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18-0706 Friday “Daily Bugle”

18-0706 Friday “Daily Bugle”

Friday, 6 July 2018

TOPThe Daily Bugle is a free daily newsletter from Full Circle Compliance, containing changes to export/import regulations (ATF, DOE/NRC, Customs, NISPOM, EAR, FACR/OFAC, FAR/DFARS, FTR/AES, HTSUS, and ITAR), plus news and events. Subscribe here for free subscription. Contact us for advertising inquiries and rates
.

[No items of interest noted today.]

  1. Items Scheduled for Publication in Future Federal Register Editions 
  2. Commerce/BIS: (No new postings.)
  3. DHS/CBP: “Drawback Certification Mailbox to be Deactivated on 9 Jul”
  4. DHS/CBP Releases Update Concerning Imports of Steel and Aluminum Under Section 232
  5. State/DDTC: (No new postings.)
  6. Australia DEC Posts Update On Outreach Programs
  7. India Amends SCOMET List and Foreign Trade Policy to Reflect Changes Resulting from the AG, WA, and MTCR
  1. The Globe and Mail: “Advocates Push for Independent Review into Use of Canadian-Made Armored Vehicles in Saudi Arabia”
  2. South China Morning Post: “Russia Puts Additional Import Duties to Some U.S. Industrial Goods”
  1. C. Dorminey: “Selling American Weapons Overseas Is Risky Business”
  2. The Export Compliance Journal: “Registration and Licensing of Arms Brokers”
  1. Full Circle Compliance Presents: “Awareness Course U.S. Export Controls: ITAR & EAR From a Non-U.S. Perspective”, 2 Oct in Bruchem, the Netherlands
  2. 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 (29 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

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[No items of interest noted today.]

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OGSOTHER GOVERNMENT SOURCES

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. Items Scheduled for Publication in Future Federal Register Editions
 

(Source:
Federal Register)
[No items of interest noted today.]

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

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3.
DHS/CBP: “Drawback Certification Mailbox to be Deactivated on 9 Jul”

(Source: 
CSMS# 18-000423, 5 Jul 2018.) 

The Office of Trade (OT) is advising the trade and drawback personnel that the Drawback Certification mailbox (
DrawbackCertification@cbp.dhs.gov), monitored by the OT Trade Transformation Office (TTO), will be deactivated on July 9, 2018. The Drawback Certification mailbox was created to assist the trade with transitioning into drawback filing in the Automated Commercial Environment (ACE).

After July 9, 2018, filers should contact their assigned Client Representatives for assistance with ACE ABI drawback questions when resolving ABI drawback transaction issues. If the specific drawback issue is unresolved, the filer may open a ticket via the CBP technical help desk at (866) 530-4172. Drawback Specialists in the field can address procedural questions.

Please refer to 
this link for other available resources to assist drawback filers with navigating drawback in ACE: ACE Drawback CATAIR, ACE Drawback Error Dictionary and the Drawback Business Rules and Process Document.

For questions or comments regarding this message, please send email to 
OTDrawback@cpb.dhs.gov
.

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4.
DHS/CBP Releases Update Concerning Imports of Steel and Aluminum Under Section 232 

(Source: 
CSMS# 18-000424, 6 Jul 2018.) 
 
BACKGROUND: 
On March 8, 2018, the President issued Proclamations 9704 and 9705 on Adjusting Imports of Steel and Aluminum into the United States, under Section 232 of the Trade Expansion Act of 1962, as amended (19 U.S.C. 1862), providing for additional import duties for steel mill and aluminum articles, effective March 23, 2018. See the Federal Register, 83 FR 11619 and 83 FR 11625 (March 15, 2018). On March 22, 2018, the President issued Proclamations 9710 and 9711 on Adjusting Imports of Steel and Aluminum into the United States. See the Federal Register, 83 FR 13355 and 83 FR 13361 (March 28, 2018). On April 30, the President issued Proclamations 9740 and 9739 on Adjusting Imports of Steel and Aluminum into the United States. See the Federal Register, 83 FR 20683 and 83 FR 20677 (May 7, 2018). On May 31, 2018, the President issued Proclamations 9758 and 9759 on Adjusting Imports of Steel and Aluminum into the United States. See the Federal Register, 83 FR 25849 and 83 FR 25857 (June 5, 2018). 
 
These duty requirements are effective with respect to goods entered, or withdrawn from warehouse for consumption, on or after 12:01 a.m. eastern daylight time on March 23, 2018.
 
GUIDANCE: 
FOREIGN TRADE ZONES
 
The aforementioned Presidential Proclamations include provisions for the treatment of steel and aluminum articles admitted to a U.S. foreign trade zone (FTZ). The current provisions, as amended, are outlined in the following paragraphs. 
 
Steel
 
Clause 5 of Proclamation 9711, as amended, is as follows:
 
Any steel article, except those eligible for admission under ”domestic status” as defined in 19 CFR 146.43, which is subject to the duty imposed pursuant to Proclamation 9705, as amended, or to the quantitative limitations established by proclamation, that is admitted into a U.S. foreign trade zone on or after 12:01 a.m. eastern daylight time on March 23, 2018, may only be admitted as ”privileged foreign status” as defined in 19 CFR 146.41, and will be subject upon entry for consumption to any ad valorem rates of duty or quantitative limitations related to the classification under the applicable HTSUS subheading. Any steel article, except those eligible for admission under ”domestic status” as defined in 19 CFR 146.43, which is subject to the duty imposed pursuant to Proclamation 9705, as amended, or to the quantitative limitations established by proclamation, that was admitted into a U.S. foreign trade zone under ”privileged foreign status” as defined in 19 CFR 146.41, prior to 12:01 a.m. eastern daylight time on March 23, 2018, will likewise be subject upon entry for consumption to any ad valorem rates of duty or quantitative limitations related to the classification under applicable HTSUS subheadings imposed by Proclamation 9705, as amended by this proclamation.
 
Clause 5 of Proclamation 9740, as amended, is as follows:
 
Steel articles shall not be subject upon entry for consumption to the duty established in clause 2 of Proclamation 9705, as amended, or to the quantitative limitations established by proclamation, merely by reason of manufacture in a U.S. foreign trade zone. However, steel articles admitted to a U.S. foreign trade zone in “privileged foreign status” pursuant to clause 5 of Proclamation 9711, as amended, shall retain that status consistent with 19 CFR 146.41(e).
 
Aluminum
 
Clause 5 of Proclamation 9710, as amended, is a follows:
 
Any aluminum article, except those eligible for admission under ”domestic status” as defined in 19 CFR 146.43, which is subject to the duty imposed pursuant to Proclamation 9704, as amended, or to the quantitative limitations established by proclamation, that is admitted into a U.S. foreign trade zone on or after 12:01 a.m. eastern daylight time on March 23, 2018, may only be admitted as ”privileged foreign status” as defined in 19 CFR 146.41, and will be subject upon entry for consumption to any ad valorem rates of duty or quantitative limitations related to the classification under the applicable HTSUS subheading. Any aluminum article, except those eligible for admission under ”domestic status” as defined in 19 CFR 146.43, which is subject to the duty imposed pursuant to Proclamation 9704, as amended, or to the quantitative limitations established by proclamation, that was admitted into a U.S. foreign trade zone under ”privileged foreign status” as defined in 19 CFR 146.41, prior to 12:01 a.m. eastern daylight time on March 23, 2018, will likewise be subject upon entry for consumption to any ad valorem rates of duty or quantitative limitations related to the classification under applicable HTSUS subheadings imposed by Proclamation 9704, as amended by this proclamation. 
 
Clause 4 of Proclamation 9739, as amended, is as follows:
 
Aluminum articles shall not be subject upon entry for consumption to the duty established in clause 2 of Proclamation 9704, as amended, or to the quantitative limitations established by proclamation, merely by reason of manufacture in a U.S. foreign trade zone. However, aluminum articles admitted to a U.S. foreign trade zone in “privileged foreign status” pursuant to clause 5 of Proclamation 9710, as amended, shall retain that status consistent with 19 CFR 146.41(e).
 
Product Exclusions and FTZs
 
Imports which have been granted a product exclusion from the Section 232 measures, and which are not subject to the Section 232 duties or quotas, are not covered by the FTZ provisions of the Proclamations, but instead are subject to the FTZ provisions in 19 CFR part 146.
 
Products Entered Under the Provisions of Chapter 98, HTSUS
 
U.S. Note 19 to Subchapter III of Chapter 99, HTSUS, was amended to read, in pertinent part, “[h]eading 9903.85.01 provides the ordinary customs duty treatment of aluminum products of all countries other than products of the United States and other than of countries expressly exempt therefrom . . . .” 
 
U.S. Note 16 to Subchapter III of Chapter 99, HTSUS, was amended to read, in pertinent part, “[h]eading 9903.80.01 provides the ordinary customs duty treatment of iron or steel products of all countries other than products of the United States and other than of countries expressly exempt therefrom . . . .” 
 
The amended U.S. Notes 19 and 16 to Subchapter III of Chapter 99, HTSUS, clarify that “[g]oods for which entry is claimed under a provision of chapter 98 and which are subject to the additional duties prescribed herein shall be eligible for and subject to the terms of such provision and applicable U.S. Customs and Border Protection (‘CBP’) regulations, except that duties under subheading 9802.00.60 shall be assessed based upon the full value of the imported article.”
 
Accordingly, where a valid claim for Chapter 98 treatment is made for goods that would have otherwise been subject to Section 232 duties (i.e., classifiable in one of the named provisions in Ch. 72, 73 or 76 and a product of a country other than the United States or an exempt country), Section 232 duties are assessed in the same manner as regular customs duties. This means that goods eligible for Chapter 98 provisions that provide duty-free treatment are free of Section 232 duties. By contrast, where the Chapter 98 provision provides for the assessment of duties on a portion of the article, such as the value of the repair or other processing, Section 232 duties are to be assessed on that value. However, an exception occurs for subheading 9802.00.60, HTSUS. If covered goods are entered under this provision, Section 232 duties are to be assessed on the entire value of the articles.
 
Temporary Importations Under Bond (“TIB”)
 
Generally, goods otherwise subject to 232 duties may enter the U.S. under a TIB. The TIB’s bond amount must account for the additional Section 232 duties in the event of the bond’s breach. 
 
Goods subject to 232 quantitative limitations may enter the U.S. under a TIB. However, goods entered under a TIB shall be decremented against any applicable 232 quotas. See T.D. 54802(53) and T.D. 54802(54). 
 
Certain Originating Goods
 
For originating goods which are products of the United States and which undergo processing in Canada or Mexico, the following rules apply:
 
If the processing performed in Canada or Mexico effects a substantial transformation so as to render the good a product of Canada or Mexico, the duties imposed by section 232 apply.
 
If, after the processing performed in Canada or Mexico, no substantial transformation occurs, the good remains a product of the United States, and is not subject to 232 duties.
 
NAFTA Duty Deferral Restrictions
 
Goods subject to NAFTA duty-deferral restrictions require a NAFTA consumption entry upon exportation to Mexico or Canada. Duties imposed by section 232 will apply when a consumption entry is required. 
 
FOR FURTHER INFORMATION: 
For more information, please refer to the Presidential Proclamations on Adjusting Imports of Steel and Aluminum into the United States, Federal Register, 83 FR 11619 and 83 FR 11625 (March 15, 2018); the March 22, 2018 Presidential Proclamations on Adjusting Imports of Steel and Aluminum into the United States. 83 FR 13355 and 83 FR 13361 (March 28, 2018); and the April 30, 2018 Proclamations on Adjusting Imports of Steel and Aluminum into the United States. 83 FR 20683 and 83 FR 20677 (May 7, 2018); and the May 31, 2018, Proclamations on Adjusting Imports of Steel and Aluminum into the United States, 83 FR 25849 and 83 FR 25857 (June 5, 2018).
 
Also see Frequently Asked Questions 
here.
 
Questions related to Section 232 entry filing requirements should be emailed to
traderemedy@cbp.dhs.gov. Questions from the importing community concerning ACE rejections should be referred to their Client Representative. 
 
  – Related CSMS No. 18-000372, 18-000352, 18-000317

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

(Source: State/DDTC)

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6. 
Australia DEC Posts Update On Outreach Programs

(Source: 
Australia DoD/DEC, 6 Jul 2018.) [Excerpts.]
 
Australia Defense Export Controls (DEC) is commencing another year of outreach programs. The next outreach event for 2018 will be held in Perth on Tuesday 24 July 2018. Events will also be held in Melbourne, Adelaide, and Sydney. 

The outreach program will cover the requirements exporters must meet when exporting controlled goods and technologies. These include military or commercial items that may have potential military end use or could be used in developing chemical, biological or nuclear weapons system. 

The program is aimed at small to medium enterprises who export and want to learn more about:
  

  – export control regulations, 
  – export controls specific to defense industry or academic and research organizations, and
  – the whole-of-government approach to Australia’s export landscape.
 
You can attend an outreach event in: 
  – Brisbane 05 June 2018 (Closed)
  – Perth 24 July 2018 
book now
  – Melbourne August 2018
  – Adelaide October 2018
  – Sydney November 2018 … 

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7. India Amends SCOMET List and Foreign Trade Policy to Reflect Changes Resulting from the AG, WA, and MTCR 

(Source: 
India DGFT, 3 Jul 2018.) 
 
The Indian Directorate of Foreign Trade (DGFT) has published the following documents to reflect changes resulting from recent updates in the Australia Group (AG), Wassenaar Arrangement (WA), and Missile Technology Control Regime (MTCR). 
 
  – 
Notification No.17/2015-2020 dated 3 Jul 2018. Harmonization of Scomet list to align with recent update in AG, WA,MTCR-Amendment in Appendix 3 (SCOMET Items) to Schedule-2 of ITC(HS) Classification of Export and Import Items,2018.
  – 
Public Notice No.19/2015-2020 dated 3 Jul 2018. Amendment to Paragraph 2.74 and Para 2.79A of the Handbook of Procedures of the Foreign Trade Policy (FTP) 2015-20.
  – 
Updated SCOMET List as on 3 Jul 2018. Updated list of Appendix 3 containing the list of SCOMET items

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NWSNEWS

(Source: 
The Globe and Mail, 5 Jul 2018.) [Excerpts.] 
 
Human-rights and arms-control advocates are urging Foreign Affairs Minister Chrystia Freeland to order an arm’s length, independent review of the deployment of Canadian-made armored vehicles in a Saudi Arabia residential area last year.
 
Amnesty International, Project Ploughshares and five other advocacy groups have written Ms. Freeland to convey their concerns that the internal probe her department conducted into the 2017 Saudi incidents was plagued by major shortcomings.
 
The report, a portion of which was made public this spring, said it could find no definitive evidence Canadian-made combat vehicles were used to commit human-rights violations and concluded that Saudi authorities used “proportionate and appropriate force” when they engaged in combat with local residents. … 
 
Existing arms-export-control rules do not require conclusive evidence that Canadian weapons are being used to commit human-rights violations abroad. They put the onus on the Canadian government to restrict exports unless it can be demonstrated there is no reasonable risk the goods might be used against civilians. … 

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(Source: 
South China Morning Post, 6 Jul 2018.) [Excerpts.] 
 
Russia said on Friday it was imposing additional import duties on some U.S. industrial goods after the United States applied tariffs on steel and aluminum
imports, warning that more retaliatory steps could be in the pipeline.
 
The economy ministry said that Russia would impose extra tariffs on some goods from the United States for which there are Russian-made substitutes.
 
The extra duties of 25 to 40 per cent will apply to imports of fiber
optics and equipment for road construction, the oil and gas industries and metal processing and mining.… 
 
The Russian move comes amid what China has called the “largest-scale trade war” that saw the United States and China slapping tit-for-tat duties on US$34 billion worth of each other’s imports on Friday.… 

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COMMCOMMENTARY

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10. 
C. Dorminey: “Selling American Weapons Overseas Is Risky Business”
(Source: 
Wall Street Journal, 5 Jul 2018.) [Excerpts.] 
* Author: Caroline Dorminey, Cato Institute, Washington DC. 
 
In ”
America Needs to Sell More Weapons” (op-ed, July 1), Alexander Benard extols the merits of increasing arms transfers, but his argument rests on several common misunderstandings about the arms trade. 
 
The U.S. makes arms-sales decisions under legislative restrictions Mr. Benard doesn’t address. The 1976 Arms Export Control Act creates a directive to ensure that American-made weapons don’t spark arms races, support terrorism, or enable human-rights violations abroad. These aren’t “worries” or “aversions.” It’s the law.
 
Mr. Benard also completely ignores the possibility that arms transfers can create negative downstream consequences. Deteriorating governance in Turkey and human-rights violations in Vietnam are legitimate causes for concern. These factors could easily lead to American weapons being used for purposes counter to U.S. national strategic interests. … 

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The expression “arms dealer” might bring to mind images from motion pictures of intrigue and espionage. In the real world there is a keen difference between arms trafficking, or gunrunning, and lawful arms brokering.
 
Trafficking involves contraband weapons and ammunition. Brokerage involves government-approved defense trade. A registered broker of defense equipment, technologies, or services is, in short, the middleman to an authorized transaction-who, equipped with a computer, telephone, and bank account, has the connections to negotiate or facilitate a sale. What makes an arms broker legitimate is their ongoing compliance with ITAR regulations, specifically the 
Brokering Rule in Part 129.
 
Brokers and brokering were challenging for regulators to define. A 
new Brokering Rule was published in the ITAR in November 2013, which clarified the base issues of “what is a broker” and “what are brokering activities” under the ITAR.
 
The importance of clear definitions and procedures is that, in general, arms brokers operate independently, but in an activity that impacts U.S. foreign policy objectives and national security interests. A 
1997 House Report stated the issue: “… in some instances U.S. persons are involved in arms deals that are inconsistent with U.S. policy. Certain of these transactions could fuel regional instability, lend support to terrorism, or run counter to a U.S. policy decision not to sell arms to a specific country or area.”
 
The 
broker-related definitions are made in ITAR 129.2. The basics are that “Broker” means any person, as follows, who engages in the business of brokering activities:
 
  (1) Any U.S. person wherever located,
  (2) Any foreign person located in the United States, or
  (3) Any foreign person located outside the United States where the foreign person is owned or controlled by a U.S. person.
 
“Brokering activities” means “any action on behalf of another to facilitate the manufacture, export, permanent import, transfer, reexport, or retransfer of a U.S. or foreign defense article or defense service, regardless of its origin. This includes, but is not limited to: Financing, insuring, transporting, or freight forwarding defense articles and defense services; or soliciting, promoting, negotiating, contracting for, arranging, or otherwise assisting in the purchase, sale, transfer, loan, or lease of a defense article or defense service.”
 
There are a number of actions that are not included. For example, activities by a U.S. person in the United States that are not for export, activities by employees of the U.S. Government acting in an official capacity, administrative services (such as providing or arranging office space and equipment), activities performed by an affiliate on behalf of another affiliate, and others detailed in 129.2(2).
 
If you’re a broker under the definition, and fall within the regulated brokering activities, there are two key requirements. First, that you register with the Directorate of Defense Trade Controls (DDTC). Then, as a registered broker, you need to get advance approvals from DDTC for the sale or facilitation of most USML items. While not yet the export of goods or services, these approvals are effectively a licensing arrangement for broker involvement, and have an annual reporting requirement (including exempt activity).
 
In the next section of the 
ITAR, Part 130, the possibly-related matters of political contributions, fees, and commissions are regulated, which overlap with the Foreign Corrupt Practices Act (FCPA). These regulations entail a reporting requirement for certain payments (paid, offered, or agreed) “for the solicitation or promotion or otherwise to secure the conclusion of a sale of defense articles or defense services” in relation to license or agreement applications and Foreign Military Sale (FMS) contracts involving defense articles or services valued at $500,000 or more for use by the armed forces of a foreign country or international organization.
 
For companies retaining the services of a broker, the responsibilities are clear. Perform anti-corruption due diligence. Ensure the party is registered, if required. Then ensure they have the required approvals before starting. Monitor payments. And include any offers, agreements, or payments in your own reporting.

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TEEX/IM TRAINING EVENTS & CONFERENCES

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12. 
Full Circle Compliance Presents “Awareness Course U.S. Export Controls: ITAR & EAR From a Non-U.S. Perspective “, 2 Oct in Bruchem, the Netherlands
(Source: Full Circle Compliance, 
events@fullcirclecompliance.eu.)
 
* What: Awareness Course U.S. Export Controls: ITAR & EAR From a Non-U.S. Perspective 
* When: 2 Oct 2018, 9.00 AM – 5.00 PM (CEST)
* Where: Landgoed Groenhoven, Bruchem, the Netherlands
* Sponsor: 
Full Circle Compliance (FCC)
* Instructors: Ghislaine Gillessen, Mike Farrell, and Alexander P. Bosch 
* Information & Registration: 
HERE or e-mail 
events@fullcirclecompliance.eu

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13. 
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
 

* 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)
# Jul 30-Aug 3: Chicago, IL; “Import 5-Day Boot Camp“; Global Trade Academy
# Jul 30-Oct 8: Wilmington, CA; “Customs Broker License Examination Course“; Foreign Trade Association; (Classes run on Monday for 11 weeks)

* 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: Frankfurt, Germany; “BAFA/U.S. Export Control Seminar 2018“; 
* 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 2: Bruchem, Netherlands; “Awareness Course U.S. Export Controls: ITAR & EAR From a Non-U.S. Perspective“; Full Circle Compliance
* 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
# Sep 12-19: Chicago, IL; “Import 5-Day Boot Camp“; Global Trade Academy
* 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 
 

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: Webinar; ”
Incoterms: Rules of Engagement“; Integration Point

* 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) 
# July 17: Webinar; “Cybersecurity Threats and Compliance“; The Volkov Law Group
* Jul 17: Commodity Webinar; “July Series: Other Articles of Steel“; National Commodity Specialist Division (NCSD) 

* Jul 19: Webinar; ”
International Logistics“; International Business Training

* Jul 19: Commodity Webinar; “July Series: Tubes and Pipes of Iron or Steel“; National Commodity Specialist Division (NCSD)
# Jul 19: Webinar; “Talking Tariffs: Making Sense of 232 and 301 Tariffs“; Foreign Trade Association

* Jul 19: Webinar; ”
UPS Customs Brokerage Webinar – Drawback Update“; United Parcel Service
* Jul 20: Webinar; “Export Documentation and Procedures“; International Business Training
* Aug 8: Webinar; ”
Incoterms 2010: Terms of Sale“; International Business Training 
# Aug 9: Webinar;
 “Export Compliance Essentials for Shipping“;
 ECTI;
 
540-433-3977
# Aug 23: Webinar; “Social Media for Trade and Logistics Professionals“; Foreign Trade Association
* Aug 27: Webinar; ”
Import Documentation and Procedures“; International Business Training
* Sep 19: Webinar; “International Logistics“; International Business Training
* Sep 24: Webinar; “Tariff Classification: Using the Harmonized Tariff Schedule; International Business Training
* Sep 25: Webinar; “NAFTA Rules of Origin“; International Business Training
* Oct 15: Webinar; “
Incoterms 2010: Terms of Sale
“; International Business Training 
# Nov 14: Webinar; “An Export Commodity Classification Number – ECCN“; Foreign Trade Association
* Dec 3: Webinar; “Tariff Classification: Using the Harmonized Tariff Schedule; International Business Training

* Dec 4: Webinar; “NAFTA Rules of Origin“; International Business Training 
* Dec 5: Webinar; “Import Documentation and Procedures“; International Business Training
* Dec 11: Webinar; “
Incoterms 2010: Terms of Sale
“; International Business Training 

* Dec 20: Webinar; “International Logistics“; International Business Training

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

ENEDITOR’S NOTES

EN_a114
. Bartlett’s Unfamiliar Quotations

(Source: Editor)


John Paul Jones (born John Paul; 6 July 1747 – 18 Jul 1792;) was a Scottish-born American naval commander in the American Revolutionary War.  He is often referred to as the “Father of the American Navy” (a sobriquet he shares with John Barry and John Adams).
  – “It seems to be a law of nature, inflexible and inexorable, that those who will not risk cannot win.”
  – “I wish to have no connection with any ship that does not sail fast; for I intend to go in harm’s way.”

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

EN_a215. Are Your Copies of Regulations Up to Date?
(Source: Editor)

The official versions of the following regulations are published annually in the U.S. Code of Federal Regulations (C.F.R.), but are updated as amended in the Federal Register.  The latest amendments to applicable regulations are listed below.
 


ATF ARMS IMPORT REGULATIONS: 27 CFR Part 447-Importation of Arms, Ammunition, and Implements of War
  – Last Amendment: 15 Jan 2016: 
81 FR 2657-2723: Machineguns, Destructive Devices and Certain Other Firearms; Background Checks for Responsible Persons of a Trust or Legal Entity With Respect To Making or Transferring a Firearm. 
 

CUSTOMS REGULATIONS: 19 CFR, Ch. 1, Pts. 0-199
  – 
Last Amendment:
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:
29 June 2018: 83 FR 30541-30548: Global Magnitsky Sanctions Regulations; and 83 FR 30539-30541: Removal of the Sudanese Sanctions Regulations and Amendment of the Terrorism List Government Sanctions 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_a316
. Weekly Highlights of the Daily Bugle Top Stories
(Source: Editor)
 

Review last week’s top Ex/Im stories in “Weekly Highlights of Daily Bugle Top Stories” posted here.

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

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

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

* TO UNSUBSCRIBE: Use the Safe Unsubscribe link below.

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