;

18-0713 Friday “Daily Bugle”

18-0713 Friday “Daily Bugle”

Friday, 13 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 Issues an Order Terminating the Denial Order Issued on 15 Apr 2018 Against ZTE
  3. State/DDTC: (No new postings.)
  1. Deutsche Welle: “German Firm Probed Over Suspected Illegal Shipment of Euthanasia Drug to U.S.”
  2. Global Trade News: “Prime Minister May Secures Cabinet Agreement on Brexit Plan”
  3. NZHerald.co.nz: “University Links with China Raise Questions”
  4. Reuters: “U.S. Lifts Ban on Suppliers Selling to China’s ZTE”
  1. The Export Compliance Journal: “U.S. Export License Provisos Compliance”
  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: 10 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

EXIM_a1

[No items of interest noted today.]

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

OGSOTHER GOVERNMENT SOURCES

OGS_a11
. Items Scheduled for Publication in Future Federal Register Editions
 

(Source:
Federal Register)
* Commerce; NOTICES; Hearings; National Security Investigation of Imports of Automobiles, including Cars, SUVs, Vans and Light Trucks, and Automotive Parts; Change of Date [Publication Date: 16 Jul 2018.]
 
* DHS/CBP; NOTICES; Meetings: Commercial Customs Operations Advisory Committee [Publication Date: 16 Jul 2018.]

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

OGS_a22
Commerce/BIS Issues an Order Terminating the Denial Order Issued on 15 Apr 2018 Against ZTE

(Source: 
Commerce/BIS, 13 Jul 2018.) [Summary.] 
 
* Respondent: Zhongxing Telecommunications Equipment Corporation of Shenzhen, China, and ZTE Kangxun Telecommunications Ltd. of Hi-New Shenzhen, China (collectively, “ZTE”)
* Order: ZTE has made full and timely payment of the $1,000,000,000 and has complied with the escrow requirements relating to the $400,000,000 suspended portion of the civil penalty. Therefore, BIS is hereby terminating the 15 April 2018 Order, and BIS will remove ZTE from the Denied Persons List.   
  This order does not modify any provision of the Superseding Order or the Superseding Settlement Agreement.
* Date of Order: 13 Jul 2018.
 

[Editor’s Note: The 15 April 2018 Order is available 
here.]

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

OGS_3
3. State/DDTC: (No new postings.)

(Source: 
State/DDTC)

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

NWSNEWS

NWS_a014. 
Deutsche Welle: “German Firm Probed Over Suspected Illegal Shipment of Euthanasia Drug to U.S.”
(Source: 
Deutsche Welle, 12 Jul 2018.) [Excerpts.] 
 
A German medical firm is suspected of illegally shipping several tons of a solution that is used to euthanize animals to the United States. The solution contains an ingredient also used to execute prisoners.
 
The prosecutor’s office in the northern town of Oldenburg is investigating German veterinary pharmaceutical company VET Pharma Friesoythe GmbH for shipping a liquid drug used for euthanizing dogs to the United States illegally, according to an investigative report by German public broadcaster NDR and 
Süddeutsche Zeitung (SZ).
 
The solution in question, called “Beuthanasia-D,” contains pentobarbital, which is used in lethal injection cocktails. The trade of pentobarbital 
is highly regulated by European Union anti-torture directives and is subject to strict export restrictions.
 
Research by NDR and SZ found that prosecutors are investigating the chief executive of VET Pharma on suspicion of a commercial breach of the German Foreign Trade and Payments Act. Several other employees are also being investigated in the case. … 

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

 
British Prime Minister Theresa May reached a “collective” agreement with the cabinet on how the United Kingdom could potentially carry out a smooth Brexit.
May had gathered the twenty-six cabinet ministers at her private country residence for over twelve hours to discuss the future relationship of the UK and EU post-Brexit.  A common position was finally reached, now two years after the referendum.
 
  “This is a proposal that I believe will be good for the UK and good for the EU, and I look forward to it being received positively,” said May.
 
Key items in the ministerial agreement include:
  – Maintaining a “common rulebook” for all goods with the EU after Brexit on March 29, 2019
  – Forming a free trade area that would allow goods and agricultural products to move across borders without delays
  – Establishing a “join institutional framework” to interpret UK-EU agreements
  – Treating the borders between the UK and EU as a “combined customs territory”
  – Ending the free movement of people between the UK and EU and instead creating a “mobility framework” to allow UK and EU citizens to travel and apply for study and work
 
You can read more about Brexit, as well as the UK’s new ministerial agreement, on 
BBC
MercoPress, and 
Tribune India.

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

NWS_a3
6
NZHerald.co.nz: “University Links with China Raise Questions”
(Source: 
NZHerald.co.nz, 13 Jul 2018.) [Excerpts.] 
 
Is our university system being used to augment China’s military development? This is the question western government around the world are grappling with, and now New Zealand is too.
 
The first outward sign of this was 
news the Security Intelligence Service and the New Zealand Immigration Service is investigating a Chinese PhD student, Hu Bin at Auckland University of Technology. His 
research on 5G technology has military applications. … 
 
Hu’s research apparently came to attention because under the 
Strategic Goods Regulations, New Zealand entities – including universities – are prohibited from the development, production, or deployment of any goods or know-how with a military end use unless a permit has been obtained from the Secretary of Foreign Affairs and Trade. New Zealand’s Strategic Goods Regulations are based on the Wassenaar Arrangement, and the control measures of the Australia Group, the Nuclear Suppliers Group and the Missile Technology Control Regime. … 

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

NWS_a4
7
Reuters: “U.S. Lifts Ban on Suppliers Selling to China’s ZTE”
(Source: 
Reuters, 13 Jul 2018.) [Excerpts.]
 
The U.S. Department of Commerce on Friday lifted a ban on U.S. companies selling goods to ZTE Corp, allowing China’s second-largest telecommunications equipment maker to resume business.
 
The Commerce Department removed the ban shortly after ZTE deposited $400 million in a U.S. bank escrow, as part of a settlement reached last month. The settlement also included a $1 billion penalty ZTE paid to the U.S. Treasury in June.
 
  “The department will remain vigilant as we closely monitor ZTE’s actions to ensure compliance with all U.S. laws and regulations,” Commerce Secretary Wilbur Ross said in an emailed statement that described the penalties and other conditions as the strictest ever imposed in such a case.
 
The terms “will allow the department to protect U.S. national security,” Ross said. … 
ZTE, which relies on U.S. components for its smart phones and networking gear, ceased major operations after the ban was ordered in April.
 
The punishment came after the company made false statements about disciplining 35 employees involved with violating U.S. sanctions and illegally shipping U.S.-origin goods to Iran and North Korea, Commerce officials said.
 
ZTE pleaded guilty and settled with Commerce last year over the sanctions violations.  
ZTE paid $892 million in penalties to the United States last year in connection with the 2017 settlement and guilty plea. The latest $1.4 billion deal comes on top of that.
 
The $400 million will remain in escrow for as long as 10 years to provide the U.S. government access to the money if ZTE violates the June settlement.
 
On Thursday, ZTE’s Hong Kong shares surged 25 percent after Reuters broke news the United States had signed an escrow agreement that paved the way for ZTE to deposit the $400 million.
 
ZTE also replaced its board of directors and senior management, as required by the June settlement.  
It will now operate with a 10-year suspended ban hanging over its head, which the United States can activate if it finds new violations. The current ban could have lasted seven years.
 
A group of Republican and Democratic U.S. senators on Thursday sent a letter seeking to reinstate penalties on ZTE Corp. Many U.S. lawmakers see the company as a national security threat.
 
The U.S. Senate paved the way for a showdown with Trump over the issue last month, when it passed an annual defense policy bill with an amendment attempting to reverse the deal. Its fate is unclear. The measure could be killed when Senate and House of Representatives meet in the coming weeks to forge a compromise version of the bill.
 
Reuters reported on the U.S. demands for a deal on June 1, and on June 5, revealed that ZTE had signed a preliminary agreement with the Commerce Department, along with the fine and other terms. It also broke news of the ban in April.  
The Commerce Secretary announced the settlement on June 7.
 
A U.S. investigation into ZTE was launched after Reuters reported in 2012 that the company had signed contracts to ship hardware and software worth millions of dollars to Iran from some of the best-known U.S. technology companies.

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

COMMCOMMENTARY

 
You’ve made the sale, done the leg-work, written up the documentation, completed and submitted the export license application — then a few weeks later, Hooray!  
Your export license is approved. You read it cautiously, however, apprehensive about the limitations or stipulations that the agency might have attached to its authorization.
 
The Department of Commerce calls them “Conditions,” Department of State calls them “Provisos,” but the meaning is the same. Your export is good to go, provided you meet certain requirements. These conditions or provisos are issued as part of the license to the applicant.
 
The apprehension about provisos is because they might entail a significant restriction or reduction to your proposed export undertaking, whether goods, services, or technology.
 
Provisos Can Run the Gamut
 
Some are only standard conditions of issuance, attached to most or all licenses. Others might be fully expected and reasonable, even easy, to accommodate. Some, however, might be unexpectedly restrictive, or over-restrictive, to your intended action, work, or delivery. Or might be difficult to understand, and require clarification from the agency.
 
The good news is that, if you think you have an excessively restrictive proviso, or that a proviso was given in error, or does not reflect the information given in your application, there is an appeal procedure available called a ‘Proviso Reconsideration’ request. This entails a re-submission of the license or agreement application with exactly the same information as before, but showing ‘Proviso Reconsideration’ in the purpose block.
 
Pointing Out the Predicament of Your Potentially Problematic Proviso
 
To this you attach a letter of explanation, in which you provide the wording of the original proviso with a statement of the problem about it. Then offer a recommendation on how the proviso should be revised, or that it should be deleted, for the reasons explained and justified in your letter. Acknowledge to yourself that the restrictive proviso might be your own fault, on account of insufficient or poorly prepared information in the original application.
 
Sometimes provisos are concerned with the actions of a foreign party or end-user, which you are sometimes obliged to share with the foreign party, and other times (if classified, for instance) you are required not to share.
 
Conditions and provisos being an integral part of the license, measures must be put in place to track and document proviso compliance. Provisos might require additional documentation or record-keeping, which must be immediately facilitated.
 
Lastly, the same attention must be given to any additional work, procedures, or arrangements that you said you were going to do in the original application, which may not be repeated back in an added condition on the license. If you said you needed to do it, then that was in account in approving your license. 

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

TEEX/IM TRAINING EVENTS & CONFERENCES

TE_a1
9. 
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.)
Our next academy course is designed for beginning compliance officers and professionals who want to enhance their knowledge on the latest ITAR/EAR requirements and best practices.  The course will cover multiple topics regarding U.S. export controls that apply to organisations outside the U.S., such as: the regulatory framework, including the latest and anticipated regulatory amendments, key concepts and definitions, classification and licensing requirements, handling (potential) non-compliance issues, and practice tips to ensure compliance with the ITAR and EAR.

* 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

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

TE_a3
10. 
List of Approaching Events – 10 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 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: Manchester, UK; ”
An Introduction to Exporting“; UK Institute of Export and International Trade 

* Jul 18-20: Raleigh, NC; “Export Controls Specialist Certification“; Global Trade Academy
# Jul 19: London, UK; “Advanced Importing“; UK Institute of Export and International Trade
* 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 27: Chicago, IL; “Incoterms: A Strategic Approach“; 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: Birmingham, UK; ”
An Introduction to Exporting“; UK Institute of Export and International Trade

* 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: London, UK; “Advanced Exporting“; UK Institute of Export and International Trade 
* 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 12-19: Chicago, IL; “Import 5-Day Boot Camp“; Global Trade Academy 
* 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: 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 25-26: San Fransisco, CA; “11th West Coast Conference on FCPA Enforcement and Compliance“; American Conference Institute
# Sep 25-26: Toronto, Canada; “4th Forum on Economic Sanctions and Compliance Enforcement“; C5 Group

* 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 5: Boston, MA; “ Incoterms: A Strategic Approach“; 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 26: Milwaukee, WI; “Incoterms: A Strategic Approach“; 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
# Oct 31 – Nov 1: Singapore; “7th Asia Summit on Anti-Corruption”; American Conference Institute
* Nov 6: Detroit, MI; “Classification: How to Classify Parts“; Global Trade Academy

* Nov 7: Detroit, MI; ”
Advanced Classification of Machinery and Electronics“; Global Trade Academy

* Nov 7-9: London, UK; “TRACE European Forum, 2018“; TRACE Anti-Bribery Compliance Solutions
* Nov 7-9: Detroit, MI; “Advanced Classification for Machinery & Electronics“; Global Trade Academy
* Nov 12-15: Washington, D.C.; “ITAR Defense Trade Controls / EAR Export Controls Seminar“; ECTI; jessica@learnexportcompliance.com; 540-433-3977
* Nov 13: Tysons Corner, VA; “Made in America, Buy America, or Buy American: Qualify your Goods and Increase Sales“; Global Trade Academy
* Nov 14: Manchester, UK; “Intermediate Seminar“; UK Department for International Trade

* Nov 14-15: London, UK; “
Economic Sanctions & Financial Crime
“; C5 Group 

* Nov 15: Manchester, UK; “Beginner’s Workshop“; UK Department for International Trade
* Nov 15: Manchester, UK; “Licenses Workshop“; UK Department for International Trade
* Nov 15: Manchester, UK; “Control List Classification – Combined Dual Use and Military“; UK Department for International Trade
* Nov 15: McLean, VA; “ITAR For the Empowered Official“; FD Associates
* Nov 16, San Diego, CA; “Incoterms 2010: Terms of Sale Seminar“; International Business Training 
* Nov 27: Houston, TX; “Duty Drawback Specialist – Certification“; Global Trade Academy
* Dec 3-7: Tysons Corner, VA; “Certified Classification Specialist“; Global Trade Academy 
* Dec 4-5: Frankfurt, Germany; “US Defence Contracting and DFARS Compliance in Europe;” C5 Group
* Dec 5: London, UK; “Intermediate Seminar“; UK Department for International Trade
* Dec 5: London, UK; “Beginner’s Workshop“; UK Department for International Trade
* Dec 6: London, UK; “Licenses Workshop“; UK Department for International Trade
* Dec 6: London, UK; “Control List Classification – Combined Dual Use and Military“; UK Department for International Trade
* Dec 6: London, UK; “International Documentation and Customs Compliance“; Institute of Export and International Trade
* Dec 6: Manchester, UK; “
Introduction to Export Controls and Licenses
“; 
* Dec 11: Manchester, UK; “International Documentation and Customs Compliance“; Institute of Export and International Trade
* Dec 14: Philadelphia, PA; “Incoterms 2010: Terms of Sale Seminar“; International Business Training
 
2019
 

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

* May 5-7: Savannah, GA; “2019 Spring Seminar“; National Association of Foreign Trade Zones (NAFTZ)
* Sep 8-11: Chicago, IL; “2019 Annual Conference and Exposition“; National Association of Foreign Trade Zones (NAFTZ)
 
Webinars 
 

* 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_a111
. Bartlett’s Unfamiliar Quotations

(Source: Editor)


Charles Scribner, Jr.(Charles Scribner IV; 13 Jul 1921 – 11 Nov 1995, also known as Charles Scribner Jr., was the head of the Charles Scribner’s Sons publishing company. He succeeded his father, Charles Scribner III, in 1952 as chief of Charles Scribner’s Sons, which had been founded by his great-grandfather, Charles Scribner I, in 1846. He oversaw the operations until 1984, when the company was bought out by Macmillan Publishing.)
  – “Language is the soul of intellect, and reading is the essential process by which that intellect is cultivated beyond the commonplace experiences of everyday life.”

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

EN_a212. 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_a313
. Weekly Highlights of the Daily Bugle Top Stories
(Source: Editor)
 

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

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

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

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

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

* SUBSCRIPTIONS: Subscriptions are free.  Subscribe by completing the request form on the Full Circle Compliance website.

* BACK ISSUES: An archive of Daily Bugle publications from 2005 to present is available HERE.

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