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18-0716 Monday “Daily Bugle”

18-0716 Monday “Daily Bugle”

Monday, 16 July 2018

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The Daily Bugle is a free daily newsletter from Full Circle Compliance, containing changes to export/import regulations (ATF, DOE/NRC, Customs, NISPOM, EAR, FACR/OFAC, FAR/DFARS, FTR/AES, HTSUS, and ITAR), plus news and events.  Subscribe 
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  1. Commerce Cancels 2nd Day of Public Hearing on Section 232 Investigation of Imports of Automobiles 
  2. DHS/CBP: COAC to Meet on 1 Aug via Webinar 
  1. Items Scheduled for Publication in Future Federal Register Editions
  2. Commerce/BIS: (No new postings.)
  3. State/DDTC: (No new postings.)
  4. Hong Kong Suspends all E-Services on 20 Jul
  1. BBC: “Iran Nuclear Deal: US Rejects EU Plea for Sanctions Exemption”
  2. Expeditors News: “Israeli Customs Releases New Optional Method to Provide an Invoice Declaration”
  3. Reuters: “Mnuchin Says U.S. Will Consider Some Waivers on Iran Sanctions”
  4. The Washington Free Beacon: “State Department Gives Up Case Against 3D Printed Gun Pioneer”
  1. J. Helder, C. Klaui & D. Lund: “EU Trade Update: Trade Aspects of the July 2018 U.K. Government White Paper on the Future U.K. EU Relationship”
  2. M. Volkov: “Episode 47 – Cybersecurity Threats and Compliance”
  1. Monday List of Ex/Im Job Openings: 180 Jobs Posted This Week, Including 9 New Jobs
  1. ECTI Presents United States Export Control (ITAR/EAR/OFAC) Seminar Training Focusing on Issues Relevant to Universities, Research Labs & Other Institutions of Higher Learning in Columbus, OH
  2. Full Circle Compliance Presents “Awareness Course U.S. Export Controls: ITAR & EAR From a Non-U.S. Perspective”, 2 Oct in Bruchem, the Netherlands
  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

1
. Commerce Cancels 2nd Day of Public Hearing on Section 232 Investigation of Imports of Automobiles

(Source: Federal Register, 16 July 2018.) [Excerpts.]
 
83 FR 32833: Public Hearing on Section 232 National Security Investigation of Imports of Automobiles, Including Cars, SUVs, Vans and Light Trucks, and Automotive Parts; Change of Date for the Public Hearing
* AGENCY: U.S. Department of Commerce.
* ACTION: Change of date for public hearing.
* SUMMARY: The Department of Commerce is cancelling one of the days of the two-day public hearing associated with the notice of request for public comments and public hearing that appeared in the Federal Register on May 30, 2018. In the notice, the Department encouraged interested public participants to participate in a hearing for the investigation assist the Department in determining whether imports of automobiles, including cars, SUVs, vans and light trucks, and automotive parts threaten to impair the national security and in recommending remedies if such a threat is found to exist. The hearing was originally scheduled for July 19 and 20. Only 45 requests to testify were received. Because these requests can all be accommodated on a single day, the second day of the hearing originally scheduled for July 20 is cancelled. The hearing will be held on July 19 only. The hearing will begin at 8:30 a.m. and will end at 5:30 p.m. The location of the hearing remains unchanged.
* DATES: The public hearing will be held on July 19, 2018, beginning at 8:30 a.m. local time and concluding at 5:30 p.m. local time.
* ADDRESSES: The public hearing will be held at 1401 Constitution Avenue NW, Washington DC, 20230.
* FOR FURTHER INFORMATION CONTACT: Sahra Park-Su, U.S. Department of Commerce (202) 482-2811. For more information about the section 232 program, including the regulations and the text of previous investigations, see www.bis.doc.gov/232.
* SUPPLEMENTARY INFORMATION:
The hearing is open to the general public and seating is on a first-come-first served basis. We anticipate a high volume of interest and encourage all members of public wishing to attend, to arrive early and be prepared to go through a security screening. You must present a valid form of identification such as a driver’s license, passport, or state issued ID. …
 
   Dated: July 11, 2018.
Earl Comstock, Director, Office of Policy and Strategic Planning, U.S. Department of Commerce.
 

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EXIM_a2

2
. DHS/CBP: COAC to Meet on 1 Aug via Webinar

(Source: Federal Register, 16 July 2018.) [Excerpts.]
 
83 FR 32885-32886: Commercial Customs Operations Advisory Committee (COAC)
* AGENCY: U.S. Customs and Border Protection (CBP), Department of Homeland Security (DHS).
* ACTION: Committee management; notice of Federal Advisory Committee meeting.
* SUMMARY: The Commercial Customs Operations Advisory Committee (COAC) will hold its public meeting on Wednesday, August 1, 2018 via webinar. The meeting will be open to the public.
* DATES: The COAC will meet on Wednesday, August 1, 2018 from 1:00 p.m. to 4:00 p.m. EST. Please note that the meeting may close early if the committee has completed its business.
* ADDRESSES: The meeting will be held via webinar. The webinar link and conference phone number will be provided to all registrants by 5:00 p.m. on July 31, 2018. For information on services for individuals with disabilities or to request special assistance at the meeting, contact Ms. Florence Constant-Gibson, Office of Trade Relations, U.S. Customs & Border Protection, at (202) 344-1440 as soon as possible. …
* FOR FURTHER INFORMATION CONTACT: Ms. Florence Constant-Gibson, Office of Trade Relations, U.S. Customs and Border Protection, 1300 Pennsylvania Avenue NW, Room 3.5A, Washington, DC 20229; telephone (202) 344-1440; facsimile (202) 325-4290; or Mr. Bradley Hayes, Executive Director, Office of Trade Relations and Designated Federal Officer for COAC at (202) 344-1440.
* SUPPLEMENTARY INFORMATION: …
Agenda
  The Designated Federal Officer will introduce the newly appointed, re-appointed, and alternate COAC members. The COAC will also hear from the following subcommittees on the topics listed below and then will review, deliberate, provide observations, and formulate recommendations on how to proceed:
    (1) The Exports Subcommittee will discuss a path forward for its work and the work of the Export Manifest Working Group for the 15th Term COAC. There will also be an update on the automated export manifest pilots, and on progress in implementing a post-departure filing pilot as part of the ocean pilot.
    (2) The Trusted Trader Subcommittee will present an update from the C-TPAT Minimum Security Criteria Working Group on its recommendation regarding CBP’s plans to roll out new C-TPAT criteria. The subcommittee will also provide an update on the progress on the Trusted Trader Strategy and the formation of a new Trade Compliance Working Group.
    (3) The Trade Modernization Subcommittee will discuss the progress of the Regulatory Reform Working Group’s efforts to identify and prioritize areas of regulations administered by CBP which can be reformed and the Foreign Trade Zone Regulations Working Group. In addition, the subcommittee will discuss the progress being made in the E-Commerce Working Group.
    (4) The Trade Enforcement and Revenue Collection (TERC) Subcommittee will provide updates from the Anti-Dumping/Countervailing Duties (AD/CVD), Bond, Forced Labor and Intellectual Property Rights Working Groups and will also speak to the lessons learned from the risk-based bonding tabletop exercise.
  Meeting materials will be available by July 31, 2018 here.
 
   Dated: July 11, 2018.
Bradley F. Hayes, Executive Director, Office of Trade Relations.

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

OGSOTHER GOVERNMENT SOURCES

OGS_a13. Items Scheduled for Publication in Future Federal Register Editions
(Source: Federal Register)

* Trade Representative, Office of United States; NOTICES; Proposed Modification of Action Pursuant to Section 301: China’s Acts, Policies, and Practices Related to Technology Transfer, Intellectual Property, and Innovation [Publication Date: 17 July 2018.]
 
* U.S. Customs and Border Protection; NOTICES; Agency Information Collection Activities; Proposals, Submissions, and Approvals [Publication Date: 17 July 2018.]:
  – General Declaration
  – Transfer of Cargo to a Container Station
 
* U.S. Customs and Border Protection; NOTICES; Quarterly IRS Interest Rates Used in Calculating Interest on Overdue Accounts and Refunds on Customs Duties [Publication Date: 17 July 2018.]

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

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

(Source:
Hong Kong Trade and Industry Department, 16 July 2018.)
 
All e-services of our website will be suspended from 18:30 to 23:00 on 20 July 2018 (Friday) due to system maintenance.

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NWSNEWS

NWS_a17
. BBC: “Iran Nuclear Deal: US Rejects EU Plea for Sanctions Exemption”

(Source:
BBC, 16 July 2018) [Excerpts.]
 
The US has rejected pleas from the EU to grant exemptions to European firms from the sanctions on Iran that will start to be reinstated next month.
 
Secretary of State Mike Pompeo and Treasury Secretary Steven Mnuchin wrote in a letter that they wanted to exert “unprecedented” pressure on Tehran.
 
Waivers will only be given on national security or humanitarian grounds.
 
President Donald Trump ordered that the sanctions be re-imposed in May after abandoning a nuclear deal with Iran.
 
The UK, France and Germany – which were also parties to the 2015 accord, along with Russia and China – pledged to continue abiding by their commitments.
 
They said they would work on measures to counter the effects of the sanctions, but major European companies like Peugeot and Total have since cut back their involvement in Iran in order not to risk their business prospects in the US.
 
Iran has said it will stay in the deal if it still receives the economic benefits. …

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NWS_a28. Expeditors News: “Israeli Customs Releases New Optional Method to Provide an Invoice Declaration”

(Source: Expeditors News, 13 July 2018.)
 
Israeli Customs has released an alternative method of issuing a declaration of origin newly titled “Invoice Declaration.”
Israeli Customs has outlined several conditions for its use:
 
* The document is on letterhead of the exporter or manufacturer.
* The document should include the logo of the exporter or manufacturer, and identify details of the exporter or manufacturer, including the address and the date of issue of the document.
* The document should be prepared and issued only by the United States manufacturer or exporter.
* The document should include the title “Invoice Declaration.”
* The following information should appear in the rows following the title of the document:
  – The sales invoice number.
  – Date of issue of the invoice.
  – Where the invoice was issued.
* In cases where the goods are transferred to distribution centers in the U.S. or in an intermediate country and the transaction invoice is issued by a U.S. company or a company based in the third country, the “other commercial document” should be issued by the U.S. company only. The document should specify the list of the original goods entitled to customs preference.
* The “Other commercial document” should include an invoice declaration as stated in Appendix A and B to this directive, with all required details.
 
The Israeli Customs press release may be found
here.  
The U.S. Customs and Border Protection announcement may be found
here
.

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

(Source:
Reuters, 16 July 2018.)
 
The United States wants to avoid disrupting global oil markets as it reimposes sanctions against Tehran and in certain cases will consider waivers for countries which need more time to wind down their oil imports from Iran, U.S. Treasury Secretary Steven Mnuchin said.
 
  “We want people to reduce oil purchases to zero, but in certain cases if people can’t do that overnight, we’ll consider exceptions,” Mnuchin told reporters on Friday, clarifying some U.S. officials’ comments that there would be no exemptions. Mnuchin’s comments were embargoed for release on Monday.
Mnuchin was talking to reporters en route from Mexico where he was part of a high-level U.S. delegation led by Secretary of State Mike Pompeo to meet Mexico’s next president, Andres Manuel Lopez Obrador.
 
The Trump administration is pushing countries to cut all imports of Iranian oil from November when the United States reimposes sanctions against Tehran, after Trump withdrew from the 2015 nuclear deal agreed between Iran and six major powers, against the advice of allies in Europe and elsewhere.
 
Mnuchin said he would meet with counterparts from developed and developing countries on the sidelines of a G20 finance ministers’ meeting in Buenos Aires on July 19-22. U.S. sanctions against Iran are likely to be raised in his talks.
 
Pompeo, also speaking to reporters on Friday, said he had discussed U.S. plans to reimpose sanctions on Iran with “all but one” country. He did not name the country he had not yet consulted.
 
  “What they’ve asked us to do is review how we get there and the timeline for that,” he said, “and so I’m very confident they understand.”
 
Iranian President Hassan Rouhani, speaking in remarks carried live on state television on Saturday, said Washington was more isolated than ever over sanctions against Iran, even among its allies.
 
His comments appeared to be trying to ease popular concerns fueled by Trump’s decision to withdraw from the deal with Iran on its nuclear program.
 
The likely return of U.S. economic sanctions has triggered a rapid fall of Iran’s currency and protests by bazaar traders usually loyal to the Islamist rulers.
 
Trump has said he asked Saudi Arabia to raise oil production if needed to ensure global oil supplies and the country has 2 million barrels per day of spare capacity.
 
The Organization of the Petroleum Exporting Countries agreed with Russia and other oil-producing allies on June 23 to raise output from July, with Saudi Arabia pledging a “measurable” supply boost, but giving no specific numbers.

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NWS_a410. The Washington Free Beacon: “State Department Gives Up Case Against 3D Printed Gun Pioneer”

(Source: The Washington Free Beacon, 15 July 2018.)
 
The Department of State settled with the Second Amendment Foundation, Cody Wilson, and his company Defense Distributed on Wednesday, dropping claims that posting firearms designs on the internet violated an arms export law.
 
In the settlement, the State Department has agreed to waive prior restraint, which was
imposed in 2013 against the plaintiffs, allowing Wilson and Defense Distributed to begin posting gun designs on the internet again. They also agreed to pay for what plaintiffs described as a “significant portion” of their attorney’s fees. Defense Distributed will also be refunded the $10,000 in registration fees it had paid to the State Department.
 
In an interview with the
Washington Free Beacon, Wilson said he believes the settlement was inevitable because he believes the State Department had a bad case.
 
“I think by the end DOJ realized they don’t actually want to argue with this because it’s such a stinker from a First Amendment point of view,” Wilson told the
Free Beacon. “So, I really think they needed to get out from under it and they already had the export control reform so they literally offered me a modification of the ITAR. They literally rewrite the ITAR for Defense Distributed in an anticipation of the change in the rules. Who knows when that happens, like a year from now. I don’t know. All this suggests they really needed to run away from it because we took it down to the mat.”
 
Wilson said his company is planning to launch
Defcad.com as a new resource for posting and sharing gun designs.
 
  “Basically, because of the settlement, if you submit to me and we post through Defcad by these new rules in the ITAR, that information becomes public domain and so it becomes for all time,” Wilson said. “So let’s say Oprah gets elected in 2020 or whatever, and decides ‘you know what this sucks, I’m not gonna do this anymore,’ well, whatever got posted in the meantime on Defcad that’s for all time, that’s good, that’s in the commons and nobody can come back and get that. And that’s a very interesting thing that I don’t think people understand yet.”
 
He said that while he first gained notoriety over his innovative work with 3D-printed firearms and the State Department actions were in response to that, the settlement will allow people to share far more than designs intended for 3D-printers.
 
  “People don’t get what you mean when you say 3D,” Wilson said. “We ain’t just talking about 3D printers and liberator pistols. We’re talking about all the engineered drawings, cad drawings, everything related to technical data of all the guns we know and care about. And, of course, the new things. The things we haven’t seen yet.”
 
Defcad, Wilson hopes, will become a hub for gun designers as well as hobbyists.
 
  “We’ll try to build a resource for our culture, our industry,” he said. “Maybe it would help new companies form faster and other people collaborate together better. Because there’s not really a standardized place right now.”
 
He said the settlement will breathe new life into the online gun-rights community.
 
  “The biggest takeaway is that this really is an opportunity for the Second Amendment to have new life on the Internet,” Wilson told the
Free Beacon. “It’s not really about 3D printing. 3D printing’s a good handle, but in essence that venture we had with 3D printing gave us access to a monopoly power to put all the data related to all guns on the Internet. It’s a beautiful expansion. I would think it’s actually difficult to overstate how important it might be to our movement.”
 
Alan Gottlieb, Second Amendment Foundation founder, said the settlement was as much a win for the First Amendment as the Second.
 
  “Not only is this a First Amendment victory for free speech, it also is a devastating blow to the gun prohibition lobby,” he said in a statement. “For years, anti-gunners have contended that modern semiautomatic sport-utility rifles are so-called ‘weapons of war,’ and with this settlement, the government has acknowledged they are nothing of the sort.”
 
Wilson said he expected the State Department’s admission that AR-15s and other semiautomatic-only firearms are not inherently military weapons would be used in future litigation against bans on so-called assault weapons and other firearms.
  “You’ve got the federal government being like literally for purposes of regulating weapons of war-the AR-15 is not a weapon of war,” Wilson said. “You can take that to the bank. And I expect people will.”
 
He said that while Brett Kavanaugh’s nomination to the Supreme Court may lead to future legal victories for the gun-rights movement, the settlement between his company and the State Department is a reason for gun-rights advocates to be happy right now.
 
  “This stuff here is good Second Amendment news right now, not stuff you have to wait for two years from now,” Wilson said.

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COMMCOMMENTARY

COMM_a0
11. J. Helder, C. Klaui & D. Lund: “EU Trade Update: Trade Aspects of the July 2018 U.K. Government White Paper on the Future U.K. EU Relationship”

(Source: Akin Gump Strauss Hauer & Feld LLP, 16 July 2018.)
 
* Authors: Jasper Helder, Esq.,
jasper.helder@akingump.com, +44 20-7661-5308; Chiara Klaui, Esq.,
chiara.klaui@akingump.com, +44 20-7661-5342; and Daniel Lund, Esq.,
daniel.lund@akingump.com, +44 20-7012-9653. All of Akin Gump Strauss Hauer & Feld LLP.
 
Key Points

 

* The White Paper sets out in detail the shape and scope of the U.K.’s desired future “association” relationship with the EU post Brexit. The U.K. government hopes that it will accelerate negotiations with the EU with a view to agreeing the substantive elements of a “future framework” alongside the withdrawal formalities by the end of 2018.

* The White Paper is wide-ranging and covers the potential for a future economic partnership, and a defence and security partnership, as well as measures designed to ensure appropriate democratic accountability through joint institutional arrangements.

* In particular, the White Paper sets out how the U.K. government seeks to achieve frictionless trade in goods between the U.K. and the EU-despite the U.K. existing outside of the Customs Union and the Single Market.

 

A Free Trade Area for Goods
 
The United Kingdom (U.K.) government takes the view that, to achieve a Brexit that respects the outcome of the 2016 referendum, the U.K. must leave both the EU Single Market and the EU Customs Union. However, the U.K. government aims to reduce the damage that this is likely to cause businesses by entering into a “deep and comprehensive” economic partnership with the European Union (EU). At the heart of the U.K. government’s proposal is the creation of a free trade area for goods. The stated purpose of the free trade area is to “avoid friction at the border [between the UK and EU] and ensure that both sides meet their commitments to Northern Ireland and Ireland through the overall future relationship.”  
 
The cornerstone of the U.K. government’s free trade area is the implementation of a Facilitated Customs Arrangement (FCA). The U.K. government hopes that the FCA will enable near frictionless trade with the EU by essentially mirroring the existing mechanisms of the Customs Union through a duty-remittance scheme and adherence to a common rulebook. However, by remaining formally outside of the Customs Union, the U.K. would not be bound by the EU’s Common Commercial Policy, and, as such, would be free to enter into new trade agreements with third countries (to the extent that such agreements are compatible with its proposed commitments with the EU).
 
In terms of timing, the White Paper notes that the FCA would receive a “phased” implementation. The U.K. has committed to remaining in the Customs Union during the transition period, which is scheduled to end in December 2020. As such, it leaves open the possibility that the U.K. may continue to stay within the Customs Union beyond December 2020 to introduce the FCA in a gradual manner, to the extent that the U.K. and EU are not ready by January 2021.
 
The Introduction of a Duty Remittance Mechanism
 
In terms of mechanics, the U.K. would apply the EU’s duties and trade policy measures for all goods landing in the U.K. but destined for the EU. Where goods land and are destined for the U.K., then the U.K. will apply its own duties and trade policy measures (to the extent that they differ). The EU would not, however, be expected to apply U.K. duties and trade policy measures at its borders. The U.K. has instead proposed that the U.K. duties be settled as part of a wider duty-remittance mechanism. The U.K. concludes that, because all goods entering the EU via the U.K. should have complied with EU customs processes and duty measures, there would be no need to introduce formal customs processes between the U.K. and the EU (notably rules of origin requirements).   
 
The White Paper provides a worked example on how the U.K. government intends for importers to settle any duties owed at the point that goods enter the U.K. The example states that, when the goods’ destination can be “robustly” demonstrated by a “trusted trader,” the importer will pay the duty amount that corresponds to that destination. In contrast, where the goods’ destination cannot be ascertained, then the importer must pay the higher of the U.K. or EU duty and seek reimbursement (if the goods’ destination were to a lower-duty jurisdiction).
 
The example, while brief, raises a number of issues. First, it fails to clarify what “robust” evidence “trusted traders” would need to provide with respect to validating the final destination of a consignment. In addition, it raises the question as to whether importers that are not “trusted traders” but otherwise provide “robust” evidence will always be required to declare the higher duty rate.  The White Paper also states that the U.K. and EU should “agree a new trusted trader scheme to allow firms to pay the correct tariff at the UK border.”  This calls into question how pre-existing schemes, notably Authorised Economic Operator (for which the White Paper proposes mutual recognition), will exist alongside any new requirements. For materials imported and subsequently processed in the U.K., the U.K. government proposes repayment as soon as possible, (e.g., at the point where the materials have been substantially transformed into U.K. goods). The U.K. government points to the pan-Euro-Mediterranean trade agreement as an example for rules of origin.
 
More broadly, the proposal is likely to place several new compliance burdens on U.K. businesses. For example, importers often do not know the final destination of their goods upon initial entry into the EU, but now will be required to do so. Moreover, in instances where U.K. businesses seek to obtain a refund due to paying additional duty (because, for example, they cannot assert the final destination of their goods at import), such businesses would be required to track the goods and evidence their consumption within the EU.
 
A Common Rulebook for Trade in Goods
 
The U.K. government has conceded that, to maximize the possibility for frictionless trade in goods post Brexit, it will need to maintain a common rulebook relating to all rules necessary to facilitate such trade at the U.K.-EU border (e.g., product conformity legislation). In reality, the U.K. government appears to have accepted that this will require it to continue to implement certain EU legislation beyond the U.K.’s departure date, with the White Paper citing the Union Customs Code as one piece of EU legislation to which the U.K. would continue to adhere.
 
As part of this, the U.K. government has requested participation in all EU technical committees and regulatory agencies relating to legislation that forms part of the common rulebook (such as the European Medicines Agency and the European Chemicals Agency). The U.K. government asserts that participation in these committees and agencies should mean, for example, that manufacturers have to undergo only one conformity assessment in either the U.K. or EU in order to place a product on both markets.  
 
The U.K. acknowledges, however, that it would not have voting rights in such committees and agencies. This raises the question as to how much influence the U.K. will continue to have over EU legislation that will directly impact the manufacturing requirements and product standards to which U.K. businesses must adhere. To this end, the U.K. government has proposed a series of institutional provisions designed to ensure that there are sufficient checks and balances in place to mitigate the risk that a change in EU legislation (that forms part of the common rulebook) does not adversely harm U.K. interests. If any such measure were to enter into force, then the U.K. government states that it would reserve the right not to implement ultimately (but acknowledges that this could have an adverse impact on the wider relationship). The White Paper also proposes an independent arbitration panel, including sectoral technical experts, to resolve disputes on regulation and could refer questions related to the common rule book to the European Court of Justice.
 
EU Response
 
The EU’s initial reaction to the U.K. government’s White Paper has been one of guarded optimism, perhaps due to the fact that it envisages a closer relationship between the U.K. and the EU than what has previously been suggested by the U.K. The EU has, however, previously stated that it would not entertain a “single market” for goods, since it deems this to be “cherry-picking.” Moreover, when the U.K. government first raised the idea of a customs partnership between the U.K. and the EU earlier this year, the EU raised a number of substantive concerns regarding its viability, notably that the arrangement would be a target for customs and value added tax fraud. This is no doubt exacerbated by the fact that the European Commission launched a £2.4 billion claim against the U.K. in March 2018 for unpaid customs duties relating to fraudulent Chinese imports. The U.K. government acknowledges that the mechanics of the proposed free trade area would require vigorous surveillance and enforcement; however, the White Paper does not provide any detail on how this would be achieved.   
 
If, therefore, the U.K. government’s latest proposals as set out in the White Paper fail to gain traction with the EU, then this is likely to make the U.K. government’s current leadership more unstable and a “no deal” situation more of a possibility.  As such, it is critical that businesses plan accordingly.

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COMM_a01
12. M. Volkov: “Episode 47 – Cybersecurity Threats and Compliance”
(Source: Volkov Law Group Blog, 15 July 2018. Reprinted by permission.)
 
* Author: Michael Volkov, Esq., Volkov Law Group,
mvolkov@volkovlaw.com, 240-505-1992.
 
Companies face evolving and significant cyber risks. The FBI estimates that ransomware will generate at least $1 billion for criminals.  Businesses stand to lose at least $400 billion each year from hacks.  The cyber defense, forensics and insurance industry will be worth nearly $200 billion by the end of this decade.  Each year there is an average of 1.5 million cyber attacks, or approximately 4000 per day.
 
In this episode, Michael Volkov discusses cybersecurity threats and compliance strategies to mitigate such risks.
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MSEX/IM MOVERS & SHAKERS

MS_a113. Monday List of Ex/Im Job Openings; 180 Jobs Posted This Week, Including 9 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

* Aerojet Rocketdyne; Huntsville, AL; 
International Trade and Compliance Specialist;

* Aerojet Rocketdyne; Camden, AR;
International Trade and Compliance Specialist;

* Agility; Atlanta, GA;
Export Compliance Administrator
;

* Agility; Houston, TX; Air Freight Export Coordinator;
* A
gility; 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; Coppel, TX; Air Import Coordinator;

* Agility; Burlingame, CA;
 
Ocean Import Coordinator;
* Agility; East Boston, MA; Entry Writer/Import Coordinator
;
* Agility; Dallas, TX;  Air Import Supervisor;

# Albemarle Corporation; Baton Rouge, LA; Logistics Specialist – Trade Compliance and Marine Specialist
# Amazon; Seattle, WA; Head, Global Trade and Product Compliance
;
# Amazon; Seattle, WA;
 
Global Trade Compliance Analyst;
* Arconic; Torrance, CA; Global Trade Compliance Manager – Import;
* 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;

# Augusta Westland; Philadelphia, PA;
Import Export Specialist;

* AutoNation; Fort Lauderdale, FL; Trade Compliance Manager
*
 BAE Systems; Los Angeles, CA; 
Program Manager, International and Offset

; Requisition ID: 33778BR 

* 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

* Boeing; Zoushan, China;
Trade Compliance Manager;

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

* Curtiss-Wright; Chanhassen, MN;
Logistics & Compliance Specialist; Requisition ID: 2835
# Dorman Products; Colmar, PA;
Global Trade Compliance Specialist;

*
 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

* 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 

*
 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

# Flash Global; Mountain Lakes, NJ;
Import and Export Specialist;

* 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; 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

* Hussman; Bridgeton, MO; 
Trade Compliance Specialist;

* 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

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

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

# Interra International; Atlanta, GA;
Global Logistics Specialist;
* 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
* Komatsu; Milwaukee, WI; Senior International Trade Compliance AnalystRequisition ID: 12728
* 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;
* Mercury Systems; Andover, MA; International Trade Compliance Director; Requisition ID: 18-165
* 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

* Muscogee International, LLC; Washington, D.C.;
DDTC Compliance Specialist II; Apply
HERE or contact their
recruiting team.
* Muscogee International, LLC; Washington, D.C.; 
DDTC Registration Analyst III
Apply HERE or contact their recruiting team. 

* Muscogee International, LLC; Washington, D.C.;
DDTC Policy Analyst
Apply 
HERE
 or contact their 
recruiting team
.
* Muscogee International, LLC; Washington, D.C.; 
DDTC Records Auditor
Apply HERE or contact their recruiting team. 
* Muscogee International, LLC; Washington, D.C.; DDTC Contract AnalystApply HERE or contact their recruiting team.

* Muscogee International, LLC; Washington, D.C.; 
DDTC Service Support Desk Lead
Apply 
HERE
 or contact their 
recruiting team
.
* Muscogee International, LLC; Washington, D.C.; 
DDTC Service Support Desk
Apply HERE or contact their recruiting team. 
* Muscogee International, LLC; Washington, D.C.; DDTC Office Support IApply HERE or contact their recruiting team.
* Muscogee International, LLC; Washington, D.C.; DDTC Office Support IIApply HERE or contact their recruiting team.

* Muscogee International, LLC; Washington, D.C.; DDTC Office Support IIIApply HERE or contact their recruiting team.

* MTS Systems; Eden Prairie, MN;
Global Trade Compliance Manager
; Requisition ID: 37841

* Northrop Grumman; Herndon, VA;
Manager, International Trade Compliance 2; Requisition ID: 18010381

* 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; McLean, VA; International Trade Compliance Analyst 3; Requisition ID: 18012973
* Northrop Grumman; Herndon, VA; International Trade Compliance Analyst 3; Requisition ID: 18007859
* Northrop Grumman; San Diego, CA; International Trade Compliance Analyst 2; Requisition ID: 18012561

* Northrop Grumman; Redondo Beach, CA; or Rancho Bernardo, CA; or Melbourne, FL; or Falls Church, VA; 
Sr. Manager, International Trade Compliance; Requisition ID: 18012105; Contact Fred Czarske at 310.332.7606,
fred.czarske@ngc.com.
# OCR Services, Inc.; Rockville, MD;
Business Analyst, Global Trade Compliance;

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

* Oracle; Unspecified, United States; Customs Compliance Specialist; Requisition ID: 18000H0N
* Oshkosh Corporation; Greenville, WI;
Global Trade Compliance Analyst
; Requisition ID: 182405

* PerkinElmer, Inc.; Shelton, CT;
Systems Analyst, Trade Compliance Solutions;
* PerkinElmer, Inc.; Shelton, CT;
International Trade Compliance Analyst – Export Coordinator
Requisition ID: 
JR-001256
* PerkinElmer, Inc.; Hopkinton, CT;  
International Trade Compliance Analyst – Export Coordinator
; Requisition ID: JR-001256 
* PerkinElmer, Inc.; Singapore; ITC Specialist; Requisition ID: JR-003936

* 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 Manager; Requisition ID:  62176BR

* United Technologies – Pratt & Whitney; East Hartford, CT;
International Trade Compliance Authorizations Manager; Requisition ID: 63222BR
* 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
;

* Vigilant; Negotiable Location, USA;  
Global Trade Account Manager
;
* Vigilant; Budapest, Hungary; 
Jr. 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
# Zagg Corp.; Midvale, UT;
Global Trade Compliance Specialist;
* 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

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

TECEX/IM TRAINING EVENTS & CONFERENCES

 
* What: University Export Controls (ITAR/EAR/OFAC) Seminar in Columbus, OH
* When: September 17-20, 2018
* Where: Columbus, OH: The Blackwell Inn on the campus of The Ohio State University
* Sponsors: Export Compliance Training Institute (ECTI), Visual Compliance, Amber Road
* ECTI Speaker Panel: John Black, Scott Gearity, & Melissa Proctor, with special presentations by Kevin Wolf (Akin Gump), James Bartlett (Full Circle Compliance), Felice Laird (Export Strategies), Jeanette Miller (OFAC), Jessa Albertson & Emily Schriver & Jen Yucel (Ohio State University), Allen DiPalma (Univ. of Pittsburgh), Mary Beran (Georgia Tech), Missy Peloso (Univ. of Penn.) and others
* Register: Here, or Jessica Lemon, 540-433-3977, jessica@learnexportcompliance.com.

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

(Source: Full Circle Compliance,
events@fullcirclecompliance.eu.)
 
Our next academy course is specifically 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: Tuesday, 2 Oct 2018, 9 AM – 5 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 via events@fullcirclecompliance.eu  
 
* * * * * * * * * * * * * * * * * * * *

ENEDITOR’S NOTES

 

Thomas Bulfinch (15 Jul 1796 – 27 May 1867; was an American writer born in Newton, Massachusetts, best known for the book Bulfinch’s Mythology, the standard for over a century and still in print 163 years after the first edition was published.)
 – “Without a knowledge of mythology much of the elegant literature of our own language cannot be understood and appreciated.”
 
Mary Baker Eddy (16 July 1821 – 3 Dec 1910; established the Church of Christ, Scientist, as a Christian denomination and worldwide movement of spiritual healers. She wrote and published the movement’s textbook, Science and Health with Key to the Scriptures and 15 other books. In 1908, at the age of 87, she founded The Christian Science Monitor, a global newspaper that has won seven Pulitzer Prizes.)
  – “Jealousy is the grave of affection.”

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

EN_a317
. 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: 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_a0318
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.  If you would to submit material for inclusion in the The Export/Import Daily Update (“Daily Bugle”), please find instructions here.

* 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.

* TO UNSUBSCRIBE: Use the Safe Unsubscribe link below.

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