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19-0130 Wednesday “Daily Bugle'”

19-0130 Wednesday “Daily Bugle”

Wednesday, 30 January 2019

[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 Postpones ACE Feb 9 Deployment
  4. State/DDTC: (No new postings.)
  1. HeraldNet: “Seattle Man Gets Prison Time for Smuggling Guns into Iraq”
  2. Nikkei Asian Review: “Huawei Tells Suppliers to Move Production to China as U.S. Ban Looms”
  3. Reuters: “Factbox: U.S. Sanctions on Venezuela’s Oil Industry”
  4. ST&R Trade Report: “HS 2017 Implementation, Classification Issues Among Topics of HSC Meeting”
  1. G. Kreijen: “EU to Amend Union General Export Authorization in the Event of a No Deal Brexit”
  2. J. Menton & C. Anderson: “Potential Impact of Brexit on the Export of Certain High Technology Goods (Dual Use Goods) to the UK”
  3. M. Volkov: “Episode 74 – ITAR Compliance Review”
  1. ECTI Presents “Cornerstones of ITAR Compliance: Administration, Documentation and Shipping” Webinar on 20 Mar
  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 

EXIMITEMS FROM TODAY’S FEDERAL REGISTER

EXIM_a1
  [No items of interest noted today.]
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OGSOTHER GOVERNMENT SOURCES

OGS_a11. Items Scheduled for Publication in Future Federal Register Editions
(Source: Federal Register)

  

* NRC; NOTICES; Agency Information Collection Activities; Proposals, Submissions, and Approvals: Export and Import of Nuclear Equipment and Material [Pub. Date: 31 Jan 2019.]
 
* U.S.-China Economic and Security Review Commission; NOTICES; Public Hearings [Pub. Date: 31 Jan 2019.]

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OGS_a2
2. 
Commerce/BIS: (No new postings.)

(Source: 
Commerce/BIS)

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OGS_a33. 
DHS/CBP Postpones ACE Feb 9 Deployment

(Source: 
CSMS# 19-000022, 29 Jan 2019.)

U.S. Customs and Border Protection (CBP) would like to inform the trade community that the upcoming Automated Commercial Environment (ACE) deployment, originally scheduled for February 9, 2019, has been postponed due to the recent government shutdown. This deployment included automation of CBP Form 5106, unique identifiers for Centers of Excellence and Expertise, and updates to the Generalized System of Preference (GSP). Deployment information, including new dates and resources, will be shared via CSMS and posted to 
CBP.gov/ACE as soon as new dates have been established.  

As a reminder, our next bi-weekly ACE support call will take place on January 31, 2019 at 2pm ET. A full schedule and dial in information is available on our support page: 
here

Please note that the mandatory filing of drawback claims pursuant to the Trade Facilitation and Trade Enforcement Act of 2015 (TFTEA) is not impacted by the shutdown and will proceed as planned, regardless of funding status after February 15th. On February 24, 2019, all drawback claims must be filed as TFTEA drawback and must be done so electronically in ACE. The next monthly drawback call will be held January 30, 2018. More information can be found 
here.

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OGS_a44. 
State/DDTC: (No new postings.)

(Source: 
State/DDTC)

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NWSNEWS

NWS_a15
HeraldNet: “Seattle Man Gets Prison Time for Smuggling Guns into Iraq” 

(Source: 
HeraldNet, 30 Jan 2019.) [Excerpts.] 
 
One of the firearms discovered was traced back to a gun show in Monroe purchased in 2017.
 
An Iraqi citizen who conspired to ship guns to Kurdish militia members in Iraq through Seattle was sentenced in January to one year in prison and three years of supervised release for smuggling weapons from the U.S.
 
The sentencing for the Seattle resident Rawnd Khaleel Aldalawi happened on Jan. 11 in U.S. District Court in Seattle and comes after an investigation found more than 47 firearms concealed in two vehicles being shipped through Turkey to Kurdistan. 
 
Co-defendant Paul Stuart Brunt, a Bellevue resident, pleaded guilty in July 2018. His sentencing is scheduled for March 1.
 
Brunt told investigators he was approached by Aldalawi, and another unknown party, in late 2016 about helping to purchase vehicles in the U.S. to be shipped to Iraq, the initial complaint says. … 

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NWS_a26.
Nikkei Asian Review: “Huawei Tells Suppliers to Move Production to China as U.S. Ban Looms”

(Source: 
Nikkei Asian Review, 30 Jan 2019.) [Excerpts.] 
 
Company calls on partners to relocate operations to avoid tech wall
 
Huawei Technologies is asking suppliers to move some production to China as it braces for possible restrictions on access to U.S. technology that could starve the Chinese group of components vital to its business.
 
The move comes as U.S. prosecutors announced criminal charges against Huawei and certain related companies on Monday, alleging that the company had committed bank fraud, breached American sanctions on Iran and stolen trade secrets.
 
Now that the company has been indicted, rather than just individual employees or executives, the focus shifts to whether President Donald Trump will impose a full-scale ban on the sale of critical semiconductors and other American-made components to Huawei. … 

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NWS_a37
Reuters: “Factbox: U.S. Sanctions on Venezuela’s Oil Industry”

(Source: 
Reuters, 30 Jan 2019.) [Excerpts.]
 
The United States imposed heavy sanctions on Venezuela’s oil industry on Monday, looking to cut off President Nicolas Maduro’s primary source of revenue. 
 
The sanctions limit transactions between U.S. companies that do business with Venezuela through purchases of crude oil and sales of refined products. However, there are currently numerous unanswered questions about the sanctions.
 
THE AIM
 
The United States is aiming to freeze sale proceeds from Venezuelan state-run oil firm PDVSA’s exports of roughly 500,000 barrels per day (bpd) of crude to the United States. There is also a prohibition on U.S firms exporting diluents – unfinished oils used for blending extra heavy crude – to Venezuela.
 
VENEZUELA’S PRIMARY CUSTOMERS
 
Venezuela exports oil primarily to the United States, India, and China, as well as some other nations. Only the United States and India are notable sources of cash, as Russian and Chinese firms currently get shipments of crude through complicated oil-for-loan agreements due to Venezuela’s heavy liabilities with those countries.
 
THE SPECIFIC SANCTIONS
 
The U.S. Treasury Department’s sanctions do not entirely cut off purchases of Venezuelan oil by U.S. refineries. However, they stipulate that refiners cannot make payments directly to PDVSA, but into escrow accounts that PDVSA will not be able to access until the company is controlled by a new government.
 
PDVSA RESPONSE
 
Maduro and Manuel Quevedo, who is both oil minister and head of PDVSA, have said that they will not allow vessels loaded with crude oil for the United States to leave the country’s ports without being prepaid. PDVSA on Tuesday said it was considering declaring force majeure on cargoes bound for the United States.
 
WHO CAN AND CANNOT DO BUSINESS WITH VENEZUELA
 
For now, companies can do business but with restrictions. Refineries that import from Venezuela can continue to receive shipments for the next few months before they are forced to shift their supply sources elsewhere. However, since payments cannot be made to PDVSA, this is expected to restrict the flow of crude oil from Venezuela to the United States.
 
The sanctions did not directly mention swaps and indirect trade with PDVSA that began in recent years with customers including PDVSA’s U.S. unit Citgo Petroleum, India’s Reliance and Russia’s Rosneft.
 
U.S. OPERATIONS IN VENEZUELA … 
 
NON-U.S. OPERATORS IN VENEZUELA … 
 
CITGO
 
Citgo Petroleum is a wholly-owned subsidiary of PDVSA and operates refining capacity to process about 750,000 bpd. It also distributes fuel to gasoline stations throughout the United States, accounting for about 4 percent of the nation’s retail fuel market.
 
The United States has exempted Citgo from its sanctions until July 27. However, previous sanctions have already prevented Citgo from sending PDVSA its profits, which had been paid to the parent in the form of dividends.
 
As of September, the company had about $500 million in cash and a credit line of approximately $900 million, according to a creditor familiar with the company’s financial statements. Citgo is able to keep importing crude oil from PDVSA for three more months, according to the sanctions.
 
VENEZUELAN IMPORTS FROM THE UNITED STATES
 
The sanctions expressly prohibit sales of diluents (heavy naphtha) to PDVSA, which are used for making the country’s extra heavy crude oil ready for export.
 
VENEZUELAN OIL PRODUCTION … 
 
CREDITORS OF VENEZUELA AND PDVSA
 
Venezuela and PDVSA are estimated to owe more than $100 billion to bondholders, suppliers, allied governments, lenders and creditors holding judgments. Some creditors have gone to U.S. courts to try to seize Citgo to satisfy their legal claims.

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NWS_a48
ST&R Trade Report: “HS 2017 Implementation, Classification Issues Among Topics of HSC Meeting” 

(Source: 
Sandler, Travis & Rosenberg Trade Report, 30 Jan 2019.)
 
U.S. Customs and Border Protection has issued the draft agenda for the 63rd session of the World Customs Organization’s Harmonized System Committee, which will be held in Brussels March 19-29. The HSC’s responsibilities include issuing classification decisions on the interpretation of the Harmonized Commodity Description and Coding System, which can take the form of published tariff classification opinions or amendments to the Explanatory Notes. The committee also considers amendments to the legal text of the Harmonized System.
 
The HSC is slated to consider a number of issues at its upcoming meeting, including the status of and challenges associated with the implementation of the 2017 edition of the HS. Also up for consideration is the classification of numerous goods, including the following.

– vitamins

– ephedrine derivatives

– nicotine products and novel tobacco products

– unmanned aircraft

– fasteners

– mollusks subjected to pre-processing heat treatments

– cough tablets

– hydraulic cements

– silicon compounds

– dental ceramics

– laminated textiles

– fiberboard of wood

– 3-D printing pen

– evaporative air cooler

– engine pulley

– communications antennas

– quadrocopters

– unassembled metal cabinets

– superluminescent diode modules

– motor vehicle windows

– hub unit bearings

– hydrated manioc (cassava) starch

– frozen boneless mutton fat trimmings

– food supplements

– dissolved gas analysis monitors

– mobile garbage bins

– blood transfusion apparatus

– solid oxide fuel cells

– sidewalls of drawer guides

– hot-rolled steel plates

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COMMCOMMENTARY

COM_a19. G
. Kreijen: “EU to Amend Union General Export Authorization in the Event of a No Deal Brexit” 

(Source: 
World Trade Controls Blog, 29 Jan 2019.)
 
* Author: Gerard Kreijen, Esq., Gerard.Kreijen@loyensloeff.com.
Loyens & Loeff, Amsterdam.
 
From time to time, a tiny flash illuminates the sombre Brexit front. One such flash is the proposal by the EU Commission to add the UK to the list of destinations covered by the Union General Export Authorization (EU001) for dual-use goods if there is a no deal Brexit on 29 March 2019. This move may prove significant as it could save EU exporters a lot of hassle, thereby facilitating their future trade with the UK.
 
Today, the intra-EU export of dual-use goods to the UK is, in general, not subject to licensing. If the UK should leave the EU on 29 March without a deal, the export of dual-use goods to the UK will require an export license as of that date. In order to avoid the adverse effects of such a development as much as possible the EU Commission now seeks to add the UK to the destinations covered by license EU001 (i.e., Australia, Canada, Japan, New Zealand, Norway, Switzerland (including Lichtenstein), and the USA). The purpose – as stated in consideration (5) of the proposed regulation – is to:
 
  – ensure a uniform and consistent application of controls throughout the EU;
  – promote a level playing field for EU exporters;
  – avoid unnecessary administrative burden; and
  – protect EU and international security.
The proposal is part of the second package of measures to prepare the EU for the withdrawal of the UK, presented by the EU Commission on 19 December 2018 and specifically regards a no deal situation. It does not affect the ongoing ordinary legislative procedure to recast Council Regulation (EC) No 428/2009 proposed by the EU Commission on 28 September 2016.
 
It will be recalled that the national authorities of the EU member states use three types of licenses for the export of dual-use goods:
 
  (i)   individual licenses (for the purpose of one specific good, one specific exporter and one specific transaction);
  (ii)   global licenses (for the purpose of a type or category of goods and one or more destinations); and
  (iii)   general licenses (for the purpose of specific goods in relation to trade destinations which the EU considers to be important).
 
General licenses merely require timely registration, usually at least two weeks before actual export takes place. They are not completely without administrative burden, however. Use of general licenses needs to be expressly stated in box 44 of the respective customs declarations and national regulators will normally require periodical reports on the exports that have taken place under a general license.
 
General export licenses for dual-use goods come in two categories: the Union General Authorization and the National General Authorization (for exporters in EU member states which have implemented such a national regime). Both licenses enable exporters with regard to specific, low-risk transactions and through the use of a simplified procedure to bring dual-us goods outside the EU. The purpose of general licenses is to support the competitiveness of the EU while at the same time maintaining a high security level and full compliance with international obligations. National General Authorizations may be imposed by the national authorities. The Union General Authorizations are provided for by Dual-Use Regulation 428/2009 in order to create a level playing field for all exporters within the EU. Union General Export Authorization EU001 (Annex IIa to Dual-Use Regulation 428/2009) specifically regards the export of dual-use goods to the destinations as set out above, which are considered to be low risk.
 
Exporters need to be aware that there are exceptions to the dual-use goods that can be exported under EU001. Thus, EU001 includes all dual-use goods listed on Annex I to Dual-Use Regulation 428/2009, but excludes the goods listed on Annex IIg. Some items listed on Annex IIg that are worth noting are:
 
  – all products listed on Annex IV (sensitive goods, including equipment designed or modified to perform ‘cryptanalytic functions’ – 5A004);
  – certain software and technology for the design, production or use of specified nuclear-related goods;
  – certain pathogenes and toxins hazardous for humans and animals;
  – certain genetical elements of genetically modified organisms; and
  – certain technology for the integration of data into flight control systems for the optimization of missile trajectories.
 
Trade volumes of dual-use goods exported from EU mainland to the UK are considerable. According to a November 2018 report of the EU Commission, an estimated 4.5 billion euros worth of dual-use goods was exported to the UK in 2016. More than 1.2 billion of the total amount was realized by exports from the Netherlands.
 
The proposal to add the UK to the destinations covered by Union General Export Authorization EU001 is likely to bring relief to EU businesses exporting dual-use goods to the UK. It should ease much of their concerns and the uncertainty about the applicable licensing regime for dual-use exports to the UK in the event of a no deal Brexit. Care should be taken however, to ensure that the respective exports are not outside the scope of EU001. But the vast majority of dual-use goods exported to the UK will fall inside that scope.
 
Whether the proposed amendment will eventually be required is in the hands of British Parliament. Today, there is another opportunity to ensure that this will not be necessary.

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COM_a210. 
J. Menton & C. Anderson: “Potential Impact of Brexit on the Export of Certain High Technology Goods (Dual Use Goods) to the UK”

(Source: 
Arthur Cox, Group Briefing, Jan 2019.)
 
* Authors: John Menton, Esq., 
john.menton@arthurcox.com; and Ciara Anderson, Esq., 
ciara.anderson@arthurcox.com. Both of Arthur Cox, Dublin, Ireland. 
 
Dual use goods are products and technologies normally used for civilian purposes which may have potential military applications. For example many widely used software and hardware products/services are classified as controlled “dual use goods” based on the type of encryption deployed in such products/services.
 
The export of dual use goods is controlled by the Dual Use Regulation (Council Regulation (EC) No 428/2009) (as amended) (“Dual Use Regulation”). Entities that export any of the categories of goods or technologies listed in the annexes to the Dual Use Regulation (as updated from time to time) must apply for authorisation from the Department of Business, Enterprise and Innovation (“DBEI”) unless they qualify for one of the exemptions contained in the Dual Use Regulation.
 
“Export” only refers to goods sent to a destination outside of the EU customs territory. For the transfer of dual use goods within the EU customs territory, no authorisation is required (with some limited exceptions). If Brexit results in the UK leaving the EU customs territory then this exemption will no longer apply to dual use exports from Ireland to the UK.
 
The requirement to apply for and receive authorisation for export of certain goods creates a cost of trade particularly if goods are exported in high volume to particular countries. In order to ease the barriers to trade, it is possible to utilise a Union General Export Authorisation (“UGEA”) which covers exports of certain goods to certain countries.
 
UGEA Category 001 covers the export of most goods set out in Annex 1 of the Dual Use Regulation to eight countries: Australia, Canada, Japan, New Zealand, Norway, Switzerland (including Liechtenstein) and the United States of America.
 
If the UK does leave the EU on 29 March 2019 with no withdrawal agreement in place, the UK will become a “third country” for the purposes of the Dual Use Regulation. If this occurs, dual use goods exported from Ireland to the UK will be subject to the Dual Use Regulation and will require authorisation from the DBEI to export.
 
To avoid this consequence in a nodeal Brexit scenario, the European Commission has published a draft regulation which would include the UK on the list of countries which are subject to UGEA Category 001. In the event the EU approval process for the draft regulation is delayed, the DBEI has now stated that it will also introduce a national measure equivalent to a UGEA in Ireland.
 
The DBEI issued a notice to exporters on 16 January 2019 and it recommends that any company currently exporting subject to a UGEA, and which is currently exporting or planning to export dual use goods to the UK, notify the Export Licensing Unit of the DBEI now in order to avoid any potential processing delays. Furthermore, even if a company does not currently operate under a UGEA but is currently exporting or planning to export dual use goods to the UK, it should also contact the Export Licensing Unit of the DBEI.

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COM_a311. 
M. Volkov: “Episode 74 – ITAR Compliance Review”

(Source: 
Volkov Law Group Blog, 27 Jan 2019. Reprinted by permission.) 
 
* Author: Michael Volkov, Esq., Volkov Law Group, 
mvolkov@volkovlaw.com, 240-505-1992. 
 
Companies involved in the export and import of defense products and services face significant risks surrounding compliance with the International Traffic in Arms (ITAR) statute and regulations.  The US State Department’s Directorate of Defense Control (DDTC) tightly regulates the defense industry and aggressively enforces ITAR rules and regulations.
 
In 
this episode, Michael Volkov interviews Colleen Hurson, Senior Counsel, at The Volkov Law Group, who specializes in ITAR compliance and enforcement matters.  Colleen can be reached at 
churson@volkovlaw.com

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TEEX/IM TRAINING EVENTS & CONFERENCES

TE_a112. 
ECTI Presents “Cornerstones of ITAR Compliance: Administration, Documentation and Shipping” Webinar on 20 Mar 

(Source: Danielle Hatch, 
danielle@learnexportcompliance.com.)
 
* What: Cornerstones of ITAR Compliance: Administration, Documentation and Shipping
* When: March 20, 2019; 1:00 p.m. (EDT)
* Where: Webinar
* Sponsor: Export Compliance Training Institute (ECTI)
* ECTI Speaker: Scott Gearity
* Register: 
Here, or contact Danielle Hatch, 540-433-3977,

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ENEDITOR’S NOTES


Franklin D. Roosevelt (Franklin Delano Roosevelt; 30 Jan 1882 – 12 Apr 1945, often referred to by his initials FDR, was an American statesman and political leader who served as the 32nd president of the United States from 1933 until his death in 1945. A Democrat, he won a record four presidential elections and became a central figure in world events during the first half of the 20th century.)
  – “When you reach the end of your rope, tie a knot in it and hang on.”
 

Saul Alinsky (Saul David Alinsky; 30 Jan 1909 – 12 Jun 1972; was an American community organizer and writer. He is generally considered to be the founder of modern community organizing. He is often noted for his book 
Rules for Radicals).
  – “The first step in community organization is community disorganization.”

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EN_a314
. 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.   

 

DOD NATIONAL INDUSTRIAL SECURITY PROGRAM OPERATING MANUAL (NISPOM): DoD 5220.22-M. Implemented by Dep’t of Defense.
  – 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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EN_a0315
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 
here

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EPEDITORIAL POLICY

* 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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