18-0926 Wednesday “Daily Bugle”

18-0926 Wednesday “Daily Bugle”

Wednesday, 26 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/BIS Amends EAR, Adds Fourteen Entities, Modifies One Entry, and Removes One Entity from the Entity List
  1. Items Scheduled for Publication in Future Federal Register Editions
  2. Commerce/BIS: (No new postings.)
  3. Energy/NNSA Develops “Fingerprinting” Technique for Exports to Keep WMD Building Blocks out of the Wrong Hands
  4. State/DDTC: (No new postings.)
  1. Expeditors News: “US and South Korea Sign Updated KORUS”
  2. ST&R Trade Report: “Section 321, Importer ID, CEEs, Broker Permits Included on Updated ACE Enhancement List”
  1. Global Trade News: “Weise Wednesday: Can the US-China Trade Dispute Be Resolved Soon?”
  2. M. Volkov: “OFAC Enforcement: The Epsilon Case and Third-Party Risks”
  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 (19 Sep 2018), DOD/NISPOM (18 May 2016), EAR (26 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 



1. Commerce/BIS Amends EAR, Adds Fourteen Entities, Modifies One Entry, and Removes One Entity from the Entity List
(Source: Federal Register, 26 Sep 2018.) [Excerpts.]
83 FR 48532-48537: Addition of Certain Entities to the Entity List, Revision of an Entry on the Entity List and Removal of an Entity From the Entity List
* AGENCY: Bureau of Industry and Security, Commerce.
* ACTION: Final rule.
* SUMMARY: This final rule amends the Export Administration Regulations (EAR) by adding fourteen entities to the Entity List. These fourteen entities have been determined by the U.S. Government to be acting contrary to the national security or foreign policy interests of the United States and will be listed on the Entity List under the destinations of Belarus, Iran, Russia, and Singapore. This rule also modifies one entry on the Entity List under the destination of the United Arab Emirates. Lastly, this rule removes one entity under the destination of Hong Kong from the Entity List. The removal is made in connection with a request for removal BIS received pursuant to the EAR and a review of information provided in that request.
* DATES: This rule is effective September 26, 2018.
* FOR FURTHER INFORMATION CONTACT: Chair, End-User Review Committee, Office of the Assistant Secretary, Export Administration, Bureau of Industry and Security, Department of Commerce, Phone: (202) 482-5991, Email: ERC@bis.doc.gov.
  This rule implements the decision of the ERC to add fourteen entities to the Entity List. The addition of these fourteen entities involves sixteen Entity List entries, as one of the entities being added has locations in three destinations. The fourteen entities are being added based on Sec. 744.11 (License requirements that apply to entities acting contrary to the national security or foreign policy interests of the United States) of the EAR. The sixteen entries consist of two entries located in Belarus, one entry located in Iran, twelve entries located in Russia and one entry located in Singapore.
  The ERC reviewed Sec. 744.11(b) (Criteria for revising the Entity List) in making the determination to add these fourteen entities to the Entity List. Under that paragraph, persons for whom there is reasonable cause to believe, based on specific and articulable facts, that they have been involved, are involved, or pose a significant risk of being or becoming involved in, activities that are contrary to the national security or foreign policy interests of the United States, along with those acting on behalf of such persons, may be added to the Entity List. Paragraphs (b)(1) through (b)(5) of Sec. 744.11 provide an illustrative list of activities that could be contrary to the national security or foreign policy interests of the United States. For each of the fourteen entities described below, the ERC made the requisite determination under the standard set forth in Sec. 744.11(b).
  Pursuant to Sec. 744.11(b) of the EAR, the ERC determined that Nilco Group, located in Belarus, Iran, and Russia, and Mohammad Najafi, located in Belarus, be added to the Entity List based on their involvement in providing material support to Iranian missile programs.
  The ERC also determined that four commercial companies–Joint Stock Company Scientific-Research Institute “Vektor”, Open Joint Stock Company Information Technology and Communication Systems, Federal State Unitary Enterprise Scientific Production Enterprise “GAMMA”, and Syrus Systems–located in Russia be added to the Entity List. These entities have enabled the activities of malicious Russian cyber actors. In addition, the ERC determined that two entities, Divetechnoservices and Oceanos, be added to the Entity List under the destination of Russia for providing equipment and support to the Russian Navy. The ERC also determined that five entities–AeroComposit; Obinsk Research and Production Enterprise (ORPE), Open Joint Stock Company Aviadvigatel, Open Joint Stock Company Scientific and Production Corporation of Precision Instruments Engineering (NPK-SPP), and Voronezh Scientific Research Institute “Vega”–be added to the Entity List for supporting Russian military aerospace production activities.
  Under the destination of Singapore, the ERC determined that one entity, All Industrial Manufacturing (AIM) Pte Ltd., be added to the Entity List based on its involvement in the proliferation of unsafeguarded nuclear activities.
  Pursuant to Sec. 744.11(b) of the EAR, the ERC determined that the conduct of these fourteen entities raises sufficient concern that prior review of exports, reexports or transfers (in-country) of all items subject to the EAR involving these entities, and the possible imposition of license conditions or license denials on shipments to the persons, will enhance BIS’s ability to prevent violations of the EAR.
  For thirteen of the fourteen entities described above that are being added to the Entity List, BIS imposes a license requirement for all items subject to the EAR and a license review policy of presumption of denial. For All Industrial Manufacturing (AIM) Pte Ltd, the entity added under Singapore, BIS imposes a license requirement for all items subject to the EAR and will exercise the license review policy set forth in subpart (d) of EAR Sec. 744.2, a nuclear end-user and end-use based provision. For all fourteen entities, the license requirements apply to any transaction in which items are to be exported, reexported, or transferred (in-country) to any of the entities or in which such entities act as purchaser, intermediate consignee, ultimate consignee, or end-user. In addition, no license exceptions are available for exports, reexports, or transfers (in-country) to the entities being added to the Entity List in this rule. The acronym “a.k.a.” (also known as) is used in entries on the Entity List to identify aliases, thereby assisting exporters, reexporters and transferors in identifying entities on the Entity List.
  This final rule adds the following fourteen entities to the Entity List, including one entity listed under three entries: …
  Dated: September 21, 2018.
Richard E. Ashooh, Assistant Secretary for Export Administration.

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OGS_a12. Items Scheduled for Publication in Future Federal Register Editions
(Source: Federal Register)

* U.S. Customs and Border Protection; NOTICES; Agency Information Collection Activities; Proposals, Submissions, and Approvals [Publication Date: 27 September 2018.]:
  – Customs Declaration
  – General Declaration

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Energy/NNSA, 24 Sep 2018.)
Fingerprints can serve as evidence of a variety of crimes or illicit actions. In the nuclear security world, there are several such ‘fingerprints’ that indicate an attempt to ship products overseas for nefarious use. And like detectives matching prints to a database of known criminals, the National Nuclear Security Administration (“NNSA”) has developed a way to identify suspicious shipments of “dual-use” goods.
Dual-use goods are commodities that could be used for commercial purposes or to contribute to a foreign weapons of mass destruction (“WMD”) program. NNSA works with experts to keep adversaries from illicitly acquiring these goods from the United States, while ensuring that legitimate trade is not impacted.
Many of these commodities require an export license from the U.S. Department of Commerce before being shipped overseas. However, determined proliferators may use methods like avoiding export licenses, lying to get a license, or using front companies and brokers to disguise the real use of items.
When an item is exported from the United States, an export declaration form is submitted to the U.S. Census Bureau, which shares this data with other U.S. agencies. Typically, these declarations describe the items in a shipment and contain a code number to help with the collection of tariffs. They also indicate if the commodity has an export license.
The United States exports an incredible volume of goods that law enforcement agencies must monitor, but the declarations offer an opportunity.
  “We developed a basket of commodity ‘fingerprints’ for goods that could be used for nuclear-, missile-, and chemical/biological-related dual uses,” said Melissa Krupa, Director of NNSA’s Office of Nuclear Export Controls. “These fingerprints allow authorities to reduce the thousands of export declarations to a more manageable number without having to review them all.”
Each fingerprint is a profile used to identify a particular dual-use commodity using the fields of the shipping documents themselves. One example is a pressure transducer, which is a sensor used in uranium enrichment. It shares the same code number as other pressure sensors, such as those used to check car tires. But research revealed that transducers used in uranium enrichment typically cost more than $1,000, weigh a few pounds, and sell in quantities of a couple dozen at a time. This fingerprint distinguishes them from other pressure sensors that share the same code number, but are cheaper, lighter, and sold in larger quantities.
By applying the fingerprint profile, authorities can pare down thousands of shipments to just hundreds, reducing the work required to inspect the shipments and nab suspicious shipments of dual-use goods before they leave the country.

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Expeditors News, 25 Sep 2018.)
On September 24, 2018, U.S. President Donald Trump and the Republic of Korea’s President Moon Jae-in signed an updated U.S.-Korea Free Trade Agreement (KORUS).
The U.S. Trade Representative (USTR) has released a fact sheet highlighting some of the new outcomes for U.S. exporters:
  – Korea will extend the 25% U.S. tariff on trucks until 2041;
  – Korea will double the number of U.S. automobile exports that can meet U.S. safety standards;
  – U.S. exporters will be able to show compliance with Korea’s emission standards using the same tests they conduct to show compliance with U.S. regulations;
  – Korea will recognize U.S. standards for auto parts necessary to service U.S. vehicles, and reduce labeling burdens for parts;
  – Korea will expand the amount of “eco-credits” available to help meet fuel economy and greenhouse gas requirements;
  – Korea will address concerns with the verification procedures through agreement on principles for conducting verification of origin of exports and establish a working group to monitor and address future issues that arise;
  – Korea will amend its Premium Pricing Policy for Global Innovative Drugs to make it consistent with Korea’s commitments under KORUS by the end of 2018.
The USTR’s fact sheet may be found
The text of the KORUS agreement may be found

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U.S. Customs and Border Protection has announced plans to use a $30 million congressional appropriation to make a number of enhancements to the Automated Commercial Environment. These enhancements have been selected based on the interests of the trade community and the potential to reduce its burdens, impact on CBP users, nexus to existing and emerging priorities, and workload efficiency and operational improvement opportunities. CBP notes that a development and deployment schedule are forthcoming and that it will engage the trade community through the Trade Support Network to establish workgroups to refine trade-facing technical requirements and implementation plans.
Section 321 Entries. Under section 321 of the Trade Facilitation and Trade Enforcement Act, the maximum value of goods that can be imported free of duty and tax by one person on one day (the so-called de minimis value) was increased from $200 to $800. CBP currently clears such goods off the manifest but is working to automate data collection on these shipments, which would create an additional pathway to clearance via development of an entry type 86 for ABI submission. This change is expected to give CBP greater visibility into low-value shipments, provide partner government agencies with required data on such shipments, and allow filers to transmit transaction data (e.g., manufacturer, importer, and consignee information) via ABI and receive electronic release messages from CBP for such shipments.
Importer ID Input Record. CBP Form 5106 collects data used to establish bond coverage, release and entry of goods, liquidation, and the issuance of bills and refunds. CBP states that automating and updating the data elements captured in ACE for this form will (a) enable the collection of more detailed importer information to support more advanced risk analysis, (b) provide for more informative risk assessments prior to importation, (c) further improve revenue functions, and (d) provide for more streamlined processing for importers, brokers, sureties, and others through the ability to create, edit, and update importer information.
FTZs. The current process provides an electronic document to request the entry of cargo into a foreign-trade zone and electronic messaging when a cargo exam is required and goods have been authorized for a permit to transfer into an FTZ. The e214 redesign will enable the submission of PGA data simultaneously with the e214 via the PGA message set or the document image system when reporting FTZ admissions.
CEEs. CBP will create unique identifiers for each of its ten Centers of Excellence and Expertise that will be designated on the center member’s ACE account, added to all the member’s post-release activity, and incorporated into CBP’s post-release workflow. CBP states that this identifier will allow it to streamline processing for the centers and provide a means for managing workload at the account level. In addition, traders will gain visibility into their center assignment and be in a position to submit documents to the appropriate center.
Broker National Permits. In line with a forthcoming proposed rule that will update the customs broker regulations in 19 CFR 111, ACE will be enhanced to transition all brokers to a single national permit and eliminate multiple district permits and waivers. Brokers will be able to conduct entry via remote location filing at any port nationwide and will no longer have to pay the initial $100 district permit fee and the annual $141.70 permit user fee per local permit for each office location.
Truck Processing. CBP will deploy drive-through multi-energy portal imaging systems to the Laredo World Trade Bridge and the Brownsville Veterans Bridge and allow non-intrusive inspections, which currently occur at secondary, to take place in pre-primary. CBP states that these capabilities are essential components of the cargo “model port” project (for which initial pilots are slated to take place soon) and should yield noticeable reductions in driver waiting times at border crossing ports of entry.
GSP. This enhancement will address mandatory updates related to the renewal of the Generalized System of Preferences and allow quicker payment of retroactive refunds when GSP expires and is later reinstated.
Manifest. CBP states that collecting shipper, consignee, and notify party phone numbers and email addresses as optional data elements on the manifest for all modes of transportation will help improve and strengthen the targeting of e-commerce shipments.
In addition, importers, consignees, and exporters will be able to electronically manage their requests for confidential treatment of their names and addresses on inward or outward vessel manifests.
Vessel Management. This enhancement will allow for the processing of electronic receipts for vessel entry fees and the addition of an online payment option for vessel agents and owner operators, which will reduce the time necessary to enter and clear vessels of all types.

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Integration Point Blog, 26 Sep 2018.)
Welcome to Weise Wednesday! Twice a month we will share a brief Q&A with the former U.S. Commissioner of Customs, Mr. George Weise. If you have questions, we encourage you to send them to
Q. Are there any signs that the escalating trade dispute between the United States and China prompted by the U.S. 301 action will be resolved soon?
A. Unfortunately, the answer is no. It appears that both sides have now dug in for a prolonged trade fight. Last week President Trump announced that it would be imposing an additional 10% tariff on about $200 billion of Chinese imports, effective September 24, and that the additional tariff on those goods would be increased to 25% on January 1. In the announcement, the President also threatened to impose tariffs on $267 billion of additional Chinese imports if China retaliated.
As expected, China immediately announced it was imposing additional tariffs of up to 10% on $60 billion of U.S. imports. This is in addition to the 25% tariff both parties had imposed on roughly $50 billion of each other’s goods earlier this year.
It remains to be seen if and when the President will follow through on his threat to impose tariffs on another $267 billion of Chinese exports.
If carried out, this would cover virtually all Chinese exports to the U.S. It is also not clear how China would respond to such an action. But many U.S. companies fear that China could turn to other actions besides tariffs to inflict economic pain on them, such as slowing down customs processing times and imposing tougher regulatory requirements for U.S. goods.
It had been hoped that these trade actions would lead to bilateral negotiations to resolve the underlying complaints in the
301 action by the U.S. about numerous unfair trade policies and practices relating to U.S. technology and intellectual property rights. The U.S. is also looking to address the significant trade deficit that China has with the U.S. 
It had appeared that progress was being made in talks between senior U.S. and Chinese trade officials in Washington in May. But unfortunately, the talks broke off. No high-level talks have been held since June and none seem to be on the horizon. Sadly, global traders will continue to face increased tariffs and uncertain times for the foreseeable future as the bilateral trade war continues.  

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Volkov Law Group Blog, 25 Sep 2018. Reprinted by permission.)
* Author: Michael Volkov, Esq., Volkov Law Group,
mvolkov@volkovlaw.com, 240-505-1992.
The Department of Treasury’s Office of Foreign Asset Control (“OFAC”) recently announced the settlement of the Epsilon enforcement action.  (
Here).  This case requires a theme song and there is none better than
Truckin (
here) from Grateful Dead’s second compilation album –
What a Long Strange Trip its Been.
This case involved two separate OFAC investigations for violations of the Iran Sanctions Program, an appeal to the US District Court for the District of Columbia (
here), and an appeal at the U.S. District Court of Appeals for the District of Columbia Circuit (
here).  The case is important because it confirms a broad reading of third party risks for companies when dealing with the Iran Sanctions Program (and the Cuba Sanctions Program).
As we all know, companies can be held liable for a sanctions violation when they ship a product to a third-party in another country and know or have reason to know that the third party intends to reship the product to Iran.  Consequently, companies have to conduct due diligence and document appropriate assurances that the third party is not intending to ship the goods to Iran.
The legal question here boils down to what does OFAC have to prove – that the products actually ended up in Iran or that the company had “reason to know” that the third party intended to ship the goods to Iran.  There is a big difference here between the two levels of proof.
The Facts
Let’s review the facts – OFAC learned in 2008 that Power Acoustik (a subsidiary of Epsilon) sent a shipment to an address in Iran and OFAC issued a subpoena.  OFAC eventually closed the investigation with a cautionary letter dated January 26, 2012.
In a separate investigation, OFAC learned that between September 2010 and October 2011, Power Acoustik received wire transfers totaling more than $1.1 million from a commercial bank in Dubai on behalf of Asra International, and that these payments may have been for products destined to Iran.  OFAC issued another subpoena.
Power Acoustik confirmed that they had 41 sales of audio and video equipment to Asra International between August 2008 and May 2012.  OFAC found that 5 of these transactions post-dated its initial cautionary letter, Dated January 26, 2012.
OFAC did not identify any direct evidence that Power Acoustik’s shipments were transported to Iran, but they located a website for Asra International which indicated that Asra, through an affiliated entity, distributed car audio and video products in Iran.  The Iran affiliate’s address was the same as the address in the original 2008 illegal shipment to Iran.  OFAC also noticed that photos from the Asra International website revealed that Asra International distributed Acoustik Power’s products (from a related party) were being distributed in Iran.
OFAC issued a pre-penalty notice concluding that Power Acoustik should pay $4,073,000, based on 34 non-egregious violations (which occurred before the January 26, 2012 cautionary letter), and 5 egregious violations (which occurred after the cautionary letter). After hearing Power Acoustik’s objections, OFAC affirmed its penalty notice.
Power Acoustik’s Appeals
The district court affirmed the OFAC determination. The US Court of Appeals, however, reversed in part and affirmed OFAC’s decision with remand instructions. The Court of Appeals affirmed OFAC’s enforcement action with respect to the 34 non-egregious cases but reversed on the 5 transactions that occurred after the January 26, 2012 cautionary letter.
The Court of Appeals affirmed that an exporter may be found liable if it ships goods from the United States to a third country, with reason to know that those goods are specifically intended for reexport to Iran, even if the goods never arrive in Iran. OFAC affirmed this finding as to the total 39 transactions.
The “reason to know” requirement can be established “through a variety of circumstantial evidence,” including “course of dealing, general knowledge of the industry or customer preferences, working relationships between the parties, or other criteria far too numerous to enumerate.”
Up until December 2011, Asra International in Dubai distributed to Iran exclusively. The evidence concerning Asra International’s website and marketing document confirmed its exclusive distribution arrangement involving an Iran affiliate. For this time period, Power Acoustik could reasonably infer that Asra in Dubai only distributed its products to Iran.
For the final five shipments, however, the Court of Appeals found that the evidence did not satisfy the “reason to know” standard. Specifically, the Court of Appeals noted that OFAC failed to address several email conversations between Acoustik’s sales team and the Asra Dubai manager during the period of September 2011 to July 2012, which indicated that the products were going to be sold from Asra International’s new retail store in Dubai.
Based on this review, the Court of Appeals re-calculated OFAC’s penalty by excluding the 5 egregious transactions. The Court of Appeals remanded the case back to OFAC for recalculation of the penalty based on the change in the 5 transactions.
The End of the Road.
OFAC and Epsilon agreed to pay $1,500,000 to settle the enforcement matter.

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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

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* T.S. Eliot (Thomas Stearns Eliot; 26 Sep 1888 – 4 Jan 1965; was an essayist, publisher, playwright, literary and social critic, and “one of the twentieth century’s major poets”. Born in the United States to a prominent Boston Brahmin family, he moved to England in 1914 at the age of 25, settling, working, and marrying there. He became a British subject in 1927 at the age of 39, renouncing his American passport.)
  – “Only those who will risk going too far can possibly find out how far one can go.”
  – “If you aren’t in over your head, how do you know how tall you are?”

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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: 19 Sep 2018: 83 FR 47283-47284: Extension of Import Restrictions Imposed on Archaeological Material From Cambodia  


  – 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: 26 Sep 2018: 83 FR 48532-48537: Addition of Certain Entities to the Entity List, Revision of an Entry on the Entity List and Removal of an Entity From the Entity List 

: 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 6,000 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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