18-1024 Wednesday “Daily Bugle”

18-1024 Wednesday “Daily Bugle”

Wednesday, 24 October 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, Revises Parts 740, 742, 744, 772, and 774 to Implement Changes to the WA List of Dual-Use Goods and Technologies 
  1. Items Scheduled for Publication in Future Federal Register Editions
  2. Commerce/BIS: (No new postings.)
  3. DoD/DSS Reposts “Implementation of Interim Backlog Mitigation Measures for Entities Cleared by DoD under the National Industrial Security Program”
  4. State/DDTC: (No new postings.)
  5. Treasury/OFAC Extends Belarus General License 2F
  6. Dutch Ministry of Foreign Affairs Publishes Export Control Fact Sheets
  1. European Sanctions Blog: “Germany Suspends Arms Exports to Saudi Arabia”
  2. Global Trade News: “Canada Imposes Safeguard Measures on Steel Imports”
  3. Reuters: “EU Mechanism for Iran Trade to Be Symbolically Ready on Nov. 4: Diplomats”
  4. ST&R Trade Report: “New Customs Valuation Regime Implemented in New Zealand”
  1. C. Gillis: “Serving Export Compliance Cocktail”
  2. M. Volkov: “Episode 61 – How to Implement and Promote a Speak Up Culture”
  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 (24 Oct 2018), FACR/OFAC (29 Jun 2018), FTR (24 Apr 2018), HTSUS (22 Oct 2018), ITAR (4 Oct 2018) 
  3. Weekly Highlights of the Daily Bugle Top Stories 



Commerce/BIS Amends EAR, Revises Parts 740, 742, 744, 772, and 774 to Implement Changes to the WA List of Dual-Use Goods and Technologies
Federal Register, 24 Oct 2018.) [Excerpts.]
83 FR 53742-53793: Wassenaar Arrangement 2017 Plenary Agreements Implementation; Final Rule 
* AGENCY: Bureau of Industry and Security, Commerce.
* ACTION: Final rule.
* SUMMARY: The Bureau of Industry and Security (BIS) maintains, as part of its Export Administration Regulations (EAR), the Commerce Control List (CCL), which identifies certain items subject to Department of Commerce jurisdiction. This final rule revises the CCL, as well as corresponding parts of the EAR, to implement changes made to the Wassenaar Arrangement List of Dual-Use Goods and Technologies (WA List) maintained and agreed to by governments participating in the Wassenaar Arrangement on Export Controls for Conventional Arms and Dual-Use Goods and Technologies (Wassenaar Arrangement, or WA) at the December 2017 WA Plenary meeting. The Wassenaar Arrangement advocates implementation of effective export controls on strategic items with the objective of improving regional and international security and stability. This rule harmonizes the CCL with the agreements reached at the 2017 Plenary meeting by revising Export Control Classification Numbers (ECCNs) controlled for national security reasons in each category of the CCL. This rule also makes other associated changes to the EAR and makes a correction.
This rule is effective October 24, 2018. … 
Wassenaar Arrangement
(Wassenaar or WA) on Export Controls for Conventional Arms and Dual-Use Goods and Technologies is a group of 42 like-minded states committed to promoting responsibility and transparency in the global arms trade, and preventing destabilizing accumulations of arms. As a Participating State, the United States has committed to controlling for export all items on the WA control lists. The lists were first established in 1996 and have been revised annually thereafter. Proposals for changes to the WA control lists that achieve consensus are approved by Participating States at annual plenary meetings. Participating States are charged with implementing the agreed list changes as soon as possible after approval. The United States’ implementation of WA list changes ensures U.S. companies have a level playing field with their competitors in other WA Participating States.
  The changes in this rule, which reflect the changes to the WA control lists that were approved at the December 2017 WA Plenary meeting, update the corresponding items listed in the EAR, and reflect the most recent changes in technologies and conditions. Unless explicitly discussed below, the revisions made by this rule will not impact the number of license applications submitted to BIS.
Revisions to the Commerce Control List Related to WA 2017 Plenary Agreements
  Revises (50) ECCNs: 0A617, 0A919, 1A002, 1C001, 1C002, 1C007, 1C010, 1C608, 2A001, 2B001, 2B006, 2B007, 2B008, 2E003, 3A001, 3A002, 3B001, 3B002, 3C002, 3C005, 3C006, 3C992, 3E001, 4A003, 4A004, 4D001, 4E001, 5A001, 5A002, 5D002, 5E002, 6A002, 6A003, 6A004, 6A005, 6A008, 6A203, 6D003, 6D991, 6E001, 6E002, 6E201, 7A006, 7E004, 9A002, 9A004, 9D001, 9D002, 9D004, and 9E003.
  License Exception eligibility additions: 3A001.i (GBS).
  ECCN Removals: 6A990 and 6E990.
  ECCN Correction: 3A991.
  ECCN change to maintain NP controls: 2B206.
Category 0–Nuclear Materials, Facilities, and Equipment [and Miscellaneous Items] … 
Category 1–Special Materials and Related Equipment, Chemicals, “Microorganisms”, and “Toxins” … 
Category 2–Materials Processing … 
Category 3–Electronics … 
Category 4–Computers … 

Category 5–Part 1–“Telecommunications” … 
Category 5–Part 2–“Information Security” … 
Category 6–Sensors and Lasers … 
Category 7–Navigation and Avionics …
Category 9–Aerospace and Propulsion … 
Part 772–Definitions of Terms as Used in the Export Administration 
Regulations (EAR)
  This rule removes 37 definitions from Sec.  772.1 and adds them to the ECCNs where they are used. According to the WA drafting guidelines, if a term is only used in a single ECCN, then the definition must be located in a Technical Note close to where that term is used. However, if the term is separated by many subparagraphs, then the definition may be located in the Definitions section of the WA List. The following 37 definitions are removed from part 772, because they are only used within a single ECCN: Automatic target tracking, carbon fiber preforms, commingled, comminution, compound rotary table, deformable mirrors, direct acting hydraulic pressing, effective gram, electronically steerable phased array antenna, flight control optical sensor array, flight path optimization, frequency mask trigger, frequency synthesizer, gas atomization, geographically dispersed, hot isostatic densification, linearity, main storage, mechanical alloying, melt extraction, melt spinning, neural computers, optical computer, plasma atomization, power management, previously separated, primary flight control, real-time bandwidth, resolution, rotary atomization, settling time, splat quenching, systolic array computer, transfer laser, vacuum atomization and variable geometry airfoils. The following definitions are revised for reasons stated either in the Federal Register instruction or under an ECCN where the term is used: Compensation systems, cryptographic activation, and user-accessible programmability. Two terms used in ECCNs 3A001 and 3A002 related to Analog-to-Digital Converters (ADC) are added to Sec.  772.1. The term “sample rate”, which is used in both ECCN 3A001 and 3A002, is added to Sec.  772.1. The definition “steady state mode” is moved from Technical Note 2 to 9E003.a.5 to Sec.  772.1 because it is now also used in a new parameter for `marine gas turbine engines’ in ECCN 9A002, as well as in Technical Notes in 9E003.a.2.d and 9E003.a.5. The Category 5–Part 2 definition “cryptographic activation” is amended by adding the word “specifically” before “activates or enables”, and taking the word “secure” out of the definition, to fit with the changes being made in the control list entries that refer to this definition (ECCNs 5A002.b, 5D002.b and 5E002.b).
Supplement No. 6 to Part 774–Sensitive List
  Paragraph (1)(i), ECCN 1A002, is amended by narrowing the scope from all of ECCN 1A002 to only subparagraph a.1 ” “Composite” structures or laminates made from an organic “matrix” and “fibrous or filamentary materials” specified by 1C010.c or 1C010.d”, because the rest of the items in ECCN 1A002 do not warrant control on the Sensitive List as they are not key technologies. This revision will minimally affect the annual number of Wassenaar reports to BIS.
  Paragraph (2)(i)–ECCN 2D001, (ii)–ECCN 2E001, and (iii)–ECCN 2E002 are simplified and restructured for easier understanding and compliance. The revisions also focus the Sensitive List entries for software and technology for machine tools having a unidirectional repeatability at 0.9 microns. For machine tools having no variations specified at 0.9 microns, there is no change to the thresholds.
Supplement No. 7 to Part 774–Very Sensitive List
  Paragraph (1)(i), ECCN 1A002, is amended by narrowing the scope from subparagraph .a to subparagraph a.1 (“Composite” structures or laminates made from an organic “matrix” and “fibrous or filamentary materials” specified by 1C010.c or 1C0010.d), because the rest of the items in ECCN 1A002.a do not warrant control on the Sensitive List as they are not key technologies. It is estimated that this will minimally affect the annual number of Wassenaar reports to BIS.
  Paragraphs (3)(iv), ECCN 6A001.a.2.c, and (3)(vi), ECCN 6A002.a.2.f, are amended by replacing the phase “user accessible programmability” with “user-accessible programmability” to add a hyphen for correctness.
Section 740.16 Additional Permissive Reexports (APR)
  License Exception APR is amended to remove a reference to ECCN 6A990 in paragraphs (a)(2) and (b)(2)(v), because ECCN 6A990 is removed from the CCL by this rule. ROICs are now specified in 6A002.f.
Section 740.17 Encryption Commodities, Software and Technology (ENC)
  License Exception ENC is corrected to replace a reference to 5D002.d with a reference to 5D002.b in the Note to paragraph (b)(2) and in paragraph (b)(3)(iv).
Section 740.20 License Exception Strategic Trade Authorization (STA)
  License Exception STA is amended to remove reference to ECCNs 6A990 and 6E990 from paragraph (b)(2)(x), because these ECCNs are removed from the CCL. ROICs are now specified in 6A002.f and ROIC technology is specified in ECCNs 6E001 and 6E002.
Section 742.6 Regional Stability
  Paragraph (b)(1)(ii) is amended by removing reference to ECCN 6E990, because this ECCN is removed by this rule. ROIC technology is now controlled under ECCNs 6E001 and 6E002.
Section 744.9 Restrictions on Exports, Reexports, and Transfers (In-Country) of Certain Cameras, Systems, or Related Components
  Section 744.9 is amended by removing reference to ECCN 6A990 from paragraphs (a) and (b), because this ECCN is removed from the CCL. ROICs are now controlled under ECCN 6A002.f. … 
Saving Clause
  Shipments of items removed from license exception eligibility or eligibility for export, reexport or transfer (in-country) without a license as a result of this regulatory action that were on dock for loading, on lighter, laden aboard an exporting carrier, or en route aboard a carrier to a port of export, on October 24, 2018, pursuant to actual orders for exports, reexports and transfers (in-country) to a foreign destination, may proceed to that destination under the previous license exception eligibility or without a license so long as they have been exported, reexported or transferred (in-country) before December 24, 2018. Any such items not actually exported, reexported or transferred (in-country) before midnight, on December 24, 2018, require a license in accordance with this final rule. … 
  Dated: October 4, 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 

[No items of interest noted today.]

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DoD/DSS, 24 Oct 2018.) 
DoD/DSS reposted “Implementation of Interim Backlog Mitigation Measures for Entities Cleared by DoD under the National Industrial Security Program” due to an incorrect email in original posting. 

In early June 2018, the Director of National Intelligence, in his capacity as the Security Executive Agent, and the Director of the Office of Personnel Management, in his capacity as the Suitability & Credentialing Executive Agent (Executive Agents), jointly issued a memorandum directing the implementation of interim measures intended to mitigate the existing backlog of personnel security investigations at the National Background Investigations Bureau (NBIB). These measures include the deferment of reinvestigations when screening results are favorable and mitigation activities are in place, as directed. 

In accordance with the guidance and direction received from the Executive Agents, Defense Security Service (DSS) will adopt procedures to defer the submission of Tier 3 Reinvestigations (T3Rs) and Tier 5 Reinvestigations (T5Rs) for entities cleared under the National Industrial Security Program. Facility Security Officers should continue to submit completed Standard Form 86 and the reinvestigation request, six years from the date of last investigation for the T5Rs and 10 years from the date of the last reinvestigation for the T3Rs. New reinvestigation requests will be screened by DSS using a risk management approach that permits deferment of reinvestigations according to policy. If the determination is made to defer reinvestigations, individuals will be immediately enrolled into the DoD Continuous Evaluation (CE)/Continuous Vetting (CV) capabilities, as required.

The Executive Agents have directed all Federal departments and agencies to reciprocally accept the prior favorable adjudication for deferred reinvestigations that are out of scope (overdue). Existing eligibility remains valid until the individual is removed from CE, no longer has any DoD affiliation, or has their eligibility revoked or suspended. 

The Office of the Under Secretary of Defense for Intelligence signed a memorandum on December 7, 2016, reminding DoD Components that personnel security clearances do not expire. Individuals with current eligibility in the Joint Personnel Adjudication System (JPAS), or its successor, should not be denied access based on an out-of-scope investigation. That memorandum is provided here for ease of reference. If you encounter any challenges with this process, please email dss.ncr.dss-isfo.mbx.psmo-i@mail.mil for assistance.

These procedures will remain in effect until further notice. More information is available in the linked frequently asked questions.

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State/DDTC: (No new postings.)

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6. Treasury/OFAC Extends Belarus General License 2F

Treasury/OFAC, 24 Oct 2018.) 
The Department of the Treasury’s Office of Foreign Assets Control, in consultation and coordination with the Department of State, is extending the expiration date of the general license authorizing transactions
involving certain Belarusian entities blocked pursuant to Executive Order (E.O.) 13405. This general license does not authorize the release of property blocked pursuant to E.O. 13405. This authorization expires on October 25, 2019, unless extended or revoked.

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Dutch Ministry of Foreign Affairs Publishes Export Control Fact Sheets

(Source: Dutch Ministry of Foreign Affairs, 23 Oct 2018.) 
The Dutch Ministry of Foreign has published a series of fact sheets (in Dutch) providing guidance concerning export control compliance. 

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Germany has announced that, until further notice, it will not be approving new arms exports to Saudi Arabia following the killing of journalist Jamal Khashoggi committed within the premises of the Saudi Consulate General in Istanbul. Germany has also urged other EU member states to follow suit. See the Joint Statement from France, Germany, and the UK.
The EU will vote later this week on a parliamentary resolution on Mr Khashoggi’s killing, including whether targeted sanctions and an EU arms embargo ought to be imposed on Saudi Arabia.

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Global Trade News: “Canada Imposes Safeguard Measures on Steel Imports” 

(Source: Integration Point Blog, 23 Oct 2018.) [Excerpts.] 
On October 25, a surtax of 25% will be imposed on the imports of steel products if the imported volume exceeds the quota limits. The details regarding the quantity of such goods that may be imported under tariff rate quotas (TRQ) can be accessed from the notice issued to importers. The quota rates will be applicable for a period of 50 consecutive days.
The Canadian government announced these provisional safeguard measures on certain steel products on October 11. The quotas issued by the Government of Canada argue that the influx of steel imports from the United States and other countries into Canada is a serious threat to its domestic market. According to the Canadian Department of Finance, the countermeasures were erected in response to the U.S. tariffs on Canadian steel and aluminum that adversely affects domestic steel producers and workers.
The impacted steel products include heavy plate, concrete reinforcing bars, energy tubular products, hot-rolled sheet, pre-painted steel, stainless steel wire, and wire rod. The complete description of the products along with the exclusion list is provided in the orders-in-council.
The surtax will impact China, South Korea, Brazil, Japan, Taiwan, Germany and Turkey – Canada’s top sources of steel other than its NAFTA partners. … 

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Reuters: “EU Mechanism for Iran Trade to Be Symbolically Ready on Nov. 4: Diplomats”

(Source: Reuters, 24 Oct 2018.) [Excerpts.] 

A new European Union mechanism to facilitate payments for Iranian exports should be legally in place by Nov. 4, when the next phase of U.S. sanctions hit, but will not be operational until early next year, three diplomats said.
The mechanism, a so-called special purpose vehicle (SPV), is designed to circumvent the sanctions, under which Washington can cut off any bank that enables oil transactions with Iran.
The SPV, which could incorporate a barter system, aims to sidestep the U.S. financial system by using an EU intermediary to handle trade with Iran. It could ensure, for example, that Iranian oil bought by Europeans could be paid for with EU goods and services of the same value. … 
The EU, with support from China and Russia, hopes to keep Tehran in a 2015 nuclear non-proliferation deal by allowing trade to flow despite U.S. penalties. … 
EU diplomats said the SPV would not be enough to preserve all trade. The aim was to convince Iran to keep its commitments under its nuclear agreement with world powers, from which U.S. President Donald Trump withdrew in May. 
The SPV will follow several other EU initiatives to try to shield European business with Iran from U.S. sanctions that Trump is reimposing, as he seeks to punish Tehran for what the West says is Iran’s role in the wars in Syria and Yemen. 
The EU agrees with Washington that Iran has failed to contain its ballistic missile arsenal and is supporting proxies across the Middle East. But France, Britain and Germany say the 2015 nuclear accord is separate and should be upheld because it prevents Iran from developing a nuclear bomb.

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ST&R Trade Report: “New Customs Valuation Regime Implemented in New Zealand” 

(Source: Sandler, Travis & Rosenberg Trade Report, 24 Oct 2018.)
The New Zealand Customs Service reports that it can now make rulings on the value of imported goods and that importers, agents, and brokers can apply for binding valuation rulings. In addition, importers that cannot determine the value of imported goods at the time of importation can now use the provisional values service to give a reasonable estimate of that value, which can then be finalized at a later date.
Binding Rulings
. NZCS states that binding valuation rulings can give importers certainty about the Service’s view of the correct method to be used in determining the value of their goods and therefore how much duty they need to pay. Following are some highlights of the ruling process.
  – applications for rulings should be made well before goods are imported; post-importation applications will be considered on a case-by-case basis
  – Customs has up to 150 days to issue a ruling
  – rulings are valid for up to three years
  – rulings can be appealed to the Customs Appeal Authority
  – the fee for a ruling is based on the recovery of costs required to make the ruling
Provisional Values
. Importers must register with the NZCS to provide provisional values and will be notified of approval or rejection within 30 days. Provisional values will be effective from the approval date. Most provisional values applications will be for ongoing use but in some situations importers can request a one-off approval for high-value or special-purpose imports.

Provisional values should be estimated based on (a) a reasonable estimate of the value of imported goods using the information available to the importer at the time of entry or (b) application of the requirements of the valuation methodology. These values will be treated as the customs value until they are finalized and importers will be liable to pay duty on them.

Provisional values must be finalized within 12 months of the end of the importer’s financial year in which the original entry was made. If this does not occur any outstanding duty will be treated as a shortfall payment, penalties and interest will apply, and the importer could be suspended from using provisional values or subject to prosecution.

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American Shipper, 17 Oct 2018.) [Excerpts.]
* Author: Christopher Gillis, Editor, American Shipper, 
Be mindful of new EU sanctions against chemical weapons proliferation as they relate to U.S. companies’ European branches and affiliates.
What happens in Europe doesn’t stay in Europe when it comes to U.S. export compliance. Take for example the announcement by the European Council earlier this week regarding its adoption of a new set of regulatory measures to curtail the proliferation of chemical weapons and the components to make them. 

The council concluded the necessity for this policy in late June. The urgency for these measures have since been amplified across the continent following the alleged nerve agent-based attacks on Russian exiles in the U.K. and more recent concern that Iran and Syria may do the same to anti-government nationals living in Europe. … 

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Volkov Law Group Blog, 21 Oct 2018. Reprinted by permission.) 
* Author: Michael Volkov, Esq., Volkov Law Group,
mvolkov@volkovlaw.com, 240-505-1992. 
Companies face a myriad of risks that can cause significant legal and reputational risks.  A company’s employees are critical sources of concerns to prevent and detect problems.  Employees have to be encouraged to raise concerns to help the company address these problems proactively.  As a result, it is critical for companies to invest and promote its speak up culture to maximize employee communication and prevent serious harm to the company.
this episode, Michael Volkov discusses how to implement and promote a “speak-up” culture.

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James Mackintosh
24 Oct 1765 – 30 May 1832; was a Scottish jurist, Whig politician and historian. His studies and sympathies embraced many interests. He was trained as a doctor and barrister, and worked also as a journalist, judge, administrator, professor, philosopher and politician.)
It is right to be contented with what we have, never with what we 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: 24 Oct 2018: 
83 FR 53742-53793
: Wassenaar Arrangement 2017 Plenary Agreements Implementation; Final Rule [Revision of EAR Parts 740, 742, 744, 772, and 774.]

: 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: 22 Oct 2018: Harmonized System Update 1818

containing 1,544 ABI records and 286 harmonized tariff records.

  – HTS codes for AES are available 
  – HTS codes that are not valid for AES are available 
  – Last Amendment:
4 Oct 2018: 83 FR 50003-50007: Regulatory Reform Revisions to the International Traffic in Arms Regulations.

  – The only available fully updated copy (latest edition: 4 Oct 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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