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18-0725 Wednesday “Daily Bugle”

18-0725 Wednesday “Daily Bugle”

Wednesday, 25 July 2018

TOP
The Daily Bugle is a free daily newsletter from Full Circle Compliance, containing changes to export/import regulations (ATF, DOE/NRC, Customs, NISPOM, EAR, FACR/OFAC, FAR/DFARS, FTR/AES, HTSUS, and ITAR), plus news and events.  Subscribe 
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  1. Commerce/BIS Seeks Comments on Section 232 National Security Investigation of Imports of Uranium 
  1. Items Scheduled for Publication in Future Federal Register Editions
  2. Commerce/BIS: (No new postings.)
  3. State/DDTC Posts Several DTAG White Papers
  4. Hong Kong Publishes Overview of Officers Authorized to Sign on Strategic Commodities Licenses and Delivery Verification Certificates
  1. Expeditors News: “Canadian Government Publishes Process for Remission of Surtaxes on Goods from the U.S.”
  2. Reuters: “U.S. Gun Control Groups Seek to Block Distribution of 3-D Gun Blueprints”
  3. Xinhua: “China Never Steals Other Countries’ Technology Through Military-Civilian Integration: FM Spokesperson”
  1. D.M. Edelman: “Reminder – First Iran JCPOA Wind Down Period Deadline Approaching- FOREIGN COMPANIES Please Read This”
  2. Global Trade News: “Weise Wednesday: Is CBP Taking a Stronger Trade Enforcement Posture Than in the Past?”
  3. K.C. Georgi, R.K. Alberda & L. Hardaway: “OFAC Issues Helpful Guidance regarding North Korea Sanctions for Businesses with Supply Chains in Asia, Middle East, and Africa”
  4. M. Volkov: “Corporate Character and Lack of Corporate Will”
  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/BIS Seeks Comments on
Section 232 National Security Investigation of Imports of Uranium

(Source: Federal Register, 25 July 2018.) [Excerpts.]
 
83 FR 35204-35205: Notice of Request for Public Comments on Section 232 National Security Investigation of Imports of Uranium
* AGENCY: Bureau of Industry and Security, Office of Technology Evaluation, U.S. Department of Commerce.
* ACTION: Notice of request for public comments.
* SUMMARY: The Secretary of Commerce has initiated an investigation to determine the effects on the national security of imports of uranium. This investigation has been initiated under section 232 of the Trade Expansion Act of 1962, as amended.
  Interested parties are invited to submit written comments, data, analyses, or other information pertinent to the investigation to the Department of Commerce’s Bureau of Industry and Security. This notice identifies issues on which the Department is especially interested in obtaining the public’s views.
* DATES: Comments may be submitted at any time but must be received by
September 10, 2018. …
* FOR FURTHER INFORMATION CONTACT: Michael Vaccaro, Acting Director, Office of Technology Evaluation, Bureau of Industry and Security, U.S. Department of Commerce (202) 482-4060, Uranium232@bis.doc.gov. 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 Department is particularly interested in comments and information directed to the criteria listed in Sec. 705.4 of the regulations as they affect national security, including the following:
 
  (a) Quantity of or other circumstances related to the importation of uranium;
  (b) Domestic production and productive capacity needed for uranium to meet projected national defense requirements;
  (c) Existing and anticipated availability of human resources, products, raw materials, production equipment, and facilities to produce uranium;
  (d) Growth requirements of the uranium industry to meet national defense requirements and/or requirements to assure such growth;
  (e) The impact of foreign competition on the economic welfare of the uranium industry;
  (f) The displacement of any domestic uranium production causing substantial unemployment, decrease in the revenues of government, loss of investment or specialized skills and productive capacity, or other serious effects;
  (g) Relevant factors that are causing or will cause a weakening of our national economy; and
  (h) Any other relevant factors. …
 
  Dated: July 19, 2018.
Wilbur Ross, Secretary of Commerce.

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OGSOTHER GOVERNMENT SOURCES

OGS_a12. Items Scheduled for Publication in Future Federal Register Editions
(Source: Federal Register)

[No items of interest noted today.]

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(Source:
State/DDTC, 25 July 2018.)
The Defense Trade Advisory Group (DTAG), a civilian group that advises the State Department’s Directorate of Defense Trade Controls (DDTC), submitted the below advisory papers to DDTC:
 

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(Source:
Hong Kong Trade and Industry Department, 24 Jul 2018.)
 
The Trade and Industry Department (TID) of Hong Kong has published an overview of officers authorized to sign on strategic commodities licenses and delivery verification certificates under import and export ordinance, cap 60 import and export (strategic commodities) regulations.
 
The overview is available
here.

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NWSNEWS

(Source:
Expeditors News, 24 Jul 2018.)
 
On July 11, 2018, the Canadian Department of Finance published the process for requesting remission or refunds of surtaxes on products of U.S. origin.
 
The Canadian Government will take into account the following circumstances when considering a request for remission:
 
  – Situations of short supply in the domestic market, either on a national or regional basis;
  – Contractual requirements for Canadian businesses to use U.S. steel or aluminum that exist prior to May 31, 2018;
  – Other exceptional circumstances that could have severe adverse impacts on the Canadian economy.
 
Only companies registered in Canada are eligible to request remission of surtaxes and must submit information outlined in a template for submissions with the request.
 
The Government of Canada requests that importers submit any inquires or remission requests to
fin.remissions-remises.fin@canada.ca. The Canadian Department of Finance’s notice, along with the template for submissions, may be found
here.

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(Source:
Reuters, 25 July 2018.)
 
Three gun control advocacy groups are banding together to try to block the Trump administration from allowing Americans to access blueprints for 3-D printable guns on the internet.
 
In a July 24 letter to a federal judge in Texas seen by Reuters, the groups said they would seek an injunction to block a company called Defense Distributed from publishing schematic designs for the guns online.
 
Such postings on the internet have the potential to allow anyone, equipped with a readily accessible 3-D printer, to make their own firearm.
 
Tuesday’s letter was signed by the Brady Center to Prevent Gun Violence, Everytown for Gun Safety and the Giffords Law Center to Prevent Gun Violence.
 
At issue is a June settlement between Defense Distributed and the U.S. State Department that allows the company to legally publish gun blueprints online, something its website says it plans to do by Aug. 1.
 
The settlement could “enable terrorists, organized crime syndicates, felons [and] domestic abusers all to get quick, easy access to untraceable guns,” said Nick Suplina, managing director of law and policy for Everytown.
 
Neither the company nor its lawyer immediately replied to a request for comment.
 
Under the Obama administration, the State Department forced Defense Distributed’s founder, Cody Wilson, to remove online gun instructions posted earlier, arguing that they posed a national security risk and violated the International Traffic in Arms Regulations.
 
Wilson fought the State Department by filing a lawsuit in the U.S. District Court for the District of Western Texas in 2015, saying the government was violating free speech and the right to bear arms guaranteed in the U.S. Constitution.
 
Since then, the government has prevailed in court, winning at trial and later on appeal. As recently as April, President Donald Trump’s Justice Department was still asking the judge to dismiss Wilson’s lawsuit.
 
Critics say there has been no explanation for the June settlement and the administration’s abrupt reversal on the issue.
 
  “For some unknown reason, having won every step of the way the government did a 180,” said Brady Center co-president Avery Gardiner.
 
According to terms of the settlement posted online, in addition to letting the company publish its blueprints, the government agreed to pay Defense Distributed nearly $40,000.
 
A State Department spokesman said the settlement was voluntarily entered into by both parties.
 
Under proposed new rules, the State Department will relinquish regulatory oversight over exports of firearms and transfer that authority to the U.S. Commerce Department.

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(Source:
Xinhua, 20 Jul 2018.) [Excerpts.]
 
The [Chinese] Foreign Ministry on Thursday strongly refuted allegations that China stole other countries’ technology through military-civilian integration.
 
“The accusations of the U.S. official against China are totally unfounded and irresponsible, the Chinese side firmly opposes them,” Foreign Ministry spokesperson Hua Chunying told a daily press briefing.
 
Hua made the remarks when asked to comment on a recent speech given by Christopher Ford, the U.S. Assistant Secretary for International Security and Nonproliferation. Ford reportedly openly claimed in the speech that China intended to evade U.S. export control policies, legally or illegally acquire advanced U.S. technology through civil nuclear cooperation, and was dedicated to using military-civil fusion approach for military purposes and great-power competition. …
 
China has for years kept a high sense of responsibility and gradually built a perfect system for nonproliferation and export controls, under which, strict measures have been adopted to ensure that relevant regulations are implemented effectively. China has in this way made active efforts and great contribution to safeguarding the international system on nonproliferation and advancing international and regional peace and security. …

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COMMCOMMENTARY

COMM_a0
9. D.M. Edelman: “Reminder – First Iran JCPOA Wind Down Period Deadline Approaching- FOREIGN COMPANIES Please Read This”

(Source: Export Compliance Matters, 24 July 2018.)
        
* Author: Doreen M. Edelman, Esq., Baker Donelson LLP, 202-508-3460,
dedelman@bakerdonelson.com.
 
On May 8, 2018, President Donald Trump announced that the U.S. will withdraw from the Iran nuclear deal, formally known as the Joint Comprehensive Plan of Action (JCPOA), and reimpose the strict economic sanctions program that was in place prior to the landmark 2015 agreement.  Based on the guidance issued by the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”), the reimposed sanctions will impact businesses outside of the U.S. that engage in business with or in Iran, particularly those who do so while also seeking to maintain or establish a U.S. presence or dealings with U.S. companies. The “secondary sanctions” control who those foreign entities can do business with and restrict how foreign entities can utilize the U.S. financial system.  Foreign persons and businesses can also be held liable for causing U.S. persons to violate sanctions regulations.
 
Two “wind-down” deadline periods were issued by OFAC for U.S. and non-U.S. businesses to cease potentially sanctionable activity in or with Iran:
 
  (1) On August 7, 2018, sanctions will be reimposed on the following:
    – The direct or indirect sale, supply, or transfer to or from Iran of graphite, raw, or semi-finished metals such as aluminum and steel, coal, and software for integrating industrial processes;
    – Iran’s trade in gold or precious metals;
    – Significant transactions related to the purchase or sale of Iranian rials, or maintenance of significant funds or accounts outside the territory of Iran denominated in the Iranian rial; and
    – Activities in Iran’s automotive sector.
 
  (2) On November 4, 2018, sanctions will be reimposed on the following:
    – Iran’s port operators and shipping sectors, including on the Islamic Republic of Iran Shipping Lines, South Shipping Line Iran, and affiliates;
    – Petroleum-related transactions and petrochemical products;
    – Transactions by foreign financial institutions with the Central Bank of Iran & others; and
    – Activities in Iran’s energy sector.
 
In addition, OFAC is requiring activities conducted under General License H to be wound down by November 4, 2018.  If your company is conducting business in the above-listed, soon to be affected sectors, you risk being penalized under U.S. sanctions regulations if you do not cease all sanctionable activity.
 
If your business engages in or transacts with Iran after the respective wind-down periods, then something as simple as transacting in the U.S. dollar, maintaining U.S. bank accounts, or maintaining a U.S. presence could risk your access to the U.S. financial system and subject you to the sanctions.  There is a menu of 12 available sanctions that can be imposed on a foreign business that violates U.S. secondary sanctions regulations, from which the Secretary of State or the Treasury are required to select at least 5 to implement at their discretion:
 
  (1) Denial of Export-Import Bank loans, credits, or credit guarantees for U.S. exports to the sanctioned entity;
  (2) Denial of licenses for the U.S. export of military or militarily useful technology to the entity;
  (3) Denial of U.S. bank loans exceeding $10 million in one year to the entity;
  (4) If the entity is a financial institution, a prohibition on its service as a primary dealer in U.S. government bonds; and/or a prohibition on its serving as a repository for U.S. government funds (each counts as one sanction);
  (5) Prohibition on U.S. government procurement from the entity;
  (6) Prohibitions in transactions in foreign exchange by the entity;
  (7) Prohibition on any credit or payments between the entity and any U.S. financial institution;
  (8) Prohibition of the sanctioned entity from acquiring, holding, using, or trading any U.S.-based property which the sanctioned entity has a (financial) interest in;
  (9) Restriction on imports from the sanctioned entity, in accordance with the International Emergency Economic Powers Act;
  (10) A ban on a U.S. person from investing in or purchasing significant amounts of equity or debt instruments of a sanctioned person;
  (11) Exclusion from the United States of corporate officers or controlling shareholders of a sanctioned firm; and/or
  (12) Imposition of any of the ISA sanctions on principal offices of a sanctioned firm.

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COMM_a01
10. Global Trade News: “Weise Wednesday: Is CBP Taking a Stronger Trade Enforcement Posture Than in the Past?”

(Source: Integration Point Blog, 25 July 2018.)
 
Welcome to Weise Wednesday! Twice a month we will share a brief Q&A with the former U.S. Commissioner of Customs, Mr. George Weise. If you have questions, we encourage you to send them to
AskGeorge@IntegrationPoint.com.
 
Q. Do you agree that CBP seems to be taking a stronger trade enforcement posture than it has in the past?
 
A. Yes, I do. Much of this has resulted from strong Congressional pressure on CBP to enhance its trade enforcement performance. The congressional pressure culminated in the enactment of the Trade Facilitation and Trade Enforcement Act (TFTEA) of 2015. Included within TFTEA was the Enforce and Protect Act (EAPA), which provided broader authority for CBP to investigate allegations of dumping or countervailing duty evasion.
 
The overall goal of TFTEA is to protect U.S. economic security through more stringent enforcement of anti-dumping and countervailing duty orders, intellectual property rights, and other provisions protecting U.S. economic interests. CBP Commissioner McAleenan has stated that effectively implementing the provisions of TFTEA is a top priority. CBP’s strategic plan implementing the law mandates increasing the number of exams and audits, the use of predictive analytics to identify audit targets, and leveraging whistleblowers and intelligence and industry sources to enhance its enforcement efforts.
 
CBP has implemented electronic filing for EAPA anti-dumping and countervailing duty allegations through its revised e-Allegations portal. CBP has also created a Trade Enforcement Task Force, which works closely with partner government agencies (PGAs) to enhance enforcement of laws protecting intellectual property rights and the prohibition of goods made with forced labor.
 
Recent data corroborates that CBP’s enhanced enforcement efforts are real. In the last two years, seizures for trade violations have increased by 31%, as have the number of trade audits. Fines and penalties for commercial violations have increased by nearly 68% in the past year.
 
What increased enforcement means for you
 
All of this, coupled with the trend of increasing tariffs and trade retaliation, has made the work of trade compliance professionals extremely challenging. Today, more than ever, it is essential for companies to maintain a formal compliance program with best-in-class processes. You must exercise “reasonable care” in everything you do. It’s also important to have an internal training program that reaches all of the key players in the organization and a stringent internal audit program. Finally, global trade management software is essential to cope with this challenging trade environment and drive compliance, security, and efficiency.
 
Recommended reading
 
Several of these topics have been featured in previous
Weise Wednesday blogposts, linked below.
 

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COMM_a3
11. K.C. Georgi, R.K. Alberda & L. Hardaway: “OFAC Issues Helpful Guidance regarding North Korea Sanctions for Businesses with Supply Chains in Asia, Middle East, and Africa”

(Source: Arent Fox LLP, 24 Jul 2018.)
 
* Authors: Kay C. Georgi, Esq.,
kaygeorgi@arentfox.com; Regan K. Alberda, Esq.,
regan.alberda@arentfox.com; and Lamine Hardaway, Associate. All of Arent Fox LLP, Washington DC.
 
Most US and multi-national corporations are quick to say, “we don’t do business with North Korea.” However, some companies will recognize the risk of sourcing products from businesses located outside North Korea that may use North Korean overseas workers or subcontract to North Korean companies. They worry about just how to reduce this risk.
 
On July 23, 2018, OFAC issued a useful
Guidance document that provides businesses a helping hand. It:
 
  (1) Clarifies that the US is not seeking to disrupt the efforts of North Korean refugees and asylum seekers and says that if North Koreans gain another citizenship they are no longer considered North Korean for purposes of US sanctions, in particular, Title III, the Korean Interdiction and Modernization of Sanctions Act of the Countering America’s Adversaries through Sanctions Act;
  (2) Provides a list of industries and countries in which North Korean laborers working on behalf of the North Korean Government were present in 2017-18 (at page 3). While the list of countries is long, it at least narrows somewhat the supply chain sourcing concerns to certain parts of Asia, Africa, and the Middle East;
  (3) Provides in Annex 3 a sectoral breakdown of where North Korean laborers are working on behalf of the North Korean Government overseas by sector. While Annex 3 states that it is NOT a comprehensive list of all countries, jurisdictions and industries, it is helpful in highlighting some higher risk jurisdictions by sector. For example, the Information Technology sector is warned about Angola, Bangladesh, China, Laos, Nigeria, Uganda, and Vietnam; and
  (4) Provides in Annex 2 a list of joint ventures that have operated or are currently operating in North Korea established prior to 2016, organized by industry sector. Again, this is not a comprehensive list, nor is it an SDN or blocked parties list, but it is a list that companies evaluating suppliers in Asia and China in particular may wish to check as they evaluate potential suppliers.

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COMM_a4
12. M. Volkov: “Corporate Character and Lack of Corporate Will”

(Source: Volkov Law Group Blog, 24 July 2018. Reprinted by permission.)
 
* Author: Michael Volkov, Esq., Volkov Law Group,
mvolkov@volkovlaw.com, 240-505-1992.
 
The right way is not always the popular and easy way. Standing for right when it is unpopular is a true test of moral character.
  — Margaret Chase Smith
 
Corporations experience numerous tests of character.  Perhaps one of the most important is how the company responds when facing potential misconduct.  Too often we read enforcement action factual statements where companies veer off the track and ignore indications of wrongdoing.  This is when a corporation’s will is tested.  It is the difference between a positive and a negative ethical culture.
 
It is easy to boil all of this down to “doing the right thing.”  A simple phrase with powerful implications – companies face important choices all the time, just like each individual whose behaviors together are reflected in corporate conduct.
 
Let’s consider one recent example where the lack of corporate will was evident.
 
Beam Suntory paid $8 million to settle with the SEC FCPA violations in India.  In calculating the appropriate penalty, the SEC declined to credit Beam for remediation of its compliance program.  In the settlement order, the SEC outlined in detail how Beam failed to respond to potential bribery conduct despite numerous early warning signs of such conduct.  Beam’s failure to act exemplified its lack of courage or its lack of corporate will.
 
Beam’s bribery conduct in India occurred during the period 2006 to 2012.
 
In 2010, Beam engaged a global accounting firm to conduct a compliance review of Beam India. In early 2011, the accounting firm reported that Beam India executives believed that third-party promoters were making bribery payments to government officials and recommended that Beam conduct and document due diligence to confirm activities by third parties, investigate red flags and discuss legal consideration of third party actions taken on Beam’s behalf. After receiving this report, Beam consulted a U.S. law firm, which advised Beam to follow up on these issues.
 
Beam then retained an Indian law firm to review and expand the work conducted by the accounting firm. The Indian law firm interviewed Beam senior managers who believed that third parties in India may make payments and provide gifts to customs officials. In the end, the Indian law firm confirmed many of the accounting firm recommendations.
 
Beam then requested its U.S. law firm to review and report on the work done by the Indian law firm. In August 2011, the U.S. law firm reviewed the Indian law firm’s report and noted that the Indian law firm did not review Beam’s books and records, internal controls or other issues related to accounting practices. In sum, the U.S. law firm confirmed the advice given by the global accounting firm, and the Indian law firm, and proposed additional steps including a financial review, and hiring of a forensic auditor. Beam did not follow any of the recommendations.
 
In September 2011, the Indian law firm recommended that Beam interview operational employees involved in high risk transactions with third party promoters. Beam again declined to do so.
 
In November 2011, a former Beam India employee alleged a scheme through which a manager was using false invoices to generate cash. A review completed in March 2012 concluded that the manager was using the funds to pay bribes over a two-year period for approval of label registrations. Despite reaching this conclusion, Beam did not expand its review to examine other third-party practices.
 
In July 2012, a former Beam accountant raised similar compliance issues that eventually resulted in the uncovering the full range of conduct that was the subject of the enforcement action.
 
Beam’s course of conduct over nearly two years revealed its unwillingness to investigate and uncover misconduct – no wonder that Beam eventually settled for $8 million. Beam failed the true test of corporate character.

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ENEDITOR’S NOTES

* Arthur Balfour (Arthur James Balfour, 1st Earl of Balfour; 25 Jul 1848 – 19 Mar 1930; was a British statesman of the Conservative Party who served as Prime Minister of the United Kingdom from 1902 to 1905.)
  – “He has only half learned the art of reading who has not added to it the more refined art of skipping and skimming.”
  – “I never forgive, but I always forget.”

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EN_a314
. 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.  

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EN_a0315
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

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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.


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