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18-0625 Monday “Daily Bugle”

18-0625 Monday “Daily Bugle”

Monday, 25 June 2018

TOP
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. President Continues National Emergency With Respect to North Korea 
  2. President Continues National Emergency With Respect to Western Balkans 
  3. Commerce Seeks Comments on Proposed Information Collection Concerning BIS-711, Statement by Ultimate Consignee and Purchaser
  4. State Extends Comment Period Concerning Maintenance of Records by DDTC Registrants
  5. State Extends Comment Period Concerning Request for Approval of Manufacturing License Agreements, Technical Assistance Agreements, and Other Agreements
  1. Items Scheduled for Publication in Future Federal Register Editions
  2. Commerce/BIS: (No new postings.)
  3. State/DDTC: (No new postings.)
  4. Norway Releases Annual White Paper on Exports of Defense-Related Products
  5. UK ECJU Changes Email Address Format
  1. The Guardian: “UK ‘Hides Extent of Arms Sales to Saudi Arabia'”
  2. Law360: “Trade Lessons from the ZTE Saga”
  3. Politico: “Trump Gets Ready to Slap China with Investment Restrictions, Export Controls”
  4. Reuters: “China’s ZTE Expected to Take Last Step to Lift Ban: U.S. Official”
  5. Reuters: “Turkey to Start Implementing Retaliatory Tariffs Against United States”
  6. SpaceNews: “Commerce Department Moves Ahead with Space Regulatory Reforms”
  1. B. Schwartz: “Strengthening the Economy at Home and U.S. Military Partnerships Abroad”
  2. M. Volkov: “Podcast Episode 44 – Compliance Program Best Practices: The FCPA Guidance and DOJ’s Evaluation of Corporate Compliance Programs”
  3. R.L. Cassin: “Compliance Pros Are Rock Stars, Yes They Are”
  1. Monday List of Ex/Im Job Openings: 198 Jobs Posted This Week, Including 11 New Jobs
  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. President Continues National Emergency With Respect to North Korea

(Source: 
Federal Register
, 25 Jun 2018.) [Excerpts.]
 
83 FR 29661-29662: Continuation of the National Emergency With Respect to North Korea
 
On June 26, 2008, by Executive Order 13466, the President declared a national emergency with respect to North Korea pursuant to the International Emergency Economic Powers Act (50 U.S.C. 1701-1706) to deal with the unusual and extraordinary threat to the national security and foreign policy of the United States constituted by the existence and risk of proliferation of weapons-usable fissile material on the Korean Peninsula. The President also found that it was necessary to maintain certain restrictions with respect to North Korea that would otherwise have been lifted pursuant to Proclamation 8271 of June 26, 2008, which terminated the exercise of authorities under the Trading With the Enemy Act (50 U.S.C. App. 1-44) with respect to North Korea.
  On August 30, 2010, the President signed Executive Order 13551, which expanded the scope of the national emergency declared in Executive Order 13466 to deal with the unusual and extraordinary threat to the national security, foreign policy, and economy of the United States posed by the continued actions and policies of the Government of North Korea, manifested by its unprovoked attack that resulted in the sinking of the Republic of Korea Navy ship Cheonan and the deaths of 46 sailors in March 2010; its announced test of a nuclear device and its missile launches in 2009; its actions in violation of United Nations Security Council Resolutions 1718 and 1874, including the procurement of luxury goods; and its illicit and deceptive activities in international markets through which it obtains financial and other support, including money laundering, the counterfeiting of goods and currency, bulk cash smuggling, and narcotics trafficking, which destabilize the Korean Peninsula and imperil United States Armed Forces, allies, and trading partners in the region. … 
  The existence and risk of proliferation of weapons-usable fissile material on the Korean Peninsula and the actions and policies of the Government of North Korea continue to pose an unusual and extraordinary threat to the national security, foreign policy, and economy of the United States. For this reason, the national emergency declared in Executive Order 13466, expanded in scope in Executive Order 13551, addressed further in Executive Order 13570, further expanded in scope in Executive Order 13687, and under which additional steps were taken in Executive Order 13722 and Executive Order 13810, and the measures taken to deal with that national emergency, must continue in effect beyond June 26, 2018. Therefore, in accordance with section 202(d) of the National Emergencies Act (50 U.S.C. 1622(d)), I am continuing for 1 year the national emergency with respect to North Korea declared in Executive Order 13466. … 
 
  [Presidential Signature.]
 
THE WHITE HOUSE, June 22, 2018.

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

EXIM_a2

2. 
President Continues National Emergency With Respect to Western Balkans

(Source: 
Federal Register, 25 Jun 2018.) [Excerpts.] 
 
83 FR: 29663: Continuation of the National Emergency With Respect to the Western Balkans
 
On June 26, 2001, by Executive Order 13219, the President declared a national emergency with respect to the Western Balkans, pursuant to the International Emergency Economic Powers Act (50 U.S.C. 1701-1706), to deal with the unusual and extraordinary threat to the national security and foreign policy of the United States constituted by the actions of persons engaged in, or assisting, sponsoring, or supporting (i) extremist violence in the Republic of Macedonia and elsewhere in the Western Balkans region, or (ii) acts obstructing implementation of the Dayton Accords in Bosnia or United Nations Security Council Resolution 1244 of June 10, 1999, in Kosovo. The President subsequently amended that order in Executive Order 13304 of May 28, 2003, to take additional steps with respect to acts obstructing implementation of the Ohrid Framework Agreement of 2001 relating to Macedonia.
  The actions of persons threatening the peace and international stabilization efforts in the Western Balkans, including acts of extremist violence and obstructionist activity, continue to pose an unusual and extraordinary threat to the national security and foreign policy of the United States. For this reason, the national emergency declared on June 26, 2001, and the measures adopted on that date and thereafter to deal with that emergency, must continue in effect beyond June 26, 2018. Therefore, in accordance with section 202(d) of the National Emergencies Act (50 U.S.C. 1622(d)), I am continuing for 1 year the national emergency with respect to the Western Balkans declared in Executive Order 13219. … 
 
  [Presidential Signature.] 
 
THE WHITE HOUSE, June 22, 2018.

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

(Source: 
Federal Register, 25 Jun 2018.) [Excerpts.] 
 
83 FR 29540: Submission for OMB Review; Comment Request 
 
The Department of Commerce will submit to the Office of Management and Budget (OMB) for clearance the following proposal for collection of information under the provisions of the Paperwork Reduction Act (44 U.S.C. chapter 35).
 
  – Agency: Bureau of Industry and Security.
  – Title: Statement by Ultimate Consignee and Purchaser.
  – Form Number(s): BIS-711.
  – OMB Control Number: 0694-0021. 
  – Type of Review: Regular submission. … 
  – Needs and Uses: The collection is necessary under Part 748.11 of the EAR. This section states that the Form BIS-711, Statement by Ultimate Consignee and Purchaser, or a statement on company letterhead (in accordance with 748.11(b)(1)), must provide information on the foreign importer receiving the U.S. technology and how the technology will be utilized. The BIS-711 or letter provides assurances from the importer that the technology will not be misused, transferred or re-exported in violation of the EAR. … 
 
Written comments and recommendations for the proposed information collection should be sent within 30 days of publication of this notice to
OIRA_Submission@omb.eop.gov
 
Sheleen Dumas, Departmental Lead PRA Officer, Office of the Chief Information Officer.

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

EXIM_a4

4. 
State Extends Comment Period Concerning Maintenance of Records by DDTC Registrants
(Source: 
Federal Register, 25 Jun 2018.) [Excerpts.] 
 
83 FR 29599: 30-Day Notice of Proposed Information Collection: Maintenance of Records by DDTC Registrants
 
* ACTION: Notice of request for public comment.
* SUMMARY: The Department of State has submitted the information collection described below to the Office of Management and Budget (OMB) for approval. In accordance with the Paperwork Reduction Act of 1995 we are requesting comments on this collection from all interested individuals and organizations. The purpose of this Notice is to allow 30 days for public comment.
* DATES: Submit comments directly to the Office of Management and Budget (OMB) up to July 25, 2018.
*  ADDRESSES: Direct comments to the Department of State Desk Officer in the Office of Information and Regulatory Affairs at the Office of Management and Budget (OMB). You may submit comments by the following methods:
  – Email: 
oira_submission@omb.eop.gov. You must include the DS form number, information collection title, and the OMB control number in the subject line of your message.
  – Fax: 202-395-5806. Attention: Desk Officer for Department of State.
* FOR FURTHER INFORMATION CONTACT: Direct requests for additional information regarding the collection listed in this notice, including requests for copies of the proposed collection instrument and supporting documents, to Andrea Battista, SA-1, 12th Floor, Directorate of Defense Trade Controls, Bureau of Political Military Affairs, U.S. Department of State, Washington, DC 20522-0112, via phone at (202) 663-3136, or via email at 
battistaal@state.gov.
* SUPPLEMENTARY INFORMATION:
  – Title of Information Collection: Maintenance of Records by Registrants.
  – OMB Control Number: 1405-0111.
  – Type of Request: Extension of a currently approved collection.
  – Originating Office: Directorate of Defense Trade Controls (PM/DDTC).
  – Form Number: No form. … 
  – Respondents: Persons registered with DDTC who conduct business regulated by the International Traffic in Arms Regulations (ITAR, 22 CFR parts 120-130). … 
 
Abstract of Proposed Collection
 
The ITAR requires persons registered with DDTC to maintain records pertaining to defense trade-related transactions. This information collection approves the record-keeping requirements imposed on registrants by the ITAR. Respondents to this collection may submit their records to DDTC as supporting documentation for disclosures of potential violations of the AECA. The method by which respondents submit these records is approved under OMB control no. 1405-0179. DDTC uses these records to analyze industry compliance processes and procedures, and to help assess whether the activity in question might merit administrative sanctions or referral to the Department of Justice for possible criminal prosecution. … 
 
Methodology
 
Respondents may maintain records in any format consistent with the provisions in ITAR §122.5.
Anthony M. Dearth, Managing Director (Acting), Directorate of Defense Trade Controls, Department of State.

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

EXIM_a5

5. 
State Extends Comment Period Concerning Request for Approval of Manufacturing License Agreements, Technical Assistance Agreements, and Other Agreements 
(Source: 
Federal Register, 25 Jun 2018.) [Excerpts.] 
 
83 FR 29599: 30-Day Notice of Proposed Information Collection: Request for Approval of Manufacturing License Agreements, Technical Assistance Agreements, and Other Agreements
 
* ACTION: Notice of request for public comment.
* SUMMARY: The Department of State has submitted the information collection described below to the Office of Management and Budget (OMB) for approval. In accordance with the Paperwork Reduction Act of 1995 we are requesting comments on this collection from all interested individuals and organizations. The purpose of this Notice is to allow 30 days for public comment.
* DATES: Submit comments directly to the Office of Management and Budget (OMB) up to July 25, 2018.
ADDRESSES: Direct comments to the Department of State Desk Officer in the Office of Information and Regulatory Affairs at the Office of Management and Budget (OMB). You may submit comments by the following methods:
 – Email: 
oira_submission@omb.eop.gov. You must include the DS form number, information collection title, and the OMB control number in the subject line of your message.
 – Fax: 202-395-5806. Attention: Desk Officer for Department of State.
* FOR FURTHER INFORMATION CONTACT: Direct requests for additional information regarding the collection listed in this notice, including requests for copies of the proposed collection instrument and supporting documents, to Andrea Battista, SA-1, 12th Floor, Directorate of Defense Trade Controls, Bureau of Political Military Affairs, U.S. Department of State, Washington, DC 20522-0112, via phone at (202) 663-3136, or via email at 
battistaal@state.gov.
* SUPPLEMENTARY INFORMATION:
  – Title of Information Collection: Request for Approval of Manufacturing License Agreements, Technical Assistance Agreements, and Other Agreements.
  – OMB Control Number: 1405-0093.
  – Type of Request: Extension.
  – Originating Office: Directorate of Defense Trade Controls (DDTC).
  – Form Number: No Form.
  – Respondents: Business, Nonprofit Organizations, or Persons who intend to furnish defense services or technical data to a foreign person. … 
 
Abstract of Proposed Collection
 
DDTC regulates the export and temporary import of defense articles and services enumerated on the USML in accordance with the Arms Export Control Act (AECA) (22 U.S.C. 2751 et seq.) and the International Traffic in Arms Regulations (ITAR) (22 CFR parts 120-130). In accordance with ITAR §124.1, any person who intends to furnish defense services or technical data to a foreign person must submit a proposed technical assistance, manufacturing, or distribution license agreement and obtain prior authorization from DDTC for such agreement. Amendments to existing agreements must also be submitted for approval. The electronic mechanism utilized for submitting, reviewing, and approving agreement proposals is the Defense Trade Application Systems (DTAS). Specifically, this process utilizes the DSP-5 license application as the primary instrument or “vehicle” for transmitting agreements and their respective amendments from one phase of the adjudication process to the next.
 
Methodology
 
Respondents will submit information as attachments to relevant license applications or requests for other approval.
 
Anthony M. Dearth, Chief of Staff (Acting), Directorate of Defense Trade Controls, U.S. Department of State.

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

OGSOTHER GOVERNMENT SOURCES

OGS_a16. Items Scheduled for Publication in Future Federal Register Editions
(Source: Federal Register)

[No items of interest noted today.]

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

OGS_abc27. 
Commerce/BIS: (No new postings.)
(Source: 
Commerce/BIS)

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

OGS_a2
8. 
State/DDTC: (No new postings.)
(Source: 
State/DDTC)

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

(Source: 
Norwegian Government, 22 Jun 2018.) [Excerpts.] 
 
Today, the Government presented the 
annual white paper (in Norwegian) on exports of defense-related products. In 2017, Norway exported arms and military equipment worth around NOK 5.4 billion, up from NOK 3.6 billion in 2016. … 
 
Traditionally, the main importers of defence-related products from Norway have been other NATO countries, and Sweden and Finland. In 2017, exports to this group of countries accounted for 63 % of exports of arms and ammunition (Category A products) and 80 % of exports of other defence-related products (Category B products). … 
 
The white paper also contains information about denied applications for licenses to export defense-related products and dual-use items for military end use. In 2017, 25 license applications were denied.   
 
  “By international standards, Norway maintains a high level of transparency about defense-related exports, when it comes to both access to information about the exports themselves and about the Ministry’s processing of export license applications for defense-related products, in line with the Ministry of Foreign Affairs guidelines. The Government considers it important to continue to ensure this level of transparency,” Ms Eriksen Søreide said.
 
  “In this year’s white paper, we have also chosen to shed light on some of the challenges arising from the fact that an increasing number of defense systems and products are developed through cooperation between manufacturers in different countries. There may be different rules and regulations in the countries the Norwegian defense industry is cooperating with, and this may potentially challenge Norwegian export control policies.
 
  “The Government will continue to ensure a predictable framework for the defense industry as regards export control, in both the defense and the civilian sectors. Predictability is important for safeguarding the jobs and value creation this industry represents. The Norwegian defense industry is a world leader in the field of technology, which is also of value to other sectors,” Ms Eriksen Søreide said.
 
  “All license applications for exports to high-risk regions are thoroughly assessed on an individual basis and in line with the strict precautionary approach taken by Norway,” Ms Eriksen Søreide said.
 
In accordance with this, in December 2017, the Government decided to suspend licenses for the export of arms and ammunition to the United Arab Emirates. This decision was based on a risk assessment of the grave and unpredictable situation in Yemen.
 
  “Licence applications for exports of other defense-related products will be thoroughly assessed to determine the risk of Norwegian defense-related products being used for internal repression or being used in Yemen, and the threshold for refusing export licenses on these grounds has been lowered further. We will continue our restrictive practice in this area,” Ms Eriksen Søreide said.  
 
The Ministry of Foreign Affairs is not aware that Norwegian defense-related products have been used in the war in Yemen. There have been claims in the media that a small amount of Norwegian-made goods has been found in Yemen. The Ministry has so far not been able to verify this information. 
 
The sale of arms and ammunition to Saudi Arabia is still not permitted. 
 
  “Norway has strict regulations in place for exports of defense-related products. Export control is an integral part of our defense and security policy,” Ms Eriksen Søreide said. 
 
The white paper also describes the Ministry’s cooperation with other government agencies and the extensive international cooperation on export control and non-proliferation. Norway participates actively in this cooperation, and is engaged both in the technical work to draw up lists of conventional defense-related products and dual-use items, and in the efforts to reach agreement on high international standards for control of exports of strategic goods and technology.

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

OGS_a410.
UK ECJU Changes Email Address Format

(Source: 
UK ECJU, Notice to Exporters, 2018/16, 22 Jun 2018.) [Excerpts.]
 
From the end of 30 June 2018, the email address convention for all DIT staff in the export control joint unit (ECJU) will change to:
 
forename.surname@trade.gov.uk. 
 
The convention ‘forename.surname@trade.gsi.gov.uk’ will be switched off and any emails that are sent using it will not be received.
 
This change also applies to non-individual email addresses, for example:
 
eco.help@trade.gov.uk
Wassenaar.Reports@trade.gov.uk
 
Please ensure you update your records of DIT staff contacts. …  

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

NWSNEWS

NWS_a111. 
The Guardian: “UK ‘Hides Extent of Arms Sales to Saudi Arabia'”
(Source: 
The Guardian, 23 Jun 2018.) [Excerpts.] 
 
Campaigners say licenses for ‘less sensitive goods’ are being used for bombs that hit civilian targets in Yemen
 
Hundreds of millions of pounds worth of British-made missiles and bombs have been sold to 
Saudi Arabia for use in Yemen under an opaque licensing system that makes tracking arms sales more difficult.
 
The disclosure has prompted accusations that the government is trying to mask the true extent of British-made arms exports to Saudi, a claim denied by the Department for International Trade. … 
 
Britain has consistently said that it keeps all arms exports under close scrutiny and that licensing is made on a case-by-case basis. But now a freedom of information request reveals that for the last five years, Britain has been selling Storm Shadow and Brimstone air-to-surface missiles and Paveway IV bombs to the Saudis under what are known as Open Individual Export Licences (OIELs), which the government says are for the export of “less sensitive goods”. … 

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

(Source: 
Law360, 21 Jun 2018.) [Excerpts; subscription required.] 
 
Less than two months after Zhongxing Telecommunications Equipment Corp. and ZTE Kangxun Telecommunications Ltd. made news because the U.S. Department of Commerce’s Bureau of Industry and Security announced it was denying export privileges to ZTE, BIS has announced that the denial order will be lifted pursuant to a new settlement with ZTE.

In March 2017, ZTE reached a settlement with the U.S. government for its violation of U.S. sanctions by supplying both Iran and North Korea with U.S.-origin telecommunications equipment. According to the Office of Foreign Assets Control … 

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

(Source: 
Politico, 24 Jun 2018.) [Excerpts.] 
 
Round two of President Donald Trump’s trade
 assault on Beijing is expected by the end of this week, when the Treasury Department rolls out new restrictions on Chinese investment in the United States and on the technologies that can be sold to China. … 
 
Like the tariffs that Trump imposed on $50 billion in Chinese imports – and those he has threatened to impose on $400 billion more if Beijing retaliates – the new investment restrictions and export controls are intended to pressure China to stop unfair trade practices that threaten the United States’ technological leadership. Trump is expected to invoke his emergency powers to protect national and economic security to put the restrictions in place.
 

But the administration is already getting pushback from bureaucrats who think it would be a misuse of the export control system, and from businesses that fear the approach will further disadvantage U.S. firms trying to enter the Chinese market. …

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

NWS_414. 
Reuters: “China’s ZTE Expected to Take Last Step to Lift Ban: U.S. Official”
(Source: 
Reuters, 22 Jun 2018.) [Excerpts.] 
 
ZTE Corp is expected to deposit $400 million in an escrow account in a U.S. bank in the “next couple of days,” the last step the Chinese company must take before a ban on U.S. suppliers can be lifted, a U.S. Department of Commerce official told Reuters on Friday.
 
ZTE, which makes smart phones and networking gear, agreed to pay a $1 billion penalty and put $400 million in escrow as part of a settlement it reached on June 7 with the Commerce Department to regain access to the U.S. market, which it needs for components.
 
ZTE, China’s second-largest telecommunications equipment maker, ceased major operations after the United States imposed the ban in April. The company had broken a prior agreement, the Commerce Department said, by making false statements about disciplining executives involved in illegally shipping U.S. goods to Iran and North Korea, which are subject to U.S. sanctions themselves, that led to nearly $900 million in civil and criminal penalties to U.S. authorities last year.
 
The escrow account in the new settlement is designed to allow the U.S. government access to the $400 million if ZTE violates the latest deal.
 
An escrow agreement, which defines the conditions under which the money could be released, was in the process of being finalized, sources told Reuters on Friday.
 
ZTE is hopeful the $400 million can be deposited on or before Monday, one person familiar with the matter said on Friday.
 
The company paid the $1 billion penalty last week, Reuters reported on Tuesday, citing sources.
 
The decision to lift the ban was made by President Donald Trump as a way of showing good will to the president of China, White House trade adviser Peter Navarro has said.
 
The Republican-controlled U.S. Senate passed legislation this week that would overturn the settlement, in a rare rebuke to Trump.
 
But the measure, an amendment to a massive defense policy bill, is still several steps from becoming law, and the White House has said it will push its allies in Congress not to let the provision move forward. … 
 
Under the new Commerce Department settlement, ZTE agreed to numerous conditions beyond monetary penalties, including changing its board and leadership within 30 days.

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

NWS_a515. 
Reuters: “Turkey to Start Implementing Retaliatory Tariffs Against United States”
(Source: 
Reuters, 21 Jun 2018.) [Excerpts.] 
 
Turkey will start implementing on Thursday retaliatory tariffs worth $266.5 million against the United States over ‘ill-advised’ and ‘unsupportable’ additional steel tariffs enacted by Washington, Economy Minister Nihat Zeybekci said.
 
The tariffs will be imposed on imports of U.S. coal, paper, walnuts/almonds, tobacco, unprocessed rice, whisky, automobiles, cosmetics, machinery equipment and petrochemical products.
 
  “The total tariff burden today being imposed by Turkey on the U.S. is commensurate with the additional costs Turkey faces due to the tariffs imposed on it by the U.S.,” Zeybekci said in a statement.
 
  “They are proportional, measured and designed to protect Turkey’s interests, while encouraging dialogue.”
 
U.S. President Donald Trump decided in March to impose import duties of 25 percent on steel and 10 percent on aluminum, drawing criticism from other countries for heightening the risk of a global trade war.
 
The U.S. tariffs have been imposed on Europe, Canada and Mexico, some of its biggest trade partners since June 1, after their temporary exemptions expired. … 

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

NWS_a616.
 
SpaceNews: “Commerce Department Moves Ahead with Space Regulatory Reforms”
(Source: 
SpaceNews, 22 Jun 2018.) [Excerpts.] 
 
Nearly a month after the signing of a policy directive calling for commercial space regulatory reforms, Commerce Department officials said this week they’re moving ahead on a number of fronts.
 
At the June 18 meeting of the National Space Council, and subsequent events in the following days, Commerce Secretary Wilbur Ross and other department officials said they’re making progress on implementing elements of Space Policy Directive (SPD) 2, signed May 24, that call for reforms to commercial remote sensing and other regulations within the jurisdiction of his department.
 
One section of SPD-2 requires Commerce Department to review existing regulations for licensing commercial remote sensing systems and, within 90 days, either revise them or publish a notice of proposed rulemaking for doing so. At the council meeting, Ross said that rulemaking would soon be published in coordination with the White House Office of Management and Budget (OMB). … 
[One] aspect of SPD-2 requires members of the National Space Council to coordinate a review of export control issues related to commercial space activities. “Next week, we will begin interagency discussions to implement space export control reform,” Ross said at the June 18 space council meeting. … 

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

COMMCOMMENTARY

COMM_a0
17.
B. Schwartz: “Strengthening the Economy at Home and U.S. Military Partnerships Abroad”

(Source: 
The Hill, 21 Jun 2018.) [Excerpts.] 
 
* Author: Benjamin Schwartz, Executive Director of the U.S. Chamber of Commerce’s Defense and Aerospace Export Council.
 
The U.S. Congress exercises an essential oversight function by requiring the U.S. Department of State to notify America’s elected representatives of all significant military equipment intended for export, but it is now time for Congress to be informed of all denials of major defense export requests as well.
 
The current notification requirement allows Congress to monitor, and at times intervene, on pending arms sales to ensure such arms exports serves American interests. These interests include preventing an arms race, averting the proliferation and risks associated with weapons of mass destruction (WMD), avoiding human rights abuses, and encouraging military balances among countries that promote peace and freedom around the world. … 

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

COMM_a01
18.
M. Volkov: “Podcast Episode 44 – Compliance Program Best Practices: The FCPA Guidance and DOJ’s Evaluation of Corporate Compliance Programs”

(Source: 
Volkov Law Group Blog, 24 Jun 2018. Reprinted by permission.) 
 
* Author: Michael Volkov, Esq., Volkov Law Group, 
mvolkov@volkovlaw.com, 240-505-1992. 
 
The Justice Department has released two important documents that provide guidance to compliance practitioners as to compliance program best practices: 
 
  (1) The FCPA Guidance; and 
  (2) The Evaluation of Corporate Compliance Programs.  
 
In combination, these two documents provide important compliance program guidance.
 
In 
this episode, Michael Volkov discusses various issues related to ethics and compliance program best practices.

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

COMM_a3
19.
R.L. Cassin: “Compliance Pros Are Rock Stars, Yes They Are”

(Source: 
The FCPA Blog, 25 Jun 2018.) [Excerpts.]
 
* Author: Richard L. Cassin, publisher and editor of the FCPA Blog. Contact Mr. Cassin at 
rlc@fcpablog.com
 
Only yesterday they were pimply FCPA nerds. But a strange thing happened. They morphed into the cool kids.
 
Today’s compliance officers are famous and wanted. 
Here’s some evidence.
 
The White House 
commuted ZTE’s corporate death sentence by arranging to embed hand-picked compliance officers in the outlaw Chinese company.
 
(True, they’re really 
compliance monitors. But to sell the deal, U.S. Commerce Secretary Wilbur Ross 
called them compliance officers.)
 
Earlier this month, Siemens named a CCO, 
Sylvie Kandé de Beaupuy of Airbus, to its board of directors. Imagine that — a role at the highest level of one Europe’s biggest companies.
 
Nations are enshrining the compliance function in their legal regimes. 
Brazil
Argentina, and 
Mexico now require some government contractors to prove they have effective compliance programs. How do you do that except with compliance officers? … 
 
[Editor’s Note: Due to copyright restrictions, we are not authorized to include the entire article. To read the entire article, click on the source link above.]

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

MSEX/IM MOVERS & SHAKERS

MS_a120. Monday List of Ex/Im Job Openings; 198 Jobs Posted This Week, Including 11 New Jobs

(Source: Editor) 
 

Published every Monday or first business day of the week. Please, send job openings in the following format to 
jobs@fullcirclecompliance.eu
.

 
* COMPANY; LOCATION; POSITION TITLE (WEBLINK); CONTACT INFORMATION; REQUISITION ID
 

#
” New or amended listing this week

* ACCO Brands; Lake Zurich, IL; Foreign Trade Zone Specialist;
* Aerovironment; Simi Valley, CA; Trade Compliance Specialist II; Job ID: 18-017

* Agility; Atlanta, GA;
Export Compliance Administrator
;

* Agility; Queens, NY;
Air Export Coordinator
;
* Agility; Bensenville, IL;
 
Air Export Coordinator;
* Agility; Carson, CA; Ocean Export Coordinator;
* Agility; Houston, TX; Air Freight Export Coordinator;
* Agility; Houston, TX; Ocean Export Coordinator;
* Agility; Doral, FL; Air Export Coordinator;
* Agility; Boston, MA; Air Export Coordinator;
* Agility; Boston, MA; Ocean Export Coordinator;
* Agility; Bensenville, IL; Ocean Export Coordinator;

* Agility; Basel, Switzerland;
International Exhibition Coordinator;

* Agility; Genf, Switzerland; Ocean Freight Coordinator; 
* Agility; Genf, Switzerland; Ocean Freight Coordinator; 
* Agility; Coppel, TX; Air Import Coordinator;

* Agility; Carson, CA;
Air Import Coordinator;
* Agility; Bensenville, IL; 
Air Import Coordinator
; 
* Agility; Queens, NY; Air Import Coordinator; 
* Agility; Atlanta, GA; Air Import Coordinator; 
* Agility; Doral, FL; Air Import Coordinator;

* Agility; Burlingame, CA;
 
Ocean Import Coordinator;
* Agility; Carson, CA;  Ocean Import Coordinator;
* Agility; East Boston, MA; Entry Writer/Import Coordinator
;
* Agility; Bensenville, IL; Entry Writer Coordinator; 
* Agility; Carson, CA; Entry Writer Coordinator; 
* Agility; Dallas, TX;  Air Import Supervisor;
* Agility; Montreal, Canada; Customs Manager;
 
* Agility; Montreal, Canada;  Customs Manager; 

* Agility; Montreal, Canada;  Customs Supervisor; 
* AMD; Austin, TX;
Manager, Import/Export; Requisition ID: 24061

* Arent Fox LLP; Washington, D.C.; International Trade Associate;

* Arent Fox LLP; Los Angeles, CA;
International Trade Associate
;

* Arm, Ltd.; Cambridge, UK; UK Trade Compliance Manager; Requisition ID: 13650

* Arrow; Shanghai, China; Compliance Manager;

* Arrow; Shenzhen, Guangdong, China; Junior GTMC Officer;
* AutoNation; Fort Lauderdale, FL; Trade Compliance Manager
*
 BAE Systems; Los Angeles, CA; 
Program Manager, International and Offset
; Requisition ID: 33778BR

* BAE Systems; Huntsville, AL; Facility Security Officer, Security Manager; Requisition ID: 36821BR
* BAE Systems; Burlington, MA; Facility Security Officer (“FSO”); Requisition ID: 35499BR
* BAE Systems; Rockville, MD; Compliance Specialist Senior; Requisition ID: 35809BR
* BAE Systems; Sterling, VA; Compliance Specialist Senior; Requisition ID: 36370BR

* BAE Systems; Greenlawn, NY;
International Trade Compliance Analyst I; Requisition ID: 
38433BR

* BAE Systems; San Diego, CA; International Trade Compliance Analyst II; Requisition ID: 38548BR  

*
 BMW North America; Woodcliff Lake, NJ;
Senior Analyst, Trade Compliance
; Requisition ID: 170004RD
* Brownells, Inc.; Grinnell, IA; International Trade Compliance Manager II;
* Brownells, Inc.; Grinnell, IA; Product Classification Specialist I;
* Buehler; Lake Bluff, IL;
Manager, Compliance and Logistics
; Requisition ID: 2018-004

* Cree, Inc.; Durham, NC; Export Compliance Specialist
Contact asignorelli@cree.com;
Requisition ID: 2018-630
0

* Danaher Science and Technology; Nijmegen, Netherlands;
Import Specialist – Senior Analyst II Supply Chain & Logistics

Job ID: BEC009349

*
 DynCorp International; Tampa, FL; Foreign Disclosure Officer; Requisition ID: PR1701977

*
 Eaton; Syracuse, NY;
Global Logistics Manager
; Requisition ID: 036620

*
 Eaton; Shanghai Shi, China;
Global Ethics and Compliance Director, APAC
; Requisition ID: 039260

# Edmonds Enterprise Services, Inc.; Washington, D.C.;
Compliance Specialist
Department of State; tmarshall@edmondses.com; (703) 778-7070
# Edmonds Enterprise Services, Inc.; Washington, D.C.; Commodity Jurisdiction Analyst II; Department of State; tmarshall@edmondses.com; (703) 778-7070

* Elbit Systems of America; Fort Worth, TX or Merrimack, NH;
Trade Compliance Manager
; 2018-5916

* Eli Lilly and Co.; Indianapolis, IN;
Import/Export Trade Associate;

* Ensign-Bickford Aerospace & Defense Co.; Moorpark, CA;
Import/Export Specialist; Missy Clark;
maclark@eba-d.com

* EoTech Technologies; Ann Arbor, MI; Trade Compliance Manager; Requisition ID: 092335 
* Erickson, Inc.; Central Point, OR; Import Specialist; Requisition ID: 756803

*
 Expeditors; Krefeld, Germany; 
Clerk Import / Export
;
*
 Expeditors; Bedfont, United Kingdom;
Customs Brokerage Clerk
;
*
 Expeditors; Dusseldorf, Germany;
Clerk, Airfreight Import
;


* Export Solutions Inc.; Melbourne FL; 
Trade Compliance Specialist
;
info@exportsolutionsinc.com

*
 EY; Belgium; 
Senior Consultant, Global Trade
; Requisition ID: BEL000PT

* Flash Global; Mountain Lakes, NJ; 
Import Export Services Manager;

* FLIR; Billerica, MA; US Customs Analyst
; 

* FLIR; Meer, Belgium; GTC EMEA Customs Analyst;
* FLIR; Irving, CA; 
Sr. Manager Export Compliance;

* FLIR; Nashua, NH; 
Global Trade Compliance Analyst, Traffic
;
 
*
 FLIR; Billerica, MA;
Global Trade Compliance Analyst, Licensing
;
* Full Circle Compliance; Bruchem, Netherlands;
Legal Analyst, Manager

* General Atomics; San Diego, CA;
Director, Compliance
; Requisition ID: 18549BR

* General Atomics; San Diego, CA;
 Government Regulatory Compliance SpecialistRequisition ID: 18686BR

* General Atomics; San Diego, CA; 
Import/Export Trade Compliance Administrator – Licensing
Requisition ID: 17968BR

* General Atomics; San Diego, CA; Senior Director of Import/Export Compliance; Requisition ID: 13892BR
* General Atomics; San Diego, CA; Internal Auditor – Senior; Requisition ID: 17524BR

* General Dynamics; Fairfax, VA; Export Policy Analyst; Job ID: 2018-36089 

* General Dynamics; Falls Church, VA;
Director, Trade Compliance
; Job ID: 2018-1122

* GHY International; Pembina, ND (or remote); Ocean & Air Import Coordinator;

* Harris Corporation; Palm Bay, FL;
Technical Trade Compliance Engineer; Contact
Laura Solomon; Requisition ID: ES20171511-22019
* Harris Corporation; Clifton, NJ;
Technical Trade Compliance Engineer;

# Harris Corporation; Van Nuys, CA; Trade Compliance Senior Specialist; Requisition ID: ES20180706-25145
* Henderson Group Unlimited; Inc; Washington, DC; 
Process Improvement Mgr

* Henderson Group Unlimited; Inc; Washington, DC; 
Defense Control Analyst

* Henkel Corp.; Rocky Hill, CT;
Global Trade Defense Information Manager; Requisition ID: 
180002QT

* Henkel Corp.; Rocky Hill, CT; Senior Global Trade ManagerRequisition ID: 18000307

* Huntington Ingalls Industries; Virginia Beach, VA; 
 AMSEC-Import/Export Administrator 2
; Requisition ID: 23979BR

* Hussman; Bridgeton, MO; 
Trade Compliance Specialist;

*
 Infineon Technologies; Munich, Germany;
Experte Export Control (w/m)
; Requisition ID: 22825
* Infineon Technologies; Melaka, Malaysia; Export Control Executive; Requisition ID: 26833
* Infineon Technologies; Porto (Maia) Portugal;  Trade Compliance Administrator; Requisition ID: 25550

* Infineon Technologies; Milpitas, CA;
Export Compliance Specialist; Requisition ID: 26988

* Infineon Technologies; El Segundo, CA;  Export Compliance Specialist; Requisition ID: 26826

* Intel; Amsterdam, Netherlands;
Trade Specialist
Requisition ID: JR0056336

*
 InteliTrac Global Solutions; Herndon, VA; 
ITAR Compliance Official / Deputy Facility Security Officer
;

*
 InteliTrac Global Solutions; Herndon, VA;
ITAR Compliance Official
;

* Johns Hopkins University; Baltimore, MD;
Assistant Director, Export Control and Facility Security;

* Johnson Controls; Milwaukee, WI;
Trade Compliance Analyst; Requisition ID: 
WD30047348124
* Johnson Controls; Lithia Springs;
Trade Compliance Specialist I; Requisition ID: 
WD30047947142
* Lam Research Corp.; Fremont, CA;
 
Foreign Trade Intern
;

* Lam Research Corp.; Shanghai, China; 
Foreign Trade (FT) Analyst;

* Lam Research Corp.; Fremont, CA; 
Foreign Trade Data Analyst;

* Leonardo DRS; Arlington, VA;
Senior Customs & Trade Compliance Manager
; Requisition ID: 87488 

* Leonardo DRS; St. Louis;
Trade Compliance Specialist
; Requisition ID: 88127, or contact 
brandy.mormino@drs.com 

* Lincoln Electric; Cleveland, OH; 
Trade Compliance Manager;

* Lockheed Martin; Manassass, VA; International Licensing; Requisition ID: 423306BR
* Lockheed Martin; Fort Worth, TX; Import Export Compliance Coordinator; Job ID: 397600BR
* Lockheed Martin; Fort Worth, TX; Export and Import Compliance Investigations Lead; Job ID: 427872BR

* Lockheed Martin; Fort Worth, TX; Licensing Integration and Support; Job ID: 433056BR

* Lockheed Martin; Fort Worth, TX; Regulatory Compliance Analyst Senior; Job ID: 433405BR 

* Lockheed Martin; Orlando, FL; 
Senior International Licensing Analyst
; Requisition ID: 
434225BR 

* Lockheed Martin; Orlando, FL; International Licensing Analyst Sr; Job ID: 424151BR
* Lockheed Martin; Oswego, NY; Licensing Analyst; Job ID: 415717BR
* Lockheed Martin; Oswego, NY; Licensing Analyst; Job ID: 415708BR

* Luminar Technologies; Orlando, FL;
Import/Export Trade Compliance Specialist
;

*
 L-3 ALST; Orlando, FL;
Contracts Manager / Empowered Official
; Requisition ID: 093069
* L-3 Warrior Sensor Systems; Londonderry, NH; Purchasing & Compliance Manager; Requisition ID:096596
*
 L-3 Warrior Sensor Systems; Middle East;
International Business Development Manager – Middle East Region
; Requisition ID: 093343
* L-3; Ann Arbor, MI; Trade Compliance Manager; Requisition ID: 092335

* L-3; Grand Rapids, MI;
Sr. Trade Compliance Administrator; Requisition ID: 097197

* L-3; Arlington, TX;
Compliance Manager
; Requisition ID: 098246

* Mattson Technology; Fremont, California;
Import/Export Compliance Analyst;

* Maersk/DAMCO; Agent de transit IMPORT – EXPORT; Job Ref.: DC-164022
* Mattson Technology; Fremont, California; Import/Export Compliance Analyst;
* Medtronic; Heerlen, The Netherlands;
Trade Compliance Analyst
; Requisition ID: 16000DYY
* Medtronic; Wash DC;
Global Trade Lawyer
;
stacy.m.johnson@medtronic.com
; Requisition ID: 170002ON

* Meggit; Akron, OH; Manager, Trade Compliance;
* Meggit; Los Angeles, CA; Trade Compliance Officer;
* Mitchell Martin, Inc.; Dallas, Texas;
Export Regulatory Trade Compliance Specialist
; Requisition ID: 104405

* Moog; East Aurora, NY;
Manager, Group Trade Compliance Manager
; Amy Hanavan,   
ahanavan@moog.com
; Requisition ID: 182102

* MTS Systems; Eden Prairie, MN;
Global Trade Compliance Manager
; Requisition ID: 37841
* Northrop Grumman; Herndon, VA;
Manager, International Trade Compliance 2

Requisition ID
:
17022803
 
 

*
 Northrop Grumman; Herndon, VA;
Manager, International Trade Compliance 2
; Requisition ID: 17022805
# Northrop Grumman; 
Redondo Beach, CA; or Rancho Bernardo, CA; or Melbourne, FL; or Falls Church, VA; 
Senior Manager, International Trade Compliance 3; Requisition ID: 
18012105

* Office of the Director of National Intelligence; McLean, VA;
Associate General Counsel
;

* Oracle; Unspecified, United States; Customs Compliance Specialist; Requisition ID: 18000H0N
* Orbital ATK, Inc.; Dulles, VA; Principal Import/Export Analyst
; Job ID:  JAY20182304-45242.
* Oshkosh Corporation; Greenville, WI;
Global Trade Compliance Analyst
; Requisition ID: 182405

* PerkinElmer, Inc.; Shelton, CT;
Systems Analyst, Trade Compliance Solutions;

* Raytheon; El Segundo, CA;
Global Trade Licensing Analyst; Requisition ID: 114977BR
* Raytheon; El Segundo, CA;
Global Trade Licensing Analyst; Requisition ID: 115189BR

* Raytheon; El Segundo, CA; 
Sr. Export Licensing And Compliance Specialist; Requisition ID: 114077BR
* Raytheon; Tucson, AZ; Export Licensing And Compliance Specialist; Requisition ID: 114936BR
# Raytheon; El Segundo, CA; Senior Principle, Global Trade Licensing; Requisition ID: 117232BR
# Raytheon; El Segundo, CA; Manager III, Global Trade Licensing; Requisition ID: 117235BR
# Raytheon; El Segundo, CA; Fullerton, CA; Goleta, CA; Aberdeen, MD; Plano, TX; McKinney, TX; Principal Analyst, Global Trade Licensing; Requisition ID: 117247BR
# Raytheon; El Segundo, CA; Aberdeen, MD; McKinney, TX; Global Trade Licensing Analyst; Requisition ID: 116976BR
# Raytheon; El Segundo, CA; Ft. Wayne, IN; Aberdeen, MD; Global Trade Licensing Analyst; Requisition ID: 118159BR

*
 SABIC; Houston TX; 
Senior Analyst, Trade Compliance
;
Danielle.Cannata@sabic.com
; Requisition ID: 8411BR

* SABIC; Houston, TX;
Senior Analyst, International Trade Compliance

Requisition ID 8655; OR Contact: Jason Washington
* The Safariland Group; Jacksonville, FL; Counsel (International Trade Compliance)
* The Safariland Group; Jacksonville, FL; Sr. Export Compliance Specialist 
# Stockholm International Peace Research Institute (SIPRI); Solna, Sweden; Senior Researcher on Dual Use and Arms Trade Controls
* Spirent; San Jose, CA;
Global Trade Compliance Specialist
; Requisition ID: 4088

* Tech Data Corporation; Miami, FL; 
Sr. Regulatory Compliance Analyst
;

* Tech Data Corporation; Clearwater, FL; Sr. Regulatory Compliance Analyst;
* Tech Data Corporation; Groveport, OH; Sr. Regulatory Compliance Analyst;
* Tech Data Corporation; Duluth, GA; Sr. Regulatory Compliance Analyst;

* Tech Data Corporation; Miami, FL; Regulatory Compliance Manager;
* Tech Data Corporation; Clearwater, FL;  Regulatory Compliance Manager;
* Tech Data Corporation; Groveport, OH;  Regulatory Compliance Manager;
* Tech Data Corporation; Duluth, GA;  Regulatory Compliance Manager;

* Teledyne Benthos; Falmouth, MA; Export Compliance Manager
* Teledyne Scientific & Imaging; Montgomeryville, PA; Contracts & Trade Compliance Administrator; Requisition ID: 6470
* Teva Pharmaceuticals; North Wales, PA; 
Senior Analyst, Customs & Trade Compliance
;

*
TLR; San Fransisco, CA;
Import CSR
 ; Requisition ID: 1040

* Trek; Waterloo, WI; Global Trade & Logistics Specialist;

* United Technologies – Pratt & Whitney; East Hartford, CT; 
International Trade Compliance IT Systems & Integration Mgr.
; Requisition ID: 62310BR

* United Technologies – Pratt & Whitney; East Hartford, CT;
International Trade Compliance Manager; Requisition ID:  62176BR

* United Technologies – Pratt & Whitney; East Hartford, CT;
International Trade Compliance Authorizations Manager; Requisition ID: 63222BR
* United Technologies – Pratt & Whitney, East Hartford, CT;
International Trade Compliance Technology Senior Manager
; Requisition ID: 55944BR
* United Technologies Corp, Pratt & Whitney; East Hartford, CT;
ITC & ACE Compliance Program Manager, ASC
; Requisition ID: 58388BR

* Varian; Belgium, Switzerland, Netherlands, or UK; EMEIA Trade Lead – Senior Manager Trade Compliance; Requisition ID: 12301BR; Contact 
Gavin Tickner at 
Gavin.Tickner@varian.com
 
* Varian; Paolo Alto, CA; Senior Trade Compliance Analyst; Requisition ID: 12735BR; Contact 
Uyen Tran at
Uyen.Tran@varian.com
* Vigilant; Negotiable Location, USA;
Global Trade Compliance Analyst
;

* Virgin Galactic; Las Cruces, NM; Export Compliance Officer; Requisition ID: 2018-3558
* Williams International; Pontiac, MI; Trade Compliance Specialist; Requisition ID: 17-0275

* Wurth Industry of North America; Indianapolis, IN;
International Trade Compliance Officer – Classification;

*
 Xylem, Inc.; Remote, United States;
Manager, Global Ethics & Compliance
;

* Xylem, Inc; Morton Grove, IL;
Trade Compliance Specialist;
* YETI; Austin, TX;
Global Trade Compliance Manager
* Zebra Technologies; Bourne End, UK; 
Trade Compliance Manager, NALA; Requisition ID: 46144
* Zebra Technologies; Lincolnshire, IL; Holtsville, NY; Mcallen, TX; Miramar, FL; Agoura Hills, CA; 
Trade Compliance Manager, EMEA; Requisition ID: 46146

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

ENEDITOR’S NOTES

 

Antoni Gaudi 
(Antoni Gaudí i Cornet; 25 Jun 1852 – 10 Jun 1926; was a Spanish architect from Catalonia. He is the best known practitioner of Catalan Modernism. Gaudí’s works have a highly individualized, and one-of-a-kind style. Most are located in Barcelona, including his main work, the church of the Sagrada Família.)
  – “There are no straight lines or sharp corners in nature. Therefore, buildings must have no straight lines or sharp corners.”
 

Ambrose Bierce 
(Ambrose Gwinnett Bierce; 24 Jun 1842 – circa 1914; was an American short story writer, journalist, poet, and Civil War veteran. A prolific and versatile writer, Bierce was regarded as one of the most influential journalists in the United States. Bierce’s book The Devil’s Dictionary was named as one of “The 100 Greatest Masterpieces of American Literature” by the American Revolution Bicentennial Administration. His story An Occurrence at Owl Creek Bridge has been described as “one of the most famous and frequently anthologized stories in American literature”; and his book Tales of Soldiers and Civilians was named by the Grolier Club as one of the 100 most influential American books printed before 1900.)
  – “Conservative, n: A statesman who is enamored of existing evils, as distinguished from the Liberal who wishes to replace them with others.”
  – “Quotation, n: The act of repeating erroneously the words of another.”

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

EN_a322
. 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: 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
here.
  – 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.  
 
*
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_a0319
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 
here

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

EPEDITORIAL POLICY

* 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.


* 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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