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18-0813 Monday “Daily Bugle”

18-0813 Monday “Daily Bugle”

Monday, 13 August 2018

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  1. Commerce/BIS Seeks Comments on Controls on Certain Spraying or Fogging Systems and “Parts” and “Components” Therefor 
  2. President Continues National Emergency with Respect to Export Control Regulations 
  1. Items Scheduled for Publication in Future Federal Register Editions
  2. Commerce/BIS: Mohawk Global Logistics Corp. of North Syracuse, NY, to Pay $155,000 to Settle Alleged Export Violations
  3. DHS/CBP Announces Additional Duty on Imports of Steel Articles from Turkey
  4. State/DDTC: (No new postings.)
  5. President Adjusts Imports of Steel into the U.S. from Turkey
  6. Australia DoD/DEC Announces Outreach Programs
  7. EU Amends Restrictive Measures Concerning South Sudan, Myanmar, and Iraq
  1. Expeditors News: “China Announces Decision to Impose Additional Tariffs on Goods of U.S. Origin”
  2. The Maritime-Executive: “Three Firms Accused of Violating Sanctions on N. Korea”
  1. K.J. Wolf: “The CFIUS Reform Legislation-FIRRMA-Will Become Law on 13 Aug 2018 [Part 1 of 2]”
  2. L. Luo: “How to Remove a Company from the EAR Controlled Entity List”
  3. M. Volkov: “Episode 51 – Interview of Dr. Pat Harned, CEO of the Ethics and Compliance Initiative”
  1. Monday List of Ex/Im Job Openings: 177 Jobs Posted This Week, Including 7 New Jobs
  1. ECS Presents “ITAR/EAR Symposium & Boot Camp” in Annapolis, MD on 11-13 Sep
  2. ECTI Presents “US Antiboycott Regulations: Clarified & Demystified” Webinar, 26 Sep
  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 Aug 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 Controls on Certain Spraying or Fogging Systems and “Parts” and “Components” Therefor
(Source: Federal Register, 13 Aug 2018.) [Excerpts.]
 
83 FR 39921-39923: Commerce Control List: Request for Comments Regarding Controls on Certain Spraying or Fogging Systems and “Parts” and “Components” Therefor
* AGENCY: Bureau of Industry and Security, Commerce.
* ACTION: Notice of inquiry.
* SUMMARY: The Bureau of Industry and Security (BIS), Department of Commerce, maintains the Export Administration Regulations, including the Commerce Control List (CCL). Certain items identified on the CCL are controlled for chemical/biological (CB) reasons, because they are identified on one of the common control lists maintained by the Australia Group (AG), which is a multilateral forum of countries (plus the European Union) that maintain export controls on specified chemicals, biological agents, and related equipment and technology that could be used in a chemical or biological weapons (CBW) program. Among the items subject to these CB controls are spraying or fogging systems described in Export Control Classification Number (ECCN) 2B352.i on the CCL. Through this notice, BIS is seeking public comments as part of a review of the effectiveness of its controls on these systems, and “parts” and “components” therefor, to ensure that the descriptions of these items on the CCL are clear, do not inadvertently control items in normal commercial use, accurately reflect CB-related technological capabilities and developments, and are consistent with the principal objective of the AG, which is to ensure that exports of certain chemicals, biological agents, and dual-use chemical and biological manufacturing facilities and equipment, do not contribute to the spread of chemical and biological weapons (CBW). This notice also requests public comments on potential alternatives to the current controls in ECCN 2B352.i.
* DATES: Comments must be received by BIS no later than October 12, 2018.
* ADDRESSES: Comments may be submitted via the Federal eRulemaking Portal. You can find this notice by searching on its regulations.gov docket number, which is BIS-2018-0013. Comments may also be submitted via email to publiccommments@bis.doc.gov or on paper to Regulatory Policy Division, Bureau of Industry and Security, U.S. Department of Commerce, Room 2099B, 14th Street and Pennsylvania Avenue NW, Washington, DC 20230. Please refer to RIN 0694-XC042 in all comments and in the subject line of email comments. All comments (including any personally identifying information) will be made available for public inspection and copying.
* FOR FURTHER INFORMATION CONTACT: For questions on the CB controls that apply to spraying or fogging systems described in ECCN 2B352.i, contact Richard P. Duncan, Ph.D., Director, Chemical and Biological Controls Division, Office of Nonproliferation and Treaty Compliance, Bureau of Industry and Security, Telephone: (202) 482-3343, Email: Richard.Duncan@bis.doc.gov. For questions on the submission of comments in response to this notice of inquiry, contact Willard Fisher, Regulatory Policy Division, Office of Exporter Services, Bureau of Industry and Security, U.S. Department of Commerce, Phone: (202) 482-2440.
* SUPPLEMENTARY INFORMATION:
  Currently, ECCN 2B352.i controls complete spraying or fogging systems, spray booms, and arrays of aerosol generating units that are: (1) “specially designed” or modified for fitting to aircraft, “lighter than air vehicles,” or “unmanned aerial vehicles” (“UAVs”); and (2) capable of delivering, from a liquid suspension, an initial droplet volume median diameter (`VMD’) of less than 50 microns at a flow rate of greater than 2 liters per minute. This ECCN also controls aerosol generating units that are “specially designed” for fitting to the aforementioned equipment. …
 
Proposed Alternatives to the Current Controls in ECCN 2B352.i
 
  As part of its review of the ECCN 2B352.i controls on spraying or fogging systems, and “parts” and “components” therefor, BIS is considering expanding the scope of these controls to include: (1) Systems for the dissemination of chemicals controlled by ECCN 1C350 or 1C355 (currently, CB controls apply only to systems for the dissemination of biological agents controlled by ECCN 1C351); and (2) ground-based systems (currently, CB controls apply only to airborne systems). These changes are being considered because potential chemical/biological warfare (CBW) threats are likely to include the dissemination of chemical agents, as well as the dissemination of biological agents, and may well involve ground-based methods of dissemination, as well as airborne means of dissemination.
  Consequently, BIS is considering one or more of the following options with respect to the EAR controls on spraying or fogging systems, and “parts” and “components” therefor.
    (1) Removing the criterion in ECCN 2B352.i that currently limits CB controls to those systems that are “specially designed” or modified for fitting to “aircraft,” “lighter than air vehicles,” or “UAVs.” The rationale for this change is that the ability of such systems to produce an aerosol is not determined by whether the systems are ground-based or airborne.
    (2) Removing the criterion in ECCN 2B352.i based on initial droplet size (i.e., an initial droplet `VMD’ of less than 50 microns). The rationale for this change is that initial droplet size is not necessarily a feature that is measured (or otherwise addressed) by all manufacturers of these systems. In addition, the initial droplet size currently indicated in ECCN 2B352.i is based solely on the airborne dissemination of biological agents (i.e., those controlled by ECCN 1C351) and would not necessarily apply to systems for the airborne dissemination of chemicals (i.e., those controlled by ECCN 1C350 or 1C355) or the ground-based dissemination of such chemicals or biological agents.
    (3) Lowering the flow rate at which spraying or fogging systems are controlled under ECCN 2B352.i. Currently, ECCN 2B352.i specifies a flow rate of “greater than 2 liters per minute.” However, BIS acknowledges that this change would involve determining a lower flow rate that would not catch typical commercial systems (e.g., systems designed for agricultural use), except when deemed necessary to ensure the continued effectiveness of CB controls on spraying or fogging systems.
    (4) Developing a control that would apply to spraying or fogging systems “specially designed” for the dissemination or dispersion of chemicals controlled by ECCN 1C350 or 1C355 or biological agents controlled by ECCN 1C351 in a manner likely to cause significant harm to humans or livestock or serious damage to crops.
  With respect to option #4 described above, note that paragraph (a)(1) of the definition of “specially designed” in Section 772.1 of the EAR states that an item is “specially designed” if, as a result of “development,” it “has properties peculiarly responsible for achieving or exceeding the performance levels, characteristics, or functions in the relevant ECCN or U.S. Munitions List (USML) paragraph.” Therefore, if the term “specially designed” were used in the control text for spraying or fogging systems in ECCN 2B352.i, the only systems that would be captured by these controls would be those that are peculiarly responsible for achieving the dissemination or dispersion of chemicals controlled by ECCN 1C350 or 1C355 or biological agents controlled by ECCN 1C351 in a manner likely to cause significant harm to humans or livestock or serious damage to crops (i.e., properties that would distinguish these systems from typical commercial systems, such as those designed for agricultural applications). Consequently, under option #4, the controls in ECCN 2B352.i would not apply to spraying or fogging systems designed for commercial use that have performance levels, characteristics, or functions that are capable of, but not peculiarly responsible for, achieving the dissemination or dispersion of chemicals controlled by ECCN 1C350 or 1C355 or biological agents controlled by ECCN 1C351 in the manner described above. …
 
   Dated: August 6, 2018.
Richard E. Ashooh, Assistant Secretary for Export Administration.

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EXIM_a2

2. President Continues National Emergency with Respect to Export Control Regulations
(Source: Federal Register, 13 Aug 2018.)
 
83 FR 39871: Continuation of the National Emergency with Respect to Export Control Regulations
 
On August 17, 2001, the President issued Executive Order 13222 pursuant to the International Emergency Economic Powers Act (50 U.S.C. 1701 et seq.). In that order, the President declared a national emergency with respect to the unusual and extraordinary threat to the national security, foreign policy, and economy of the United States related to the expiration of the Export Administration Act of 1979, as amended (50 U.S.C. 4601 et seq.). Because the Congress has not renewed the Export Administration Act, the national emergency declared on August 17, 2001, must continue in effect beyond August 17, 2018. Therefore, in accordance with section 202(d) of the National Emergencies Act (50 U.S.C. 1622 (d)), I am continuing for 1 year the national emergency declared in Executive Order 13222, as amended by Executive Order 13637 of March 8, 2013.
 
(Presidential Sig.)
THE WHITE HOUSE,
August 8, 2018.

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OGSOTHER GOVERNMENT SOURCES

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

* Trade Representative, Office of United States; NOTICES; Public Hearings: Russia’s Implementation of its WTO Commitments [Publication Date: 14 August 2018.]
 
* U.S. Customs and Border Protection; NOTICES; Agency Information Collection Activities; Proposals, Submissions, and Approvals: Certificate of Origin [Publication Date: 14 August 2018.]

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

(Source:
Commerce/BIS, 10 Aug 2018.) [Excerpts.]
 
* Respondent: Mohawk Global Logistics Corp., formerly known as Mohawk Customs and Shipping Corp. of North Syracuse, New York
* Charges: Three alleged violations of the EAR, namely:
  – One charge of 15 C.F.R. 764.2(b) – Causing, Aiding, or Abetting a Violation: On or about 16 August 2012, Mohawk caused, aided, and/or abetted a violation of the EAR, namely, the export of an LNP-20 Liquid Nitrogen Plant, an item subject to the EAR, designated as EAR99, and valued at $33,587. Mohawk forwarded the item for export from the United States to the All-Russian Scientific Research Institute of Experimental Physics (“VNIIEF”) in Sarov, Russia. VNIIEF was at all relevant times listed on the Entity List, Supplement No.4 to Part 744 of the EAR. A BIS license was at all relevant times required to export any item subject to the EAR to VNIIEF.
  – Two charges of 15 C.F.R. 764.2(b) – Causing, Aiding, or Abetting a Violation: On two separate occasions, on or about 12 February 2014, and or about 12 August 2015, Mohawk caused, aided and/or abetted a violation of the EAR, namely the export of Real-Time Back Reflection Laue Camera Detectors and Accessories, items subject to the EAR, designated EAR99, and valued at $177,156, to the University of Electronic Science and Technology of China (“UESTC”) in Chengdu, People’s Republic of China, without the required BIS license. At all relevant times UESTC was listed on the Entity List, and a BIS license was required to export any item subject to the EAR to that entity.
* Penalty: Civil penalty of $155,000 of which $20,000 shall be suspended and eventually waived provided that Mohawk has not violated its Settlement Agreement, this Order, or otherwise violated the EAR, and the rest of the civil penalty has been paid as agreed.
* Debarred: Not if penalty is paid as agreed.
* Date of Order: 10 August 2018.
* * * * * * * * * * * * * * * * * * * *

(Source:
CSMS #18-000477, 12 Aug 2018.)
 
UPDATE: Additional Duty on Imports of Steel Articles under Section 232 of the Trade Expansion Act of 1962; Steel Articles from the Republic of Turkey
 
BACKGROUND:
 
On March 8, 2018, the President issued Proclamations 9704 and 9705 on Adjusting Imports of Steel and Aluminum into the United States, under Section 232 of the Trade Expansion Act of 1962, as amended (19 U.S.C. 1862), providing for additional import duties for steel mill and aluminum articles, effective March 23, 2018. See the Federal Register, 83 FR 11619 and 83 FR 11625 (March 15, 2018).
 
On March 22, April 30, and May 31, 2018, the President issued Proclamations 9710, 9711, 9739, 9740, 9758, and 9759 on Adjusting Imports of Steel and Aluminum into the United States. See the Federal Register, 83 FR 13355 and 83 FR 13361 (March 28, 2018); 83 FR 20683 and 83 FR 20677 (May 7, 2018); and 83 FR 25849 and 83 FR 25857 (June 5, 2018). On August 10, 2018, the President issued a new proclamation on Adjusting Imports of Steel into the United States.
 
GUIDANCE:
 
STEEL ARTICLES FROM THE REPUBLIC OF TURKEY
 
Per the August 10, 2018 Presidential Proclamation, steel articles covered by the Section 232 remedy that are the product of the Republic of Turkey (Turkey) will be subject to an increased ad valorem duty rate.
 
Steel articles will be subject to an ad valorem duty rate of 50%.
 
The increased rates of duty on steel articles that are the product of Turkey are effective with respect to goods entered, or withdrawn from warehouse for consumption, on or after 12:01 a.m. eastern daylight time on August 13, 2018.
 
FILING INSTRUCTIONS:
 
Steel Products from Turkey
 
In addition to reporting the regular Chapters 72 & 73 of the Harmonized Tariff Schedule of the United States (HTSUS) classification for the imported merchandise, importers shall report the following HTSUS classification for imported merchandise subject to the additional duty:
 
  – 9903.80.02 (50% ad valorem duty rate for products of iron and steel that are the product of Turkey)
 
FOR FURTHER INFORMATION:
 
For more information, please refer to the Presidential Proclamations on Adjusting Imports of Steel and Aluminum into the United States, Federal Register, 83 FR 11619 and 83 FR 11625 (March 15, 2018); 83 FR 13355 and 83 FR 13361 (March 28, 2018); 83 FR 20683 and 83 FR 20677 (May 7, 2018); 83 FR 25849 and 83 FR 25857 (June 5, 2018); and the August 10, 2018 Proclamations on Adjusting Imports of Steel into the United States.
 
Also see Frequently Asked Questions
here.
 
Questions related to Section 232 entry filing requirements should be emailed to
traderemedy@cbp.dhs.gov. Questions from the importing community concerning ACE rejections should be referred to their Client Representative.
 
 – Related CSMS No. 18-000424, 18-000412, 18-000378

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

(Source:
The White House, 10 Aug 2018.)
 
On January 11, 2018, the Secretary of Commerce (Secretary) transmitted to me a report on his investigation into the effect of imports of steel articles on the national security of the United States under section 232 of the Trade Expansion Act of 1962, as amended (19 U.S.C. 1862). The Secretary found and advised me of his opinion that steel articles are being imported into the United States in such quantities and under such circumstances as to threaten to impair the national security of the United States.
 
In Proclamation 9705 of March 8, 2018 (Adjusting Imports of Steel Into the United States), I concurred in the Secretary’s finding that steel articles, as defined in clause 1 of Proclamation 9705, as amended by clause 8 of Proclamation 9711 of March 22, 2018 (Adjusting Imports of Steel Into the United States), are being imported into the United States in such quantities and under such circumstances as to threaten to impair the national security of the United States, and decided to adjust the imports of these steel articles by imposing a 25 percent ad valorem tariff on such articles imported from most countries.
 
In Proclamation 9705, I also directed the Secretary to monitor imports of steel articles and inform me of any circumstances that in the Secretary’s opinion might indicate the need for further action under section 232 with respect to such imports.
 
The Secretary has informed me that while capacity utilization in the domestic steel industry has improved, it is still below the target capacity utilization level the Secretary recommended in his report. Although imports of steel articles have declined since the imposition of the tariff, I am advised that they are still several percentage points greater than the level of imports that would allow domestic capacity utilization to reach the target level.
 
In light of the fact that imports have not declined as much as anticipated and capacity utilization has not increased to that target level, I have concluded that it is necessary and appropriate in light of our national security interests to adjust the tariff imposed by previous proclamations.
 
In the Secretary’s January 2018 report, the Secretary recommended that I consider applying a higher tariff to a list of specific countries should I determine that all countries should not be subject to the same tariff. One of the countries on that list was the Republic of Turkey (Turkey). As the Secretary explained in that report, Turkey is among the major exporters of steel to the United States for domestic consumption. To further reduce imports of steel articles and increase domestic capacity utilization, I have determined that it is necessary and appropriate to impose a 50 percent ad valorem tariff on steel articles imported from Turkey, beginning on August 13, 2018. The Secretary has advised me that this adjustment will be a significant step toward ensuring the viability of the domestic steel industry.
 
Section 232 of the Trade Expansion Act of 1962, as amended, authorizes the President to adjust the imports of an article and its derivatives that are being imported into the United States in such quantities or under such circumstances as to threaten to impair the national security.
 
Section 604 of the Trade Act of 1974, as amended (19 U.S.C. 2483), authorizes the President to embody in the Harmonized Tariff Schedule of the United States (HTSUS) the substance of statutes affecting import treatment, and actions thereunder, including the removal, modification, continuance, or imposition of any rate of duty or other import restriction.
 
Now, Therefore, I, Donald J. Trump, President of the United States of America, by the authority vested in me by the Constitution and the laws of the United States of America, including section 232 of the Trade Expansion Act of 1962, as amended, section 301 of title 3, United States Code, and section 604 of the Trade Act of 1974, as amended, do hereby proclaim as follows:
 
  (1) In order to establish increases in the duty rate on imports of steel articles from Turkey, subchapter III of chapter 99 of the HTSUS is modified as provided in the Annex to this proclamation. Clause 2 of Proclamation 9705, as amended by clause 1 of Proclamation 9740 of April 30, 2018 (Adjusting Imports of Steel Into the United States), is further amended by striking the last two sentences and inserting in lieu thereof the following three sentences: “Except as otherwise provided in this proclamation, or in notices published pursuant to clause 3 of this proclamation, all steel articles imports specified in the Annex shall be subject to an additional 25 percent ad valorem rate of duty with respect to goods entered for consumption, or withdrawn from warehouse for consumption, as follows: (a) on or after 12:01 a.m. eastern daylight time on March 23, 2018, from all countries except Argentina, Australia, Brazil, Canada, Mexico, South Korea, and the member countries of the European Union; (b) on or after 12:01 a.m. eastern daylight time on June 1, 2018, from all countries except Argentina, Australia, Brazil, and South Korea; and (c) on or after 12:01 a.m. eastern daylight time on August 13, 2018, from all countries except Argentina, Australia, Brazil, South Korea, and Turkey. Further, except as otherwise provided in notices published pursuant to clause 3 of this proclamation, all steel articles imports from Turkey specified in the Annex shall be subject to a 50 percent ad valorem rate of duty with respect to goods entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. eastern daylight time on August 13, 2018. These rates of duty, which are in addition to any other duties, fees, exactions, and charges applicable to such imported steel articles, shall apply to imports of steel articles from each country as specified in the preceding two sentences.”.
 
  (2) The text of U.S. note 16(a)(i) to subchapter III of chapter 99 of the HTSUS is amended by deleting “Heading 9903.80.01 provides” and inserting the following in lieu thereof: “Except as provided in U.S. note 16(a)(ii), which applies to products of Turkey that are provided for in heading 9903.80.02, heading 9903.80.01 provides”.
 
  (3) U.S. note 16(a)(ii) to subchapter III of chapter 99 of the HTSUS is re-designated as U.S. note 16(a)(iii) to subchapter III of chapter 99 of the HTSUS.
 
  (4) The following new U.S. note 16(a)(ii) to subchapter III of chapter 99 of the HTSUS is inserted in numerical order: “(ii) Heading 9903.80.02 provides the ordinary customs duty treatment of iron or steel products of Turkey, pursuant to the article description of such heading. For any such products that are eligible for special tariff treatment under any of the free trade agreements or preference programs listed in general note 3(c)(i) to the tariff schedule, the duty provided in this heading shall be collected in addition to any special rate of duty otherwise applicable under the appropriate tariff subheading, except where prohibited by law. Goods for which entry is claimed under a provision of chapter 98 and which are subject to the additional duties prescribed herein shall be eligible for and subject to the terms of such provision and applicable U.S. Customs and Border Protection (“CBP”) regulations, except that duties under subheading 9802.00.60 shall be assessed based upon the full value of the imported article. No claim for entry or for any duty exemption or reduction shall be allowed for the iron or steel products enumerated in subdivision (b) of this note under a provision of chapter 99 that may set forth a lower rate of duty or provide duty-free treatment, taking into account information supplied by CBP, but any additional duty prescribed in any provision of this subchapter or subchapter IV of chapter 99 shall be imposed in addition to the duty in heading 9903.80.02.”.
 
  (5) Paragraphs (b), (c), and (d) of U.S. note 16 to subchapter III of chapter 99 of the HTSUS are each amended by replacing “heading 9903.80.01” with “headings 9903.80.01 and 9903.80.02”.
 
  (6) The “Article description” for heading 9903.80.01 of the HTSUS is amended by replacing “of Brazil” with “of Brazil, of Turkey”.
 
  (7) The modifications to the HTSUS made by clauses 2 through 6 of this proclamation and the Annex to this proclamation shall be effective with respect to goods entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. eastern daylight time on August 13, 2018, and shall continue in effect, unless such actions are expressly reduced, modified, or terminated.
 
  (8) The Secretary, in consultation with U.S. Customs and Border Protection of the Department of Homeland Security and other relevant executive departments and agencies, shall revise the HTSUS so that it conforms to the amendments directed by this proclamation. The Secretary shall publish any such modification to the HTSUS in the Federal Register.
 
  (9) Any provision of previous proclamations and Executive Orders that is inconsistent with the actions taken in this proclamation is superseded to the extent of such inconsistency.
 
IN WITNESS WHEREOF, I have hereunto set my hand this tenth day of August, in the year of our Lord two thousand eighteen, and of the Independence of the United States of America the two hundred and forty-third.
 
DONALD J. TRUMP

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(Source:
Australia DoD/DEC, 10 Aug 2018.) [Excerpts.]
 
Defence Export Controls (DEC), within the Department of Defence is commencing another year of outreach programs.

Our next outreach event for 2018 will be held in Melbourne on Wednesday, 12 September 2018, at the University of Melbourne. Please visit our Eventbrite page for location details.

Events will also be held in Adelaide and Sydney.

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

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

  – Export control regulations,
  – Export controls specific to defence industry or academic and research organisations, and
  – The whole-of-government approach to Australia’s export landscape.
 
You can attend an outreach event in:
  – Melbourne 12 September 2018,
book now
  – Adelaide 23 October 2018, registration will open 1 October 2018
  – Sydney 20 November 2018, registration will open 15 October 2018 …
 

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OGS_a79. EU Amends Restrictive Measures Concerning South Sudan, Myanmar, and Iraq
(Source:
Official Journal of the European Union, 13 Aug 2018.)
 
Regulations:
* Council Implementing Regulation (EU) 2018/1115 of 10 August 2018 implementing Article 20(1) of Regulation (EU) 2015/735 concerning restrictive measures in respect of the situation in South Sudan
* Council Regulation (EU) 2018/1116 of 10 August 2018 amending Regulation (EU) 2015/735 concerning restrictive measures in respect of the situation in South Sudan
* Council Implementing Regulation (EU) 2018/1117 of 10 August 2018 implementing Regulation (EU) No 401/2013 concerning restrictive measures in respect of Myanmar/Burma
* Commission Implementing Regulation (EU) 2018/1124 of 10 August 2018 amending Council Regulation (EC) No 1210/2003 concerning certain specific restrictions on economic and financial relations with Iraq
 
Decisions:
* Council Decision (CFSP) 2018/1125 of 10 August 2018 amending Decision (CFSP) 2015/740 concerning restrictive measures in view of the situation in South Sudan
* Council Decision (CFSP) 2018/1126
of 10 August 2018 amending Decision 2013/184/CFSP concerning restrictive measures against Myanmar/Burma
 

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NWSNEWS

(Source:
Expeditors News, 10 Aug 2018.)
 
On August 3, 2018, the Chinese Ministry of Finance announced additional tariffs on goods of U.S. origin worth approximately $60 Billion in US dollars. 
 
The tariff increases range from 5% to 25% on 5,207 items in four separate annexes:
  – Annex 1 consists of 2493 HS Headings with an additional 25% tariff;
  – Annex 2 consists of 1078 HS Headings with an additional 20% tariff;
  – Annex 3 consists of 974 HS Headings with an additional 10% tariff;
  – Annex 4 consists of 662 HS Headings with an additional 5% tariff.
 
The implementation date will be announced separately.
 
The original Chinese announcement may be found here.
 
The annexes may be found here:
  – Annex 1;
  – Annex 2;
  – Annex 3; and
  – Annex 4.
 
Google translated versions of the announcement and annexes may be found here:
  – Announcement;
  – Annex 1;
  – Annex 2;
  – Annex 3; and
  – Annex 4.

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The Korea Customs Service has accused three South Korean firms of importing nearly $6 million worth of banned North Korean commodities from April to October 2017.
 
KCS alleges that the firms imported 35,000 tons of pig iron and coal from the DPRK in seven separate voyages, using Russian port transshipments to disguise the cargo’s origins. As a form of payment in kind, KCS charges, these unnamed companies helped North Korea to export its goods to other nations. If accurate, these transactions could be in violation of U.N. Security Council sanctions on Pyongyang’s nuclear program, and Korea plans to report four vessels involved in the shipments to the United Nations.
 
KCS said that all three firms accused already face charges for violating other Korean laws, and they did not reportedly cooperate with the investigation. Without their assistance, prosecutors may face some difficulty in proving any charges, as officials report that it is not easy to distinguish between coal from the DPRK and coal from Russia.
 
Multiple previous reports have suggested that North Korean commodities are making their way into South Korea, despite UN sanctions on the North’s exports. According to the UN Security Council’s panel on North Korea, the bulkers Sky Angel and Rich Glory offloaded mislabeled North Korean coal in Pohang and Incheon last October. Between them, the two vessels have called in South Korean ports at least three dozen times over the past year. Last month, the Korea Customs Service said that it was aware of numerous instances of banned shipments arriving in South Korea since August 2017.

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COMMCOMMENTARY

COMM_a0
12. K.J. Wolf: “The CFIUS Reform Legislation-FIRRMA-Will Become Law on 13 Aug 2018 [Part 1 of 2]”
(Source: Akin Gump Strauss Hauer & Feld LLP, 10 Aug 2018.)
 
* Author: Kevin J. Wolf, Esq., Akin Gump Strauss Hauer & Feld LLP,
kwolf@akingump.com, +1 202-887-4051.
 
[Editor’s Note: Due to its length this item is divided into two parts. The second part will be included in tomorrow’s Daily Bugle.]
 
Key Points
  – CFIUS will continue to have broad jurisdiction to conduct national security reviews of foreign investments that could result in foreign control of a U.S. business. When regulations implementing FIRRMA become effective within the next 18 months, CFIUS will have additional jurisdiction over (a) real estate transactions near sensitive government locations and ports, and (b) noncontrolling investments in U.S. businesses associated with critical technology, critical infrastructure or sensitive personal data. Certain covered transactions involving foreign government investors and, potentially, U.S. critical technology companies will trigger mandatory CFIUS filings.
  – To address concerns regarding the transfer of uncontrolled critical emerging and foundational technologies to foreign persons, FIRRMA requires an interagency process to identify and, after public notice and comment, control such technologies in the export control regulations. (This identification process has already begun.) Unlike the bill as introduced, FIRRMA does not expand CFIUS’s authority to review outbound investments to address this issue.
  – The timelines for CFIUS review of filings will be extended when the law goes in to effect. The Treasury Department is, however, required to publish regulations to create a quicker short-form “declaration”-“light filing”-process that could be used in place of full filings.
  • FIRRMA leaves many key details and definitions to the Treasury Department to address through implementing regulations. Those potentially affected by the new CFIUS authorities will likely want to monitor and eventually comment on them, particularly:
    • U.S. businesses that might receive noncontrolling foreign investments and that are involved in critical technology, critical infrastructure or sensitive personal data;
    • funds with foreign limited partners that might have access to such information or the ability to influence what is done with it; and
    • those involved, directly or indirectly, with covered investments by foreign governments and involving U.S. critical technology companies because of the mandatory filing requirements that will be created.
 
I. Introduction
 
On Monday, August 13, 2018, the President is expected to sign the John S. McCain National Defense Authorization Act for Fiscal Year 2019 (NDAA), which includes the Foreign Investment Risk Review Modernization Act of 2018 (FIRRMA) that reforms the Committee on Foreign Investment in the United States (CFIUS) process. Most of the changes affecting foreign investment in the United States will not become effective until implementing regulations are passed, which must occur within the next 18 months. The NDAA also contains the Export Control Reform Act of 2018 (ECRA), which, among other things, (a) establishes permanent statutory authority for the export control rules administered by the Department of Commerce and (b) requires the administration to identify and control emerging and foundational technologies essential to national security.
 
II. CFIUS
 
CFIUS is an interagency committee that conducts national security reviews of investments that could result in a foreign person’s gaining the ability to control a U.S. business-a “covered transaction.” CFIUS has the authority to initiate reviews of transactions, impose mitigation measures to address national security concerns, and recommend that the President block pending transactions or order divestitures of completed transactions. To mitigate against such risks, parties may file a voluntary notice with CFIUS seeking safe harbor clearance with respect to a notified transaction.
 
III. Reasons for Amending and Expanding the Authority of CFIUS
 
Sens. John Cornyn (R-TX) and Dianne Feinstein (D-CA), Rep. Robert Pittenger (R-NC) and many other co-sponsors introduced FIRRMA in November 2017 “to modernize and strengthen the process by which [CFIUS] reviews” foreign investments to address “gaps in the existing CFIUS review process” by which “potential adversaries . . . have been effectively degrading our country’s military technological edge by acquiring, and otherwise investing in, U.S. companies.” In particular, there was a concern that critical emerging and foundational technologies not subject to U.S. export controls were being transferred, intentionally or otherwise, to countries of concern, primarily China, as a result of foreign investments in the United States and foreign ventures abroad with U.S. companies. Those who introduced the legislation and the administration wanted more authority for the U.S. government to review and, if necessary, block or apply mitigation measures to such transactions to address emerging national security concerns.
 
Over the course of the subsequent eight months, multiple House and Senate committees held hearings [FN/1] to consider how best to address these issues. Members and staff engaged with industry representatives, former officials from previous Democratic and Republican administrations, subject-matter experts and the administration to develop what eventually became bills that passed the committees of jurisdiction and both houses with overwhelming bipartisan support.
 
Without specifically mentioning China, FIRRMA’s “sense of Congress” introduction echoes and refines the original policy objectives. Specifically, Congress stated that “it should continue to be the policy of the United States to enthusiastically welcome and support foreign investment, consistent with the protection of national security.” However, Congress pointed out that, “at the same time, the national security landscape has shifted in recent years, and so has the nature of investments that pose the greatest potential risk to national security, which warrants an appropriate modernization of the processes and authorities of [CFIUS] and the United States export control system.”
 
As an apparent effort to address concerns that CFIUS is, or might become, a tool of industrial policy or trade protectionism, FIRRMA states that CFIUS “should continue to review transactions for the purpose of protecting national security and should not consider issues of national interest absent a national security nexus.” Although FIRRMA contains guidance for the types of national security issues that CFIUS should consider when reviewing covered transactions, the definition of what is and is not an unresolvable national security risk is ultimately up to the discretion of CFIUS, its member agencies and the President.
 
IV. FIRRMA Creates Four New Types of “Covered Transactions”
 
Once regulations implementing FIRRMA become effective within the next 18 months, CFIUS will have jurisdiction over four additional types of “covered transactions.” That is, CFIUS will have the authority to review, mitigate, or recommend the block or divestiture of four additional categories of foreign investments in the United States:
 
A. First New Type of “Covered Transaction”-Investments in Real Estate Near Sensitive U.S. Government Locations and Ports
 
Under current rules, foreign investments in real estate near sensitive U.S. government locations or ports are within CFIUS’s jurisdiction only if they could result in a foreign person’s control over a U.S. business. FIRRMA expands CFIUS’s jurisdiction over the purchase, lease or concession of U.S. real estate to a foreign person that:
  (1) is in close proximity to a U.S. military or other sensitive U.S. government location if such property could reasonably allow for the collection of intelligence or otherwise expose national security activities at a U.S. government site; or
  (2) is located within, or will function as part of, an air or maritime port.
 
To address the potential breadth and ambiguity of this provision, FIRRMA requires the implementing regulations to (i) exclude investments in single-housing units or in urbanized areas, and (ii) create a bright-line definition of “close proximity.”
 
B. Second New Type of “Covered Transaction” -Noncontrolling Investments (Called “Other Investments”)
 
The final version of FIRRMA essentially combined the different approaches that the Senate and the House bills took toward giving CFIUS new jurisdiction over other noncontrolling investments of concern. The Senate bill focused on the nature of the target company, namely, whether it was a “critical technology company” or a “critical infrastructure company.” The House bill focused on whether investments involving specific countries could result in foreign persons’ gaining access to information about critical technology, critical infrastructure or sensitive personal data.
 
Once implementing and clarifying regulations become effective, there will be a multipart test nested with several critical definitions that determine whether a noncontrolling investment is a “covered transaction.” Such “other investments” will be subject to CFIUS jurisdiction if they are by a foreign person in an
unaffiliated U.S. business that:
  (1) owns, operates, manufactures, supplies or services ”
critical infrastructure;”
  (2) produces, designs, tests, manufactures, fabricates or develops ”
critical technology;” or
  (3) maintains or collects
sensitive personal data of U.S. citizens that may be exploited in a manner that threatens national security.
 
However, such an investment will be covered only
if it affords the foreign person:
  (1) access to any ”
material nonpublic technical information” possessed by the U.S. business;
  (2) membership, observer or nomination rights for the board (or equivalent body) of the U.S. business; or
  (3) any involvement, other than through voting of shares, in substantive decisionmaking related to sensitive personal data, critical technologies or critical infrastructure.
 
Although FIRRMA does not use the term “passive investment,” this definition largely preserves the concept that purely passive investments should not be within the scope of CFIUS jurisdiction. This new provision will indeed subject many more investments, particularly smaller ones, to CFIUS jurisdiction. Its impact, however, may not be as broad as many think, given (i) the need for an investment to “afford” such access, membership or involvement to a foreign person for it to be caught; and (ii) that the current definition of “control” is already quite broad and could often be reasonably interpreted to apply to such investments. [FN/2]
 
Key Definitions Related to “Other Investments”
 
Other definitions and clarifications through which one will need to work to determine whether an investment is a covered “other investment” are:
 
  (1) “Unaffiliated.” Although earlier versions of the bills defined the term to mean companies that did not have the same ultimate owner, FIRRMA left the definition of this term to the implementing regulations. The policy objective behind the limitation is a decision that CFIUS need not have jurisdiction over noncontrolling investments between affiliates, such as parent and subsidiary companies.
 
  (2) “Material non-public technical information.” As further defined in regulations, this will mean nonpublic information that provides (i) background to the design, location or operation of critical infrastructure; or (ii) that which is necessary to develop or produce “critical technologies” (discussed below). In addition to controlled technology, this definition, and the associated provision above, capture uncontrolled information (e.g., “EAR99” technology) that could be released to a foreign person through a noncontrolling investment. The provision does not create new export controls on technology but may overlap with the scope to the foundational and emerging technologies to be identified and controlled separately through the export control system. This term does not, however, include financial information regarding the performance of a U.S. business.
 
  (3) “Critical Technologies.”A “critical technology” is essentially any technology on an export control list, primarily the U.S. Munitions List (USML) (sensitive military items) or the Commerce Control List (CCL) (commercial, dual-use and less sensitive military items). If it is not listed, then it is not a “critical technology.”
 
Critical technologies will eventually include now-uncontrolled emerging and foundational technologies essential to national security that are identified through a regular order interagency process and, after a public notice-and-comment process, identified on an export control list. This element of the definition was the result of significant congressional debate pertaining to whether CFIUS should have jurisdiction over outbound investments to give the government the ability to review them, thereby deciding whether they involved technology that government officials subjectively would deem to be “critical,” even if not listed.
 
Congress ultimately decided on a regular order, list-based approach to enhance certainty about what would and would not be “critical,” both for export control and CFIUS purposes. This approach allows defined critical technologies to be controlled for release to foreign persons regardless of the nature of the underlying transaction. (Our forthcoming alert on the Export Control Reform Act of 2018 will contain more detail on this process and the types of technologies to be identified.)
 
  (4) “Critical Infrastructure.”FIRRMA adopts the existing definition, which is any “systems or assets, whether physical or virtual, so vital to the United States that incapacity or destruction . . . would have a debilitating impact on national security.” In response to concerns that the term is too broad, FIRRMA requires that the regulations limit this definition to what is likely important to national security and to give specific types and examples of such infrastructure.
 
  (5) “Sensitive Personal Data.” Although FIRRMA did not define the term, it did limit the scope to that which “may be exploited in a manner that threatens national security” and did not refer to the broader concept of “personally identifying information.” Nonetheless, this definition still is not specific enough to allow most companies with large quantities of personal data to discern whether their data would be sensitive or of national security concern. For this and other reasons, FIRRMA requires CFIUS to publish guidance on the types of transactions that would be “other investments.”
 
  (6) “Investment Fund Investments.” FIRRMA creates a specific carveout from the “other investment” provision for limited partner (or equivalent) investments in funds that are accompanied with advisory board or similar fund committee rights 
if:
 
  (a) the fund is managed exclusively by a U.S. person general partner, managing member or equivalent;
  (b) neither the board or committee nor the foreign person has the ability to approve, disapprove, or otherwise control investment decisions or decisions regarding the entities in which the fund is invested;
  (c) the foreign person does not otherwise have the ability to control the fund, including the right to unilaterally dismiss, retain, select or determine the compensation of the general partner;
and

  (d) the foreign person does not have access to material nonpublic technical information.
 
For purposes of this exemption, FIRRMA excludes waivers of potential conflicts of interest and allocation limits from constituting control over a relevant decision of the investment fund. In other words, non-U.S. limited partners can have these rights and still not be subject to the “other investment” provision, assuming that they meet the other conditions of the exemption.
Investment funds may want to review and potentially revise their limited partner agreements in light of these more detailed standards to determine whether a fund investment would be covered.
 
  (7) “U.S. Business
.” FIRMMA defines the term as a “person engaged in the interstate commerce in the United States.” The current regulatory definition is similar, but it applies “only to the extent of [the business’s] activities in interstate commerce.” We do not know whether CFIUS will carry this existing limitation forward to the new regulations. If it does not, then CFIUS would arguably have jurisdiction to mitigate or block transactions with respect to the non-U.S. activities of companies that are doing business in the United States.
 
C. Third New Type of “Covered Transaction” -Change in Rights
 
Any change in a foreign investor’s rights that results in foreign “control” of a U.S. business or an “other investment” (described above) constitutes the third new type of “covered transaction.” With respect to foreign control, CFIUS had already interpreted its jurisdiction to cover such situations, so this is not a significantly new concept.
 
D. Fourth New Type of “Covered Transaction”-Evasion
 
Any transaction designed or intended to evade or circumvent CFIUS jurisdiction is the fourth new type of covered transaction. The motivation for this provision was to address an oft-cited view that foreign investors were deliberately structuring investments to fall outside of CFIUS’s jurisdiction (such as by entering into joint ventures) to have the ability to access uncontrolled emerging and foundational technology, including know-how, without any U.S. government review or oversight. Other than to address this general policy concern, there was little discussion about how CFIUS intends to interpret this authority and when, for example, structuring a transaction to merely avoid CFIUS review might be considered a violation.
 
————–

  [FN/1]
Here is a link to the prepared remarks of Kevin Wolf before one of the four congressional hearings at which he testified. It describes in more detail many of the background issues and concerns that were debated.

  [FN/2] “Control” is defined as “the power, direct
or indirect,
whether or not exercised, through the ownership of a majority or a dominant minority of the total outstanding voting interest in an entity, board representation, proxy voting, a special share, contractual arrangements, formal
or informal arrangements to act in concert,
or other means, to determine, direct, or decide important matters affecting an entity; in particular, but without limitation, to determine, direct, take, reach, or cause decisions regarding [a list of matters],
or any other similarly important matters affecting an entity. . . .” Id. § 800.204(a). (emphasis supplied).

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

COMM_a01
13. L. Luo: “How to Remove a Company from the EAR Controlled Entity List”

(Source: China Law Blog, 9 Aug 2018.)
 
* Author: Laura Luo, Esq., King & Wood Mallesons, Laura.Luo@us.kwm.com, +1 212 319 4755.
 
On August 1, 2018, the Bureau of Industry and Security (“BIS”) issued a rule amending the Export Administration Regulations (“EAR”) by adding forty-four Chinese entities to the Entity List. A list of the newly added companies can be found here.
 
Export Administration Regulations Overview
 
The EAR are a set of regulations issued under the Export Administration Act that governs the export of certain U.S.-origin commodities, including foreign-made products that incorporate certain U.S.-origin goods, technology, or software. Generally, companies seeking to export, reexport, or transfer (in-country) goods covered by the EAR must obtain a license or license exemption from BIS depending on the purchasing entity and the country on destination. Additional information concerning the EAR and long-arm jurisdiction in export control can be found here. Placement on the Entity List signifies that the End-User Review Committee (“ERC”) has determined that the listed entities have been, or pose a significant risk of, acting contrary to U.S. national security and foreign policy interests. As a result, the EAR impose additional license requirements on, and limit the availability of most license exceptions for, exports, reexports, and transfer (in-country) of U.S.-origin controlled goods and technology to such companies. With respect to the forty-four newly-added Chinese companies, BIS has provided that:
  – there is a presumption of denial for any license review, and
  – there are no license exceptions available for any of these entities.
 
Despite being listed of the Entity List, these Chinese companies may still sell goods and services to purchasers in the U.S. because the EAR concern only the export, reexport, and transfer (in-country) of certain goods to listed entities. However, if the goods involved are controlled goods within the meaning of the EAR, such Chinese entities must still comply with the EAR or otherwise find themselves subject to penalties for violations of the EAR.
 
Requesting Removal from the Entity List
 
Only listed companies may appeal a decision by submitting a written request to the ERC to modify or remove their entries. Because the ERC will deliberate with other agencies and examine information from public and non-public sources, including law enforcement data and classified information, third parties are not allowed to file requests on behalf of any listed company. Any requests must be made in English and supported by the party’s basis for removal or modification. The ERC must review any such requests and provide a written decision within thirty calendar days of receiving such requests. Prior to filing a request with the ERC, a listed entity should conduct its own internal due diligence to first determine whether it does wish to appeal the ERC’s decision and to then gather all relevant information for preparation of its submission and ensuing discussions with the ERC. A listed entity should consider:
 
  (1) the national security or foreign policy interests involved,
  (2) whether the entity poses any risk to such interests, and
  (3) whether there is a reasonable basis for the ERC’s initial placement of the entity on the Entity List.
 
Appealing parties remain subject to any additional licensing requirements until (1) the ERC approves of the party’s appeal, and (2) a formal notice of the party’s removal is published in the Federal Register. The bar for removal, however, is rather high. All decisions to remove or modify an entry on the Entity List must be made by unanimous vote of the ERC, whereas inclusion on the list only requires a majority vote. Decisions made by the ERC are final and unappealable. Due to national security concerns and the confidential nature of the business information reviewed by the ERC, BIS will not share with the public any detailed information on which the ERC relied to make its determination or any information exchanged between the applying entity and the ERC. Despite this high voting standard, companies have previously been successful in petitioning for removal. On September 25, 2017, the ERC removed China National Commercial New Tone Trading Company Ltd from the Entity List, after having initially placed the company on the Entity List on July 28, 2015 and subsequently receiving a request for removal. Finally, even if a listed entity fails to obtain a positive outcome with respect to a request for removal, the Entity List is constantly changing, as the ERC reviews the Entity List on an annual basis to determine whether any listed entities should be removed or modified.
 
Additional Recourse for Listed Entities
 
Should a listed entity choose to pursue the matter further, it must turn to the federal judicial system in hopes of overturning the ERC’s determination. This avenue of recourse presents yet another uphill battle for the listed entity to overcome, as the courts will generally give deferential treatment to an agency’s decision, unless it is shown to either violate the law or otherwise be arbitrary and capricious.
* * * * * * * * * * * * * * * * * * * * 

COMM_a3
14. M. Volkov: “Episode 51 – Interview of Dr. Pat Harned, CEO of the Ethics and Compliance Initiative”
(Source: Volkov Law Group Blog, 12 Aug 2018. Reprinted by permission.)
 
* Author: Michael Volkov, Esq., Volkov Law Group,
mvolkov@volkovlaw.com, 240-505-1992.
 
Dr. Pat Harned is the CEO of the Ethics and Compliance Initiative (ECI).  The mission of the ECI is to empower organizations to build and sustain high quality ethics & compliance programs.  Dr. Harned is a leading compliance advocate and strategist.  The ECI has been at the forefront of developing compliance standards and best practices.
 
In this episode, Michael Volkov interviews Dr. Harned about the ECI’s activities and her view of the compliance profession.
* * * * * * * * * * * * * * * * * * * * 

MSEX/IM MOVERS & SHAKERS

MS_a115. Monday List of Ex/Im Job Openings; 177 Jobs Posted This Week, Including 7 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;
 
* Aerojet Rocketdyne; Canoga Park, CA; 
Manager, Industrial Security & Compliance
;

* Agility; Atlanta, GA; Ocean Import Coordinator

* Agility; Bensenville, IL; Ocean Export Coordinator;

* Agility; Basel, Switzerland;
International Exhibition Coordinator

* Agility; Burlingame, CA;
 
Ocean Import Coordinator
;

* Agility; East Boston, MA; 
Customs/Entry Writer Coordinator


Agility; Houston, TX; 
Air Freight Export Account Executive;

* Agility; Queens, NY; Air Export Coordinator;
* Agility; Queens, NY; Air Export Coordinator;

* Albemarle Corporation; Baton Rouge, LA; Logistics Specialist – Trade Compliance and Marine Specialist

*
 Alcoa Group; Knoxville, TN;
Trade Compliance Administrator
;

* Amazon; Seattle, WA; Head, Global Trade and Product Compliance
;
* Amazon; Seattle, WA;
 
Global Trade Compliance Analyst;

*
Amazon; Seattle, WA; US Export Compliance PM;

* Arrow; Multiple Locations: Centennial, CO; Phoenix, AZ; Reno, NV;
Global Trade Management & Compliance Officer – Trade Compliance Analyst
;

* Arrow; Shanghai, China; Compliance Manager;

*
Augusta Westland; Philadelphia, PA;
Manager, Import Export
;

* BAE
 Systems; Arlington, VN; 
Senior Import Export Analyst
; Requisition ID: 39941BR
* BAE
 Systems; Kingsport, TN; 
Government Compliance Manager
; Requisition ID: 41212BR
* BAE
 Systems; McLean, VN; 
Import Export Director
; Requisition ID: 40458BR

* BAE Systems; Rockville, MD; Compliance Specialist Senior; Requisition ID: 35809BR
* BAE Systems; Sterling, VA; Compliance Specialist Senior; Requisition ID: 36370BR

* Bass Pro Shops; Springfield, MO;
Global Trade Compliance Specialist
;

* Boeing; Dallas, TX; 
Global Regulatory and Compliance Specialist 4
; Requisition ID: 12795

* Boeing; Englewood, CO;
Compliance Specialist 4
; Requisition ID: 1268;

* Boeing; Manassas, VA; 
Export Control Manager
; Requisition ID: 1900

#
Boeing; Saint Louis, MO;
Trade Control Specialist
; Requisition ID: 1800068012
* Boeing; Zoushan, China; 
 Compliance Analyst
* Boeing; Zoushan, China;
Trade Compliance Manager;
#
Cobham; Lansdale, PA; Export Compliance Officer; Ali Neice Alicia.Neice@yoh.com; Requisition ID 1611

* 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
* Curtiss-Wright; Shelby, NC; 
Import / Export Compliance Analyst; 
Requisition ID: 3294
* Destaco; Auburn Hills, MI; 
Manager, Global Compliance
; Clenetta Frazier; 
cfrazier@destaco.com
; Requisition ID:  16261


* Disney Parks & Resorts; Kissimmee, FL;
Senior Manager, Trade Compliance
; Requisition ID: 552655BR;

* The Dow Chemical Company; Drusenheim, France; International Trade Compliance Specialist; Requisition ID: 
1805345

#
DuPont; Wilmington, DE;
Trade Compliance Leader
; Requisition ID: 196737W-01

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

* Eaton; Hungary; Manager Global Trade Management EMEA – Imports (in any EMEA location)Requisition ID: 052687

* Eaton; Multiple Locations: Cleveland, Ohio; Moon Township, Pennsylvania; Eden Prairie, Minnesota; Peachtree City, Georgia; Galesburg, Michigan; Manager, Supply Chain Governance, Risk & ComplianceRequisition ID: 054321

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

Embraer; Fort Lauderdale, FL;
Compliance Specialist II
; Requisition ID: 170685;
* 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; Bedfont, United Kingdom; 
District Trade Compliance Manager
;
* Expeditors; Detroit, MI; US Export Compliance Consultant;
* Expeditors; Dublin, IE; Consultant – Customs and Trade Compliance;
* Expeditors; Dusseldorf, Germany; Clerk, Airfreight Import;

*
 Expeditors; Krefeld, Germany; 
Clerk, Airfreight Import
; 
* Expeditors; Plainfield, IN; District Trade Compliance Manager;
* Expeditors; Sunnyvale, CA, USA; Customs Compliance Coordinator;
* Expeditors; Sunnyvale, CA, USA; Customs Compliance Specialist;
* Expeditors; Stockholm, SE; District Trade Compliance Manager;


* 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;
Associate Compliance Specialist
; Requistion ID: 19856BR;
* General Atomics; San Diego, CA;
Government Compliance Specialist
; Requisition ID: 19499BR;

* 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;
Senior Government Compliance Specialist
; Requisition ID: 19500BR;

* General Electric; Ft Worth TX, Chicago IL, or Erie, PA; 
Senior Project Manager, Customs & Brokerage, Transportation
; Requisition ID: 3134046

* General Electric; Lynn, MA;
Senior Export Control Specialist, Aviation
; Requisition ID: 3146429

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

* Honeywell International Inc.; Sunnyvale, CA or Lincolnshire, IL; Sr. Import/Export Analyst; HRD32371

* Infineon Technologies; Milpitas, CA;
Export Compliance Specialist; Requisition ID: 26988
* Infineon Technologies; Munich, Germany; Manager Export Control;
* Infineon Technologies; Munich, Germany; Specialist Export Control;

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

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

#
IPG Photonics; Oxford, MA; Global Director Trade Compliance;

* Johnson Controls; Boca Raton, FL; Licensing Coordinator; Requisition ID: 
WD30047852135
* Johnson Controls; Boca Raton, FL; Licensing Coordinator; Rquisition ID: 
WD30047853135
* Johnson Controls; Milwaukee, WI; Trade Compliance Analyst; Requisition ID: WD30047348124
* Johnson Controls; Tamaulipas, Matamoros, Mexico; Trade Compliance Specialist; Requisition ID: EB00064420180

* Komatsu; Milwaukee, WI; Senior International Trade Compliance AnalystRequisition ID: 12728

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

* Leonardo DRS; Arlington, VA; 
Trade & Compliance Director

Requisition ID: 91287
* Leonardo DRS; Cypress, CA; 
Contracts & Compliance Manager
; Requisition ID: 91594
* Leonardo DRS; Dallas, TX; 
 Contracts & Compliance Administrator
; Requisition ID: 91611
* Leonardo DRS; Dallas, TX; 
Contracts & Compliance Manager
; Requisition ID: 91608
* Leonardo DRS; Melbourne, FL; 
Senior Manager Contract and Compliance
; Requisition ID: 90731
* Leonardo DRS; Melbourne, FL; 
Senior Supply Chain Analyst – Small Business Compliance
; Requisition ID: 91669

* 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; Arlington, VA; 
International Trade Compliance Engineer
; Job ID: 439787BR

* Lockheed Martin; Arlington, VA; 
Senior International Licensing Analy
st; ID: 
438635BR
* Lockheed Martin; Arlington, VA; 
International Trade Compliance Engineer
; ID: 
439787BR

* Lockheed Martin; Fort Worth, TX; Export and Import Compliance Investigations Lead; Job ID: 427872BR

* Lockheed Martin; Fort Worth, TX; 
Regulatory Compliance Analyst
; Job ID: 439674BR

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

*
Lockheed Martin; Littleton, CO;
Supply Chain Management Compliance Analyst
; Requisition ID: 440613BR

* Lockheed Martin; Orlando, FL; 
Senior International Licensing Analyst
; Requisition ID: 
434225BR 
* Lockheed Martin; Orlando, FL; 
International Trade Compliance Manager; 
Job ID: 439904BR 
* Lockheed Martin; Stratford, CT; 
 Compliance Auditor
; Job ID; 434724BR


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

* 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
* Maersk/DAMCO; Agent de transit IMPORT – EXPORT; Job Ref.: DC-164022
* Medtronic; Heerlen, The Netherlands;
Trade Compliance Analyst
; Requisition ID: 16000DYY

#
Medtronic; Minneapolis, MN;
Trade Compliance Program Manager
; Requisition ID: 18000BJW;

* Medtronic; Wash DC;
Global Trade Lawyer
;
stacy.m.johnson@medtronic.com
; Requisition ID: 170002ON

* Meggit; Akron, OH;
Senior Manager Trade Compliance;

* 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

* Muscogee International, LLC; Washington, D.C.;
DDTC Compliance Specialist II; 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.

*
Netflix; Los Angeles, CA;
Manager, Trade Compliance
;

* Northrop Grumman; Baltimore, MD; 
International Trade Compliance Analyst (level 2 or 3)- Import
; Requisition ID: 18013545
* Northrop Grumman; Baltimore, MD; 
International Trade Compliance Analyst (level 2 or 3)- Import
; Requisition ID: 18014715

* 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; Herndon, VA; International Trade Compliance Analyst 3; Requisition ID: 18007859
* Northrop Grumman; McLean, VA; International Trade Compliance Analyst 3; Requisition ID: 18012973

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

* Optics 1; Bedford NH, Senior Trade Compliance Administrator

* Oracle; Unspecified, United States; Customs Compliance Specialist; Requisition ID: 18000H0N

* Oshkosh Corporation; Greenville, WI; Senior Global Trade Compliance Analyst – Licensing; ID: 
183273

* PerkinElmer, Inc.; Shelton, CT;
Systems Analyst, Trade Compliance Solutions;
* PerkinElmer, Inc.; Singapore; ITC Specialist; Requisition ID: JR-003936

#
Raytheon; Billerica, MA;
Import Ctl&Compliance Advisor
; Requisition ID:
119749BR

* Raytheon; Billerica, MA; 
Mgr I Export-Import Control
; Requisition ID: 
118298BR

* Raytheon; El Segundo, CA; 
Import Control and Compliance Advisor
; APPLY Requisition ID 119247BR

* 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; Tucson, AZ; Export Licensing And Compliance Specialist; Requisition ID: 114936BR  

#
Raytheon; Tucson, AZ; 
Import Ctl&Compliance Advisor
; Requisition ID:
119749BR

* Raytheon; Woburn, MA; 
Global Trade Export Licensing & Compliance Advisor
Requisition ID:
117939BR
* Raytheon; Woburn, MA; Supply Chain Compliance Advisor; Requisition ID:
115557BR

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

* The Safariland Group; Jacksonville, FL; Counsel (International Trade Compliance)
* The Safariland Group; Jacksonville, FL; Sr. Export Compliance Specialist  

Spirent; Calabasas, CA;
Global Trade Compliance Specialist
; Requisition ID: 4088;

* Teva Pharmaceuticals; North Wales, PA; 
Senior Analyst, Customs & Trade Compliance
;

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

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

* Varian; Paolo Alto, CA; Senior Trade Compliance Analyst; Requisition ID: 12735BR; Contact 
Uyen Tran at
Uyen.Tran@varian.com
* Varian; Paolo Alto, CA; 
Trade Compliance Analyst; 
Requisition ID: 
13097BR;

* Vigilant; Negotiable Location, USA;
Global Trade Compliance Analyst
;

* Vigilant; Negotiable Location, USA;  
Global Trade Account Manager
;

* Virgin Galactic; Las Cruces, NM; Export Compliance Officer; Requisition ID: 2018-3558

* Watts Water Technologies; Andover, MA;
Customs Compliance Specialist
;
* World Wide Technology; Edwardsville, IL;
International Trade Compliance Specialist
;

* Xylem, Inc.; Bangalore, Karnataka, IndiaThird Party Contract & Compliance Coordinator;

* Xylem, Inc; Morton Grove, IL; 
Trade Compliance Specialist 

* Xylem, Inc.; Pewaukee, WI; Logistics Manager/Trade Compliance;

* YETI; Austin, TX;
Global Trade Compliance Manager 

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

TECEX/IM TRAINING EVENTS & CONFERENCES

 
* What: The ECS ITAR/EAR Symposium & Boot Camp, Annapolis, MD
* When: September 11-13, 2018
* Sponsor: Export Compliance Solutions & Consulting (ECS)
* ECS Speaker Panel:  Timothy Mooney, Commerce/BIS; Matt Doyle, Lockheed; Matt McGrath, McGrath Law, Scott Jackson, Curtiss-Wright, Suzanne Palmer & Mal Zerden.
* Register here for the three-day event, or here for the one-day Symposium or by calling 866-238-4018 or e-mail spalmer@exportcompliancesolutions.com

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

(Source: Danielle Hatch,
danielle@learnexportcompliance.com)
 
* What: US Antiboycott Regulations: Clarified & Demystified
* When: September 26, 2018; 1:00 p.m. (EDT)
* Where: Webinar
* Sponsor: Export Compliance Training Institute (ECTI)
* ECTI Speaker: Scott Gearity
* Register: Here or Danielle Hatch, 540-433-3977, danielle@learnexportcompliance.com.

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

ENEDITOR’S NOTES

* Edith Hamilton (12 Aug 1867 – 31 May 1963; was an American educator and internationally-known author who was one of the most renowned classicists of her era.  She was sixty-two years old when her first book, The Greek Way, was published. It was an immediate success. Hamilton’s other notable works include The Roman WayThe Prophets of IsraelMythology, and The Echo of Greece.)
 – “Faith is not belief. Belief is passive. Faith is active.”
 
Felix Adler (13 Aug 1851 – 24 Apr 1933; was a German American professor of political and social ethics, rationalist, influential lecturer on euthanasia, religious leader and social reformer who founded the Ethical Culture movement.)
  – “The family is the school of duties.”
 
Monday is pun day.
* Do not open an attachment from Hormel Foods Corporation.  It could be Spam.

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

EN_a319
. 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 Amendments: 3 Aug 2018: 83 FR 38021-38023: Revision of Export and Reexport License Requirements for Republic of South Sudan Under the Export Administration Regulations; and 83 FR 38018-38021: U.S.-India Major Defense Partners: Implementation Under the Export Administration Regulations of India’s Membership in the Wassenaar Arrangement and Addition of India to Country Group A:5

  
*
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_a0320
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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