19-0123 Wednesday “Daily Bugle'”

19-0123 Wednesday “Daily Bugle”

Wednesday, 23 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. DHS/CBP Announces ACE CERT Scheduled Maintenance for Tonight
  4. DoD/DSS Announces Knowledge Center PCL Inquiries Closure
  5. State/DDTC: (No new postings.)
  1. American Shipper: “Months of ‘Cascading Effects’ from Closure Expected”
  2. IN MEMORIAM: Jill Garrison, SIA Business Manager
  3. ST&R Trade Report: “Multilateral Trade Agreements in Asia Envisioned in New Law”
  1. Expeditors: “U.S. Government, Trade-Related On-Line Resources”
  2. Global Trade News: “Weise Wednesday: How Has the Recent Government Shutdown Impacted CBP and the Trade Community?”
  3. M. Volkov: “Ethics and Compliance Trends: Humans and Automation, Intelligence and Technology”
  4. R.L. Cassin: “Should Some Parts of a Compliance Program Be Kept Secret?”
  1. Barbara Linney Moves to BakerHostetler
  1. ECTI Presents “Cornerstones of ITAR Compliance: Controlled Items, Activities & Technical Data” Webinar on 27 Feb
  1. Bartlett’s Unfamiliar Quotations 
  2. Are Your Copies of Regulations Up to Date? Latest Amendments: DHS/Customs (14 Jan 2019), 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) 
  3. 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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CSMS #19-000014, 22 Jan 2019.)
There will be an ACE CERT Scheduled Maintenance Wednesday evening January 23, 2019 from 1700 ET to 2000 ET.

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DoD/DSS, 23 Jan 2019.)
The DSS Knowledge Center, Personnel Security (PCL) inquiries option #2, to include e-QIP authentication resets, will be closed on Friday, January 25, 2019, and will resume normal business hours on Monday, January 28, 2019.

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NWS_a16. American Shipper: “Months of ‘Cascading Effects’ from Closure Expected”
(Source: American Shipper, 21 Jan 2019.)
The ongoing government shutdown is affecting trade functions across the federal government, according to an analysis published by JD Supra on Thursday.
Updates to the Automated Commercial Environment (ACE) to reflect exclusions from Section 301 tariffs won’t be implemented until 10 business days after the shutdown has ended, the analysis says, though the Office of the U.S. Trade Representative recently granted almost 1,000 product exclusion requests with regard to the initial tranche of tariffs across $34 billion worth of goods from China in 2017 import value.
  “This means that until the government reopens, importers that qualify for the exclusions will have to continue paying the additional tariffs on affected goods,” said the analysis.
U.S. Customs and Border Protection is continuing several of its responsibilities during the shutdown – which hit its 31st day Monday – including issuing customs broker licenses, permits, filer codes and reviewing and responding to Enforce and Protect Act trade evasion allegations and electronic allegations of trade fraud.
While CBP’s liquidation process is functioning, the agency isn’t processing refunds on any type of normal entry or drawback transaction and interest may apply to the delayed refunds, the analysis says. Customs also isn’t currently issuing any new rulings to importers on its Customs Rulings Online Search System (CROSS) database.
In addition to customs, other trade-related agencies are affected by the shutdown.
Almost 90 percent of Commerce Department staff has been furloughed, as the International Trade Administration (ITA) and Bureau of Industry and Security (BIS) are operating with “extremely minimal” staff, according to the analysis.
  “The ITA has effectively ceased all antidumping and countervailing duty investigations as well as other administrative proceedings including annual administrative reviews due to the lack of funding,” the analysis says. “The delay in ongoing proceedings will have cascading effects on impending deadlines for months to come as all cases are either delayed or postponed for several weeks after the agency reopens.”
The shutdown has also halted BIS’ exclusion process for Section 232 tariffs on steel and aluminum, with no new exclusions granted since Dec. 21, and a significant continuing backlog and further delays expected as Commerce has more than 100,000 requests to review.
USTR announced on Jan. 14 it was starting furloughs.

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NWS_a27. IN MEMORIAM:  Jill Garrison, SIA Business Manager
(Source:  SIA News Alert, SIA-web@wildapricot.org)
Statement of 22 Jan 2019 from SIA: “It is with an extremely heavy heart, the Society of International Affairs Board of Directors regrets to inform you that Jill Garrison passed away on January 21, 2019, from complications related to her long battle with Carcinoid Syndrome.  She is survived by her husband Scott, and her two sons Bryce and Brett.  Jill served as SIA’s Business Manager for over 15 years. However, Jill was so much more than the Business Manager for SIA.  Jill was our anchor.  Without Jill, this organization would not be what it is today; she helped transform SIA, and helped guide our volunteers, and keep our Board on the straight and narrow.  Jill brought exuberance and grace to everything that she did.  She touched so many hearts throughout the years with her smile, laughter, quick wit, and not just external but inner beauty. Many of us have had the privilege to work with her and have been fortunate enough to be able to call her our friend. There are not sufficient words to capture the grief that many of us are experiencing at this time.  However, knowing Jill, she is at peace and she lived an amazing life, gracing us each in our own way. We ask that you all remember her vitality and all that she was, and celebrate her rich, fulfilling life. We will always carry her in our hearts. Details regarding funeral services and donations are to follow.”

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NWS_a38. ST&R Trade Report: “Multilateral Trade Agreements in Asia Envisioned in New Law”
President Trump has signed into law a bill that encourages trade agreements with countries in the Indo-Pacific region. The Asia Reassurance Initiative Act (S. 2736) also provides for a robust U.S. commercial presence throughout the Indo-Pacific region to promote U.S. exports and additional trade facilitation efforts, authorizes the imposition of penalties on entities and governments engaged in the theft of U.S. intellectual property, and requires a new comprehensive U.S. policy to promote energy exports.
The bill states that Congress supports multilateral, bilateral, or regional trade agreements with partners that comply with trade obligations; respect, promote, and strictly adhere to the rule of law; and increase U.S. employment and expand the economy. An Australian Financial Review article notes that this “call for the U.S. to return to multilateral trade deals counter[s] the president’s own tendency to pursue agreements with individual countries such as Mexico, Canada and Japan.”
The bill also expresses congressional support for (a) formal economic dialogues that include concrete, verifiable, and measured outcomes, (b) negotiations under the auspices of the World Trade Organization, including negotiations to enter into appropriate plurilateral and sectoral agreements, (c) full implementation of WTO Trade Facilitation Agreement by Indo-Pacific countries, and (d) the proactive, strategic, and continuing high-level use of the Asia-Pacific Economic Cooperation forum, the East Asia Summit, and the Group of 20 to pursue U.S. economic objectives in the Indo-Pacific region.
Other provisions of the bill include the following.
  – encouraging the president to negotiate a comprehensive economic engagement framework with the Association of Southeast Asian Nations
  – encouraging the president to produce a robust and comprehensive trade capacity building and trade facilitation strategy, including leveling the playing field for U.S. companies competing in the Indo-Pacific region
  – requiring a report from the president to Congress that (a) describes U.S. government efforts to combat intellectual property violations and commercial cyber-enabled theft in the Indo-Pacific region, particularly China; and (b) includes a country-by-country assessment of priority areas for U.S. engagement and capacity building assistance (with funding for the Office of the U.S. Trade Representative to sponsor bilateral and multilateral activities designed to build capacity in these areas)

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Expeditors News, 22 Jan 2019.)
Many U.S. government and other trade-related web sites offer a wide variety of information to importers, exporters, manufacturers and other interested parties, within the United States and worldwide; however, due to the lapse in Federal funding, not all websites may be current.
One of the most powerful web sites for accessing U.S. government agency information from the local to the federal level is
Direct links to several other useful sites includes:
Alcohol and Tobacco Tax and Trade Bureau (TTB), administers and enforces Federal laws and tax code provisions related to the production and taxation of alcohol and tobacco products.
APHIS (USDA), Animal and Plant Health Inspection Service of the U.S. Department of Agriculture, includes information on animal and plant importation restrictions and requirements.
Bureau of Industry and Security, includes information and regulations on U.S. export controls and compliance.
Congress, includes U.S. Congress and other government documents for researching legislation.
Customs and Border Protection, utilizes the border protection and inspection functions of INS, Customs and APHIS, bringing together employees that focus exclusively on securing U.S. borders and facilitating the movement of legitimate trade and travelers.
Department of Homeland Security, cabinet-level department which combines the functions and resources of dozens of federal government agencies performing functions that relate to the security of the United States.
FDA Basics for Industry, addresses common industry and import topics, including determining whether or no FDA regulations apply to a product and what registration requirements exist.
Federal Register, includes access to Federal Register notices, archives and other government documents through the U.S. Government Printing Office.
Federal Trade Commission, includes information on care label requirements for imported apparel, consumer protection and anti-dumping issues.
International Chamber of Commerce, INCOTERMS, world business
International Trade Commission, includes U.S. and world trade guides and information. Also see
https://dataweb.usitc.gov/, for direct access to trade data and customized reports.
National Highway Transportation Safety Administration, includes information on U.S. Department of Transportation regulations and transportation issues within the United States.
OTEXA (Office of Textiles & Apparel) of the U.S. Commerce Department’s International Trade Administration, includes information on trade agreements, quotas, policies and trade data for textile and apparel imports and exports.
U.S. Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF), law enforcement functions relating to firearms, explosives and arson. ATF also administers the U.S. Criminal Code provisions concerning alcohol and tobacco smuggling and diversion.
U.S. Census Bureau, includes information from the U.S. Census.
U.S. Code, includes searchable database of the Code of Laws of the United States.
U.S. Council for International Business, administers ATA Carnets in the United States.
U.S. Department of Commerce, includes information on several different agency regulations, including Census, International Trade Commission and U.S. Bureau of Industry and Security.
U.S. Department of State Bureau of International Information Programs, includes material on current U.S. foreign policy and other topics.
U.S. Environmental Protection Agency, includes information on U.S. government restrictions on pollutants, emissions and chemicals.
U.S. Fish & Wildlife Service, includes information and restrictions on importing wildlife and endangered species.
U.S. Food and Drug Administration, includes information on food, medical product, radiation and pharmaceutical product safety issues and regulations.
U.S. Trade Representative, U.S. trade policy issues.

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Integration Point Blog, 23 Jan 2019.)
Welcome to Weise Wednesday! Twice a month we will share a brief Q&A with the former U.S. Commissioner of Customs, Mr. George Weise. If you have questions, we encourage you to send them to
Q. Can you discuss the most recent government shutdown and its impact on CBP and the trade community?
A. The current “partial” government shutdown impacts about 25% of total government discretionary spending because Congress had already passed full-year appropriations for five of the twelve appropriations bills pending. The seven bills affected by the shutdown include Agriculture, Commerce-Justice-Science, Financial Services, Homeland Security, Interior-Environment, State-Foreign operations, and Transportation-Housing and Urban Development.
Unfortunately, from a trade perspective, the shutdown impacts virtually all trade agencies, including U.S. Customs and Border protection (CBP), the Department of Commerce, the Office of the U.S. Trade Representative, and the U.S. International Trade Commission.
In a shutdown, affected federal agencies must discontinue all non-essential discretionary government services until new funding legislation is passed and signed into law. Essential services and mandatory spending programs continue to function.
While designated “essential” employees stay on the job, “non-essential” employees are furloughed. No employees, however, are paid during the shutdown period. In past shutdowns, legislation was subsequently passed to provide retroactive pay for both furloughed and non-furloughed workers. That is likely to be done again in this case when the shutdown ends, but there is no guarantee.
Fortunately, like in past shutdowns, the adverse impact on trade has been limited because CBP designated nearly 90% of its employees as “essential.” It kept its personnel in place at land, air, and sea borders and between our ports of entry to carry out its important responsibility of securing our borders and keeping legitimate goods and people moving. Administrative and headquarters personnel were deemed “non-essential” and furloughed.
The shutdown, which began at midnight on December 21, 2018, when the Congress failed to enact legislation to fund the programs covered by these appropriations bills, is now the longest running U.S. government shutdown ever. Affected government workers are about to miss their second paycheck in a month, and morale is naturally eroding. Unfortunately, the President and Democratic leadership in the Congress seem to be at a complete standoff over funding the building of a wall on the southwest border, and no resolution of the conflict appears to be in sight.
What trade professionals should expect during the shutdown
Looking forward, the trade community should expect to see consequences from the shutdown such as delayed responses to requests for rulings and resolution of protests and delays regarding in-bond enforcement. It should also be expected that upcoming trade events, such as COAC meetings, are likely to be cancelled or postponed. Nor will the CBP website be actively managed during the shutdown. Consequently, transactions submitted via the website are not likely to be processed, and responses to inquiries should not be expected.

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Volkov Law Group Blog, 22 Jan 2019. Reprinted by permission.)
* Author: Michael Volkov, Esq., Volkov Law Group,
mvolkov@volkovlaw.com, 240-505-1992.
For me, the year-end retrospectives have become a rite of passage. While there has been modest changes and trends in the enforcement arena, I am amazed each year at the pace at which compliance as a discipline and a profession continues to move forward.
While there is much that is written about compliance and current or immediate trends, in reality, on the ground, compliance as a force moves relatively slowly. This has nothing to do with the value or the commitment of companies to compliance but a more important and overriding influence – companies are slow to change (unless forced to do so by government or strong economic factors).
In my old/mid-life age range and perspective, I have become more realistic about the pace at which change can occur. Corporations are slow to move, akin to a large ship changing direction. It is unfortunate but part of reality that companies have strong internal and external forces that can slow change advocates or managers.
Within this “realistic” framework, compliance continues as a pace setter in the corporate governance landscape. Many companies maintain deficient ethics and compliance programs. As a result, compliance professionals are in high demand since corporate leaders frequently embrace compliance as an important objective among competing priorities.
At the same time, the market is responding to compliance needs, especially in the design of automated compliance-focused technologies. Some may scoff at the continuing focus of compliance on technology. After all, compliance is a function that ultimately depends on humans and interpersonal relationships. For example, the risk of whistleblower retaliation has little to do with technology or automated solutions and everything to do with people-to-people treatment, motivations and ultimately the company’s culture.
Corporate compliance now is tracking along two trends – one that emphasizes the company’s culture, meaning the company’s adoption, communication and adherence to a code of ethical strictures guiding day-to-day activities.
In parallel, CCOs are seeking efficient technologies and automated solutions marketed by vendors with quickly advancing platforms and technical capabilities to promote and ensure compliance.
These two themes are not competing nor mutually-exclusive. They work in tandem and reinforce each other. A company’s culture is insurance against corporate misconduct – and in the end, a culture of ethics creates sustainability and an environment in which companies can increase profitability. A corporate compliance program that is organized around effective technologies will minimize costs, promote efficient solutions and maximize compliance given a set of resources.
This past year companies continued to focus on the value of their corporate cultures. Corporate leaders have identified the need for promoting corporate culture, not just to avoid potential government enforcement actions, but as a separate goal meant to achieve optimal performance. Ethical companies perform better in the marketplace than unethical companies. Corporate leaders now recognize this important reality and are now demanding that corporate compliance officers assess and supervise the company’s culture.
Meanwhile, the compliance industry is monitoring and embracing technological solutions to manage third-party risks, promote policy management, administer hotlines, generate and monitor compliance data, and manage its supply chain. In an interesting phenomenon, technology is bring together business and compliance interests, meaning that technology assists both the company’s business operations and its related compliance functions.
As a result, companies are embracing artificial intelligence, blockchain and regtech solutions that are built on powerful computer capabilities and processes. New technologies offer expansive capabilities to search large amounts of data, implement machine-learning solutions, and generate large amounts of data that may facilitate proactive identification of financial and behavioral anomalies.
Without too much hyperbole, compliance is steadily evolving and will ultimately advance corporate governance functions. Corporate innovations occur regularly with new products and services, and compliance is an important influence in this process. As time passes, and more resources are allocated to compliance, the corporate governance landscape may radically change over the next five years. In other words, buckle up, we are in for an interesting ride.

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FCPA Blog, 23 Jan 2019.)
* Author: Richard L. Cassin, Publisher and Editor of the FCPA Blog, rlc@fcpablog.com
Most big companies publish their ethics and compliance programs online. Anyone can read them and know what goals the company has set and how it hopes to achieve them.
That sounds like the right approach. Totally transparent. Accountable. And fair to everyone.
But does full disclosure about compliance programs always make sense?
Internal controls, for example, share some DNA with corporate security systems. The controls must be there, according to the FCPA and securities laws, so that management knows where all the company’s assets are, who’s handling them, and for what purpose. That’s a way to stop the company assets from being used to pay bribes.
But from a corporate security perspective, the internal controls are there to stop people from stealing from the company, or using the assets to commit fraud or other crimes. Internal controls, then, are something like the security system around a bank vault.
Most vaults are protected by a combination of visible and invisible security. You can see a guard standing nearby, and security cameras jut down from the ceiling. There’s a big lock on the vault’s thick door and a touch pad beside it.
But there might also be invisable features — hidden cameras, invisible motion detectors, weight sensors, perimeter doors that shut and lock automatically, silent alarms, and so on. The secret parts are there as another line of defense against the crooks.
In Israel, the defense forces say they destroy all the attack tunnels they discover. But some speculate that the IDF keeps some tunnels open. Why? To find out who might use them and for what purpose.
Does that same concept work inside corporations? Should some aspects of the internal controls be kept secret, as a way to catch bad actors in the act?
Another argument for some corporate secrecy is to avoid becoming a target. We know that whenever a company announces that its systems can’t be hacked, hackers from everywhere take up the challenge and usually succeed. Does publicizing internal controls do the same thing?
Last week I wrote about AI-enhanced internal controls. Powerful new tools will be able to detect when anyone leaves a virtual fingerprint anywhere inside the company. Is it a good idea to reveal where all those new tools are embedded and how they’ll work? Or will publicizing them incite devious employees to challenge the artificial intelligence embedded in the internal controls?
In an ideal world, we would always disclose all aspects of a compliance program. And that should be the aim. After all, transparency is good and secrecy is bad. But is transparency always … practical? Does it always produce the result we’re looking for?
If parts of a compliance program also have a role in corporate security, there’s an argument to be made for secrecy. As distasteful as that outcome might be, it’s probably going to become more common as AI-enhanced internal controls proliferate.

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(Source: Editor)

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TE_a114. ECTI Presents “Cornerstones of ITAR Compliance: Controlled Items, Activities & Technical Data” Webinar on 27 Feb

(Source: Danielle Hatch, danielle@learnexportcompliance.com)
* What: Cornerstones of ITAR Compliance: Controlled Items, Activities & Technical Data
* When: February 27, 2019; 1:00 p.m. (EST)
* Where: Webinar
* Sponsor: Export Compliance Training Institute (ECTI)
* ECTI Speaker: Scott Gearity
* Register: Here or Danielle Hatch, 540-433-3977, danielle@learnexportcompliance.com.

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Stendhal (Marie-Henri Beyle; 23 Jan 1783 – 23 Mar 1842; better known by his pen name Stendhal, was a 19th-century French writer. Best known for the novels Le Rouge et le Noir (The Red and the Black, 1830) and La Chartreuse de Parme (The Charterhouse of Parma, 1839), he is highly regarded for the acute analysis of his characters’ psychology and considered one of the earliest and foremost practitioners of realism.
  – “Only great minds can afford a simple style.”
* Potter Stewart (23 Jan 1915 – 7 Dec 1985; was an Associate Justice of the United States Supreme Court, serving from 1958 to 1981. During his tenure, he made, among other areas, major contributions to criminal justice reform, civil rights, access to the courts, and Fourth Amendment jurisprudence. His concurring opinion in Jacobellis v. Ohio regarding the definition of hard-core pornography popularized the phrase “I know it when I see it.”)
  – “Ethics is knowing the difference between what you have a right to do and what is right to do.”
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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: 14 Jan 2019: 84 FR 112-116: Extension of Import Restrictions Imposed on Certain Archaeological and Ecclesiastical Ethnological Material from Bulgaria; and 84 FR 107-112: Extension of Import Restrictions Imposed on Certain Archaeological Material From China 

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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