;

18-0824 Friday “Daily Bugle”

18-0824 Friday “Daily Bugle”

Friday, 24 August 2018

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

  1. Commerce Seeks Comments Concerning Request for Exclusions from the Section 232 National Security Adjustments of Imports of Aluminum and Steel
  2. Treasury Seeks Comments Concerning Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010 (“CISADA”) Reporting Requirements under Section 104(e)
  1. Items Scheduled for Publication in Future Federal Register Editions 
  2. Commerce/BIS: (No new postings.)
  3. State/DDTC: (No new postings.)
  4. Singapore Customs: “CorpPass Will Be the Only Mode of Login for Companies to Transact With Singapore Customs From 1 Sep 2018”
  1. Expeditors News: “CBP Publishes Responsible Business Practices on Forced Labor Risk in the Global Supply Chain”
  2. Global Trade News: “United States and China Impose More Tariffs”
  3. Reuters: “U.S. Sanctions on Russia Tied to UK Attack to Take Effect Monday”
  4. ST&R Trade Report: “China’s Compliance with WTO Commitments is Focus of Annual Review”
  1. A.P. Bosch & V.J.A. Goossen: “New Round of Russia Sanctions Announced Today by State Department”
  2. China Law & Practice: “China’s Proposed Export Control Law – a Major New Weapon in the Sino-U.S. Trade Dispute”
  3. M. Volkov: “CFIUS Reform: An Expanded Role (Part II of II)”
  1. FCC to Present U.S. Export Controls Awareness Training Course for Non-U.S. Organizations, 2 Oct in Bruchem, the Netherlands
  2. List of Approaching Events: 5 New Events Posted This Week
  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 (3 Aug 2018), FACR/OFAC (29 Jun 2018), FTR (24 Apr 2018), HTSUS (14 Aug 2018), ITAR (14 Feb 2018) 
  3. Weekly Highlights of the Daily Bugle Top Stories 

EXIMITEMS FROM TODAY’S FEDERAL REGISTER

EXIM_a1

1.
Commerce Seeks Comments Concerning Request for Exclusions from the Section 232 National Security Adjustments of Imports of Aluminum and Steel
(Source: 
Federal Register, 24 Aug 2018.) [Excerpts.] 
 
83 FR 42867-42868: Submission for OMB Review; Comment Request: Procedures for Submitting Request for Exclusions From the Section 232 National Security Adjustments of Imports of Aluminum and Steel
 
The Department of Commerce will submit to the Office of Management and Budget (OMB) for clearance the following proposal for collection of information under the provisions of the Paperwork Reduction Act (44 U.S.C. Chapter 35). 
 
  – Agency: Bureau of Industry and Security.

  – Title: Proposed Information Collection; Comment Request; Procedures for Submitting Request for Exclusions from the Section 232 National Security Adjustments of Imports of Aluminum and Steel
  – Form Number(s): N/A.

  – OMB Control Number: 0694-0139. … 
  – Needs and Uses: This collection of information supports Presidential Proclamations 9704 Adjusting Imports of Aluminum into the United States and 9705 Adjusting Imports of Steel into the United States. On March 8, 2018, the President issued Proclamations 9704 and 9705 concurring with the findings of the two investigation reports submitted by the Secretary of Commerce pursuant to section 232 of the Trade Expansions Act of 1962 (19 U.S.C. § 1862) and determining that adjusting imports through the imposition of duties on aluminum and steel is necessary so that imports of aluminum and steel will no longer threaten to impair the national security. … 
  This information collection request may be viewed at 
http://www.reginfo.gov/public/. Follow the instructions to view Department of Commerce collections currently under review by OMB. 
  Written comments and recommendations for the proposed information collection should be sent within 30 days of publication of this notice to 
OIRA_Submission@omb.eop.gov
.

Sheleen Dumas, Departmental Lead PRA Officer, Office of the Chief Information Officer. 

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

EXIM_a2

2. 
Treasury Seeks Comments Concerning Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010 (“CISADA”) Reporting Requirements under Section 104(e)
(Source: 
Federal Register, 24 Aug 2018.) [Excerpts.] 
 
83 FR 42981: Agency Information Collection Activities; Submission for OMB Review; Comment Request; Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010 (“CISADA”) Reporting Requirements
 
* AGENCY: Departmental Offices, U.S. Department of the Treasury.
* ACTION: Notice.
* SUMMARY: The Department of the Treasury will submit the following information collection requests to the Office of Management and Budget (OMB) for review and clearance in accordance with the Paperwork Reduction Act of 1995, on or after the date of publication of this notice. The public is invited to submit comments on these requests.
* DATES: Comments should be received on or before September 24, 2018 to be assured of consideration.
* ADDRESSES: Send comments regarding the burden estimate, or any other aspect of the information collection, including suggestions for reducing the burden, to (1) Office of Information and Regulatory Affairs, Office of Management and Budget, Attention: Desk Officer for Treasury, New Executive Office Building, Room 10235, Washington, DC 20503, or email at 
OIRA_Submission@OMB.EOP.gov and (2) Treasury PRA Clearance Officer, 1750 Pennsylvania Ave. NW, Suite 8142, Washington, DC 20220, or email at 
PRA@treasury.gov.
* FOR FURTHER INFORMATION CONTACT: Copies of the submissions may be obtained from Jennifer Quintana by emailing 
PRA@treasury.gov, calling (202) 622-0489, or viewing the entire information collection request at
www.reginfo.gov.
* SUPPLEMENTARY INFORMATION: 
Financial Crimes Enforcement Network (FinCEN)
  – Title: Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010 (“CISADA”) Reporting Requirements under Section 104(e).
  – OMB Control Number: 1506-0066.
  – Type of Review: Extension without change of a currently approved 
collection.
  – Abstract: FinCEN, to comply with the congressional mandate to prescribe regulations under section 104(e) of the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010 (“CISADA”) and consistent with its statutory mission under 31 U.S.C. 310, issued regulations that would require a U.S. bank that maintains a correspondent account for a foreign bank to inquire of the foreign bank, and report to FinCEN, with respect to whether the foreign bank maintains a correspondent account for, or has processed one or more transfers of funds within the preceding 90 calendar days, other than through a correspondent account, related to any financial institution designated by the U.S. Government in connection with Iran’s proliferation of weapons of mass destruction or delivery systems for weapons of mass destruction, or in connection with Iran’s support for international terrorism. In addition, FinCEN is requiring a U.S. bank that maintains a correspondent account for a foreign bank to inquire of the foreign bank, and report to FinCEN, with respect to whether the foreign bank has processed one or more transfers of funds within the preceding 90 calendar days related to Iran’s Islamic Revolutionary Guard Corps (“IRGC”) or any of its agents or affiliates designated by the U.S. Government. Under the regulations, U.S. banks will only be required to report this information to FinCEN upon receiving a specific written request from FinCEN.
  – Form: None. … 
 
  Dated: August 21, 2018.
 
Spencer W. Clark, Treasury PRA Clearance Officer.

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

OGSOTHER GOVERNMENT SOURCES

OGS_a13
. Items Scheduled for Publication in Future Federal Register Editions
 

(Source:
Federal Register)
* State; NOTICES; Determinations Regarding Use of Chemical Weapons by Russia Under the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991 [Publication Date: 27 Aug 2018.]

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

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

OGS_3
5
State/DDTC: (No new postings.)

(Source: 
State/DDTC)

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

OGS_a4
6. 
Singapore Customs: “CorpPass Will Be the Only Mode of Login For Companies to Transact With Singapore Customs From 1 Sep 2018”

(Source: 
Singapore Customs, Notice No. 15/2018, 24 Aug 2018.)
 
Singapore Customs has released a notice concerning CorpPass, the only mode of login for companies to transact with Singapore Customs from 1 Sep 2018. The notice is available 
here.

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

NWSNEWS

(Source: 
Expeditors News, 22 Aug 2018.)
 
On August 17, 2018, U.S. Customs and Border Protection (CBP) published guidelines in a document titled, “Responsible Business Practices on Forced Labor Risk in the Global Supply Chain.”
 
The document details best practices for importers of goods into the U.S. The guidelines also refer readers to the Organization for Economic Co-operation and Development Guidelines for Multinational Enterprises, which include additional recommendations.
 
The CBP document may be found 
here.

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

(Source: 
Integration Point Blog, 24 Aug 2018.) [Excerpts.] 
 
The United States and China escalated the trade war when both parties implemented punitive tariffs of 25% on goods valued at $16 billion.
 
The last round brings the value of imports subject to tariffs by both countries since the beginning of July to a total of $50 billion. And there are even more tariffs pending. U.S. President Trump had previously threatened to impose duties on nearly all of the $500+ billion in Chinese goods exported annually to the U.S. unless China agrees to certain trade concessions, such as overhauling its intellectual property practices.
 
The latest U.S. tariffs apply to semiconductors, plastics, chemicals, railway equipment, and more. The U.S. Immigration and Customs Enforcement Service (ICE) confirmed on its website that at 12:01 EDT on Thursday, just after noon in Beijing, it would start collecting additional fees in 279 categories of products imported from China worth $16 billion.
China’s list of 333 U.S. product categories subject to duties includes coal, copper scrap, fuel, steel products, buses, and medical equipment. China said its tariffs on $16 billion worth of imports would take effect at 12:01 local time.
 

The tariffs came into effect in the middle of two days of talks in Washington between mid-level officials on both sides – the first formal negotiations since the U.S. Trade Secretary met with Chinese economic adviser Liu He back in June. … 

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

(Source: 
Reuters, 24 Aug 2018.) [Excerpts.] 
 
U.S. sanctions against Russia tied to a nerve agent attack in Britain, which were announced earlier this month, will come into effect on Monday, the U.S. government said on Friday, adding to the array of economic penalties it has imposed on Moscow in recent years.
 
The new measures, detailed in a 
notice posted at the Federal Register, will terminate foreign assistance and some arms sales and financing to Russia, as well as deny the country credit and  prohibit the export of security-sensitive goods and technology. … 
 
Although President Donald Trump has often said he would like better ties with his Russian counterpart, Vladimir Putin, Washington’s relations with Moscow are at a low – frayed by U.S. allegations Russia interfered in its 2016 presidential election, and by disagreements over Russia’s 2014 annexation of Crimea and its role in the Syrian civil war.
 
Plans to impose the latest sanctions were announced by the Trump administration on Aug. 8, a response to what the State Department said was Moscow’s use of a nerve agent against a former Russian agent and his daughter in Britain in March.
 
Sergei Skripal, a former colonel in Russia’s GRU military intelligence service, and his 33-year-old daughter, Yulia, were found unconscious on a bench in the southern English city of Salisbury after a liquid form of the Novichok type of nerve agent was applied to the front door of his home. Both survived the attack.
 
Moscow has denied involvement in the attack. It has also denied meddling in the 2016 U.S. elections. … 
 
The new measures will be published and come into effect on Aug. 27 and remain in place for at least one year, according to the notice in the Federal Register, a daily catalog of government agency actions. They are authorized by the 1991 Chemical and Biological Weapons and Warfare Elimination Act. 
 
Space flight activities, government space cooperation, areas concerning commercial aviation safety and urgent humanitarian assistance will be exempt.
 
A second batch of penalties will be imposed after 90 days unless Russia gives “reliable assurance” that it would no longer use chemical weapons and allow on-site inspections by the United Nations or another international observer group. … 

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

NWS_a4
10
ST&R Trade Report: “China’s Compliance with WTO Commitments is Focus of Annual Review”

(Source: 
Sandler, Travis & Rosenberg Trade Report, 24 Aug 2018.)
 
China’s compliance with its World Trade Organization accession commitments will be the focus of a hearing and comment period designed to assist the Office of the U.S. Trade Representative in preparing its annual report to Congress. Highlights of last year’s report, which took on a decidedly sharper tone than in previous years, can be 
found here.
 
The hearing will be held in Washington, D.C., Oct. 3. Comments and requests to appear at the hearing are due by Sept. 19. Specific topics on which input is being sought include the following.
 
  – trading rights
  – import regulation (e.g., tariffs, tariff-rate quotas, quotas, import licenses)
  – export regulation
  – internal policies affecting trade (e.g., subsidies, standards and technical regulations, sanitary and phytosanitary measures, government procurement, trade-related investment measures, taxes and charges levied on imports and exports)
  – intellectual property rights (including enforcement)
  – services

  – rule of law issues (e.g., transparency, judicial review, uniform administration of laws and regulations) and status of legal reform

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

COMMCOMMENTARY

 
* Authors: Alexander P. Bosch, 
apbosch@fullcirclecompliance.eu; and Vincent J.A. Goossen, 
vjagoossen@fullcirclecompliance.eu. Both of Full Circle Compliance, and Assistant Editors of the Daily Bugle.
 
Today, the U.S. State Department announced a new round of sanctions against Russia, which will come into effect on Monday, 27 August. The sanctions were announced on 6 August and are related to an alleged Russian nerve agent attacks on former Russian intelligence officer Sergei Skripal and his daughter Yulia in the British city of Salisbury. Moscow has repeatedly denied any role in the incident, but London and Washington, accused Russia of orchestrating the attack. 
 
The new measures, which are pursuant to Section 306(a) of the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991, and outlined in a 
notice to posted in the Federal Register on Monday, include:
 
  (1) Foreign Assistance: Termination of assistance to Russia under the Foreign Assistance Act of 1961, except for urgent humanitarian assistance and food or other agricultural commodities or products.
  (2) Arms Sales: Termination of (a) sales to Russia under the Arms Export Control Act of any defense articles, defense services, or design and construction services, and (b) licenses for the export to Russia of any item on the United States Munitions List. State has determined that it is essential to national security interests to waive the application of this sanction with respect to the issuance of licenses in support of government space cooperation and commercial space launches, provided that such licenses shall be issued on a case-by-case basis and consistent with export licensing policy for Russia prior to the enactment of these sanctions.
  (3) Arms Sales Financing: Termination of all foreign military financing for Russia under the Arms Export Control Act.
  (4) Denial of United States Government Credit or Other Financial Assistance: Denial to Russia of any credit, credit guarantees, or other financial assistance by any department, agency, or instrumentality of the United States Government, including the Export-Import Bank of the United States.
  (5) Exports of National Security-Sensitive Goods and Technology: Prohibition on the export to Russia of any goods or technology on that part of the control list established under Section 2404(c)(1) of the Appendix to Title 50.
 
State determined that it is “essential to U.S. national security interests” that the following are exempt from this sanction: 
 
  (1) LICENSE EXCEPTIONS: Exports and reexports of goods or technology eligible under License Exceptions GOV, ENC, RPL, BAG, TMP, TSU, APR, CIV, and AVS.
  (2) SAFETY OF FLIGHT: Exports and reexports of goods or technology pursuant to new licenses necessary for the safety of flight of civil fixed-wing passenger aviation, provided that such licenses shall be issued on a case-by-case basis, consistent with export licensing policy for Russia prior to enactment of these sanctions.
  (3) DEEMED EXPORTS/REEXPORTS: Exports and re-exports of goods or technology pursuant to new licenses for deemed exports and reexports to Russian nationals, provided that such licenses shall be issued on a case-by-case basis, consistent with export licensing policy for Russia prior to enactment of these sanctions.
  (4) WHOLLY-OWNED U.S. SUBSIDIARIES: Exports and reexports of goods or technology pursuant to new licenses for exports and reexports to wholly-owned U.S. subsidiaries in Russia, provided that such licenses shall be issued on a case-by-case basis, consistent with export licensing policy for Russia prior to enactment of these sanctions.
  (5) SPACE FLIGHT: Exports and reexports of goods or technology pursuant to new licenses in support of government space cooperation and commercial space launches, provided that such licenses shall be issued on a case-by-case basis, consistent with export licensing policy for Russia prior to enactment of these sanctions.
  (6) COMMERCIAL END-USERS: Exports and reexports of goods or technology pursuant to new licenses for commercial end-users civil end-uses in Russia, provided that such licenses shall be issued on a case-by-case basis, consistent with export licensing policy for Russia prior to enactment of these sanctions.

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

COMM_a2a
12. 
China Law & Practice: “China’s Proposed Export Control Law – a Major New Weapon in the Sino-U.S. Trade Dispute”

(Source: 
China Law & Practice, 23 Aug 2018.) [Excerpts; subscription required.]
 
William Marshall of Tiang & Co analyzes the proposed Export Control Law and China’s competitive advantage over the U.S., especially in relation to technology, should this legislation come into force.
 
News of foreign investment blocks and punitive tariff measures between the United States and China certainly dominate the headlines. These are, however, merely small skirmishes in a much larger battle.  The primary ground for which each side is fighting relates to technology.  Not specifically China’s practices as to the protection of intellectual property, which is the stated rationale for the Section 301 tariff measures imposed by the U.S — but rather the strategic control of competitive advantage in and access to technology globally.

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

(Source: 
Volkov Law Group Blog, 23 Aug 2018. Reprinted by permission.) 
 
* Author: Michael Volkov, Esq., Volkov Law Group, 
mvolkov@volkovlaw.com, +1 240-505-1992. 
 
[Editor’s Note: Part I was published in the Daily Bugle of Wednesday, 22 Aug 2018.]
 
Congress enacted the Foreign Investment Risk Review Modernization Act of 2018 (FIRRMA), which was intended to modernize and strengthen the CFIUS process.  FIRRMA was incorporated into the National Defense Authorization Act which as passed and signed into law.
 
FIRRMA expands CFIUS jurisdiction to include four new types of transactions, expands the definition of “critical technology,” requires CFIUS to respond to written notices, extends the time period for review of transactions, and creates a CFIUS filing fee.
 
FIRRMA expands CFIUS’ jurisdiction to cover four new types of transactions, including:
 
  – A non-passive investment by a foreign person in any U.S. business involved in critical infrastructure or in the production of critical technologies, or that maintains sensitive personal data that could threaten national security;
  – Any change in a foreign investor’s rights regarding such a U.S. business;
  – Any other transaction, transfer, agreement or arrangement designed to circumvent or evade CFIUS; and
  – The purchase, lease, or concession by or to a foreign person of certain real estate in close proximity to military or other sensitive national security facilities.
 
To expedite the CFIUS review process, particularly in situations where there is little security risk, FIRRMA allows parties to obtain an initial review after filing a streamlined declaration (no more than five pages).  In response, CFIUS could include a request to file a full notice, a request for additional information, initiation of a unilateral review, or notification that no further action is required.
 
If a transaction results in the acquisition of a substantial interest in a US business by a foreign person in which a foreign government has a substantial interest, FIRRMA requires that the parties submit a written declaration no more than 45 days before closing.  CFIUS regulations will define the term “substantial interest,” based on the ability of a foreign government to influence the foreign person (e.g. board membership, ownership interests, shareholder rights), and will exclude investments with a less than 10 percent voting interest.
 
FIRRMA also includes provisions that:
 
  – Provide CFIUS additional time to review a transaction from 30 days to 45 days, with a 15-day extension for extraordinary circumstances;
  – Require CFIUS to establish a process for identifying transactions that occur that do not fall within the CFIUS notification requirements in order to identify potential transactions that raise national security concerns;
  – Creates exemptions from review for investment fund investments where the foreign partner is a limited partner; and
  – Allow CFIUS to impose filing fees not to exceed $300,000.
To address potential national security risks, and depending on a risk-based analysis, CFIUS will have authority to:
 
  – Suspend a transaction during review or investigation;
Use mitigation agreements and conditions to address specific risks; and
  – Impose interim mitigation agreements and conditions on completed transactions that are undergoing CFIUS review.
 

FIRRMA requires CFIUS to formulate and adhere to a compliance plan for any mitigation agreement so that such agreements include specific requirements and authorizes CFIUS to impose penalties for violations of the agreement requirements.  Parties are authorized to contract with independent, non-government entities to monitor compliance with any mitigation agreement.

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

TEEX/IM TRAINING EVENTS & CONFERENCES

TE_a1
14
FCC to Present U.S. Export Controls Awareness Training Course for Non-U.S. Organizations, 2 Oct in Bruchem, the Netherlands

(Source: Full Circle Compliance, events@fullcirclecompliance.eu.)
 
Our next academy course is specifically designed for beginning compliance officers and professionals who want to enhance their knowledge on the latest ITAR/EAR requirements and best practices.  The course will cover multiple topics regarding U.S. export controls that apply to organisations outside the U.S., such as: the regulatory framework, including the latest and anticipated regulatory amendments, key concepts and definitions, classification and licensing requirements, handling (potential) non-compliance issues, and practice tips to ensure compliance with the ITAR and EAR.
 
* What: Awareness Course U.S. Export Controls: ITAR & EAR From a Non-U.S. Perspective 
* When: Tuesday, 2 Oct 2018, 9 AM – 5 PM (CEST)
* Where: Landgoed Groenhoven, Bruchem, the Netherlands
* Sponsor: Full Circle Compliance (FCC)
* Instructors: Ghislaine Gillessen, Mike Farrell, and Alexander P. Bosch 
* Information & Registration: HERE or via
events@fullcirclecompliance.eu
  

Register today and get a 10% Early Bird discount on the course fee!
* * * * * * * * * * * * * * * * * * * *

TE_a3
15. 
List of Approaching Events: 5 New Events Posted This Week
(Sources: Editor and Event Sponsors)

Published every Friday or last publication day of the week, o
ur overview of Approaching Events is organized to list c
ontinuously available training, training events, s
eminars & conferences, and 
webinars. 
 
Please, submit your event announcement to Alexander Witt, Events & Jobs Editor (email: awitt@fullcirclecompliance.eu
), composed in the below format:
 
# DATE: LOCATION; “EVENT TITLE”; EVENT SPONSOR; WEBLINK; CONTACT DETAILS (email and/or phone number)
 

#” = New or updated listing  

 
Continuously Available Training
 
* E-Seminars: “US Export Controls” / “Defense Trade Controls“; Export Compliance Training Institute; danielle@learnexportcompliance.com 

* Webinar: ”
Company-Wide US Export Controls Awareness Program“; Export Compliance Training Institute;
danielle@learnexportcompliance.com 

* E-Seminars: “ITAR/EAR Awareness“; Export Compliance Solutions;
spalmer@exportcompliancesolutions.com
* Online: “Simplified Network Application Process Redesign (SNAP-R)“; Commerce/BIS; 202-482-2227
* E-Seminars: “Webinars On-Demand Library“; Sandler, Travis & Rosenberg, P.A.
* Online: “International Trade Webinars“; Global Training Center
*
 
Online: “On-Demand Webinars“; “General Training“; Center for Development of Security Excellence; Defense Security Service (DSS)
* Online: “ACE Reports Training and User Guide“; DHS/CBP

* Online: ”
Increase Your International Sales – Webinar Archive“; U.S. Commercial Service

* Web Form: “Compliance Snapshot Assessment“; Commonwealth Trading Partners (CTP)
* Online: “
Customs Broker Exam Prep Course
“; The Exam Center
 
 
Seminars and Conferences

  


*
Aug 29: Leeds, UK; “
Understanding Incoterms
“; Chamber International

*
Sep 3: Edinburgh, UK; “
Intermediate Seminar
“; UK Department for International Trade
*
Sep 4: Edinburgh, UK; “
Beginner’s Workshop
“; UK Department for International Trade

*
Sep 4: Edinburgh, UK; “
Control List Classification – Combined Dual Use and Military
“; UK Department for International Trade

*
Sep 4: Edinburgh, UK; “
Licenses Workshop
“; UK Department for International Trade

*
Sep 4: Leeds, UK; “
Methods of Payment & Letters of Credit
; Chamber International

*
 Sep 4: London, UK; “
An Introduction to Exporting
“; UK Institute of Export and International Trade

*
Sep 5: Aberdeen, UK; “
Beginner’s Workshop
“; UK Department for International Trade

Sep 5: Aberdeen, UK; “
Intermediate Seminar
“; UK Department for International Trade
*
 Sep 6: Aberdeen, UK; “
Licenses Workshop
“; UK Department for International Trade


Sep 11-13: Annapolis, MD; “
ITAR/EAR Symposium & Boot Camp Global Trade Academy
“; Export Compliance Solutions (ECS)

* Sep 11-13: Detroit, MI; “
Export Controls Specialist Certification
“; Global Trade Academy 

*
Sep 11: Leeds, UK; “
Export Documentation and Export Procedures
“; Chamber International

* Sep 12: Buffalo, NY; “Export Documentation and Procedures Seminar“; International Business Training 


Sep 12: Melbourne, Australia; 
Defence Export Controls Outreach
; Australian Department of Defense

* Sep 12-13: Springfield, RI; “Complying with US Export Controls“; Bureau of Industry and Security
* Sep 12-19: Chicago, IL; “Import 5-Day Boot Camp“; Global Trade Academy 
* Sep 13: Buffalo, NY; “Import Documentation and Procedures Seminar“; International Business Training 
* Sep 13: Frankfurt, Germany; “BAFA/U.S. Export Control Seminar 2018“; 
* Sep 13-17: Galveston, TX (Cruise); “ICPA @ SEA!“; International Compliance Professionals Association (ICPA)
* Sep 16-19: Atlanta, GA; “2018 Annual Conference and Exposition“; National Association of Foreign Trade Zones (NAFTZ)
* Sep 17: Los Angeles, CA; “Import Compliance“; Global Trade Academy
* Sep 17-20: Columbus, OH; “University Export Controls Seminar at The Ohio State University in Columbus“; Export Compliance Training Institute (ECTI); jessica@learnexportcompliance.com; 540-433-3977
* Sep 17-21: Los Angeles, CA; “Import 5-Day Boot Camp“; Global Trade Academy  
* Sep 18: Anaheim, CA; “Import Documentation and Procedures Seminar“; International Business Training 

Sep 18: Kontich, Belgium; “
Export Controls Master Class
“; Customs4Trade

* Sep 18: Los Angeles, CA; “Tariff Classification for Importers and Exporters“; Global Trade Academy 
* Sep 19: Washington, D.C.; “DDTC In-House Seminar“; Department of State (Registration: Aug 10 – Aug 31; first come, first served)
* Sep 19: Los Angeles, CA; “NAFTA and Trade Agreements“; Global Trade Academy
* Sep 19-20: Rome, Italy; “Defense Exports 2018“; SMi

* Sep 19-20: Los Angeles, CA; ”
Complying With U.S. Export Controls“; BIS

* Sep 20: Pittsburgh, PA; “Export Documentation and Procedures Seminar“; International Business Training 
* Sep 20: Los Angeles, CA; “Country and Rules of Origin“; Global Trade Academy


Sep 20: Mountain View, CA; “
Assist Valuation: What Every Import Professional Needs to Know
“; Professional Association of Exporters and Importers

* Sep 21: Los Angeles, CA; “Customs Valuation – The Essentials“; Global Trade Academy
* Sep 21: Pittsburgh, PA; “Incoterms 2010: Terms of Sale Seminar“; International Business Training 
* Sep 21-24: Detroit, Michigan; “Best Customs Broker Exam Course“; GRVR Attorneys 

*
 Sep 24: Seligenstadt, Germany; “
Follow-Up Fachtagung
“; FALEX

* Sep 25-26; Chicago, IL; ”
Financial Crime Executive Roundtable“; American Conference Institute
* Sep 25: Kansas City, MO; “Import Documentation and Procedures Seminar“; International Business Training 

*
 Sep 25: Leeds, UK; “
Understanding Exporting & Incoterms
“; Chamber International

*
 
Sep 25-26: San Francisco, CA; “
11th West Coast Conference on FCPA Enforcement and Compliance
“; American Conference Institute

* Sep 25-26: Toronto, Canada; ”
4th Forum on Economic Sanctions and Compliance Enforcement“; C5 Group

* Sep 26: Kansas City, MO; “Export Documentation and Procedures Seminar“; International Business Training 
* Sep 26: McLean, VA; “EAR Basics“; FD Associates 
* Sep 26: Oxford, UK; “Intermediate Seminar“; UK Department for International Trade
* Sep 27: Oxford, UK; “Beginner’s Workshop“; UK Department for International Trade
* Sep 27: Oxford, UK; “Licenses Workshop“; UK Department for International Trade
* Sep 27: Oxford, UK; “Control List Classification – Combined Dual Use and Military“; UK Department for International Trade
* Sep 28: Anaheim, CA; “Export Documentation and Procedures Seminar“; International Business Training 

* Oct 2: Bruchem, Netherlands; “Awareness Course U.S. Export Controls: ITAR & EAR From a Non-U.S. Perspective“; Full Circle Compliance

*
 Oct 2: Leeds, UK; “
Export Documentation
“; Chamber International

* Oct 2: Manchester, UK; “E-Z CERT: 
How To Process Your Export Documentation Online
” Greater Manchester Chamber of Commerce;


Oct 3: London, UK; “Control List Classification – Combined Dual-Use and Military“; UK Department for International Trade

Oct 4: London, UK; “Making better License Applications“; UK Department for International Trade

* Oct 5: Boston, MA; “
Incoterms 2010: Terms of Sale Seminar“; International Business Training
* Oct 5: Boston, MA; “ Incoterms: A Strategic Approach“; International Business Training
* Oct 9: New Orleans, LA
; “
Import Documentation and Procedures Seminar
“; International Business Training

* Oct 10: Manchester, UK; “
Export Documentation Training Course
“; Greater Manchester Chamber of Commerce

*
 Oct 10: New Orleans, LA; “Tariff Classification Seminar“; Global Learning Centre

* Oct 11: New Orleans, LA; “Export Documentation and Procedures Seminar“; International Business Training 

*
 Oct 11: Rotterdam, NL; “
Trade Compliance Congres
“; SDU, Customs Knowledge, and EvoFenedex

* Oct 12: New Orleans, LA; “Incoterms 2010: Terms of Sale Seminar“; International Business Training
* Oct 15-19: Chicago, IL; “Certified Classification Specialist“; Global Trade Academy
* Oct 16-18: Dallas, TX; “Partnering for Compliance West Export/Import Control Training and Education Program“; Partnering for Compliance

* 
Oct 16: Kontich, Belgium; “
Export Control Compliance Basics
“; Customs4Trade

* Oct 17: Manchester, UK; “
Understanding Tariff Codes
” Greater Manchester Chamber of Commerce
* October 17-18; Miami/Fort Lauderdale, FL; “11th Maritime Forwarding, Freight Logistics & Global Chain Supply Workshop“; ABS Consulting; albert@abs-consulting.net; 954 218-5285
 

* Oct 18-19: McLean, VA; “ITAR Fundamentals“; FD Associates
* Oct 19: Dallas TX; “
Customs/Import Boot Camp
“; Partnering for Compliance
* Oct 21-23: Grapevine, TX; “2018 Fall Conference“; International Compliance Professionals Association (ICPA)
* Oct 22-26: Dallas, Texas; “Best Customs Broker Exam Course“; GRVR Attorneys
* Oct 22-23: Arlington, VA; “2018 Fall Advanced Conference“; Society for International Affairs (SIA)


Oct 23: Adelaide, Australia; 
Defence Export Controls Outreach
; Australian Department of Defense

*
 Oct 23: Kontich, Belgium; “
Export Control Compliance Basics
“; Customs4Trade

* Oct 24: Leeds, UK; “Intermediate Seminar“; UK Department for International Trade
* Oct 25: Leeds, UK; “Beginner’s Workshop“; UK Department for International Trade
* Oct 25: Leeds, UK; “Licenses Workshop“; UK Department for International Trade
* Oct 25: Leeds, UK; “Control List Classification – Combined Dual Use and Military“; UK Department for International Trade
* Oct 26: Louisville, KY; “Incoterms 2010: Terms of Sale Seminar“; International Business Training
* Oct 26: Milwaukee, WI; “Incoterms: A Strategic Approach“; International Business Training 
* Oct 29 – Nov 1: Phoenix, AZ; ITAR Defense Trade Controls / EAR Export Controls Seminar“; ECTI; jessica@learnexportcompliance.com; 540-433-3977

* Oct 29: Seattle, WA; ”
Export Compliance & Controls 101“; Global Trade Academy

* Oct 30 – Nov 1: Seattle, WA; “Export Controls Specialist – Certification“; Global Trade Academy

Oct 30: Singapore; “
4th Asia Summit on Economic Sanctions
“; American Conference Institute

*
 
Oct 31 – Nov 1: Singapore;
” 7th Asia Summit on Anti-Corruption“;
American Conference Institute


* Nov 6: Detroit, MI; “Classification: How to Classify Parts“; Global Trade Academy


Nov 6: Manchester, UK; “Export Control Symposium Autumn 2018“; UK Department for International Trade


* Nov 7: Detroit, MI; ”
Advanced Classification of Machinery and Electronics“; Global Trade Academy
* Nov 7: Manchester, UK; “
Understanding Incoterms
” Greater Manchester Chamber of Commerce

* Nov 7-9: London, UK; “TRACE European Forum, 2018“; TRACE Anti-Bribery Compliance Solutions
* Nov 7-9: Detroit, MI; “Advanced Classification for Machinery & Electronics“; Global Trade Academy

*
 Nov 8-9: Shanghai, China; “
ICPA China Conference
“; International Compliance Professionals Association

* Nov 12-15: Washington, D.C.; “ITAR Defense Trade Controls / EAR Export Controls Seminar“; ECTI; jessica@learnexportcompliance.com; 540-433-3977
* Nov 13: Tysons Corner, VA; “Made in America, Buy America, or Buy American: Qualify your Goods and Increase Sales“; Global Trade Academy
* Nov 14: Manchester, UK; “Intermediate Seminar“; UK Department for International Trade
* Nov 15: Manchester, UK; “Beginner’s Workshop“; UK Department for International Trade
* Nov 15: Manchester, UK; “Licenses Workshop“; UK Department for International Trade
* Nov 15: Manchester, UK; “Control List Classification – Combined Dual Use and Military“; UK Department for International Trade
* Nov 15: McLean, VA; “ITAR For the Empowered Official“; FD Associates
* Nov 16, San Diego, CA; “Incoterms 2010: Terms of Sale Seminar“; International Business Training

* Nov 20: Manchester, UK; “
How to Claim Duty Relief on Export and Import Processes
” Greater Manchester Chamber of Commerce


Nov 20: Sydney, Australia; 
Defence Export Controls Outreach
; Australian Department of Defense;


Nov 21: London, UK; “Cyber Export Controls“; UK Department for International Trade

* Nov 21: Manchester, UK; “
Introduction to Exporting
” Greater Manchester Chamber of Commerce
 

* Nov 27: Houston, TX; “Duty Drawback Specialist – Certification“; Global Trade Academy
* Dec 3-7: Tysons Corner, VA; “Certified Classification Specialist“; Global Trade Academy 
* Dec 4-5: Frankfurt, Germany; “US Defence Contracting and DFARS Compliance in Europe;” C5 Group
* Dec 5: London, UK; “Intermediate Seminar“; UK Department for International Trade

*
 Dec 6: London, UK; “
Beginner’s Workshop
“; UK Department for International Trad

* Dec 6: London, UK; “Licenses Workshop“; UK Department for International Trade
* Dec 6: London, UK; “Control List Classification – Combined Dual Use and Military“; UK Department for International Trade
* Dec 6: London, UK; “International Documentation and Customs Compliance“; Institute of Export and International Trade

*
 Dec 6: Manchester, UK; “
Export Documentation Training Course
;” Greater Manchester Chamber of Commerce

* Dec 6: Manchester, UK; “
Introduction to Export Controls and Licenses
“; 
* Dec 14: Philadelphia, PA; “Incoterms 2010: Terms of Sale Seminar“; International Business Training
 
2019
 

* Jan 6-7: Long Beach, CA; ”
Fundamentals of FTZ Seminar“;
* Jan 21-24, 2019: San Diego, CA; “ITAR Defense Trade Controls / EAR Export Controls Seminar”; ECTI; 540-433-3977


Feb 6-7: Orlando, FL; “
Boot Camp: Achieving ITAR/EAR Compliance
“; Export Compliance Solutions (ECS)

* Feb 12-13: Washington, D.C.; “
2019 Legislative Summit
“; National Association of Foreign Trade Zones (NAFTZ) 


Mar 26-27: Scottsdale, AZ; “
Seminar Level II: Managing ITAR/EAR Complexities
“; Export Compliance Solutions
 

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


 
* Aug 27: Webinar; ”
Import Documentation and Procedures“; International Business Training

* Sep 6: Webinar; “University Export Controls Program: Strength in Numbers“; 
ECTI; 540-433-3977
* Sep 
19: Webinar; “
International Logistics
“; International Business Training
 

* Sep 24: Webinar; “Tariff Classification: Using the Harmonized Tariff Schedule; International Business Training
* Sep 25: Webinar; “NAFTA Rules of Origin“; International Business Training 

* Sep 26: Webinar; “
US Antiboycott Regulations: Clarified & Demystified
“; ECTI; 540-433-3977

* Oct 15: Webinar; “
Incoterms 2010: Terms of Sale
“; International Business Training  
* Nov 14: Webinar; “An Export Commodity Classification Number – ECCN“; Foreign Trade Association
* Dec 3: Webinar; “Tariff Classification: Using the Harmonized Tariff Schedule; International Business Training 

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

* Dec 20: Webinar; “International Logistics

“; International Business Training  

 

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

ENEDITOR’S NOTES

EN_a116
. Bartlett’s Unfamiliar Quotations

(Source: Editor)

William Wilberforce (24 Aug 1759 – 29 Jul 1833; was an English politician known as a leader of the movement to stop the slave trade.)
  – “If you love someone who is ruining his or her life because of faulty thinking, and you don’t do anything about it because you are afraid of what others might think, it would seem that rather than being loving, you are in fact being heartless.” 
 

Thomas Babington Macaulay (Thomas Babington Macaulay, 1st Baron Macaulay; 25 Oct 1800 – 28 Dec 1859; was a British historian and Whig politician. He wrote extensively as an essayist, on contemporary and historical sociopolitical subjects, and as a reviewer. His 
The History of England was a seminal and paradigmatic example of historiography, and its literary style has remained an object of praise since its publication.)
  
– “Nothing except the mint can make money without advertising.”
 
Friday Funnies.
 
My goal for 2018 was to lose 10 pounds. Only 15 pounds to go!  I don’t mean to brag, but I finished my 14-day diet food in only 3 hours and 20 minutes.
 
  Son:  “Hey Dad —  Why so glum?”
  Dad:  “I’ve been thinking about getting older, and about all the people I’ve lost along the way.”
  Son:  “Hmmm.  So maybe a career as a tour guide wasn’t for you.”

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

EN_a217. 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:
83 FR 17749-17751
: Foreign Trade Regulations (FTR): Clarification on the Collection and Confidentiality of Kimberley Process Certificates

  – HTS codes that are not valid for AES are available 
here.
  –
The latest edition (30 April 2018) of Bartlett’s Annotated FTR (“BAFTR”), by James E. Bartlett III, is available for downloading in Word format. The BAFTR contains all FTR amendments, FTR Letters and Notices, a large Index, and approximately 250 footnotes containing case annotations, practice tips, Census/AES guidance, and explanations of the numerous errors contained in the official text. Subscribers receive revised copies in Microsoft Word every time the FTR is amended.  The BAFTR is available by annual subscription from the Full Circle Compliance 
website
BITAR subscribers are entitled to a 25% discount on subscriptions to the BAFTR. Government employees (including military) and employees of universities are eligible for a 50% discount on both publications at www.FullCircleCompiance.eu
 
* HARMONIZED TARIFF SCHEDULE OF THE UNITED STATES (HTS, HTSA or HTSUSA), 1 Jan 2018: 19 USC 1202 Annex. (“HTS” and “HTSA” are often seen as abbreviations for the Harmonized Tariff Schedule of the United States Annotated, shortened versions of “HTSUSA”.)

  –
Last Amendment: 
14 Aug 2018: 
Harmonized System Update 1812
, containing 27 ABI records and 6 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_a318
. Weekly Highlights of the Daily Bugle Top Stories
(Source: Editor)
 

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

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

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

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

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

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

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

* TO UNSUBSCRIBE: Use the Safe Unsubscribe link below.

Scroll to Top