; “
Export Controls Specialist – Certification“; Global Trade Academy
* Aug 7-9: Detroit, MI; “Export Controls Specialist – Certification“; Global Trade Academy
* Aug 8: Orlando, FL; “Export Documentation and Procedures Seminar“; International Business Training 
* Aug 14-15: Milpitas, CA; “Complying with US Export Controls“; Bureau of Industry and Security
* Aug 14-15: Atlanta, GA; “2018 Trade Symposium“; U.S. Customs and Border Protection
* Aug 15: Minneapolis, MN; “Export Documentation and Procedures Seminar“; International Business Training 
* Aug 16: Indianapolis, IN; “
Export Documentation and Procedures Seminar
“; International Business Training 
* Aug 16: Milpitas, CA; “Encryption Controls“; Bureau of Industry and Security
# Aug 16: Minneapolis, MN; “Incoterms 2010: Terms of Sale Seminar“; International Business Training
# Aug 17: Indianapolis, IL; Incoterms 2010: Terms of Sale Seminar“; International Business Training
* Aug 20: Cincinnati, OH; “Export Documentation and Procedures Seminar“; International Business Training 
* Aug 22: Minneapolis, MN; “Import Documentation and Procedures Seminar“; International Business Training
* Aug 23: Cincinnati, OH; “Import Documentation and Procedures Seminar“; International Business Training 
* Aug 24: Houston, TX; “Export Documentation and Procedures Seminar“; International Business Training 

* September 11-13: Annapolis, MD; ”
Defense Industry Experts and ITAR/EAR Boot Camp“; Export Compliance Solutions;
spalmer@exportcompliancesolutions.com; 866-238-4018
* Sep 11-13: Detroit, MI; “
Export Controls Specialist Certification
“; Global Trade Academy 

* Sep 12: Buffalo, NY; “Export Documentation and Procedures Seminar“; International Business Training 
* Sep 12-13: Springfield, RI; “Complying with US Export Controls“; Bureau of Industry and Security
* Sep 13: Buffalo, NY; “Import Documentation and Procedures Seminar“; International Business Training 
* 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: Anaheim, CA; “Import Documentation and Procedures Seminar“; International Business Training 

* Sep 18: San Diego, CA; “
12th CompTIA Global Trade Compliance Best Practices Conference“; CompTIA

* Sep 18: Los Angeles, CA; “Tariff Classification for Importers and Exporters“; Global Trade Academy 
* Sep 19: Washington, D.C.; “ DDTC In-House Seminar“; Department of State (Registration: Aug 10 – Aug 31; first come, first served)
* Sep 19: Los Angeles, CA; “NAFTA and Trade Agreements“; Global Trade Academy
* Sep 19-20: Rome, Italy; “Defense Exports 2018“; SMi

* Sep 19-20: Los Angeles, CA; ”
Complying With U.S. Export Controls“; BIS

* Sep 20: Pittsburgh, PA; “Export Documentation and Procedures Seminar“; International Business Training 
* 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: Pittsburgh, PA; “Incoterms 2010: Terms of Sale Seminar“; International Business Training
* Sep 21-24: Detroit, Michigan; “Best Customs Broker Exam Course“; GRVR Attorneys 

* Sep 25: Kansas City, MO
; “
Import Documentation and Procedures Seminar
“; International Business Training

* Sep 26: Kansas City, MO; “Export Documentation and Procedures Seminar“; International Business Training 
* 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
* Sep 28: Anaheim, CA; “Export Documentation and Procedures Seminar“; International Business Training 

# Oct 5: Boston, MA; “
Incoterms 2010: Terms of Sale Seminar“; International Business Training
* Oct 9: New Orleans, LA
; “
Import Documentation and Procedures Seminar
“; International Business Training

* Oct 11: New Orleans, LA; “Export Documentation and Procedures Seminar“; International Business Training 
# Oct 12: New Orleans, LA; “Incoterms 2010: Terms of Sale Seminar“; International Business Training
* Oct 15-19: Chicago, IL; “Certified Classification Specialist“; Global Trade Academy
* 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“; International Compliance Professionals Association (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 26: Louisville, KY; “Incoterms 2010: Terms of Sale Seminar“; International Business Training
* Oct 29 – Nov 1: Phoenix, AZ; ITAR Defense Trade Controls / EAR Export Controls Seminar“; ECTI; jessica@learnexportcompliance.com; 540-433-3977

* Oct 29: Seattle, WA; ”
Export Compliance & Controls 101“; Global Trade Academy

* 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: Detroit, MI; ”
Advanced Classification of Machinery and Electronics“; 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 14-15: London, UK; “
Economic Sanctions & Financial Crime
“; C5 Group 

* 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 15: McLean, VA; “ITAR For the Empowered Official“; FD Associates
# Nov 16, San Diego, CA; “Incoterms 2010: Terms of Sale Seminar“; International Business Training
* 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
# Dec 14: Philadelphia, PA; “Incoterms 2010: Terms of Sale Seminar“; International Business Training
 
2019
 

* Jan 6-7: Long Beach, CA; ”
Fundamentals of FTZ Seminar“;
* Feb 12-13: Washington, D.C.; “
2019 Legislative Summit
“; National Association of Foreign Trade Zones (NAFTZ) 

* 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)
 
Webinars 
 

Jun 18: Commodity Webinar; “June Series: Heating and Cooling Treatment Facilities“; National Commodity Specialist Division (NCSD)  
Jun 19: Commodity Webinar; “June Series: Sanitary Ware of Iron or Steel“; National Commodity Specialist Division (NCSD) 

* Jun 19: Webinar; ”
Export 101: Starting at the Beginning“; ECTI

Jun 20: Commodity Webinar; “June Series: Polymer Basics“; National Commodity Specialist Division (NCSD) 
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 28: Webinar; ”
International Letters of Credit“; Massachusetts Export Center

Jul 7: Commodity Webinar; “July Series: What’s a Toy?“; National Commodity Specialist Division (NCSD)  
Jul 10: Commodity Webinar; “July Series: Food Incorporating Alcohol“; National Commodity Specialist Division (NCSD)  

* 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 17: Commodity Webinar; “July Series: Other Articles of Steel“; National Commodity Specialist Division (NCSD) 

* Jul 19: Commodity Webinar; “July Series: Tubes and Pipes of Iron or Steel“; National Commodity Specialist Division (NCSD)

# Jul 19: Webinar; ”
UPS Customs Brokerage Webinar – Drawback Update“; United Parcel Service

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

ENEDITOR’S NOTES

EN_a118
. Bartlett’s Unfamiliar Quotations

(Source: Editor)

Jacques Delille (22 Jun 1738 – 1 May 1813; was a French poet and translator.)
  – “Fate chooses our relatives, we choose our friends.”
 
David Ogilvy (David Mackenzie Ogilvy; 23 Jun 1911 – 21 Jul 1999; was an advertising tycoon, founder of Ogilvy & Mather, and known as the father of advertising. Trained at the Gallup research organization, he attributed the success of his campaigns to meticulous research into consumer habits.)
  – “The best ideas come as jokes. Make your thinking as funny as possible.”

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

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 Jun 2018: 83 FR 27380-27407: Air Cargo Advance Screening (ACAS)
 
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: 6 June 2018: 83 FR 26204-26205: Unverified List (UVL); Correction 

 

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

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

 

FOREIGN TRADE REGULATIONS (FTR): 15 CFR Part 30  

  – Last Amendment: 24 Apr 2018:
83 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 
here.
  –
The latest edition (30 April 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: 8 Jun 2018: Harmonized System Update 1809, containing 901 ABI records and 192 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: 25 Apr 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.  If you would to submit material for inclusion in the The Export/Import Daily Update (“Daily Bugle”), please find instructions here.

* 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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