18-0918 Tuesday “Daily Bugle”

18-0918 Tuesday “Daily Bugle”

Tuesday, 18 September 2018

The Daily Bugle is a free daily newsletter from Full Circle Compliance, containing changes to export/import regulations (ATF, DOE/NRC, Customs, NISPOM, EAR, FACR/OFAC, FAR/DFARS, FTR/AES, HTSUS, and ITAR), plus news and events.  Subscribe 
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  1. Commerce/Census Seeks Comments on Automated Export System Program
  2. State/DDTC Seeks Comments on Form DS-6004, Request to Change End User, End Use and/or Destination of Hardware
  3. USTR Seeks Requests for Exclusion of Particular Products from Additional Action Pursuant to Section 301 Concerning China
  1. Items Scheduled for Publication in Future Federal Register Editions
  2. Commerce/BIS: (No new postings.)
  3. State/DDTC: (No new postings.)
  4. President Places Additional Tariffs on $200 Billion of Imports from China
  1. American Shipper: “Antiboycott Rules Can Bite Exporters, Forwarders”
  1. M. Volkov: “The Real Focus for Compliance: Post-Acquisition Integration of an Acquired Company (Part III of III)”
  2. T. Murphy: “Section 301 — The U.S. Imposes Additional Duties on ~$200 Billion Worth of Chinese-Origin Imports”
  1. ECS Presents “Seminar Level II: Managing ITAR/EAR Complexities” in Scottsdale, AZ on 26-27 Mar 2019
  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 



. Commerce/Census Seeks Comments on Automated Export System Program

(Source: Federal Register, 18 Sep 2018.) [Excerpts.]
83 FR 47129-47130: Proposed Information Collection; Comment Request; Automated Export System Program
* AGENCY: U.S. Census Bureau, Commerce.
* ACTION: Notice. …
* DATES: To ensure consideration, written comments must be submitted on or before November 19, 2018.
* ADDRESSES: Direct all written comments to Jennifer Jessup, Departmental Paperwork Clearance Officer, Department of Commerce, Room 6616, 14th and Constitution Avenue NW, Washington, DC 20230 (or via the internet at docpra@doc.gov).
* FOR FURTHER INFORMATION CONTACT: Requests for additional information or copies of the information collection instrument(s) and instructions should be directed to Kiesha Downs, Chief, Trade Regulations Branch, U.S. Census Bureau, 4600 Silver Hill Road, Washington, DC 20233-6700, (301) 763-7079, by fax (301) 763-8835 or by email kiesha.downs@census.gov.
   The Automated Export System (AES) or successor system is the instrument used for collecting export trade information from parties exporting goods from the United States. The U.S. Census Bureau compiles data collected through the AES and these data are the basis for the official U.S. goods export trade statistics. These statistics are used to determine the balance of international trade and are also designated for use as a principal federal economic indicator. Title 13, United States Code (U.S.C.), Chapter 9, Section 301 authorizes the U.S. Census Bureau to collect, compile and publish export trade data. Title 15, Code of Federal Regulations, Part 30, contains the regulatory provisions for preparing and filing the AES record in accordance to the Foreign Trade Regulations (FTR). These data are used in the development of U.S. Government policies that affect the economy. These data also enable U.S. businesses to develop practical export marketing strategies as well as provide a means for the assessment of the impact of exports on the domestic economy. In addition to being used in the development of U.S. government economic and foreign trade policies, these data are also used for export control, to detect and prevent the export of certain items by unauthorized parties or to unauthorized destinations or end users.
   The FTR was amended on April 19, 2017, through the issuance of a Final Rule, “Clarification on Filing Requirements,” to make changes related to the implementation of the International Trade Data System (ITDS), in accordance with the Executive Order 13659, Streamlining the Export/Import Process for American Businesses. The ITDS was established by the Security and Accountability for Every (SAFE) Port Act of 2006. The ITDS is an electronic information exchange capability, or “single window,” through which businesses transmit the data required by participating agencies for the importation or exportation of cargo. This rule added the original Internal Transaction Number (ITN) data element in the AES. The Original ITN field is an optional field that may be utilized if the filer has to create an additional AES record for a shipment that was previously filed. The Original ITN field assists the export trade community and enforcement agencies in identifying that a filer completed the mandatory filing requirements for the original shipment. In doing so, this may decrease the issuance of unnecessary penalties for these types of shipments. Overall, these changes did not impact the reporting burden of the export trade community.
   The FTR was also amended on April 24, 2018, through the issuance of a Final Rule, “Clarification on the Collection and Confidentiality of Kimberley Process Certificates,” to clarify that the data collected from the Kimberley Process Certificates (KPCs) are collected in compliance with the Clean Diamond Trade Act. In addition, this Rule clarified the submission requirements and permissible uses of the KPCs. However, these changes did not impact the reporting burden of the export trade community.
   Currently, the Census Bureau is drafting a Notice of Proposed Rulemaking (NPRM) to clarify the responsibilities of parties participating in routed and standard export transactions. This rule also proposes to revise and add several key terms used in the regulatory provision of these transactions, including authorized agent, forwarding agent, standard export transaction and written release. While revisions to the FTR are necessary to improve clarity to the filing requirements for the routed export transaction, it is critical for the Census Bureau to ensure that any revisions made to the FTR will allow for the continued collection and compilation of accurate trade statistics. Additionally, it is important that the responsibilities of the U.S. Principal Party in Interest (USPPI) and the U.S. authorized agent are clearly defined to ensure that the Electronic Export Information is filed by the appropriate party to prevent receiving duplicate filings or in some cases, no filings. The changes proposed in the NPRM will not have an impact on the reporting burden of the export trade community. …
  Sheleen Dumas, Departmental Lead PRA Officer, Office of the Chief Information Officer.

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. State/DDTC Seeks Comments on Form DS-6004, Request to Change End User, End Use and/or Destination of Hardware

(Source: Federal Register, 18 Sep 2018.) [Excerpts.]
83 FR 47235-47236: 60-Day Notice of Proposed Information Collection: Request To Change End User, End Use and/or Destination of Hardware
* ACTION: Notice of request for public comment. …
* DATES: The Department will accept comments from the public up to November 19, 2018.
* ADDRESSES: You may submit comments by any of the following methods:
  – Web: Persons with access to the internet may comment on this notice by going to www.Regulations.gov. You can search for the document by entering “Docket Number: DOS-2018-0041” in the Search field. Then click the “Comment Now” button and complete the comment form.
  – Regular Mail: Send written comments to: Directorate of Defense Trade Controls, Attn: Andrea Battista, 2401 E St. NW, Suite H-1205, Washington, DC 20522-0112.
   You must include the subject (PRA 60 Day Comment), information collection title (Request to Change End User, End Use, and/or Destination Hardware), and OMB control number (1405-0173 in any correspondence.
* FOR FURTHER INFORMATION CONTACT: Direct requests for additional information regarding this collection to Andrea Battista, who may be reached at BattistaAL@state.gov or 202-663-3136.
  – Title of Information Collection: Request to Change End User, End Use and/or Destination of Hardware.
  – OMB Control Number: 1405-0173.
  – Type of Request: Extension of a Currently Approved Collection.
  – Originating Office: Directorate of Defense Trade Controls (DDTC).
  – Form Number: DS-6004. …
  – Abstract of Proposed Collection
  The Request to Change End-User, End-Use and/or Destination of Hardware information collection is used to request DDTC approval prior to any sale, transfer, transshipment, or disposal, whether permanent or temporary, of classified or unclassified defense articles to any end-user, end-use or destination other than as stated on a license or other approval. …
  Anthony M. Dearth, Chief of Staff, Directorate of Defense Trade Controls, U.S. Department of State.

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. USTR Seeks Requests for Exclusion of Particular Products from Additional Action Pursuant to Section 301 Concerning China

(Source: Federal Register, 18 Sep 2018.) [Excerpts.]
83 FR 47236-47238: 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
* AGENCY: Office of the United States Trade Representative (“USTR”).
* ACTION: Notice and request for comments.
* SUMMARY: In a notice published on August 16, 2018 (83 FR 40823), the U.S. Trade Representative (Trade Representative) determined to take an additional action in the Section 301 investigation of China’s acts, policies, and practices related to technology transfer, intellectual property, and innovation. The August 16 notice also announced that the Trade Representative would establish a process by which U.S. stakeholders may request that particular products classified within a tariff subheading covered by the additional action be excluded from the additional duties. This notice sets out the specific procedures and criteria related to requests for product exclusions, and opens up a docket for the receipt of exclusion requests.
* DATES: USTR must receive all requests to exclude a particular product by December 18, 2018. Responses to a request for exclusion of a particular product are due 14 days after the request is posted in docket number USTR-2018-0032 on www.regulations.gov. Any replies to responses to an exclusion request are due the later of 7 days after the close of the 14-day response period, or 7 days after the posting of a response.
* ADDRESSES: USTR strongly prefers electronic submissions made through the Federal eRulemaking Portal. Follow the instructions for submitting requests for exclusion, responses to requests, and replies to responses in section B below. The docket number is USTR-2018-0032.
* FOR FURTHER INFORMATION CONTACT: For questions about the product exclusion process, contact Assistant General Counsels Megan Grimball or Philip Butler, or Director of Industrial Goods Justin Hoffmann at (202) 395-5725. For questions on customs classification or implementation of additional duties, contact traderemedy@cbp.dhs.gov.
  After review, the Trade Representative determined to impose additional duties on 279 tariff subheadings, with an annual trade value of approximately $16 billion. See 83 FR 40823 (August 16, 2018). The additional duties on these products took effect on August 23, 2018.
  During the notice and comment process, a number of interested persons asserted that specific products within a particular tariff subheading only were available from China, that the imposition of additional duties on the specific products would cause severe economic harm to a U.S. interest, and that the specific products were not strategically important or related to the “Made in China 2025” program. In light of such concerns, the Trade Representative determined to establish a process by which U.S. stakeholders may request that particular products classified within a covered HTSUS subheading be excluded from the additional action. That process is set out in the remainder of this notice. …
  Robert E. Lighthizer, United States Trade Representative.

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

* State; NOTICES; Agency Information Collection Activities; Proposals, Submissions, and Approvals: Annual Brokering Report [Publication Date: 19 September 2018.]
* State; NOTICES; Determinations; Use of Chemical Weapons by Russia under the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991; Correction [Publication Date: 19 September 2018.]
* Treasury; Foreign Assets Control Office; NOTICES; Blocking or Unblocking of Persons and Properties [Publication Date: 19 September 2018.]
* U.S. Customs and Border Protection; RULES; Extension of Import Restrictions Imposed on Archaeological Material from Cambodia [Publication Date: 19 September 2018.]
* U.S. Customs and Border Protection; NOTICES; Agency Information Collection Activities; Proposals, Submissions, and Approvals: Application for Foreign-Trade Zone Admission and/or Status Designation, and Application for Foreign-Trade Zone Activity Permit [Publication Date: 19 September 2018.]
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The White House, 17 Sep 2018.)
Today [Yesterday, ed.], following seven weeks of public notice, hearings, and extensive opportunities for comment, I directed the United States Trade Representative (USTR) to proceed with placing additional tariffs on roughly $200 billion of imports from China.  The tariffs will take effect on September 24, 2018, and be set at a level of 10 percent until the end of the year.  On January 1, the tariffs will rise to 25 percent.  Further, if China takes retaliatory action against our farmers or other industries, we will immediately pursue phase three, which is tariffs on approximately $267 billion of additional imports.
We are taking this action today as a result of the Section 301 process that the USTR has been leading for more than 12 months.  After a thorough study, the USTR concluded that China is engaged in numerous unfair policies and practices relating to United States technology and intellectual property – such as forcing United States companies to transfer technology to Chinese counterparts.  These practices plainly constitute a grave threat to the long-term health and prosperity of the United States economy.
­For months, we have urged China to change these unfair practices, and give fair and reciprocal treatment to American companies.  We have been very clear about the type of changes that need to be made, and we have given China every opportunity to treat us more fairly.  But, so far, China has been unwilling to change its practices.  To counter China’s unfair practices, on June 15, I announced that the United States would impose tariffs of 25 percent on $50 billion worth of Chinese imports.  China, however, still refuses to change its practices – and indeed recently imposed new tariffs in an effort to hurt the United States economy.
As President, it is my duty to protect the interests of working men and women, farmers, ranchers, businesses, and our country itself.  My Administration will not remain idle when those interests are under attack.
China has had many opportunities to fully address our concerns.  Once again, I urge China’s leaders to take swift action to end their country’s unfair trade practices.  Hopefully, this trade situation will be resolved, in the end, by myself and President Xi of China, for whom I have great respect and affection.

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American Shipper, 17 Sep 2018.) [Excerpts.]
If a U.S. company is persuaded by an overseas importer to provide a written statement that it has no business ties to Israel, that’s a violation of the federal government’s decades-old antiboycott regulations.

Antiboycott regulations prohibit U.S. persons from complying with certain requirements of unsanctioned boycotts. In addition, the regulations require that persons report the receipt of these boycott requests to the Commerce Department’s Bureau of Industry and Security.

The antiboycott regulations date back more than 40 years ago – namely to Congress’ 1977 amendments to the Export Administration Act (EAA) and the Ribicoff Amendment to the 1976 Tax Reform Act – and were aimed primarily at precluding U.S. participation in the Arab League’s boycott of Israel. However, they also apply to all boycotts imposed by foreign governments against countries that are friendly to the United States.

Although the laws have been on the books for decades and are generally well known by companies, especially those engaged in exports of goods and services to the Middle East, violations of the antiboycott regulations still occur. 

In August, Citibank settled a $60,000 civil penalty with BIS over allegations that it provided information about business relationships with boycotted countries or blacklisted persons on 20 occasions between January 2012 and March 2016 for export transactions from the United States to Kuwait, Lebanon, Oman, Pakistan, Qatar and the United Arab Emirates.

Earlier this year, Mitsui Plastics of New York agreed to pay a $28,000 civil penalty with BIS that it illegally supplied information about business relationships with boycotted countries or blacklisted persons to a customer in Bahrain from December 2010 to April 2011 and for failure to report to the agency receipt of the request to engage in this restrictive practice. 

Last year, eight companies were charged for failure to comply with U.S. antiboycott regulations. 

Freight forwarders aren’t immune to these regulations. In August 2017, C. H. Robinson Freight Services Ltd. (formerly Phoenix International Freight Services Ltd.) was assessed a civil penalty of $37,000 for 10 violations of furnishing information about business relationships with boycotted countries or blacklisted persons for exports from the United States to the United Arab Emirates between June 2012 to July 2015. In addition, the company committed seven violations of the antiboycott regulations by failing to report to BIS requests to engage in this restrictive trade practice, which occurred between June 2012 and September 2014. …

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Volkov Law Group Blog, 13 Sep 2018. Reprinted by permission.)
* Author: Michael Volkov, Esq., Volkov Law Group,
mvolkov@volkovlaw.com, 240-505-1992.
[Editor’s Note: Parts I and II in this series were included in the Wednesday, 12 Sep 2018, and Monday 17 Sep 2018, Daily Bugle’s respectively.]
In light of the evolving (or evolved) DOJ and SEC approach to FCPA enforcement in the merger and acquisition context, global companies have to emphasize their post-acquisition process. Obviously, this is not limited to ethics and compliance issues. An acquiring company has a long list of tasks needed to complete in order to integrate the new company into the existing company’s operations.
Global companies that succeed in this process devote significant resources to the project and begin planning and execution early in the acquisition process. In some cases, global companies do very little to nothing and permit acquired companies operate independent of the acquiring company. This is a recipe for disaster but you would be surprised at the number of acquisitions that result in minimal integration efforts or take years to complete the process.
In stark contrast, there are global companies that recognize the importance of post-acquisition integration, assign a senior manager responsibility for the project and then insist on broad representation of each and every corporate function in the process, including ethics and compliance. A task force approach, if effective, will meet regularly and develop assigned tasks and responsibilities for participants to carry out and complete on a strict timeline. Global companies that are successful in the integration process usually succeed financially and in a sustainable manner over a course of years.
A target company has to address and plan for important integration issues such as:
  – Implementing compatible ERP systems;
  – Ensuring timely connection to corporate communications systems;
  – Transition of executives, managers, employees to Human Resource programs;
  – Plan for integration of physical facilities, staff and corporate operations;
  – Staffing and transition of operations from separate to integrated status;
  – Assumption of financial operations, including accounting controls, invoice-to-payment process, financial authorizations, and other critical controls; and
  – Health, safety and environmental responsibilities and other regulatory requirements.
This list is not exhaustive but is just a beginning point.
From an ethics and compliance perspective, the integration process has to include:
Ethics and Compliance Code of Conduct, Policies and Procedures: The acquiring company has to take affirmative steps to ensure that its code of conduct, compliance policies and procedures are applied “as quickly as is practicable” to the acquired business operations. This requires prompt integration of the acquired company into the acquiring company’s intranet portal and other ethics and compliance resources.
Train the Directors, Officers and Employees: The acquiring company has to prioritize ethics and compliance training of the acquired company’s directors, officers and employees., Depending on the acquired company’s risk profile, the acquired company should consider training of third-party business partners and third-party representatives. Such training should focus on the FCPA and other anti-corruption laws, the company’s code of conduct and compliance policies and procedures (e.g. due diligence, gifts, meals and entertainment expenses).
Conduct an FCPA Audit: The acquiring company should conduct “as quickly as practicable” an in-depth and robust internal FCPA audit of the acquired company’s operations. In essence, the FCPA audit should include deep dives into issues and operations that may have been identified during the pre-acquisition due diligence. Whether this is conducted internally or by external attorneys and forensic accountants, the audit has to be detailed and involve a broad review and robust sampling to ensure that no potential violations occurred in the past or are ongoing. This review is critical. If the company does not uncover any illegal conduct, the acquiring company will bear the risk of liability if discovered after the post-acquisition audit. Moreover, the company’s ability to secure a declination in such circumstances may diminish.

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(Source: Author, 17 Sep 2018).

President Trump announced on Monday that the United States would be moving ahead to impose additional duties on a further $200 billion worth of Chinese-origin imports (referred to as ‘List 3’).  According to the announcement, the additional duties will start at 10% and run through the end of the year.  If the matter has not been resolved satisfactorily by then, the rate will be increased to 25% on January 1, 2019.  The additional duties will become effective next Monday, September 24, 2018.  A copy of the statement is attached for your reference.
The additional duties will apply to Chinese-origin goods classified in the tariff subheadings included on the final list.  This list has not been published yet, but, given the effective date (a week from now), it is expected in the next day or two.  The Section 301 Committee has been considering the comments and testimony received on the list of 6,031 tariff subheadings originally proposed for List 3.  It is being reported that a relatively small number of tariff subheadings (a few hundred) are being removed from the final list as a result of this process.
Once the final List 3 is published, it is widely expected that China will retaliate by imposing additional duties on a list of U.S.-origin products worth approximately $60 billion.  It is also being reported that China may decline any invitation issued by the United States to begin negotiations until after the midterm elections and/or may engage other levers domestically to squeeze U.S. companies doing business in China.
If China does retaliate, the President’s statement says that the Administration “will immediately pursue phase three, which is tariffs on approximately $267 billion of additional imports.”  
This would be List 4 and it would cover all of the remaining imports from China.
This is the latest (and undoubtedly not the last) salvo in the on-going trade war between the United States and China.  Unfortunately, it is hard to view this salvo as being effective.  Rather than force the parties to the table, an additional 10% duty is arguably offset by the declining value of the yuan (which is down high single-digit percentages in a year) and is likely going to be viewed as a sign of wavering resolve from a president in a contentious midterm election year.  In short, today’s announcement will likely prolong the trade war, rather than help bring it to a speedy conclusion (which, in all fairness, may be the plan after all – if the war drags on long enough, companies will start to leave the war zone . . .).

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* What: Seminar Level II: Managing ITAR/EAR Complexities; Scottsdale, AZ
* When: March 26-27, 2019
* Sponsor: Export Compliance Solutions (ECS)
* ECS Instructors:  Suzanne Palmer; Lisa Bencivenga
* Register here or by calling 866-238-4018 or e-mail spalmer@exportcompliancesolutions.com

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Samuel Johnson (18 Sep 1709 – 13 Dec 1784; often referred to as Dr. Johnson, was an English writer who made lasting contributions to English literature as a poet, essayist, moralist, literary critic, biographer, editor and lexicographer. After nine years of work, Johnson’s A Dictionary of the English Language was published in 1755. It had a far-reaching effect on Modern English and has been acclaimed as “one of the greatest single achievements of scholarship”. The Oxford Dictionary of National Biography describes Johnson as “arguably the most distinguished man of letters in English history”.)
  – “Great works are performed not by strength but by perseverance.”
  – “Praise, like gold and diamonds, owes its value only to its scarcity.”  

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. 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.
: 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. 
: 19 CFR, Ch. 1, Pts. 0-199
  – Last Amendment: 12 Jun 2018: 83 FR 27380-27407: Air Cargo Advance Screening (ACAS)

  – 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 

: 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

: 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 

: 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
  – 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.  
, 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 
  – HTS codes that are not valid for AES are available 
  – 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
. BAFTR subscribers receive a 25% discount on subscriptions to the BITAR, please
contact us
to receive your discount code.

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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 

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* 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.

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