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18-0907 Friday “Daily Bugle”

18-0907 Friday “Daily Bugle”

Friday, 7 September 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/BIS Seeks Comments Concerning Licensing Responsibilities and Enforcement
  1. Items Scheduled for Publication in Future Federal Register Editions 
  2. Commerce/BIS: (No new postings.)
  3. DHS/CBP Updates Export Manifest Appendix I
  4. State/DDTC: (No new postings.)
  5. EU Amends Restrictive Measures Concerning Iraq
  6. German BAFA Releases Update Concerning Demilitarization of War Weapons
  7. Singapore Customs Publishes Circular Concerning the Implementation of the ROO and OCP Under CECA
  1. Nikkei Asian Review: “U.S. Chip Industry to Warn Trump Against Export Controls on Chinese Trade”
  2. Reuters: “France Says It Must Use Fewer U.S. Parts in Its Weapons Systems”
  3. WorldECR: “Swiss Plans to Ease Arms Export Controls Criticized After Weapons Found In Syria”
  1. L. Feldman: “The Art of the Trade Deal 2.0 – Update on Top Strategies to Avoid or Reduce Section 232 and 301 Duty Increases”
  2. T. Stocker: “UK Firms Are Stuck in The Export Sanctions Maze”
  1. 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 (4 Sep 2018), FACR/OFAC (29 Jun 2018), FTR (24 Apr 2018), HTSUS (14 Aug 2018), ITAR (30 Aug 2018) 
  3. Weekly Highlights of the Daily Bugle Top Stories 

EXIMITEMS FROM TODAY’S FEDERAL REGISTER

EXIM_a1

1. 
Commerce/BIS Seeks Comments Concerning Licensing Responsibilities and Enforcement
(Source: Federal Register, 7 Sep 2018.) [Excerpts.] 
 
83 FR 45414: Submission for OMB Review; Comment Request; Licensing Responsibilities and Enforcement
 
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: Licensing Responsibilities and Enforcement.
  – Form Number(s): N/A.
  – OMB Control Number: 0694-0122.
  – Type of Review: Regular submission. … 
  – Needs and Uses: This collection of information involves nine miscellaneous activities described in section 758 of the Export Administration Regulation[s] (EAR) that are associated with the export of items controlled by the Department of Commerce. Most of these activities do not involve submission of documents to BIS but instead involve exchange of documents among parties in the export transaction to insure that each party understands its obligations under U.S. law. Others involve writing certain export control statements on shipping documents or reporting unforeseen changes in shipping and disposition of exported commodities. These activities are needed by the Office of Export Enforcement and the U.S. Customs Service to document export transactions, enforce the EAR and protect the National Security of the United States. … 
 
This information collection request may be viewed 
here. 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, Department Lead PRA Officer, Office of the Chief Information Officer.

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

OGSOTHER GOVERNMENT SOURCES

OGS_a12
. Items Scheduled for Publication in Future Federal Register Editions
 

(Source:
Federal Register)
 
* Commerce/BIS; NOTICES; Change in Comment Deadline for Section 232 National Security Investigation of Imports of Uranium [Publication Date: 10 Sep 2018.]
 
* Commerce/BIS; RULES; Revisions to the Requirements for Submissions of Exclusion Requests and Objections to Submitted Requests for Steel and Aluminum [Publication Date: 11 Sep 2018.]
 
* DHS/CBP; NOTICES; Meetings: Commercial Customs Operations Advisory Committee [Publication Date: 10 Sep 2018.]
 
* Justice; ATF; NOTICES; Agency Information Collection Activities; Proposals, Submissions, and Approvals
[Publication Dates: 10 Sep 2018.]:
  – Report of Theft or Loss of Explosives; and
  – Transactions Among Licensee/Permittees and Transactions Among Licensees and Holders of User Permits  
 
* Treasury/OFAC; NOTICES; Blocking or Unblocking of Persons and Properties [Publication Dates: 10 Sep 2018.]
 
[Editor’s Note: The below document was withdrawn from public inspection by the Office of the Federal Register due to “technical errors”:
* Commerce/BIS; RULES; Entity List; Additions, Revisions, Removals.]

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

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

OGS_3
4. 
DHS/CBP Updates Export Manifest Appendix I

(Source: 
CSMS# 18-000522, 6 Sep 2018.) 

CBP has updated the Export Manifest Appendix I – Reference and Exemption Codes 
here.

  – Related CSMS No. 18-000445, 18-000515

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

OGS_a4
5. 
State/DDTC: (No new postings.)

(Source: 
State/DDTC)

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

OGS_a5
6. 
EU Amends Restrictive Measures Concerning Iraq

(Source: 
Official Journal of the European Union, 7 Sep 2018.) 
 
Regulations

Commission Implementing Regulation (EU) 2018/1218 of 6 September 2018 amending Council Regulation (EC) No 1210/2003 concerning certain specific restrictions on economic and financial relations with Iraq

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

OGS_a6
7. 
German BAFA Releases Update Concerning Demilitarization of War Weapons

(Source: Editor, 7 Sep 2018.) 
 
Effective 1 Sep 2018, the process of demilitarization of War Weapons in Germany is governed by Ordinance on the Disarmament of Military Weapons. The competent authority for the demilitarization of War Weapons is the German Federal Ministry for Economic Affairs and Energy (BMWi). Upon request, it can determine that a good has lost its war weapon character and can be described as unusable.
 
  In German: Verordnung über die Unbrauchbarmachung von Kriegswaffen und über den Umgang mit unbrauchbar gemachten Kriegswaffen (KrWaffUnbrUmgV)
 
You can find the update [in  German] on the German Federal Office for Economic Affairs and Export Control (BAFA) website 
here.

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

OGS_a7
8. 
Singapore Customs Publishes Circular Concerning the Implementation of the ROO and OCP Under CECA

(Source: 
Singapore Customs, 7 Sep 2018.) 
 
Singapore Customs has published 
Circular No. 09/2018 concerning the implementation of the revised Rules of Origin (ROO) and Operational Certification Procedures (OCP) under the India-Singapore Comprehensive Economic Cooperation Agreement (CECA).  

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

NWSNEWS

(Source: 
Nikkei Asian Review, 7 Sep 2018.) [Excerpts.] 
 
Attempt to curb Beijing’s ‘Made in China 2025’ could be devastating say companies
 
The U.S. semiconductor industry will warn President Donald Trump’s administration that curbs on exports of chips and equipment to China could damage American jobs when representatives travel to Washington in two weeks to lobby against a new wave of constraints on Chinese trade, according to top supplier KLA-Tencor.
 
  “There is a business risk if the U.S. administration puts export controls [on China],” Oreste Donzella, KLA-Tencor’s senior vice president and chief marketing officer, said in a news briefing at the SEMICON Taiwan exhibition on Thursday. “This is huge business to the U.S. economy. I cannot imagine the White House would reduce the economy when we [U.S. chip and equipment suppliers] make a lot of money from the exports.”
 
Donzella said he remained hopeful that export controls would be avoided. …

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

(Source: 
Reuters, 6 Sep 2018.) 
 
France must cut its dependence on U.S. components in its weapons systems to minimize Washington’s ability to block its arms exports, its defense minister said on Thursday.
 
U.S. export control laws can be used to limit European weapons sales if even small components come from U.S. suppliers. That legislation was in place prior to Donald Trump’s presidency, but the industry has grown increasingly worried that his administration is acting to halt exports that might have been permitted in the past.
 
Washington has this year blocked the sale to Egypt of French-made SCALP cruise missiles, which contain a U.S. part.
 
Without giving specific examples, Defence Minister Florence Parly said France needed to “gradually wean ourselves off our reliance on a certain number of American parts.”
 
  “We have had trade difficulties linked to the prospects for exports. And we know that these difficulties are linked to strategic questions and often to problems of commercial rivalry,” she told a small group of journalists.
 
She was quizzed on the subject in July by parliament’s defense committee.
 
Asked at that time by one lawmaker about the blocked SCALP sale, Parly said: “We are at the mercy of the Americans.”
 
Parly said Washington’s actions underlined the need to minimize dependence on U.S. parts in the Future Combat Air System (SCAF) project – Europe’s next-generation combat jet which France and Germany are taking the lead in developing.
 
France’s Dassault Aviation and European planemaker Airbus have signed a deal to work together on the jet, which is expected to be at the center of a broader weapons system capable of commanding a squadron of drones.
 
France’s air force uses Reaper drones, built by U.S. firm General Atomics, in its counter-terrorism operations against Islamist militants. Parly said France had needed U.S. congressional approval to arm the drones.
 
  “Is that satisfactory? No. But we don’t have any choice,” she said.

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NWS_a3
11. 
WorldECR: “Swiss Plans to Ease Arms Export Controls Criticized After Weapons Found In Syria”
(Source: 
WorldECR, 7 Sep 2018.) [Excerpts.] 
 
Criticisms follow reports that ISIS in Syria had Swiss-made weapons.
 
Switzerland’s plan to ease arms export controls has been strongly criticized following press reports that Swiss-made weapons were found in the hands of ISIS (‘Daesh’) in Syria.
 
In June, the Federal Council decided to relax its ordinance on war materiel, a decision supported by two parliamentary committees. The move would allow arms to be exported to countries in internal conflict – provided there is no reason to believe the arms will be used in the conflict – which is currently banned.
 

On 2 September, Swiss newspaper SonntagsBlickreported that hand grenades made by Swiss manufacturer RUAG had been photographed in an arms cache seized from an ISIS cell in Syria.  According to Reuters, RUAG has since acknowledged that it produced the arms, which could have been part of a batch sold to the United Arab Emirates (‘UAE’) some 15 years ago. … 

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

COMMCOMMENTARY

COMM_a1
12.
L. Feldman: “The Art of the Trade Deal 2.0 – Update on Top Strategies to Avoid or Reduce Section 232 and 301 Duty Increases”

(Source: 
Sandler, Travis & Rosenberg Trade Report, 7 Sep 2018.) [Excerpts.] 
 
* Author: Lenny Feldman, Managing Member of Sandler, Travis & Rosenberg, 
lfeldman@strtrade.com.
 
U.S. importers, exporters, and manufacturers are continuing to look for ways to mitigate the impact of the 10 to 25 percent additional tariffs the U.S. has levied on tens of billions of dollars’ worth of imported goods, including steel and aluminum from all global sources and hundreds of products from China, as well as the retaliatory tariffs U.S. trading partners are imposing on U.S. exports. Despite on-going policy changes, there are a number of proven and legitimate ways to avoid or reduce these duties that companies are beginning to use with great success. This article provides an update on several duty-busting strategies that companies can use in structuring their own trade deals. … 
 
Exclusion Requests. Both the Department of Commerce (for aluminum and steel) and the Office of the U.S. Trade Representative (for China goods) have implemented processes to accept requests that specific products be excluded from the tariffs. These processes offer companies or trade associations an opportunity to explain how and why particular goods are critical to the U.S. economy and could not be sourced elsewhere. The DOC has outright rejected requests that do not adhere to the specific criteria but granted exclusions in other cases. USTR has yet to respond to product-specific requests for exclusion from the Section 301 tariffs on $34 billion worth of imports from China (the so-called list 1 tariffs) and the deadline for submitting such requests is Oct. 9. However, the DOC recently announced that it will also accept requests for exclusions from the import quotas on steel and aluminum from the few countries that negotiated such quotas and USTR could soon begin accepting Section 301 tariff exclusion requests for an additional $16 billion worth of Chinese goods (the so-called list 2 tariffs).
 
Tariff Engineering. As much as U.S. Customs and Border Protection has resisted the idea in the past, the courts have affirmed for years that CBP can only levy tariffs on the condition of goods as imported. This has led importers in a variety of industries where high duties prevail to import products in unfinished or embellished forms to legally take advantage of classification provisions carrying a lower or free rate of duty. For instance, products ranging from turbine generators and split system air conditioners that are typically imported into the U.S. complete will now likely be subject to an additional 25 percent tariff. However, if the components of such goods are imported separately they would fall into an entirely different tariff provision that is currently excluded from that tariff increase. Despite the government’s recent narrowing of its policy, classification concepts are particularly useful for certain U.S. or other products that fall within the special HTSUS Chapter 98 provisions, many of which are wholly or partially exempt from the additional tariffs.
 
Operational Engineering. If you cannot modify the tariff provision for an imported product you might be able to change its country of origin. For instance, CBP has found that the assembly of numerous parts to create various modules or motors, and their subsequent assembly into engines or dedicated machines, results in a substantial transformation of the parts so that their country of origin is where the finished product is produced. Shifting key operations from one country to another may thus enable your company to escape a duty increase.
 
Valuation. First sale valuation is a strategy that has long proven useful to industries that have been subject to high duties. Importers only pay duty on the price that a trading company pays the manufacturer instead of the higher price the importer pays the trading company. While the additional tariffs would still apply in this scenario, the dutiable value is significantly lower, resulting in a lower duty bill. Various criteria must be met to ensure the first sale price reflects a sale that is clearly destined to the U.S. and conducted at arm’s length, but, once validated, a viable first sale value can provide substantial duty savings. It can also serve as a type of long-term annuity; i.e., even once the additional tariffs expire, use of first sale valuation would continue to provide a lower declared value and thus reduce the regular duties assessed on a company’s products.
 
Bonded Facilities. For those companies involved in manufacturing as well as import for export trade, bonded facilities are providing a safe haven from the additional tariffs. Goods admitted to a foreign-trade zone in privileged foreign status will retain their character and tariff classification as admitted even if they are manufactured into a product affected by the additional tariffs that may be withdrawn from the zone and entered for U.S. consumption. In addition, goods otherwise subject to the additional tariffs could be entered and stored in a bonded warehouse for up to five years to avoid those duties if they are (a) exported directly from the warehouse or (b) entered for U.S. consumption once the additional tariffs have lapsed or a product-specific exclusion has been granted.
 
Duty Drawback.  Drawback, which provides for the refund of 99 percent of duties and fees paid on goods imported into the U.S. that are subsequently exported, is available for section 301 duties. Although CBP is not paying drawback for section 232 duties, it is unclear that the president had the authority to eliminate drawback under his import authority. Now, the stakes are even higher as CBP transitions from its core drawback regulatory process to the broader one provided for under the Trade Facilitation and Trade Enforcement Act.
 
Section 321 De Minimis.  CBP laws and regulations provide for a duty exemption for goods manifested at less than $800 fair retail value in the country of shipment if imported by one person on one day.  Although it appears this option is not available for section 232, CBP has confirmed that it applies to section 301 duties. In assessing this opportunity, parties should carefully consider the accuracy of the information provided for de minimis shipments to avoid cargo holds and possibly seizures due to partner government agency or intellectual property compliance issues.
 
When assessing particular duty savings models, importers, exporters, and manufacturers need to consider the art of crafting their own trade deals to effectively escape or limit the impact of the section 232 and 301 tariffs. A bit of flexibility and ingenuity can have a profound impact on a company’s bottom line when facing substantial duty exposure.

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COMM_a2a
13. 
T. Stocker: “UK Firms Are Stuck in The Export Sanctions Maze”
(Source: 
The Scotsman, 7 Sep 2018.) [Excerpts.] 
 
* Author: Tom Stocker, Partner at Pinsent Masons, 
 
Increasingly, the US, the EU and the UK implement trade and financial sanctions as a foreign policy tool, as well as to tackle persons connected with financing terrorism.
 
During the past decade, the EU and the US have mainly adopted a consistent approach to sanctions. However, that changed with the US re-imposing extra-territorial sanctions against Iran and threatening to enforce these against non-US businesses. In parallel, an EU Blocking Statute is aimed at countering the effect of US sanctions on EU economic operators engaging in lawful activity with third countries.
 
Against this backdrop, exporting can be a daunting prospect, but the UK and Scottish governments are making considerable efforts to encourage exporters and to explain the support that is available.
 
A new UK authority called the Office of Financial Sanctions Implementation (OFSI) has been established to better inform businesses of the risks that arise from sanctions. …

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

TEEX/IM TRAINING EVENTS & CONFERENCES

TE_a3
14. 
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

 


* 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; Cleveland, OH; “
Documenting Export Compliance
“; Cleveland State University
 

* 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 23-24: New Orleans, LA; “
Complying with U.S. Export Controls – 2 Days
“; 
Commerce/BIS;

* 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 25: New Orleans, LA; “
How to Build an Export Compliance Program – 1 Day
“; 
Commerce/BIS;

* 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 30 – Nov 1: Chicago, IL; “
Export Controls Specialist – Certification
“; Global Trade Academy

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


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

* Nov 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

* Jan 30-31: Washington, DC; “
5th National Forum on CFIUS
;” American Conference Institute (ACI)

* 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 


 


Sep 19; Webinar; “Drastic Regulatory Changes for China Trade Management“, Amber Road

* 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 25: Webinar; “
Meeting CBP’s Informed Compliance and Reasonable Care Standards
;” Sandler, Travis & Rosenberg, P.A. (ST&R)

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

* Oct 2: Webinar; “
Mitigating Section 301 Duties With First Sale Customs Valuation
;” Sandler, Travis & Rosenberg, P.A. (ST&R)
* Oct 10: Webinar; “
Advanced Classification, Part 2
;” Sandler, Travis & Rosenberg, P.A. (ST&R)

* 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_a115
. Bartlett’s Unfamiliar Quotations

(Source: Editor)

Elizabeth I (7 Sep 1533 – 24 Mar 1603; was Queen of England and Ireland from 17 November 1558 until her death on 24 March 1603. Elizabeth was the daughter of Henry VIII and Anne Boleyn, his second wife, who was executed two-and-a-half years after Elizabeth’s birth.) 

 
 – “Brass shines as fair to the ignorant as gold to the goldsmiths.” 
  – “The past cannot be cured.”

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

EN_a216. 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: 
4 Sep 2018: 
83 FR 44821-44828
: Addition of Certain Entities to the Entity List, Revision of Entries on the Entity List and Removal of Certain Entities From the Entity List

 

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: 
30 Aug 2018:
83 FR 44228-44229
, USML Chapter XI(c).
  – The only available fully updated copy (latest edition: 30 Aug 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_a317
. 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.

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