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18-0917 Monday “Daily Bugle”

18-0917 Monday “Daily Bugle”

Monday, 17 September 2018

TOP
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  1. Commerce/BIS Seeks Comments on Effectiveness of Licensing Procedures for Agricultural Commodities to Cuba
  2. Commerce/ITA Posts Notice on NAFTA Request for Panel Review Concerning Uncoated Groundwood Paper from Canada, Final Determination of Sales at Less Than Fair Value
  3. Commerce/ITA Posts Notice on NAFTA Request for Panel Review Concerning Uncoated Groundwood Paper from Canada, Final Affirmative Countervailing Duty Determination
  1. Items Scheduled for Publication in Future Federal Register Editions
  2. Commerce/BIS: (No new postings.)
  3. State/DDTC: (No new postings.)
  4. Treasury/OFAC Posts Two New Ukraine-/Russia-related FAQs
  5. White House Releases EO Targeting Foreign Interference in U.S. Elections
  6. EU Adopts Regulation Concerning the Classification of Certain Goods in the CN
  1. Expeditors News: “Argentina Establishes Duty on Exports”
  2. Sputnik: “UK Could Face Legal Action Over Exports of Surveillance Tech – NGO”
  3. ST&R Trade Report: “Imports of 28 Chemical Substances to Require Advance Notice”
  1. J. McEachern: “Hurry! Deadline for Filing GSP Retroactive Duty Refund Request is 19 September”
  2. M. Volkov: “The Importance of Pre-Acquisition FCPA Due Diligence (Part II of III)”
  3. T. Murphy: “Miscellaneous Tariff Bill – Signed into Law!”
  1. Monday List of Ex/Im Job Openings: 161 Openings Posted This Week, Including 4 New Openings
  1. FCC to Present U.S. Export Controls Awareness Training Course for Non-U.S. Organizations, 2 Oct in Bruchem, the Netherlands
  1. Bartlett’s Unfamiliar Quotations 
  2. Are Your Copies of Regulations Up to Date? Latest Amendments: ATF (15 Jan 2016), Customs (12 Jun 2018), DOD/NISPOM (18 May 2016), EAR (13 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 on Effectiveness of Licensing Procedures for Agricultural Commodities to Cuba

(Source: Federal Register, 17 Sep 2018.) [Excerpts.]
 
83 FR 46912-46913: Effectiveness of Licensing Procedures for Agricultural Commodities to Cuba
* AGENCY: Bureau of Industry and Security, Commerce.
* ACTION: Request for comments.
* SUMMARY: The Bureau of Industry and Security (BIS) is requesting public comments on the effectiveness of its licensing procedures as defined in the Export Administration Regulations for the export of agricultural commodities to Cuba. BIS will include a description of these comments in its biennial report to the Congress, as required by the Trade Sanctions Reform and Export Enhancement Act of 2000, as amended (TSRA).
* DATES: Comments must be received by October 17, 2018. …
* FOR FURTHER INFORMATION CONTACT: Mark Salinas, Office of Nonproliferation and Treaty Compliance, Telephone: (202) 482-4252. Additional information on BIS procedures and previous biennial reports under TSRA is available here. Copies of these materials may also be requested by contacting the Office of Nonproliferation and Treaty Compliance.
* SUPPLEMENTARY INFORMATION: …
   By this notice, BIS requests public comments on the effectiveness of the licensing procedures for the export of agricultural commodities to Cuba set forth under Sec. 740.18 of the EAR. Parties submitting comments are asked to be as specific as possible. All comments received by the close of the comment period will be considered by BIS in developing the report to Congress.
   All comments must be in writing and will be available for public inspection and copying. Any information that the commenter does not wish to be made available to the public should not be submitted to BIS.
 
   Dated: September 11, 2018.
Richard E. Ashooh, Assistant Secretary for Export Administration.

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

EXIM_a2

2
. Commerce/ITA Posts Notice on NAFTA Request for Panel Review Concerning Uncoated Groundwood Paper from Canada, Final Determination of Sales at Less Than Fair Value

(Source: Federal Register, 17 Sep 2018.)
[Excerpts.]
 
83 FR 46915-46916: North American Free Trade Agreement (NAFTA), Article 1904; Binational Panel Review: Notice of Request for Panel Review
* AGENCY: United States Section, NAFTA Secretariat, International Trade Administration, Department of Commerce.
* ACTION: Notice of NAFTA Request for Panel Review in the matter of Certain Uncoated Groundwood Paper From Canada: Final Determination of Sales at Less Than Fair Value (Secretariat File Number: USA-CDA-2018-1904-05).
* SUMMARY: A Request for Panel Review was filed on behalf of Kruger Trois-Rivieres L.P. (“KTR”), Corner Brook Pulp and Paper Limited (“CBPP”), Kruger Publication Papers Inc. (“KPPI”), and Kruger Brompton L.P. (collectively “Kruger”) with the United States Section of the NAFTA Secretariat on September 7, 2018, pursuant to NAFTA Article 1904. Panel Review was requested in regards to the Department of Commerce’s final antidumping duty determination of Certain Uncoated Groundwood Paper from Canada. The final determination was published in the Federal Register on August 9, 2018 (83 FR 39412). The NAFTA Secretariat has assigned case number USA-CDA-2018-1904-05 to this request.
* FOR FURTHER INFORMATION CONTACT: Paul E. Morris, United States Secretary, NAFTA Secretariat, Room 2061, 1401 Constitution Avenue NW, Washington, DC 20230, (202) 482-5438. …
 
   Dated: September 12, 2018.
Paul E. Morris, U.S. Secretary, NAFTA Secretariat.

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

EXIM_a3

3
. Commerce/ITA Posts Notice on NAFTA Request for Panel Review Concerning
Uncoated Groundwood Paper from Canada,
Final Affirmative Countervailing Duty Determination

(Source: Federal Register, 17 Sep 2018.) [Excerpts.]
 
83 FR 46913-46914: North American Free Trade Agreement (NAFTA), Article 1904; Binational Panel Review: Notice of Request for Panel Review
* AGENCY: United States Section, NAFTA Secretariat, International Trade Administration, Department of Commerce.
* ACTION: Notice of NAFTA Request for Panel Review in the matter of Certain Uncoated Groundwood Paper from Canada: Final Affirmative Countervailing Duty Determination (Secretariat File Number: USA-CDA-2018-1904-06).
* SUMMARY: A Request for Panel Review was filed on behalf of Government of Canada; the Government of Alberta; the Government of British Columbia; the Government of Newfoundland and Labrador; the Government of Ontario; the Government of Quebec; Alberta Newsprint Company; Catalyst Paper Corporation, Catalyst Pulp and Paper Sales Inc. and Catalyst Paper (USA) Inc.; Kruger Trois-Rivieres L.P., Comer Brook Pulp and Paper Limited, Kruger Publication Papers Inc. and Kruger Brompton L.P.; Resolute FP Canada Inc. and Resolute FP US Inc.; and Tembec Inc. with the United States Section of the NAFTA Secretariat on September 10, 2018, pursuant to NAFTA Article 1904. Panel Review was requested of the Department of Commerce’s final affirmative countervailing duty determination regarding Groundwood Paper from Canada. The final determination was published in the Federal Register on August 9, 2018 (83 FR 39414). The NAFTA Secretariat has assigned case number USA-CDA-2018-1904-06 to this request.
* FOR FURTHER INFORMATION CONTACT: Paul E. Morris, United States Secretary, NAFTA Secretariat, Room 2061, 1401 Constitution Avenue NW, Washington, DC 20230, (202) 482-5438. …
 
   Dated: September 12, 2018.
Paul E. Morris, U.S. Secretary, NAFTA Secretariat.

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

OGSOTHER GOVERNMENT SOURCES

OGS_a14. Items Scheduled for Publication in Future Federal Register Editions
(Source: Federal Register)

* Commerce; Census; NOTICES; Agency Information Collection Activities; Proposals, Submissions, and Approvals: Automated Export System Program [Publication Date: 18 September 2018.]
 
* Office of United States Trade Representative; NOTICES; Procedures to Consider Requests for Exclusion of Particular Products from the Additional Action Pursuant to Section 301: China’s Acts, Policies, and Practices Related to Technology Transfer, Intellectual Property, and Innovation [Publication Date: 18 September 2018.]
 
* State; NOTICES; Agency Information Collection Activities; Proposals, Submissions, and Approvals: Request to Change End User, End Use and/or Destination of Hardware [Publication Date: 18 September 2018.]

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

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

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

(Source:
Treasury/OFAC, 14 Sep 2018.)   
 
On 14 September 2018, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) published
two new Frequently Asked Questions (FAQs) to provide guidance on “maintenance” as that term is used in General Licenses (GLs)
14,
15, and
16.

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

(Source:
The White House, 12 Sep 2018.) [Excerpts.]
 
Executive Order (EO) on Imposing Certain Sanctions in the Event of Foreign Interference in a United States Election
 
By the authority vested in me as President by the Constitution and the laws of the United States of America, including the International Emergency Economic Powers Act (50 U.S.C. 1701 et seq.) (IEEPA), the National Emergencies Act (50 U.S.C. 1601 et seq.) (NEA), section 212(f) of the Immigration and Nationality Act of 1952 (8 U.S.C. 1182(f)), and section 301 of title 3, United States Code,
 
I, DONALD J. TRUMP, President of the United States of America, find that the ability of persons located, in whole or in substantial part, outside the United States to interfere in or undermine public confidence in United States elections, including through the unauthorized accessing of election and campaign infrastructure or the covert distribution of propaganda and disinformation, constitutes an unusual and extraordinary threat to the national security and foreign policy of the United States. Although there has been no evidence of a foreign power altering the outcome or vote tabulation in any United States election, foreign powers have historically sought to exploit America’s free and open political system. In recent years, the proliferation of digital devices and internet-based communications has created significant vulnerabilities and magnified the scope and intensity of the threat of foreign interference, as illustrated in the 2017 Intelligence Community Assessment. I hereby declare a national emergency to deal with this threat.
 
Accordingly, I hereby order:
 
Section 1. (a) Not later than 45 days after the conclusion of a United States election, the Director of National Intelligence, in consultation with the heads of any other appropriate executive departments and agencies (agencies), shall conduct an assessment of any information indicating that a foreign government, or any person acting as an agent of or on behalf of a foreign government, has acted with the intent or purpose of interfering in that election. The assessment shall identify, to the maximum extent ascertainable, the nature of any foreign interference and any methods employed to execute it, the persons involved, and the foreign government or governments that authorized, directed, sponsored, or supported it. The Director of National Intelligence shall deliver this assessment and appropriate supporting information to the President, the Secretary of State, the Secretary of the Treasury, the Secretary of Defense, the Attorney General, and the Secretary of Homeland Security.
  (b) Within 45 days of receiving the assessment and information described in section 1(a) of this order, the Attorney General and the Secretary of Homeland Security, in consultation with the heads of any other appropriate agencies and, as appropriate, State and local officials, shall deliver to the President, the Secretary of State, the Secretary of the Treasury, and the Secretary of Defense a report evaluating, with respect to the United States election that is the subject of the assessment described in section 1(a):
    (i) the extent to which any foreign interference that targeted election infrastructure materially affected the security or integrity of that infrastructure, the tabulation of votes, or the timely transmission of election results; and
    (ii) if any foreign interference involved activities targeting the infrastructure of, or pertaining to, a political organization, campaign, or candidate, the extent to which such activities materially affected the security or integrity of that infrastructure, including by unauthorized access to, disclosure or threatened disclosure of, or alteration or falsification of, information or data.
The report shall identify any material issues of fact with respect to these matters that the Attorney General and the Secretary of Homeland Security are unable to evaluate or reach agreement on at the time the report is submitted. The report shall also include updates and recommendations, when appropriate, regarding remedial actions to be taken by the United States Government, other than the sanctions described in sections 2 and 3 of this order.
  (c) Heads of all relevant agencies shall transmit to the Director of National Intelligence any information relevant to the execution of the Director’s duties pursuant to this order, as appropriate and consistent with applicable law. If relevant information emerges after the submission of the report mandated by section 1(a) of this order, the Director, in consultation with the heads of any other appropriate agencies, shall amend the report, as appropriate, and the Attorney General and the Secretary of Homeland Security shall amend the report required by section 1(b), as appropriate.
  (d) Nothing in this order shall prevent the head of any agency or any other appropriate official from tendering to the President, at any time through an appropriate channel, any analysis, information, assessment, or evaluation of foreign interference in a United States election.
  (e) If information indicating that foreign interference in a State, tribal, or local election within the United States has occurred is identified, it may be included, as appropriate, in the assessment mandated by section 1(a) of this order or in the report mandated by section 1(b) of this order, or submitted to the President in an independent report.
  (f) Not later than 30 days following the date of this order, the Secretary of State, the Secretary of the Treasury, the Attorney General, the Secretary of Homeland Security, and the Director of National Intelligence shall develop a framework for the process that will be used to carry out their respective responsibilities pursuant to this order. The framework, which may be classified in whole or in part, shall focus on ensuring that agencies fulfill their responsibilities pursuant to this order in a manner that maintains methodological consistency; protects law enforcement or other sensitive information and intelligence sources and methods; maintains an appropriate separation between intelligence functions and policy and legal judgments; ensures that efforts to protect electoral processes and institutions are insulated from political bias; and respects the principles of free speech and open debate.
 
Sec. 2. (a) All property and interests in property that are in the United States, that hereafter come within the United States, or that are or hereafter come within the possession or control of any United States person of the following persons are blocked and may not be transferred, paid, exported, withdrawn, or otherwise dealt in: any foreign person determined by the Secretary of the Treasury, in consultation with the Secretary of State, the Attorney General, and the Secretary of Homeland Security:
    (i) to have directly or indirectly engaged in, sponsored, concealed, or otherwise been complicit in foreign interference in a United States election;
    (ii) to have materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, any activity described in subsection (a)(i) of this section or any person whose property and interests in property are blocked pursuant to this order; or
    (iii) to be owned or controlled by, or to have acted or purported to act for or on behalf of, directly or indirectly, any person whose property or interests in property are blocked pursuant to this order.
  (b) Executive Order (EO) 13694 of April 1, 2015, as amended by Executive Order 13757 of December 28, 2016, remains in effect. This order is not intended to, and does not, serve to limit the Secretary of the Treasury’s discretion to exercise the authorities provided in Executive Order 13694. Where appropriate, the Secretary of the Treasury, in consultation with the Attorney General and the Secretary of State, may exercise the authorities described in Executive Order 13694 or other authorities in conjunction with the Secretary of the Treasury’s exercise of authorities provided in this order.
  (c) The prohibitions in subsection (a) of this section apply except to the extent provided by statutes, or in regulations, orders, directives, or licenses that may be issued pursuant to this order, and notwithstanding any contract entered into or any license or permit granted prior to the date of this order. …
 
DONALD J. TRUMP
THE WHITE HOUSE,
September 12, 2018.
 
[Editor’s Note:
For more information, see the 
Presidential Message to the US Congress
, and the 
White House Factsheet
.]

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

(Source:
Official Journal of the European Union, 17 Sep 2018.)
 
Regulations
* Commission Implementing Regulation (EU) 2018/1243 of 13 September 2018 concerning the classification of certain goods in the Combined Nomenclature (CN)

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

NWSNEWS

(Source:
Expeditors News, 14 Sep 2018.)
 
On September 3, 2018, the government of Argentina published Decree 793/2018, establishing an export duty on goods in the Mercosur Common Nomenclature (NCM).
 
According to the decree, it was necessary to establish export duties on goods exported out of Argentina due to the international environment, the need to consolidate the fiscal country policies, and the recent currency exchange alterations with its effect on internal prices in Argentina.
 
This new measure establishes a 12% export duty, which is applicable on all goods covered in the NCM out of the country and is in addition to any duty already established for some goods.
 
The enforcement date started on the day of publication of the decree and will last until December 2020.
 
Decree 793/2018 may be found
here.

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

(Source:
Sputnik, 15 Sep 2018.) [Excerpts.]
 
Campaigners are considering taking the UK government to court over their exports of surveillance equipment to regimes believed to be implicated in human rights abuse, which, if proven, constitutes a violation of the European Union’s export rules, Nick Dearden, the director of Global Justice Now (GJN) campaign group, told Sputnik.
 
Under EU legislation such as the Consolidated EU and National Arms Export Licensing Criteria, the United Kingdom is required to consider the potential use of military or dual-use equipment prior to permitting sales to take place. The GJN maintains that the UK is currently exporting a plethora of surveillance-related technology including specialist “intrusion software” and communications monitoring equipment that could potentially be used to crack down on dissent.
 
  “If you look at what [export] procedures there actually are, much of those in Europe and Britain are actually quite good in terms of not selling this stuff when it can be used for human rights abuses, so these procedures are simply not working – they are either being ignored, or loopholes are being found. These are exactly the loopholes we want to see closed, so we’re looking at some kind of judicial review claiming that they [the government] have not followed their own procedures when it comes to exporting this kind of equipment,” Dearden said.
 
The export rules, for instance, stipulate several criteria which should be met to issue relevant export licenses, including holding the “respect for human rights and fundamental freedoms in the country of final destination” as a binding requirement.
 
The United Kingdom, meanwhile, supplies the equipment in question to the countries with “established record of major violations of international human rights,” the campaign group maintains, citing Saudi Arabia, Bahrain and Honduras as examples. …

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

 
The Environmental Protection Agency has issued a direct final rule that will require persons who intend to manufacture (including import) or process any of 28 specified chemical substances for an activity designated as a significant new use by this rule to notify the EPA at least 90 days before commencing that activity. Persons may not commence manufacture or processing for the significant new use until the EPA has conducted a review of the notice, made an appropriate determination, and taken such actions as are required with that determination.
 
Importers must certify that shipments of these substances comply with all applicable rules and orders under the Toxic Substances Control Act, including any SNUR requirements. In addition, any persons who export or intend to export any of these substances on or after Oct. 17 are subject to the export notification provisions of 15 USC 2611(b) and must comply with the export notification requirements in 40 CFR part 707, subpart D.
 
These rules will be effective as of Nov. 16. However, if the EPA receives written adverse or critical comments, or notice of intent to submit such comments, by Oct. 17 it will withdraw the relevant sections of this rule before Nov. 16 and proceed with a related proposed rule.

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

COMMCOMMENTARY

(Source:
Shapiro, 14 Sep 2018.)
 
* Author: Janice McEachern, Classification Specialist, Shapiro.
 
Customs and Border Protection (CBP) has published an official reminder (
CSMS 18-000505) to file Generalized System of Preferences (GSP) refund requests for goods entered or withdrawn from a warehouse for consumption during the lapse period of January 1, 2018 through April 21, 2018.
The three phases of the retroactive duty refund plan are as follows:
 
  –
Phase I – CBP has completed the auto refund processing of importations entered during the lapse with special program indicator (SPI) “A” and checks are forthcoming.
  –
Phase II – CBP began processing manual refunds of importations entered during the lapse with the SPI “A” that may be subject to additional review.
  –
Phase III – Importers wishing to claim GSP preference on importations entered during the lapse period without the SPI “A” must submit a Post Summary Correction (PSC) or protest requesting the GSP refund no later than September 19, 2018.
 
CBP will deny all GSP duty refund requests received after September 19, 2018 (unless the request is a re-submission of a request made prior to the September 19 deadline).

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

(Source:
Volkov Law Group Blog, 12 Sep 2018. Reprinted by permission.)
 
* Author: Michael Volkov, Esq., Volkov Law Group,
mvolkov@volkovlaw.com, 240-505-1992.
 
Several years ago (or in the recent past as some would say), pre-acquisition due diligence was a major compliance focus for global companies that grew through aggressive merger and acquisition strategies. In some respects, and perhaps in reaction to relaxation of some of DOJ’s strict requirements that applied ten years ago (i.e. Halliburton Opinion Letter 08-02), companies appear to be adjusting their compliance priorities and changing the balance between pre-acquisition due diligence and post-acquisition integration to emphasize post-acquisition audits, integration and remediation strategies.
 
I am not so sure that is a good idea because a robust pre-acquisition due diligence program is a critical step in the entire process, especially in planning for an efficient and effective post-acquisition integration of the acquired company. Some compliance officers have confided and complained that they are often brought into the acquisition process too late to conduct meaningful due diligence of the target, and they acknowledged that they rarely have the influence to slow down a transaction even if they find various red flags.
 
Compliance officers have to take a different tack. If they are not getting adequate pre-acquisition notification and access to planning, compliance officers have to change that dynamic. This is too important an issue to relegate it to the “don’t rock the boat” pile.
 
Compliance officers have to design and implement a robust pre-acquisition due diligence program through the company’s policy committee. Frankly, it is just as important as a company’s third-party risk management strategy. In both cases, the FCPA risks are significant and have to be mitigated.
 
A robust pre-acquisition due diligence policy is vital to uncover potential FCPA violations, but is just as important in establishing the proper tone and culture for the target’s company’s integration into the acquiring company’s internal controls and compliance program. The goals of a company’s pre-acquisition due diligence policy should be to:
 
  – Identify potential corruption risks created by the proposed acquisition;
  – Design appropriate anti-corruption contractual representations;
  – Determine the scope and issues that need to be addressed in post-acquisition integration;
  – Evaluate potential changes to personnel, contracts, markets and relationships;
  – Communicate the company’s commitment to ethics and compliance to the target company; and
  – Document the due diligence review and process.
 
The pre-acquisition due diligence process is particularly important in acquisitions of target companies with significant operations in ” high-risk” countries or industries.   For example, if the target company is involved in the construction, defense contracting, energy, health care, mining, telecommunications and transportation sectors, it is important to conduct a robust pre-acquisition due diligence process.
 
Aside from countries and industries of operation, pre-acquisition due diligence, like a comprehensive anti-corruption risk and compliance program assessment, has to focus on:
 
  – Past violations or internal investigations involving potential FCPA corruption issues and red flags such as large-scale fraud, shadow vendors, third-party representatives, and internal accounting control weaknesses;
  – Past violations or allegations involving business integrity or other violations of local laws, including tax, customs, health and safety, environmental, regulatory and permitting compliance;
  – Use of third-party representatives who interact with foreign officials and:  
      (i) require high fees, billing rates, commissions for securing business from foreign officials or influencing foreign representatives on political and business-related issues; or
      (ii) demand unusual payment terms or arrangements, such as payments to accounts in foreign jurisdictions.
  – Use of third-party representatives who appear to lack required qualifications to perform duties required by the engagement or who rely on political contacts as opposed to expertise;
  – Employment of any person or entity based on personal, familial or professional relationships with a government officials (or was suggested by a government official);
  – Contract management system and consistent use of contracts and compliance-related provisions;
  – Charitable donations and/or political contributions that are not subject to due diligence review and approval;
  – Financial transactions with companies and persons who reside or operate outside the jurisdiction in which the goods or services are to be provided;
  – Existence of a code of business ethics and compliance, anti-corruption policies and procedures, and related controls, including gifts, meals, entertainment and travel expenditures; facilitation payments; extortion or threats of harm; due diligence and mergers and acquisitions.
  – Internal accounting controls and examination of adequacy of controls, identified deficiencies and potential corruption-related issues (e.g. invoice-to-payment process) identified in prior assessments;
  – Existing training programs for directors, officers, managers, employees and third-parties;
  – Hotline reports and internal reporting avenues for communication of employee concerns and procedures for responding to and investigating such concerns;
  – Internal investigation procedures and reports, including time-to-close data, nature of allegations, reporting of substantiated violations, resolution of internal investigations, and remediation procedures for such findings;
  – Internal risk assessment, culture assessments and other employee culture assessments conducted by target company;
  – External assessments, reviews and analyses of target company’s compliance program, culture and internal accounting controls.
 
This is not an exhaustive list but it is a good one to get started.
 
Once all red flags are identified, a careful crafting of the target company’s risk profile should be prepared. To avoid any potential liability, the due diligence process has to be documented and all red flags must be thoroughly investigated and resolved.

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

COMM_a315. T. Murphy: “Miscellaneous Tariff Bill – Signed into Law!”
(Source: Author, 14 Sep Aug 2018.)
 
* Author: Ted Murphy, Esq., Baker & McKenzie LLP,  ted.murphy@bakermckenzie.com, +1 202 452 7000.
 
President Trump signed the Miscellaneous Tariff Bill Act of 2018 into law yesterday (13 Sep 2018).
 
All companies should review the list of products included in the MTB.  The provisions are not (supposed to be) company-specific.  Stated differently, any company that imports an article covered by a MTB description can claim the duty benefit (even if you were not the proponent of the provision).  
 
Also, keep in mind that the MTB only impacts the Column 1, General rates of duty for covered articles (i.e., the Most Favored Nation/Normal Trade Relations rates).  The MTB does not change or otherwise impact Section 232 or Section 301 duties; those still apply.

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

MSEX/IM MOVERS & SHAKERS

MS_a116. Monday List of Ex/Im Job Openings: 161 Openings Posted This Week, Including 4 New Openings

(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; 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; 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;


Airbus; Getafe, Spain; VIE Procurement Sustainability Management – Export Compliance; Requistion ID
: 10409879 ER EN EXT 1

Airschott, Inc.; Dulles, VA; Imports/Exports/International Logistics & Business

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

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

* Amazon; Seattle, WA;
 
Global Trade Compliance Analyst;

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

American Trucking Associations (ATA); Arlington, VA;
Mgr Customs, Immigration & Cross-Broder Ops
;

* Arrow; Shanghai, China; Compliance Manager;

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

* BAE
 Systems; Kingsport, TN; 
Government Compliance Manager
; Requisition ID: 41212BR;

*
Boeing; Adelaide, Brisbane, Canberra, Melbourne, Australia; 
Trade Control Specialist
; Requisition ID: 1800072289;

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

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

* Boeing; Zoushan, China; 
 Compliance Analyst
* Boeing; Zoushan, China;
Trade Compliance Manager;
*
Booz Allen Hamilton; NY; 
Associate General Counsel
; Requisition ID: R0035318;

* Bose; Framingham, MA;
Senior Trade Compliance Analyst
;

* CGI, Fairfax, VA; 
Trade Compliance Analyst/Manager
Requisition ID: J0818-1218;


Cobham; Exeter, NH, Lansdale, PA; Export Compliance OfficerAlicia.Neice@yoh.com; Requisition ID 1611
*
Cognizant; Budapest, Hungary; 
Ethics & Compliance Senior Manager Continental Europe

Cognizant;
Mexico City, Mexico; Regional Ethics & Compliance Officer LATAM;
* 
Cognizant; Shanghai, China; Regional Ethics & Compliance Officer – APAC;

Cobham; Lansdale, PA; Export Compliance Officer; Ali Neice Alicia.Neice@yoh.com; Requisition ID 1611;

ConvaTec; Greensboro, NC; Associate Manager, Customs & Trade;

* 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;

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

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


Energizer Holdings; St. Louis, MO; Trade Compliance Analyst; Kieshana Miles,kieshana.miles@energizer.com; Requisition ID: NAM00604;

#
Esterline – Korry Electronics; Everett, WA;
Manager of Trade Compliance
; Requisition ID: 14718BR;

* Expeditors; Amsterdam, Netherlands; 
Regional Compliance SME (Subject-Matter expert) Supervisor On-site

*
 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 II;  

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

* FLIR; Billerica, MA; US Customs Analyst
; 

* FLIR; Meer, Belgium; GTC EMEA Customs Analyst;
* FLIR; Irving, CA; 
Sr. Manager Export Compliance;

* FLIR; Nashua, NH; 
Global Trade Compliance Analyst, Traffic
;
 
*
 FLIR; Billerica, MA;
Global Trade Compliance Analyst, Licensing
;
* Full Circle Compliance; Bruchem, Netherlands;
Legal Analyst, Manager

* General Atomics; San Diego, CA;
Director, Compliance
; Requisition ID: 18549BR

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

* General Atomics; San Diego, CA; 
Import/Export Trade Compliance Administrator – Licensing
Requisition ID: 17968BR

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

* Harris Corporation; Van Nuys, CA; Trade Compliance Specialist; rwellbro@harris.com; Job ID: ES20182408-26963

* Henderson Group Unlimited; Inc; Washington, DC; 
Defense Control Analyst

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

* 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
;

* 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

* Kohls; Menomonee Falls, WI; Senior Manager, Customs Compliance

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

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

* 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 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 
 

* Livingston; CA; 
Import Analyst; 
Requisition ID: 60988
* Livingston; CA; 
Import Specialist; 
Requisition ID: 60644
* Livingston; FL; 
Import Analyst; 
Requisition ID: 59941
* Livingston; GA; 
Import Specialist; 
Requisition ID: 61165
* Livingston; IL; 
Import Specialist; 
Requisition ID: 60803
* Livingston; IL; 
Import Specialist; 
Requisition ID: 60905
* Livingston; IL; 
Client Import Analyst; 
Requisition ID: 60964
* Livingston; NY; 
Client Import Analyst; 
Requisition ID: 61123
* Livingston; NY; 
Release Customs Analyst; 
Requisition ID: 61518
* Livingston; OH; 
Import Analyst; 
Requisition ID: 60702
* Livingston; TX; 
Release Import Analyst; 
Requisition ID: 60867

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

* 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; Orlando, FL; 
Senior International Licensing Analyst
; Requisition ID: 
434225BR 
 


* 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
* 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

* 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; 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
;

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

* PerkinElmer, Inc.; Shelton, CT;
Systems Analyst, Trade Compliance Solutions;

#
Polaris; Minneapolis, MN;
Sr. Global Trade Compliance Specialist, Tariff Classification
; Requisition ID: 11770BR

* 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; Supply Chain Compliance Advisor; Requisition ID:
115557BR

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

* Textron Aviation Inc; Wichita, KS; 
Trade Compliance Specialist
; Requisition ID: 268442

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

* Sierra Nevada Corporation; Denver, CO; 
International Trade Compliance Analyst III
; Requisition ID: R0006075  


#
Solvay; Alpharetta, GA; Anaheim, CA; Greenville, TX; Piedmont, SC; Winona, MN;
Export Compliance Manager
; Requisition ID: GBU007183;

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

* Thales; Cambridge, UK; 
Trade Compliance Support Officer
; Krista Helvey; Requisition ID R0034813;

* Thales; Cambridge, UK; 
Trade Compliance Officer
; Krista Helvey; Requisition ID R0034820;

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

* Toro; Bloomington, MN; 
Import – Export Compliance Manager

*
 
United Technologies – Pratt & Whitney; East Hartford, CT; 
Authorizations and Investigations Specialist

Requisition ID: 70957BR

* 
United Technologies – Pratt & Whitney; East Hartford, CT; 
Export Authorization Manager, ITC Operations
; Requisition ID: 71189BR 
* 
United Technologies – Pratt & Whitney; East Hartford, CT; ITC Site Lead, Hot Section Module Center; Requisition ID: 71012BR
* 
United Technologies – Pratt & Whitney; East Hartford, CT; Senior Export Operations Associate; Requisition ID: 71010BR

* United Technologies – Pratt & Whitney; East Hartford, CT; 
Senior Manager, Digital Systems & Integration
; Requisition ID: 70425BR

* 
United Technologies – Pratt & Whitney; East Hartford, CT; 
Senior Manager, Military ITC Programs
; Requisition ID: 71119BR
* 
United Technologies – Pratt & Whitney; East Hartford, CT; 
Senior Program Manager, ITC Operations
; Requisition ID: 71195BR

* 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

* World Wide Technology; Edwardsville, IL;
International Trade Compliance Specialist
;

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

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

TECEX/IM TRAINING EVENTS & CONFERENCES

TE_a117. 
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 organizations 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

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

ENEDITOR’S NOTES

* Warren E. Burger (Warren Earl Burger; 17 Sep 1907 – 25 Jun 1995; was the 15th Chief Justice of the United States, serving from 1969 to 1986.)
  – “Judges rule on the basis of law, not public opinion, and they should be totally indifferent to pressures of the times.”
 
* Hank Williams (Hiram “Hank” Williams; 17 Sep 1923 – 1 Jan 1953; was an American singer-songwriter. Regarded as one of the most significant and influential American singers and songwriters of the 20th century, Williams recorded 35 singles that reached the Top 10 of the Billboard Country & Western Best Sellers chart, including 11 that ranked number one, including “Move It on Over”, “Lovesick Blues”, “Your Cheatin’ Heart”, “Hey, Good Lookin'”, and “I’m So Lonesome I Could Cry”.  Williams was unable to read or notate music to any significant degree.) 
  – “You got to have smelt a lot of mule manure before you can sing like a hillbilly.”
 
Monday is pun day:
* Yesterday, a clown held the door open for me.  Such a nice jester!
* Q:  What’s the difference between a hippo and a Zippo? 
   A:  A hippo is really heavy, and a Zippo is a little lighter.
* Q: What job did the frog have at the hotel? 
   A: Bellhop

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

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 Amendment: 13 Sep 2018: 83 FR 46391-46392: Addition of Certain Entities to the Entity List, Revision of Entries on the Entity List and Removal of Certain Entities From the Entity List; Correction

  
*
FOREIGN ASSETS CONTROL REGULATIONS (OFAC FACR)
: 31 CFR, Parts 500-599, Embargoes, Sanctions, Executive Orders

  – Last Amendment: 29 June 2018: 83 FR 30541-30548: Global Magnitsky Sanctions Regulations; and 83 FR 30539-30541: Removal of the Sudanese Sanctions Regulations and Amendment of the Terrorism List Government Sanctions Regulations 

 
*
FOREIGN TRADE REGULATIONS (FTR)
: 15 CFR Part 30
  – Last Amendment: 24 Apr 2018: 3 FR 17749-17751: Foreign Trade Regulations (FTR): Clarification on the Collection and Confidentiality of Kimberley Process Certificates
  – HTS codes that are not valid for AES are available
here.
  – The latest edition (30 Apr 2018) of Bartlett’s Annotated FTR (“BAFTR”), by James E. Bartlett III, is available for downloading in Word format. The BAFTR contains all FTR amendments, FTR Letters and Notices, a large Index, and approximately 250 footnotes containing case annotations, practice tips, Census/AES guidance, and explanations of the numerous errors contained in the official text. Subscribers receive revised copies in Microsoft Word every time the FTR is amended. The BAFTR is available by annual subscription from the Full Circle Compliance websiteBITAR subscribers are entitled to a 25% discount on subscriptions to the BAFTR. Government employees (including military) and employees of universities are eligible for a 50% discount on both publications at www.FullCircleCompiance.eu.  
 
*
HARMONIZED TARIFF SCHEDULE OF THE UNITED STATES (HTS, HTSA or HTSUSA)
, 1 Jan 2018: 19 USC 1202 Annex. (“HTS” and “HTSA” are often seen as abbreviations for the Harmonized Tariff Schedule of the United States Annotated, shortened versions of “HTSUSA”.)
  –
Last Amendment: 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_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, 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 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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