18-1116 Friday “Daily Bugle”

18-1116 Friday “Daily Bugle”

Friday, 16 November 2018

TOPThe Daily Bugle is a free daily newsletter from Full Circle Compliance, containing changes to export/import regulations (ATF, DOE/NRC, Customs, NISPOM, EAR, FACR/OFAC, FAR/DFARS, FTR/AES, HTSUS, and ITAR), plus news and events. Subscribe here for free subscription. Contact us for advertising inquiries and rates

  1. Commerce Publishes Fall 2018 Semiannual Agenda of Regulations
  2. DHS/CBP Announces COAC Meeting on 5 Dec in Herndon, VA
  1. Items Scheduled for Publication in Future Federal Register Editions 
  2. Commerce/BIS: (No new postings.)
  3. DHS/CBP Issues New Information Notice Concerning ACE Reports
  4. State Publishes List of Restricted Entities and Subentities Associated with Cuba as of 15 Nov
  5. State/DDTC: (No new postings.)
  6. White House Announces Continuation of National Emergency with Respect to Burundi
  1. ST&R Trade Report: “Dates and Deadlines: ITAR, Tariff Suspensions, CBP Forms, Cargo Container Fees”
  1. M. Volkov: “Ethics and Compliance Initiative Report: The Importance of Ethics Communications and Accountability”
  2. P. Jeydel: “New ‘Troika of Tyranny’ Cuba Sanctions – More Bark Than Bite”
  3. T. McBride: “Update on Russia: Restrictions Expanded to New Actors, Industries”
  1. ECS Presents: “Seminar Level I – Boot Camp: Achieving ITAR/EAR Compliance”, 10-11 Jul 2019 in Seattle, WA
  2. FCC Presents “Designing an Internal Compliance Program for Export Controls & Sanctions”, 5 Feb 2019 in Bruchem, the Netherlands
  3. List of Approaching Events: 7 New Events Posted This Week
  1. Bartlett’s Unfamiliar Quotations 
  2. Are Your Copies of Regulations Up to Date? Latest Amendments: ATF (15 Jan 2016), Customs (19 Sep 2018), DOD/NISPOM (18 May 2016), EAR (2 Nov 2018), FACR/OFAC (15 Nov 2018), FTR (24 Apr 2018), HTSUS (1 Nov 2018), ITAR (4 Oct 2018) 
  3. Weekly Highlights of the Daily Bugle Top Stories 



Federal Register, 16 Nov 2018.) [Excerpts.] 
83 FR 57998: Fall 2018 Semiannual Agenda of Regulations 
* AGENCY: Office of the Secretary, Commerce.
* ACTION: Semiannual regulatory agenda.
* SUMMARY: In compliance with Executive Order 12866, entitled “Regulatory Planning and Review,” and the Regulatory Flexibility Act, as amended, the Department of Commerce (Commerce), in the spring and fall of each year, publishes in the Federal Register an agenda of regulations under development or review over the next 12 months. Rulemaking actions are grouped according to prerulemaking, proposed rules, final rules, long-term actions, and rulemaking actions completed since the spring 2018 agenda. The purpose of the Agenda is to provide information to the public on regulations that are currently under review, being proposed, or issued by Commerce. The agenda is intended to facilitate comments and views by interested members of the public.
  Commerce’s fall 2018 regulatory agenda includes regulatory activities that are expected to be conducted during the period October 1, 2018, through September 30, 2019. 
  – Specific: For additional information about specific regulatory actions listed in the agenda, contact the individual identified as the contact person.
  – General: Comments or inquiries of a general nature about the agenda should be directed to Asha Mathew, Chief Counsel for Regulation, Office of the Assistant General Counsel for Legislation, Regulation, and Oversight, U.S. Department of Commerce, Washington, DC 20230, telephone: 202-482-3151.
* SUPPLEMENTARY INFORMATION: Commerce hereby publishes its fall 2018 
Unified Agenda of Federal Regulatory and Deregulatory Actions pursuant to Executive Order 12866 and the Regulatory Flexibility Act, 5 U.S.C. 601 et seq. Executive Order 12866 requires agencies to publish an agenda of those regulations that are under consideration pursuant to this order. By memorandum of June 18, 2018, the Office of Management and Budget issued guidelines and procedures for the preparation and publication of the spring 2018 Unified Agenda. The Regulatory Flexibility Act requires agencies to publish, in the spring and fall of each year, a regulatory flexibility agenda that contains a brief description of the subject of any rule likely to have a significant economic impact on a substantial number of small entities. … 
  In this edition of Commerce’s regulatory agenda, a list of the most important significant regulatory and deregulatory actions and a Statement of Regulatory Priorities are included in the Regulatory Plan, which appears in both the online Unified Agenda and in part II of the issue of the Federal Register that includes the Unified Agenda. … 
  Commerce’s fall 2018 regulatory agenda follows.
Peter B. Davidson, General Counsel. … 
Bureau of Industry and Security (BIS)
Proposed Rule Stage
(199) Expansion of Export, Reexport, and Transfer (In-Country) Controls for Military End Use or Military End Users in the People’s Republic of China (China), Russia, or Venezuela
  E.O. 13771 Designation: Other.
  Legal Authority: 10 U.S.C. 7420; 10 U.S.C. 7430(e); 15 U.S.C. 1824a; 22 U.S.C. 287c; 22 U.S.C. 3201 et seq.; 22 U.S.C. 6004; 22 U.S.C. 7201 et seq.; 22 U.S.C. 7210; 30 U.S.C. 185(s); 30 U.S.C. 185(u); 42 U.S.C. 2139a; 43 U.S.C. 1354; 50 U.S.C. 1701 et seq.; 50 U.S.C. 4305; 50 U.S.C. 4601 et seq.; E.O. 12058; E.O. 12851; E.O. 12938; E.O. 12947; E.O. 13026; E.O. 13099; E.O. 13222; E.O. 13224; Pub. L. 108-11
  Abstract: The Bureau of Industry and Security (BIS) proposes to amend the Export Administration Regulations (EAR) to expand license requirements on exports, reexports, and transfers (in-country) of items intended for military end use or military end users in the Peoples Republic of China (China), Russia, or Venezuela. Specifically, this rule would expand the licensing requirements for China to include “military end users,” in addition to “military end use.” It would broaden the items for which the licensing requirements and review policy apply and expand the definition of “military end use.” Next, it would create a new reason for control and associated review policy for regional stability for certain items to China, Russia, or Venezuela, moving existing text related to this policy. Finally, it would add Electronic Export Information filing requirements in the Automated Export System for exports to China, Russia, and Venezuela.
  – Action: NPRM 
  – Date: 02/00/19
  – FR Cite: 
  Regulatory Flexibility Analysis Required: Yes.
  Agency Contact: Hillary Hess, Director, Regulatory Policy Division, Department of Commerce, Bureau of Industry and Security, 14th Street and Pennsylvania Avenue NW, Washington, DC 20230, Phone: 202 482-2440, Fax: 202 482-3355, Email: 
    RIN: 0694-AH53 

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


Federal Register, 16 Nov 2018.) [Excerpts.] 
83 FR 57745-57746: Commercial Customs Operations Advisory Committee (COAC)
* AGENCY: U.S. Customs and Border Protection (CBP), Department of Homeland Security (DHS).
* ACTION: Committee Management; Notice of Federal Advisory Committee meeting.
* SUMMARY: The Commercial Customs Operations Advisory Committee (COAC) will hold its quarterly meeting on Wednesday, December 5, 2018, in Herndon, Virginia. The meeting will be open to the public.
* DATES: The COAC will meet on Wednesday, December 5, 2018, from 1:00 p.m. to 5:00 p.m. EST. Please note that the meeting may close early if the committee has completed its business.
* ADDRESSES: The meeting will be held at the Hilton Dulles Washington Airport, 13869 Park Center Road, Herndon, Virginia 20171. For information on facilities or services for individuals with disabilities or to request special assistance at the meeting, contact Ms. Florence Constant-Gibson, Office of Trade Relations, U.S. Customs & Border Protection, at (202) 344-1440 as soon as possible.
Pre-Registration: Meeting participants may attend either in person or via webinar after pre-registering using one of the methods indicated below:
  For members of the public who plan to attend the meeting in person, please register by 5:00 p.m. EST on December 4, 2018, either online 
here by email to 
tradeevents@dhs.gov; or by fax to (202) 325-4290. You must register prior to the meeting in order to attend the meeting in person.
  For members of the public who plan to participate via webinar, please register online 
here by 5:00 p.m. EST on December 4, 2018.
  Please feel free to share this information with other interested members of your organization or association.
  Members of the public who are pre-registered to attend in person or via webinar and later need to cancel, please do so by December 4, 2018, utilizing the following links: 
here to cancel an in person registration or 
here to cancel a webinar registration.
  To facilitate public participation, we are inviting public comment on the issues the committee will consider prior to the formulation of recommendations as listed in the Agenda section below.
  Comments must be submitted in writing and received no later than December 3, 2018, and must be identified by Docket No. USCBP-2018-0041, and may be submitted by one (1) of the following methods:
  – Federal eRulemaking Portal: 
http://www.regulations.gov. Follow the instructions for submitting comments.
  – Email: 
tradeevents@dhs.gov. Include the docket number in the subject line of the message.
  – Fax: (202) 325-4290, Attention Florence Constant-Gibson.
  – Mail: Ms. Florence Constant-Gibson, Office of Trade Relations, U.S. Customs and Border Protection, 1300 Pennsylvania Avenue NW, Room 3.5A, Washington, DC 20229.
Instructions: All submissions received must include the words “Department of Homeland Security” and the docket number (USCBP-2018-0041) for this action. Comments received will be posted without alteration at 
http://www.regulations.gov. Please do not submit personal information to this docket.
Docket: For access to the docket or to read background documents or comments, go to 
http://www.regulations.gov and search for Docket Number 
USCBP-2018-0041. To submit a comment, click the “Comment Now!” button located on the top-right hand side of the docket page.
  There will be multiple public comment periods held during the meeting on December 5, 2018. Speakers are requested to limit their comments to two (2) minutes or less to facilitate greater participation. Contact the individual listed below to register as a speaker. Please note that the public comment period for speakers may end before the time indicated on the schedule that is posted on the CBP web page, 
here. … 
  The COAC will hear from the current subcommittees on the topics listed below and then will review, deliberate, provide observations, and formulate recommendations on how to proceed:
  (1) The Secure Trade Lanes Subcommittee will present plans for the scope and activities of the Trusted Trader and CTPAT Minimum Security Criteria Working Groups. It is anticipated that recommendations will be presented regarding the proposed Forced Labor Trusted Trader Strategy. The subcommittee will also deliver recommendations from the Petroleum Pipeline Working Group regarding the results of a proof of concept test that used the Automated Commercial Environment to electronically report and manage petroleum moving in-bond via pipeline; as well as recommendations from the In-bond Working Group regarding potential automation, visibility, system and regulatory issues.
  (2) The COAC Next Generation Facilitation Subcommittee will discuss the E-Commerce Working Group’s progress on mapping the supply chains of various modes of transportation to identify the differences between e-commerce and traditional channels. The subcommittee will also provide an update on the status of the Emerging Technologies Working Group’s NAFTA/CAFTA, Intellectual Property Rights, and Pipeline Blockchain Proof of Concept projects. Finally, the subcommittee will provide a progress report for the Regulatory Reform Working Group as it completes its review of Title 19 of the Code of Federal Regulations (CBP regulations) and begins its preparation of high-level recommendations.
  (3) The Intelligent Enforcement Subcommittee will provide recommendations from the Intellectual Property Rights Working Group and updates from the Anti-Dumping and Countervailing Duty, Bond, and Forced Labor Working Groups.
  Meeting materials will be available by December 3, 2018 at: 
  Dated: November 13, 2018.
Bradley F. Hayes, Executive Director, Office of Trade Relations.

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


. Items Scheduled for Publication in Future Federal Register Editions

Federal Register)
* Commerce/BIS; PROPOSED RULES; Review of Controls for Certain Emerging Technologies [Pub. Date: 19 Nov 2018.]
* Justice/ATF; NOTICES; Agency Information Collection Activities; Proposals, Submissions, and Approvals: 
Report of Theft or Loss of Explosives [Pub. Date: 19 Nov 2018.]

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

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DHS/CBP Issues New Information Notice Concerning ACE Reports

CSMS# 18-000682, 15 Nov 2018.) 
U.S. Customs and Border Protection (CBP) continues to create new data universes and reports, as well as enhance current reports to meet the needs of the trade community. A new Information Notice is available with details on recent and upcoming updates. Please see the ACE Reports Information Notice 
Please email 
ace.reports@cbp.dhs.gov with any questions.

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

State Publishes List of Restricted Entities and Subentities Associated with Cuba as of 15 Nov

State, 15 Nov 2018.) [Excerpts.] 
Below is the U.S. Department of State’s list of entities and subentities under the control of, or acting for or on behalf of, the Cuban military, intelligence, or security services or personnel with which direct financial transactions would disproportionately benefit such services or personnel at the expense of the Cuban people or private enterprise in Cuba. For information regarding the prohibition on direct financial transactions with these entities, please see the Department of the Treasury’s Office of Foreign Assets Control 
website and the Department of Commerce’s Bureau of Industry and Security 
website. All entities and subentities were listed effective November 9, 2017, unless otherwise indicated.

Entities or subentities owned or controlled by another entity or subentity on this list are not treated as restricted unless also specified by name on the list. ***
Ministries; Holding Companies; Hotels in Havana and Old Havana; Hotels in Santiago de Cuba; Hotels in Varadero; Hotels in Pinar del Rio; Hotels in Baracoa; Hotels in Cayos de Villa Clara; Hotels in Holguín; Hotels in Jardines del Rey; Hotels in Topes de Collantes; Tourist Agencies; Marinas; Stores in Old Havana; Entities Directly Serving the Defense and Security Sectors; Additional Subentities of CIMEX; Additional Subentities of GAESA; Additional Subentities of Gaviota; Additional Subentities of Habaguanex … 

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

State/DDTC: (No new postings.)


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

White House Announces Continuation of National Emergency with Respect to Burundi 

The White House, 16 Nov 2018.) 
Text of a Notice on the Continuation of the National Emergency with Respect to Burundi
On November 22, 2015, by Executive Order 13712, the President declared a national emergency to deal with the unusual and extraordinary threat to the national security and foreign policy of the United States constituted by the situation in Burundi, which has been marked by the killing of and violence against civilians, unrest, the incitement of imminent violence, and significant political repression, and which threatens the peace, security, and stability of Burundi and the region.
The situation in Burundi continues to pose an unusual and extraordinary threat to the national security and foreign policy of the United States.  For this reason, the national emergency declared on November 22, 2015, to deal with that threat must continue in effect beyond November 22, 2018.  Therefore, in accordance with section 202(d) of the National Emergencies Act (50 U.S.C. 1622(d)), I am continuing for 1 year the national emergency declared in Executive Order 13712.
This notice shall be published in the 
Federal Register and transmitted to the Congress.

November 16, 2018.

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


Following are highlights of regulatory effective dates and deadlines, federal agency meetings, and other trade-related events coming up in the next week.
* Nov. 19 – effective date of new 
fees on cargo containers at Los Angeles-area ports
* Nov. 19 – deadline for comments to Census on 
Automated Export System information collection
* Nov. 19 – deadline for comments to State Department on update to 
International Traffic in Arms Regulations
* Nov. 19 – deadline for comments to ITA on 
softwood lumber subsidy programs
* Nov. 21 – deadline for comments to ITC on 
IPR import restriction request on fuel vapor canister systems
* Nov. 23 – deadline for comments to ITC on questionnaire for 
economic assessment of temporary duty suspensions
* Nov. 23 – deadline for comments on CBP information collection on 
entry and manifest of goods free of duty

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


M. Volkov: “Ethics and Compliance Initiative Report: The Importance of Ethics Communications and Accountability”

Volkov Law Group Blog, 16 Nov 2018. Reprinted by permission.) 
* Author: Michael Volkov, Esq., Volkov Law Group, 
mvolkov@volkovlaw.com, 240-505-1992. 
The Ethics and Compliance Initiative (“ECI”) continues to publish important surveys and studies.  In a recent report (available 
here), the ECI cited important research from its Q3 Global Business Ethics Survey (“GBES”) demonstrating the value of ethical communications and trust in an organization.  In particular, the ECI study found that:
  – Employees are 11 times more likely to speak up when faced with witnessing wrongdoing in the workplace where the company proactively communicates about ethical conduct;
  – Conversely, fewer than 4 in 100 employees whose managers and supervisors fail to demonstrate accountability also feel that those managers demonstrate respect for their employees; and
  – Employees are 15 times more likely to believe that their organizations reward and measure ethical behavior when they see consistent, regular communication from upper management on issues like trust and ethical conduct.
Ethical Communications: ECI’s report notes that leaders and managers at all levels of a company have to communicate their expectations as to the standards of ethical conduct.  This message is critical and has to be reinforced at every level of leadership. 
An important part of this message also has to focus on employees raising concerns.  Leaders should encourage employees to raise concerns and speak up when they are aware of potential misconduct.  As part of this message, leaders have to reiterate, as often as possible, the company’s zero tolerance policy to prevent retaliation against employees who speak up.
Workplace Trust:  To instill workplace trust, ECI observes that managers and supervisors must demonstrate accountability.  A manager must be willing to accept responsibility for their own mistakes.  Most importantly, senior managers have to take ownership of their own actions and not blame others when things go wrong.
Managers and supervisors have to engage their employees with honesty and integrity.  In doing so, they have to listen to their employees and express empathy and care for their well-being.  A manager has to be skilled at making employees feel that their opinions and observations matter and that they are valued at the company.
To this end, it is critical for employees to believe their top management is open and honest, and act with integrity.  Supervisors have to communicate their care for their employees, and employees have to feel that their concerns have been heard by their supervisors.
The ECI study found that 50 percent of employees in the United States believe that proactive ethical communications are present in their organization.  At the same time, 43 percent of employees believe the same about workplace trust.
ECI concludes that proactive communications consist of speaking about ethics and a culture that encourages speaking up.  When these elements are not present, employees generally feel the company lacks an ethical culture and places no value on speaking up.

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* Author: Peter Jeydel, Esq., Esq., 
pjeydel@steptoe.com. Steptoe & Johnson LLP.
Effective tomorrow [Thursday, 15 November, ed.] the State Department is updating its 
Cuba Restricted List (press release 
here) to add 26 new subentities (along with amending the entries for 5 previously-listed subentities). National Security Advisor John Bolton had previewed this action in a 
speech in Miami in which he labeled Cuba, Venezuela and Nicaragua the “Troika of Tyranny” and said the U.S. government would be designating “over two dozen additional entities owned or controlled by the Cuban military and intelligence services to the restricted list of entities with which financial transactions by U.S. persons are prohibited.” Bolton had ominously warned that this “Troika” had “finally met its match” and that all three countries “will feel the full weight of America’s robust sanctions” under this new policy. Bolton suggested that the Administration would implement a tough new sanctions policy against Cuba, quipping, in contrast to the Obama Administration, that “Our concern is with sanctions, not selfies.”
So what was the follow up to this strident threat? Adding several hotels and other seemingly minor entities to a sanctions list that itself has little impact in many cases. What this list does under the U.S. sanctions regulations, as we’ve 
previously advised, is limit the availability of certain carve-outs from the Cuba embargo but only when one is engaging in “direct financial transactions” with one of the listed entities, including “by acting as the originator on a transfer of funds whose ultimate beneficiary is” on the list “or as the ultimate beneficiary on a transfer of funds whose originator is” on the list. So in many instances being on this list does not give rise to any additional sanctions restrictions. There is also an impact under U.S. export controls, and these listed entities will generally not be eligible to receive goods, software or technology subject to U.S. jurisdiction.
Organizations operating in Cuba may want to take note that some of the newly added entities are in the real estate business. For example, Compañía Inmobiliaria Aurea S.A. 
reportedly rents out office space in Havana. So you would not want them as your landlord, as those rent payments may constitute “direct financial transactions.” Telecoms companies should take note that an entity called Servicios de Telecomunicaciones a los Órganos de la Defensa (“SERTOD”) was added to the list. SERTOD 
reportedly provides telecommunications network design, maintenance and related services. So it would be prudent to avoid SERTOD as a subcontractor, service provider or other business partner in Cuba.

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

T. McBride: “Update on Russia: Restrictions Expanded to New Actors, Industries”
Global Trade, 7 Nov 2018.) [Excerpts.] 
* Author: Thad McBride, partner in Bass, Berry & Sims PLC’s Washington, D.C. office in the firm’s International Trade Practice Group. He may be reached at 
Since the beginning of August 2018, the United States has taken multiple actions that will affect U.S. trade with 
Russia.  The actions cover exports to Russia, doing business with Russian partners, and potential Russian investment in the United States.  These actions have added to the already challenging landscape of conducting business in and with 
Economic Sanctions in Place Since 2014 Are Expanded Again … 
New Export Restrictions Announced Under Chemical and Biological Weapons Law … 

Russian Investment in United States Likely to Be Subject to Greater Scrutiny … 

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 ECS Presents: “
Seminar Level I – Boot Camp: Achieving ITAR/EAR Compliance”, 10-11 Jul 2019 in Seattle, WA
(Source: S. Palmer, spalmer@exportcompliancesolutions.com.)
* What: Seminar Level I – Boot Camp: Achieving ITAR/EAR Compliance; Seattle, WA
* When: July 10-11, 2019
* Sponsor: Export Compliance Solutions (ECS)
* ECS Speaker Panel:  Suzanne Palmer, Mal Zerden
* Register here or by calling 866-238-4018 or e-mail 

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

FCC Presents “Designing an Internal Compliance Program for Export Controls & Sanctions”, 5 Feb 2019 in Bruchem, the Netherlands
(Source: Full Circle Compliance, events@fullcirclecompliance.eu.)
The next Full Circle Compliance (FCC) academy course is specifically designed for beginning compliance professionals who aim to enhance their organization’s compliance efforts.  The course will cover multiple topics and tackle various questions, including but not limited to:
  – Setting the Scene: ensuring compliance in the export control and sanctions arena
  – What is expected from your organization? A closer look at the frameworks and guidelines from U.S. and European government agencies (incl. State/DDTC, Commerce/BIS, Treasury/OFAC, European Union, The Netherlands, and Germany) 
  – Key elements of an Internal Compliance Program
  – Strategic benefits of an Internal Compliance Program
  – Best practice tips for enhancing your 
compliance activities
  – Compliance Toolkit: internal controls samples (policies, procedures, instructions, checklists)
* What: Designing an Internal Compliance Program for Export Controls & Sanctions 
* When: Tuesday, 5 Feb 2019, 9.00 AM – 4.30 PM 
* Where: Landgoed Groenhoven, Bruchem, the Netherlands
* Sponsor: Full Circle Compliance (FCC)

* Instructors: Drs. Ghislaine C.Y. Gillessen RA, Marco F.N. Crombach MSc

* Information & Registration: via the event page, via
events@fullcirclecompliance.eu or call +31 (0)23 – 844 – 9046.

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

List of Approaching Events: 7 New Events Posted This Week
(Sources: Editor and Event Sponsors)

Published every Friday or last publication day of the week, o
ur overview of Approaching Events is organized to list c
ontinuously available training, training events, s
eminars & conferences, and 
Please, submit your event announcement to Alexander Witt, Events & Jobs Editor (email: 
), composed in the below format:

#” = New or updated listing  

Continuously Available Training
* E-Seminars: “US Export Controls” / “Defense Trade Controls“; Export Compliance Training Institute; danielle@learnexportcompliance.com 

* Webinar: ”
Company-Wide US Export Controls Awareness Program“; Export Compliance Training Institute;

* E-Seminars: “ITAR/EAR Awareness“; Export Compliance Solutions;
* Online: “Simplified Network Application Process Redesign (SNAP-R)“; Commerce/BIS; 202-482-2227
* E-Seminars: “Webinars On-Demand Library“; Sandler, Travis & Rosenberg, P.A.
* Online: “International Trade Webinars“; Global Training Center
Online: “On-Demand Webinars“; “General Training“; Center for Development of Security Excellence; Defense Security Service (DSS)
* Online: “ACE Reports Training and User Guide“; DHS/CBP

* Online: ”
Increase Your International Sales – Webinar Archive“; U.S. Commercial Service

* Web Form: “Compliance Snapshot Assessment“; Commonwealth Trading Partners (CTP)
* Online: “
Customs Broker Exam Prep Course
“; The Exam Center
Seminars and Conferences


* Nov 20: Manchester, UK; “
How to Claim Duty Relief on Export and Import Processes
” Greater Manchester Chamber of Commerce

* Nov 20: Sydney, Australia; 
Defence Export Controls Outreach
; Australian Department of Defense;

Nov 20: Singapore; “
The WorldECR Export controls And Sanctions Forum 2018
“; WorldECR

Nov 20: Varese, Italy; “
Dual Use: aggiornamenti 2018
“; Camera di Comercio di Varese;

* Nov 21: Brussels, Belgium; “
Academic Export Control Outreach Event

Flanders Department of Foreign Affairs;

* Nov 21: London, UK; “Cyber Export Controls“; UK Department for International Trade

* Nov 21: Manchester, UK; “
Introduction to Exporting
” Greater Manchester Chamber of Commerce

Nov 22: Hong Kong; “
The WorldECR Export controls And Sanctions Forum 2018
“; WorldECR

* Nov 27: Houston, TX; “Duty Drawback Specialist – Certification“; Global Trade Academy

* Nov 28-30: Brussels, Belgium; “

Brussels Diplomatic Academy

Nov 27 – 30: Washington, D.C.; “
35th International Conference on the Foreign Corrupt Practices Act
“; American Conference Institute
Nov 29: Washington, D.C.; “
Other Transaction Authority Agreements: An Introduction
“; Public Contracting Institute

* Dec 3-7: Tysons Corner, VA; “Certified Classification Specialist“; Global Trade Academy 
* Dec 4-5: Frankfurt, Germany; “US Defence Contracting and DFARS Compliance in Europe;” C5 Group
* Dec 5: London, UK; “Intermediate Seminar“; UK Department for International Trade

 Dec 6: London, UK; “
Beginner’s Workshop
“; UK Department for International Trad

* Dec 6: London, UK; “Licenses Workshop“; UK Department for International Trade
* Dec 6: London, UK; “Control List Classification – Combined Dual Use and Military“; UK Department for International Trade
* Dec 6: London, UK; “International Documentation and Customs Compliance“; Institute of Export and International Trade

 Dec 6: Manchester, UK; “
Export Documentation Training Course
;” Greater Manchester Chamber of Commerce

* Dec 6: Manchester, UK; “
Introduction to Export Controls and Licenses

* Dec 6: San Pedro, CA; “
2018 FTA Holiday Celebration
“; Foreign Trade Association (FTA)

Dec 6: Washington D.C.; “
Other Transaction Authority Agreements: Key Terms and Compliance Obligations
“; Public Contracting Institute
Dec 7: Boston, MA: “
Export Expo
Massachusetts Export Center

Dec 7: Washington D.C.; “
2018 Holiday Party
“; SIA

Dec 11: York, PA; 
International Traffic in Arms Regulations Seminar
; World Trade Center Harrisburg

* Dec 13: Brussels, Belgium; “
2018 Export Control Forum
“; European Commission

Dec 13: Washington, D.C.; “
Other Transaction Authority Agreements: Accelerators, Consortia, and Recent Developments
“; Public Contracting Institute

* Dec 14: Philadelphia, PA; “Incoterms 2010: Terms of Sale Seminar“; International Business Training

* Jan 6-7: Long Beach, CA; ”
Fundamentals of FTZ Seminar“; NAFTZ 

Jan 15: Arlington, VA; “
Voluntary Disclosure/Voluntary Self-Disclosure Seminar
“; SIA

Jan 21-24: San Diego, CA; “ITAR Defense Trade Controls / EAR Export Controls Seminar”; ECTI; 540-433-3977

Jan 29: Rotterdam, The Netherlands; “
Awareness training Export Control, Dual-use en Sancties

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

Feb 5; Bruchem, the Netherlands; “Designing an Internal Compliance Program for Export Controls & Sanctions“; Full Circle Compliance 

* Feb 6-7: Orlando, FL; “
Boot Camp: Achieving ITAR/EAR Compliance
“; Export Compliance Solutions (ECS)

* Feb 6-7: Scottsdale, AZ;

Complying with U.S. Export Controls
“; Commerce/BIS

* Feb 12-13: Washington, D.C.; “
2019 Legislative Summit
“; National Association of Foreign Trade Zones (NAFTZ) 
* Feb 18-21: Orlando, FL; “
ITAR Defense Trade Controls / EAR Export Controls Seminar

Mar 4-6: Savannah, GA; “
2019 Winter Back to Basics Conference
“; SIA

Mar 5-7:  Orlando, FL; “
‘Partnering for Compliance’ Export/Import Control Training and Education Program
“; Partnering for Compliance

* Mar 6-7: San Diego, CA;

Complying with U.S. Export Controls
“; Commerce/BIS

 Mar 9: Orlando, FL; “
Customs/Import Boot Camp
;” Partnering for Compliance

* Mar 12-14: Dallas, TX;

Complying with U.S. Export Controls
“; Commerce/BIS
* Mar 12-14: Dallas, TX;

How to Build an Export Compliance Program
“; Commerce/BIS

* Mar 18-21: Las Vegas, NV; “
ITAR Defense Trade Controls / EAR Export Controls Seminar

* Mar 26-27: Scottsdale, AZ; “
Seminar Level II: Managing ITAR/EAR Complexities
“; Export Compliance Solutions

* Apr 1-4: Washington, DC;ITAR Defense Trade Controls / EAR Export Controls Seminar“; ECTI

* Apr 3-4: Denver, CO;

Complying with U.S. Export Controls
“; Commerce/BIS
* Apr 23-24: Portsmouth, NH;

Complying with U.S. Export Controls
“; Commerce/BIS
Apr 25: Portsmouth, NH;

Technology Controls
“; Commerce/BIS

 Apr 30-May 1: Nashville, TN: “Seminar Level III-Mastering ITAR/EAR Challenges“; Export Compliance Solutions (ECS);

* May 5-7: Savannah, GA; “2019 Spring Seminar“; National Association of Foreign Trade Zones (NAFTZ)

May 6-7: Atlanta, GA; “
2019 Spring Conference
“; SIA

Jul 10-11: Seattle, WA: “Seminar Level I-Boot Camp: Achieving ITAR/EAR Compliance“; Export Compliance Solutions (ECS);

* Aug 20-21: Cincinnati, OH;

Complying with U.S. Export Controls
“; Commerce/BIS

* Sep 8-11: Chicago, IL; “2019 Annual Conference and Exposition“; National Association of Foreign Trade Zones (NAFTZ)

Oct 28 – 29: Washington D.C.; “
2019 Fall Advanced Conference
“; SIA



Nov 27: Webinar; “
Advanced Classification, Part 2
Sandler, Travis & Rosenberg, P.A
Nov 29: Webinar; “
Conflicts between EU and Export Control Rules
“; ECTI;

Nov 29: Webinar; “
Other Transaction Authority Agreements: An Introduction
“; Public Contracting Institute

 Nov 29: Webinar;
“Trade Wars: Episode IX [Monthly Update]”
; Sandler, Travis & Rosenberg, P.A

* Dec 3: Webinar; “Tariff Classification: Using the Harmonized Tariff Schedule; International Business Training 

* Dec 4: Webinar; “NAFTA Rules of Origin“; International Business Training 

Dec 5: Webinar; “
Export Compliance Essentials for the Aerospace Industry
; call 540-433-3977

* Dec 5: Webinar; “Import Documentation and Procedures“; International Business Training

Dec 6: Webinar; “
Other Transaction Authority Agreements: Key Terms and Compliance Obligations
“; Public Contracting Institute
* Dec 11: Webinar; “
Incoterms 2010: Terms of Sale
“; International Business Training 

Dec 13: Webinar; “
Other Transaction Authority Agreements: Accelerators, Consortia, and Recent Developments
“; Public Contracting Institute

* Dec 20: Webinar; “International Logistics
“; International Business Training

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


. Bartlett’s Unfamiliar Quotations

(Source: Editor)

Louis XVIII of France (Louis Stanislas Xavier; 17 Nov 1755 – 16 Sep 1824; ruled as King of France from 1814 to 1824, except for a period in 1815 known as the Hundred Days. He spent twenty-three years in exile, from 1791 to 1814, during the French Revolution and the First French Empire, and again in 1815, during the period of the Hundred Days, upon the return of Napoleon I from Elba.)
– “Punctuality is the politeness of kings.”

Honda (17 Nov 1906 – 5 Aug 1991; was a Japanese engineer and industrialist. In 1948, he established Honda Motor Co., Ltd., and oversaw its expansion from a wooden shack manufacturing bicycle motors to a multinational automobile and motorcycle manufacturer.)
  – “Success is 99 percent failure.”
  – “There is a Japanese proverb that literally goes ‘Raise the sail with your stronger hand’, meaning you must go after the opportunities that arise in life that you are best equipped to do.”
Friday funnies:
* A boy asks his father, “Dad, are bugs good to eat?” “That’s disgusting. Don’t talk about things like that over dinner,” the dad replies. After dinner the father asks, “Now, son, what did you want to ask me?” “Oh, nothing,” the boy says. “There was a bug in your soup, but now it’s gone.”
* Instead of “the John,” I call my toilet “the Jim.” That way it sounds better when I say I go to the Jim first thing every morning.
Editor’s Note:  I discovered a radio station from the small village of Urk, Netherlands, that plays pipe organ and choral music in Dutch and English, available 24×7 on the Internet 
here.  Choose ”
Geestelijke Stream“.

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

EN_a217. Are Your Copies of Regulations Up to Date?
(Source: Editor)

The official versions of the following regulations are published annually in the U.S. Code of Federal Regulations (C.F.R.), but are updated as amended in the Federal Register.  The latest amendments to applicable regulations are listed below.

ATF ARMS IMPORT REGULATIONS: 27 CFR Part 447-Importation of Arms, Ammunition, and Implements of War
  – Last Amendment: 15 Jan 2016: 
81 FR 2657-2723: Machineguns, Destructive Devices and Certain Other Firearms; Background Checks for Responsible Persons of a Trust or Legal Entity With Respect To Making or Transferring a Firearm. 

CUSTOMS REGULATIONS: 19 CFR, Ch. 1, Pts. 0-199
  – Last Amendment: 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 


  – Last Amendment: 2 Nov 2018: 
83 FR 55099: Wassenaar Arrangement 2017 Plenary Agreements Implementation [Correction to 24 Oct EAR Amendment Concerning Supplement No. 1 to Part 774, Category 3.]


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

  – Last Amendment: 15 Nov 2018: 
83 FR 57308-57318: Democratic Republic of the Congo Sanctions Regulations



  – Last Amendment: 24 Apr 2018:
83 FR 17749-17751
: Foreign Trade Regulations (FTR): Clarification on the Collection and Confidentiality of Kimberley Process Certificates

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

Last Amendment: 1 Nov 2018: 
Harmonized System Update 1809
containing 1,200 ABI records and 245 harmonized tariff records.

  – HTS codes for AES are available 
  – HTS codes that are not valid for AES are available here.


  – 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.

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

. Weekly Highlights of the Daily Bugle Top Stories
(Source: Editor)

Review last week’s top Ex/Im stories in “Weekly Highlights of Daily Bugle Top Stories” posted here.

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

* The Ex/Im Daily Update is a publication of FCC Advisory B.V., compiled by: Editor, James E. Bartlett III; Assistant Editors, Alexander P. Bosch and Vincent J.A. Goossen; and Events & Jobs Editor, Alex Witt. The Ex/Im Daily Update is emailed every business day to approximately 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 cannot be relied upon as legal or expert advice.  Consult your own legal counsel or compliance specialists before taking actions based upon news items or opinions from this or other unofficial sources.  If any U.S. federal tax issue is discussed in this communication, it was not intended or written by the author or sender for tax or legal advice, and cannot be used for the purpose of avoiding penalties under the Internal Revenue Code or promoting, marketing, or recommending to another party any transaction or tax-related matter.

* SUBSCRIPTIONS: Subscriptions are free.  Subscribe by completing the request form on the Full Circle Compliance website.

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