19-0103 Thursday “Daily Bugle'”

19-0103 Thursday “Daily Bugle”

Thursday, 3 January 2019

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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[No items of interest noted today.] 

  1. Items Scheduled for Publication in Future Federal Register Editions
  2. Commerce/BIS: (No new postings.)
  3. DoD/DSS Posts Notice on Filling in the ‘Prime Contract Number’ Field in JPAS When Submitting Personnel Security Clearance Investigations
  4. State/DDTC: (No new postings.)
  1. Expeditors News: “CBP to Make Section 201, 232, and 301 Reports Available to Importers/Brokers Through ACE”
  2. Reuters: “U.S. Warns Iran against Space Launches, Ballistic Missiles”
  3. Saipan Tribune: “FBI Arrests Man Wanted in Florida for Arms Violations Conspiracy”
  1. International Trade Compliance Blog: “EU – Council Extends Sanctions against Russia”
  2. J. Reeves: “How the Partial Government Shutdown Affects ATF Operations and Export Licensing”
  3. M. Volkov: “FCPA Predictions for 2019” 
  4. P.A. Quinter: “USTR Grants Tariff Exclusions from List 1 of Section 301 Extra Tariffs Against China” 
  1. FCC Presents Renewed U.S. Export Controls Awareness Course: “ITAR & EAR from a non-U.S. Perspective”, 9 April in Bruchem, the Netherlands
  1. New Editions of the BAFTR and BITAR Are Available 
  2. Bartlett’s Unfamiliar Quotations 
  3. Are Your Copies of Regulations Up to Date? Latest Amendments: DHS/Customs (18 Dec 2018), DOC/EAR (20 Dec 2018), DOC/FTR (24 Apr 2018), DOD/NISPOM (18 May 2016), DOE/AFAEC (23 Feb 2015), DOE/EINEM (20 Nov 2018), DOJ/ATF (26 Dec 2018), DOS/ITAR (4 Oct 2018), DOT/FACR/OFAC (15 Nov 2018), HTSUS (19 Dec 2018) 
  4. Weekly Highlights of the Daily Bugle Top Stories 


[No items of interest noted today.]
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OGS_a11. Items Scheduled for Publication in Future Federal Register Editions
(Source: Federal Register)


[No items of interest noted today.]  

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Commerce/BIS: (No new postings.)


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DoD/DSS, 3 Jan 2019.)
Beginning February 1, 2019, DSS may reject investigation submissions that don’t include the prime contract number, as shown on the associated industry guidance. The prime contract number is a required field in the Joint Personnel Adjudication System for personnel security clearance investigations. Please contact the VROC Knowledge Center for questions (888) 282-7682, select option #2.

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Expeditors News, 2 Jan 2018.)
On December 21, 2018, U.S. Customs and Border Protection (CBP) announced in Cargo Systems Messaging Service (CSMS) #18-000753 that they will soon make additional reports on Section 201, 232, and 301 available to importers and brokers holding ACE accounts.
The reports include:
  – TR-001 Section 232 Aluminum – provides data on entries subject to Section 232 duties for aluminum;
  – TR-002 Section 232 Steel – provides data on entries subject to Section 232 duties for steel;
  – TR-004 Section 301 Totals – provides aggregate data on entries subject to Section 301;
  – TR-005 Section 301 Details – provides line-level data on entries subject to Section 301;
  – TR-006 Section 201 Totals – provides aggregate data on entries subject to Section 201; and
  – TR-007 Section 201 Details – provides line-level data on entries subject to Section 201.
CBP asks that any comments or questions be sent to
The CSMS may be found here.

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NWS_a26. Reuters: “U.S. Warns Iran against Space Launches, Ballistic Missiles”

(Source: Reuters, 3 Jan 2018.) [Excerpts.]
The United States issued a pre-emptive warning to Iran on Thursday against pursuing three planned space rocket launches that it said would violate a U.N. Security Council resolution because they use ballistic missile technology.
  “The United States will not stand by and watch the Iranian regime’s destructive policies place international stability and security at risk,” Pompeo said in a statement.
  “We advise the regime to reconsider these provocative launches and cease all activities related to ballistic missiles in order to avoid deeper economic and diplomatic isolation.” …
Pompeo said such rocket launches would violate United Nations Security Council Resolution 2231, which endorsed a 2015 nuclear deal between Iran and world powers. It calls upon Iran not to undertake activities related to ballistic missiles capable of delivering nuclear weapons, including launches using such technology. It stops short of explicitly barring such activity. …
In July 2017, Iran launched a rocket it said could deliver a satellite into space, an act the U.S. State Department called provocative. Earlier that month, the United States slapped new economic sanctions on Iran over its ballistic missile program.
Iran says its space program is peaceful, but Western experts suspect it may be a cover for developing military missile technologies.

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. Saipan Tribune: “FBI Arrests Man Wanted in Florida for Arms Violations Conspiracy”

(Source: Saipan Tribune, 3 Jan 2018.)
The Federal Bureau of Investigation arrested on Saipan last Saturday a 72-year-old Russian national who had been indicted in Florida in 2017 for alleged involvement in a conspiracy to illegally ship military items to Russia.
Dmitrii Makarenko was served with an arrest warrant on Saturday at 3am. No other details were available as of yesterday as to why the defendant is on Saipan.
Last Monday, Makarenko appeared in the U.S. District Court for the NMI for his initial court appearance, accompanied by private counsel Tiberius Mocanu and an interpreter. 
According to records filed with the U.S. District Court for the NMI, a grand jury sitting in the Southern District of Florida returned an indictment against Makarenko, also known as Dmitryi, on June 15, 2017, charging him with one count of conspiracy to export defense articles without a license, and two counts of money laundering.
Based on the indictment, on that same day of June 15, the U.S. District Court for the Southern District of Florida issued a warrant for his arrest.
Assistant U.S. attorney Garth R. Backe asked the court for an order o transfer Makarenko to Florida.  . . .  
After the hearing, Makarenko was remanded to the custody of the U.S. Marshal to be transferred to Florida.  . . .
The indictment said generation 4 ATN MARS night-vision rifle scopes, ATN Odin 61BW IX (30 Hz) thermal multi-purpose monoculars (ODIN 61BW thermal multi-purpose monocular), and Sellier & Bellot firearm ammunition primers are defense articles covered by the USML.  
Makarenko is being accused of attempting to export military-grade night vision and thermal vision devices, and ammunition primers to Russia.
Makarenko’s co-defendant, Vladimir Nevidomy, had already pleaded guilty in Florida and was sentenced to 26 months in prison last June. 
According to the indictment, Nevidomy was a resident of Hallandale Beach, Florida, who was the owner, registered agent and principal of Primex Group Inc., a Florida corporation located in Sunny Isles Beach in Florida.  . . .
Beginning April 2013 and continuing through in or around November 2013, in Miami-Dade and Broward Counties, in the Southern District of Florida, and elsewhere, the defendants, conspired to export defense articles from the U.S. to Russia, without having first obtained a license or written approval from the State Department DDTC. . . .
Makarenko would place an order for defense articles including night-vision rifle scopes, monoculars, and ammunition primers from Nevidomy.  
Nevidomy would procure the defense articles from U.S. vendors and receive the defense articles in Broward County, Florida.  
Nevidomy would then allegedly ship the defense articles from the U.S. to Makarenko in Russia without obtaining the required licenses from the State Department’s DDTC.  . . .
On Oct. 2, 2013, Nevidomy attempted to ship a parcel from Hallandale Beach, Florida, to Makarenko in Vladivostok, Russia, containing 1,000 Sellier & Bellot firearm ammunition primers.
On Nov. 20, 2013, after Makarenko received a letter from U.S. Customs and Border Protection indicating that the primers had been seized for attempted illegal export without a license, Makarenko sent an email message to Nevidomy asking, “What are we going to do?”

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On 21 December 2018, the Council announced that it prolonged the economic sanctions targeting specific sectors of the Russian economy until 31 July 2019.
This decision follows an update from President Macron and Chancellor Merkel to the European Council of 13-14 December 2018 on the state of implementation of the Minsk agreements, to which the sanctions are linked. Given that no progress has been made, the European Council took the political decision to roll-over the economic sanctions against Russia.
The Council adopted this decision by written procedure and, in line with the rule for all such decisions, unanimously.
The measures target the financial, energy and defence sectors, and the area of dual-use goods. They were originally introduced on 31 July 2014 for one year in response to Russia’s actions destabilising the situation in Ukraine and strengthened in September 2014.
The economic sanctions prolonged by this decision include:
  – limiting access to EU primary and secondary capital markets for 5 major Russian majority state-owned financial institutions and their majority-owned subsidiaries established outside of the EU, as well as three major Russian energy and three defence companies;
  – imposing an export and import ban on trade in arms;
  – establishing an export ban for dual-use goods for military use or military end users in Russia;
  – curtailing Russian access to certain sensitive technologies and services that can be used for oil production and exploration.
In addition to these economic sanctions, several EU measures are also in place in response to the crisis in Ukraine including:
  – targeted individual restrictive measures, namely a visa ban and an asset freeze, currently against 164 people and 44 entities until 15 March 2019;
  – restrictive measures in response to the illegal annexation of Crimea and Sevastopol, limited to the territory of Crimea and Sevastopol, currently in place until 23 June 2019.
The duration of the sanctions was linked to the complete implementation of the Minsk agreements by the European Council on 19 March 2015, which was foreseen to take place by 31 December 2015. Since this did not happen, the sanctions have remained in place.

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R/D Report, 2 Jan 2018.)
* Author: Johanna Reeves, Esq., Reeves & Dola, LLP jreeves@reevesdola.com, +1 202-715-9941.
I. ATF Operations
According to the U.S. Department of Justice Contingency Plan for Fiscal Year 2019, only the following operations within the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) are operating with the current lapse in appropriations:
  – All agents in ATF field divisions who conduct criminal investigations in firearms, arson, explosives, alcohol and tobacco programs;
  – Industry Operations Investigators (IOIs) who conduct compliance inspections of Federal Firearms and Federal Explosives Licensees as well as application inspections; and
  – Personnel who collect, review and analyze intelligence data in support of criminal investigations.
Headquarters support (Washington, DC and Martinsburg, WVA) will be maintained only to the extend necessary to support excepted operations, including approvals necessary to support law enforcement and the U.S. military. In addition, the Director of ATF is not subject to furlough because the Director is a Presidential Appointee.
II. U.S. Department of State Export Licensing
As of 12:01 am on Saturday, December 22, 2018, services at the U.S. Department of State’s Directorate of Defense Trade Controls are significantly reduced. This includes export and temporary license applications, requests for advisory opinions, and retransfer authorization requests except those that provide direct support to the military, humanitarian aid, or other similar emergencies.
DDTC advises that all D-Trade submissions are being rejected by the system, and requests that were in process at DDTC as of December 21, 2018, will remain in that status, but further review actions will be delayed until funding is restored. DDTC instructs industry applicants who believe they have a case involving direct support to the military, humanitarian aid, or other similar emergencies to email the DDTC Response Team at DDTCResponseTeam@state.gov, and in the subject line reference “Request for Emergency License.” The email message must include the pending license number, applicant name and registration code, the end-use/end-user, an explanation of the justification for needing an emergency license, and a point of contact. DDTC will then contact the requestor with guidance on how to proceed if the request will be honored.
For more information, please visit DDTC’s website at https://www.pmddtc.state.gov/ for its announcement, dated 12-22-18.
III. U.S. Department of Commerce Export Licensing
Within the Bureau of Industry and Security, the following operations will continue (see also the Department of Commerce’s Plan for Orderly Shutdown Due to Lapse of Congressional Appropriations):
  – Activities related to the ongoing conduct of criminal investigations, and prosecutions, and coordination with other law enforcement and intelligence agencies in furtherance of our national security; and
  – Licensing emergency export applications.
The BIS licensing portal, Simplified Application Process-Redesign (SNAP-R) at snapr.bis.doc.gov is unavailable until funding is restored.

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Volkov Law Group Blog, 3 Jan 2019. Reprinted by permission.)
* Author: Michael Volkov, Esq., Volkov Law Group,
mvolkov@volkovlaw.com, 240-505-1992.
Here we go – another year, another set of predictions. Who knows whether they will come true?
Actually, I went back and read my annual prediction posting for 2018 and 2017, respectively. Some things I called correctly, and others I missed the mark on.
One consistent error – the Wal-Mart FCPA case would be resolved. So this year, I am employing reverse psychology. The Wal-Mart FCPA case will NOT be resolved in 2019.
A prediction I am proud of – I predicted 25 individual criminal prosecutions in 2018, and I was off by one – 26 occurred. For 2019, I will go out on a limb and predict at least 35 individual criminal prosecutions.
So here goes on more predictions for 2019.
Aside from an increase in the number of individual FCPA-related criminal cases (e.g. FCPA and money laundering charges), the number of declinations (with possible disgorgement) under the FCPA Corporate Enforcement Policy will increase. In 2018, there were 4 separate declinations, two of which included disgorgement. In 2019, I predict there will be 8 to 10 declinations under the FCPA Corporate Enforcement Policy (separate from declinations for other reasons, e.g. lack of evidence, statute of limitations issues).
Second, the U.K.’s Serious Fraud Office under the new leadership of Lisa Osofsky will play a larger role in bribery prosecutions, particularly with respect to individuals.
Third, the number of corporate monitors will continue to decline. In fact, for 2019, it is possible there may not be a monitor assigned in any case. Defense counsel are much more adept at remediation and enhancement at corporate compliance programs as a way to foreclose appointment of corporate monitors.
Fourth, DOJ will bring a new undercover case involving the use of an informant and undercover officers. The last undercover cases were the Baptiste case, which involved corruption in Haiti, and included Title III wiretaps and undercover recordings, and part of the PDVSA case, which involved a recorded informant. In 2019, we are likely to witness a new undercover case involving corruption in another separate investigation.
For 2019, we are still awaiting the resolution of several significant corporate cases (aside from Wal-Mart which will NOT be resolved in 2019). These include:
Goldman Sachs: The Goldman Sachs 1MDB case continues to dominate FCPA enforcement headlines. It is the next “big” case that will be closely followed. Malaysian prosecutors recently announced criminal charges against Goldman Sachs. DOJ’s investigation and handling of this matter will be closely scrutinized. If the case is resolved this year, it will likely not occur until late in 2019.
Ericsson: This case has been pending since 2013. Ericsson has continued to disclose updates about the investigation and its discovery of issues and potential code violations. Given its long history, this case will hopefully conclude sometime in 2019.
Microsoft: This enforcement action continues to live under the radar screen. We expected it to settle in the last two years but unfortunately it continues to lag. The focus of the case has been on Microsoft’s channel partners in Hungry, Italy, China and Romania, but little else is known about the case.
Fresenius: This case was predicted to end last year after Fresenius announced the reserve of $245 million in February 2018 for a possible settlement. This amount was increased by $86 million in October 2018. This case should be resolved in the first quarter of 2019.
The FCPA pipeline of case continues to grow. In 2018, the number of disclosures of new investigations exceeded 100 (more than 2017). Some of the significant new or ongoing investigations include: Airbus, Glencore Mining, General Electric, CHS, Inc., and Cognizant Technology. There are more for sure but these are just a sample of some of the ongoing investigations.

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(Source: Author)

Many of us have been involved with filing Section 301 Exclusion Requests with the USTR for List 1 and 2.  On December 28, 2018, in the Federal Register, the USTR approved numerous exclusion requests.
CBP has issued instructions on the procedure for the refunds retroactive to the imposition of the extra duties on July 6, 2018.  See CBP Cargo Messaging System instructions here.

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TE_a112FCC Presents U.S. Export Controls Awareness Course: “ITAR & EAR from a non-U.S. Perspective”, 9 April in Bruchem, the Netherlands

Our next academy course is specifically designed for beginning compliance professionals and those in a similar role who aim to stay up-to-date with the latest U.S. export control requirements that apply to non-U.S. transactions, and industry’s best practices.
The course will cover multiple topics relevant for organizations outside the U.S. that are subject to U.S. export controls, including: the U.S. regulatory framework, key concepts and definitions, tips regarding classification and licensing, essential steps to ensure a U.S. export control compliant shipment, how to handle a (potential) non-compliance issue, recent enforcement trends, and the latest and anticipated regulatory amendments.  Participants will receive a certification upon completion of the training.
* What: Awareness Course U.S. Export Controls: ITAR & EAR from a Non-U.S. Perspective 
* When: Tuesday, 9 Apr 2010, 9.30 am – 4.30 pm (CET)
* Where: Landgoed Groenhoven, Bruchem, the Netherlands
* Sponsor: Full Circle Compliance (FCC)
* Instructors: Michael E. Farrell and Drs. Alexander P. Bosch 
* Information & Registration: HERE, email 
 or call us at +31 6 15 65 02 09.
Register now and get a 10% Early Bird discount 
on the course fee!

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(Source: Editor)
The latest editions (1 Jan 2019) of Bartlett’s Annotated FTR (the “BAFTR”), and Bartlett’s Annotated ITAR (the “BITAR”), by James E. Bartlett III, are available to subscribers for downloading in Word format. The BAFTR and BITAR contain the official text of the Foreign Trade Regulations and International Traffic in Arms Regulations, plus all amendments, hundreds of footnotes containing case annotations, practice tips, agency guidance, and explanations of the numerous errors contained in the official text of both regulations. Subscribers receive revised copies in Microsoft Word every time the FTR and ITAR are amended.
The BAFTR and BITAR are available by annual subscription from the Full Circle Compliance
website. BITAR subscribers are entitled to a 25% discount on subscriptions to the BAFTR. Significant discounts are available for volume subscriptions. Government employees (including military) and employees of universities are eligible for a 50% discount on both publications at
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* J.R.R. Tolkien (John Ronald Reuel Tolkien, 3 Jan 1892 – 2 Sep 1973; was an English writer, poet, philologist, and university professor best known as the author of the classic high fantasy works The Hobbit, The Lord of the Rings, and The Silmarillion.)
  – “All that is gold does not glitter, not all those who wander are lost; the old that is strong does not wither, deep roots are not reached by the frost.”
  – “All we have to decide is what to do with the time that is given us.”
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. Are Your Copies of Regulations Up to Date?
(Source: Editor)

* DHS CUSTOMS REGULATIONS: 19 CFR, Ch. 1, Pts. 0-199.  Implemented by Dep’t of Homeland Security, U.S. Customs & Border Protection.
  – Last Amendment: 18 Dec 2018: 83 FR 64942-65067: Modernized Drawback  

DOC EXPORT ADMINISTRATION REGULATIONS (EAR): 15 CFR Subtit. B, Ch. VII, Pts. 730-774. Implemented by Dep’t of Commerce, Bureau of Industry & Security.
  – Last Amendment: 20 Dec 2018: 83 FR 65292-65294: Control of Military Electronic Equipment and Other Items the President Determines No Longer Warrant Control Under the United States Munitions List (USML); Correction [Concerning ECCN 7A005 and ECCN 7A105.]
* DOC FOREIGN TRADE REGULATIONS (FTR): 15 CFR Part 30.  Implemented by Dep’t of Commerce, U.S. Census Bureau.
  – 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 here.
  – The latest edition (1 Jan 2019) 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 website.  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.   


  – Last Amendment: 18 May 2016: Change 2: Implement an insider threat program; reporting requirements for Cleared Defense Contractors; alignment with Federal standards for classified information systems; incorporated and cancelled Supp. 1 to the NISPOM (Summary here.)
DOE ASSISTANCE TO FOREIGN ATOMIC ENERGY ACTIVITIES: 10 CFR Part 810; Implemented by Dep’t of Energy, National Nuclear Security Administration, under Atomic Energy Act of 1954.
  – Last Amendment: 23 Feb 2015: 80 FR 9359, comprehensive updating of regulations, updates the activities and technologies subject to specific authorization and DOE reporting requirements. This rule also identifies destinations with respect to which most assistance would be generally authorized and destinations that would require a specific authorization by the Secretary of Energy.
DOE EXPORT AND IMPORT OF NUCLEAR EQUIPMENT AND MATERIAL; 10 CFR Part 110; Implemented by Dep’t of Energy, U.S. Nuclear Regulatory Commission, under Atomic Energy Act of 1954.
  – Last Amendment: 20 Nov 2018, 10 CFR 110.6, Re-transfers.

* DOJ ATF ARMS IMPORT REGULATIONS: 27 CFR Part 447-Importation of Arms, Ammunition, and Implements of War.  Implemented by Dep’t of Justice, Bureau of Alcohol, Tobacco, Firearms & Explosives.
  – 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.  


DOS INTERNATIONAL TRAFFIC IN ARMS REGULATIONS (ITAR): 22 C.F.R. Ch. I, Subch. M, Pts. 120-130. Implemented by Dep’t of State, Directorate of Defense Trade Controls.
  – 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: 1 Jan 2019) of the ITAR with all amendments is contained in Bartlett’s Annotated ITAR (“BITAR”), by James E. Bartlett III. The BITAR contains all ITAR amendments to date, plus a large Index, over 800 footnotes containing amendment histories, case annotations, practice tips, DDTC guidance, and explanations of errors in the official ITAR text. Subscribers receive updated copies of the BITAR in Word by email, usually revised within 24 hours after every ITAR amendment. The BITAR is available by annual subscription from the Full Circle Compliance website. BAFTR subscribers receive a $25 discount on subscriptions to the BITAR, please contact us to receive your discount code.
* DOT FOREIGN ASSETS CONTROL REGULATIONS (OFAC FACR): 31 CFR, Parts 500-599, Embargoes, Sanctions, Executive Orders. 

Implemented by Dep’t of Treasury, Office of Foreign Assets Control.

  – Last Amendment: 15 Nov 2018: 83 FR 57308-57318: Democratic Republic of the Congo Sanctions Regulations
* USITC HARMONIZED TARIFF SCHEDULE OF THE UNITED STATES (HTS, HTSA or HTSUSA), 1 Jan 2018: 19 USC 1202 Annex. Implemented by U.S. International Trade Commission. (“HTS” and “HTSA” are often seen as abbreviations for the Harmonized Tariff Schedule of the United States Annotated, shortened versions of “HTSUSA”.)
  – Last Amendment: 19 Dec 2018: Harmonized System Update (HSU) 1820, containing 19,061 ABI records and 3,393 harmonized tariff records.
  – HTS codes for AES are available here.
  – HTS codes that are not valid for AES are available here.

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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 6,500 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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