;

19-0208 Friday “Daily Bugle”

19-0208 Friday “Daily Bugle”

Friday, 8 February 2019

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

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  1. Commerce/BIS Seeks Comments Concerning Section 232 National Security Adjustments of Imports of Aluminum and Steel 
  1. Items Scheduled for Publication in Future Federal Register Editions 
  2. Commerce/BIS: (No new postings.)
  3. State/DDTC: (No new postings.)
  4. EU Commission Updates TARIC-Dual Use Correlation List
  5. EU Publishes Regulation Concerning Tariff Rate Quotas Included in WTO Schedule of the Union Following Brexit
  1. Global Trade News: “Progress Halted for Post-Brexit UK Trade Agreements”
  2. iTnews: “Australian Department of Defense Dumped Unrestricted Crypto Research Permits Without Warning”
  3. Jane’s 360: “Cracks Emerge in Franco-German Export Control Plans”
  4. ST&R Trade Report: “Pressure Mounts to Eliminate Steel and Aluminum Tariffs to Secure USMCA Approval”
  5. WorldECR: “UK Implements EU Blocking Statute”
  1. FCC Presents U.S. Export Controls Awareness Course: “ITAR & EAR from a non-U.S. Perspective”, 9 April in Bruchem, the Netherlands
  2. Jim Bartlett to Join Speakers at Madison Int’l Trade Assn Tuesday, 12 Feb, in Madison, WI
  3. List of Approaching Events: 97 Events Posted This Week, Including 11 New Events
  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 (1 Jan 2019)
  3. Weekly Highlights of the Daily Bugle Top Stories 

EXIMITEMS FROM TODAY’S FEDERAL REGISTER

EXIM_a1

1. Commerce/BIS Seeks Comments Concerning Section 232 National Security Adjustments of Imports of Aluminum and Steel

(Source: Federal Register, 8 Feb 2019.) [Excerpts.]
 
84 FR 2813: Submission for OMB Review; Comment Request; Procedures for Submitting Request for Objections From the Section 232 National Security Adjustments of Imports of Aluminum and Steel …
* Agency: Bureau of Industry and Security.
* Title: Procedures for Submitting Request for Objections from the Section 232 National Security Adjustments of Imports of Aluminum and Steel.
* Form Number(s): N/A.
* OMB Control Number: 0694-0138.
* Type of Review: Regular submission. …
* Needs and Uses: This collection of information supports Presidential Proclamations 9704 Adjusting Imports of Aluminum into the United States and 9705 Adjusting Imports of Steel into the United States. On March 8, 2018, the President issued Proclamations 9704 and 9705 concurring with the findings of the two investigation reports submitted by the Secretary of Commerce pursuant to section 232 of the Trade Expansions Act of 1962 (19 U.S.C. 1862) and determining that adjusting imports through the imposition of duties on aluminum and steel is necessary so that imports of aluminum and steel will no longer threaten to impair the national security. …

 
This information collection request may be viewed at reginfo.gov:
http://www.reginfo.gov/public/. Follow the instructions to view Department of Commerce collections currently under review by OMB.

 
Written comments and recommendations for the proposed information collection should be sent within 30 days of publication of this notice to OIRA_Submission@omb.eop.gov.  
 
  Sheleen Dumas, Departmental Lead PRA Officer, Office of the Chief Information Officer, Commerce Department. 

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

OGSOTHER GOVERNMENT SOURCES

OGS_a12
. Items Scheduled for Publication in Future Federal Register Editions
 

(Source:
Federal Register)
 

* Commerce; NOTICES; Agency Information Collection Activities; Proposals, Submissions, and Approvals: Procedures for Submitting Rebuttals and Surrebuttals Requests for Exclusions from and Objections to the Section 232 National Security Adjustments of Imports of Steel and Aluminum [Pub. Date: 11 February 2019.]

* Treasury; Foreign Assets Control Office; NOTICES; Blocking or Unblocking of Persons and Properties [Pub. Date: 11 February 2019.]

 
* U.S. Customs and Border Protection; NOTICES; Meetings: Commercial Customs Operations Advisory Committee [Pub. Date: 11 February 2019.]
 

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

OGS_a23
Commerce/BIS: (No new postings.)

(Source: 
Commerce/BIS)

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

OGS_a03
4. State/DDTC: (No new postings.)
(Source: State/DDTC)
* * * * * * * * * * * * * * * * * * * *

OGS_a4
5. EU Commission Updates TARIC-Dual Use Correlation List

(Source: European Commission, 10 Jan 2019.)
 
The updated correlation list between TARIC and the Dual-Use Annex of the Regulation 428/2009 can be found
here.

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

OGS_a5
6. EU Publishes Regulation Concerning Tariff Rate Quotas Included in WTO Schedule of the Union Following Brexit

 
Regulations
* Regulation (EU) 2019/216 of the European Parliament and of the Council of 30 January 2019 on the apportionment of tariff rate quotas included in the WTO schedule of the Union following the withdrawal of the United Kingdom from the Union, and amending Council Regulation (EC) No 32/2000.

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

NWSNEWS

 
Although the United Kingdom has successfully signed continuity agreements with Chile, the Faroe Islands, and Eastern and Southern Africa, the embattled nation is still struggling to lock down free trade agreements (FTA) ahead of the March 29 Brexit date. Speaking at a parliamentary inquiry to the International Trade Committee on February 6, trade minister Liam Fox was unable to confirm that all 40 FTAs that make up the UK’s existing deals as a member of the European Union would still be in place after the exit date.
 
If the UK fails to secure a deal with a current trading partner before March 29, then both parties will default to World Trade Organization (WTO) trading rules. This would incur additional tariffs to a wide range of traded goods that were previously duty free when the UK was part of the EU. If a withdrawal agreement is successfully secured between the UK and the EU before the exit date, then all 40 agreements are expected to be extended during the transition period, which is set to end in 2021.
 
Continuity agreements
 
The UK is expected to strike additional continuity agreements with Israel and Switzerland in the coming month. Although these agreements are open-ended, the UK can leverage them to facilitate further trade relationships with other partners independently from the EU. No other continuity agreements are confirmed to be in negotiation at this time.
 
Fox is scheduled to address the International Trade Committee again on March 8.
 
If you would like to read more about post-Brexit trade agreements, visit
Global Trade Review or UK’s
Department of International Trade.

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

(Source:
iTnews, 8 Feb 2019.] [Excerpts.]
 
 
But permanent replacement under consideration.
 
The [Australian] Department of Defense quietly stopped renewals of unrestricted communication exemptions for cyber security and cryptography researchers subject to export control laws at the end of 2018, a move that came without warning to the research community.
 
iTnews 
reported the apparent change to policy around permits allowing researchers to communicate about cryptography with any non-sanctioned country earlier this week.
 
The general permission was introduced on a trial basis in 2017 to bypass the Defense Trade Controls (DTC) Act 2012, which regulates the supply of military and so-called ‘dual-use’ technologies overseas. …

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

(Source:
Jane’s 360, 6 Feb 2019.) [Excerpts.]
 
News has emerged in French media of local companies facing problems fulfilling export contracts due to more stringent export regulations in Germany.
 
As a result of the tightening of export controls in Germany, critical components have not been cleared for export to end users, resulting in delays as French suppliers seek substitute components or potentially have to cancel orders.
 
The first reports of the issue emerged on 5 February in French news outlet 
La Tribune , which said that Germany had blocked the export of the MBDA Meteor beyond-visual-range air-to-air missile (BVRAAM) to Saudi Arabia. Germany halted defence exports to Saudi Arabia in October 2018 following the death of journalist Jamal Khashoggi in Turkey.
 
MBDA Deutschland subsidiary Bayern-Chemie supplies the propulsion system, booster, and ramjet for the Meteor BVRAAM. 
Jane’s sources reported in early 2015 that Saudi Arabia had signed a contract valued at USD1.1 billion for Meteor systems to arm its Eurofighter Typhoon aircraft. …

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

 
The Trump administration is coming under increasing pressure to eliminate its Section 232 tariffs on imports of steel and aluminum products from Canada and Mexico in order to secure approval of the U.S.-Mexico-Canada Trade Agreement.
 
In a recent letter to Commerce Secretary Wilbur Ross and U.S. Trade Representative Robert Lighthizer, a number of U.S. trade associations urged the removal of the Section 232 tariffs as well as the retaliatory duties that have been imposed by Mexico and Canada, stating that the damage they are causing “far outweighs any benefit that may accrue” to U.S. manufacturers, farmers, and ranchers from the USMCA. The letter called on the officials to “take all necessary steps to resolve this matter so that zero-tariff North American trade can resume, and we can turn our attention to working with you to gain prompt Congressional approval of the USMCA.”
 
According to Inside US Trade, House Ways and Means Committee Ranking Member Kevin Brady, R-Texas, added that Congress is “not really willing to consider this agreement until the steel and aluminum tariffs are assured of being lifted off.” However, the publication noted that in a Feb. 6 meeting with the Senate Advisory Group on Negotiations Lighthizer offered little information on if and when the administration might remove the tariffs.
 
The White House is seeing pressure from its trade partners as well. Canadian Foreign Affairs Minister Chrystia Freeland said during a visit to Washington this week to discuss the USMCA with U.S. lawmakers that the continued imposition of the “absurd” and “illegal” tariffs on steel and aluminum from Canada is a hurdle to implementing the agreement. Earlier in the week ministers from Ontario and Quebec urged the Canadian federal government to press the U.S. harder to remove the tariffs, which they said are harming Canadian workers and industry. There have been some calls for Canada to lift its retaliatory tariffs as an enticement for the U.S. to eliminate its tariffs, but Freeland indicated that Ottawa is unlikely to do so.

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

(Source:
WorldECR, 7 Feb 2019.)
 
The EU Blocking Statute criminalizes compliance with U.S. sanctions where they are not compatible with EU law.
 
Legislation is now in force in the United Kingdom which criminalizes activity in contravention of the EU blocking statute – e.g., compliance with U.S. sanctions where not compatible with EU law.
 
In June 2018, following the announcement of the US withdrawal from the Joint Comprehensive Plan of Action (‘JCPOA’ or ‘Iran nuclear deal’), the EU amended (to include the reversal of the US position on Iran) its original blocking statute of 1996, which was drafted to:
 
counteract the effects of the extra-territorial application of laws, including regulations and other legislative instruments adopted by third countries, and of actions based thereon or resulting therefrom, where such application affects the interests of natural and legal persons in the Union engaging in international trade and/or the movement of capital and related commercial activities between the Union and third countries.
 
The UK implementing law is the Extraterritorial US Legislation (Sanctions against Cuba, Iran and Libya) (Protection of Trading Interests) (Amendment) Order 2018.
 
An explanatory note states: ‘Criminal offences in respect of breaches by United Kingdom entities and nationals of Council Regulation (EC) No.2271/96 protecting against the effects of the extraterritorial application of legislation adopted by a third country, and actions based thereon or resulting therefrom (OJ No. L 309, 29.11.1996, p.1) (“the Regulation”) were created by the Extraterritorial US Legislation (Sanctions against Cuba, Iran and Libya) (Protection of Trading Interests) Order 1996 (S.I. 1996/3171). This Order amends S.I. 1996/3171 so that it refers to the Regulation as last amended by Commission Delegated Regulation (EU) 2018/1100 (OJ L I 199, 7.8.2018, p. 1), thereby ensuring that the criminal offences extend to conduct within scope of the Regulation as amended.’
 
The UK legislation can be found
here.

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

TEEX/IM TRAINING EVENTS & CONFERENCES

TEC_a1
12. 
FCC Presents U.S. Export Controls Awareness Course: “ITAR & EAR from a non-U.S. Perspective”, 9 April in Bruchem, the Netherlands
(Source: Full Circle Compliance, 
events@fullcirclecompliance.eu.)
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, or email 
events@fullcirclecompliance.eu.
 
Register before 18 February and get a 10% Early Bird discount on the course fee!

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

TEC_a2
13
. Jim Bartlett to Join Speakers at Madison Int’l Trade Assn Tuesday, 12 Feb, in Madison, WI

(Source: Editor)
 
* What: “Trade Compliance in 2019: Strategies for Surviving and Thriving in a Time of Disruption”
* Where:  Fluno Center, 601 University Ave., Madison, Wisconsin
* When:  Tuesday, 12 February, Noon-4 pm.
* Sponsor:  Madison International Trade Association (MITA)

* Speakers: 
   Lunch Program: Alec Streeter, Director of Global Trade Compliance at Oshkosh Corporation, “Trade Compliance in 2019: Strategies for Surviving and Thriving in a Time of Disruption”
   The Ask the Experts Roundtables:  
    – Navigating the Tariffs – Alec Streeter, Director of Global Trade Compliance, Oshkosh Corporation
    – Global Export Control Regimes and Your Business – Jay Nash, Nash Global Trade
    – Understanding assists and reporting proper values to CBP – Sandi Siegel, M.E. Dey
    – Export Documentation and Payment Methods – Paul Jarz, LR International
    – Trade Compliance Violations: To Disclose or Not to Disclose? – Wendy Arends, Godfrey & Kahn, S.C.
  Afternoon Program – Trade Compliance 2.0 
    – “A View from the Inside: Opportunities and Challenges of an In-House Trade Compliance Manager” – Alec Streeter, Director of Global Trade Compliance, Oshkosh Corporation
    – “Export Compliance in a Time of Disruption” – Jay Nash, Nash Global Trade
    – “Using ACE reports to monitor your Import Compliance” – Margaret Lange, Compliance Director, M.E. Dey
    – “Enforcement of Trade Violations — What to Do When the Feds Kick Down Your Doors!” – Jim Bartlett, Law Firm of James E. Bartlett III, PLLC; Partner, Full Circle Compliance, Bruchem, Netherlands

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

TE_a314. 
List of Approaching Events: 97 Events Posted This Week, Including 11 New Events
(Sources: Editor and Event Sponsors)

Published every Friday or last publication day of the week, o
ur overview of Approaching Events is organized to list c
ontinuously available training, training events, s
eminars & conferences, and 
webinars. 
 
Please, submit your event announcement to Alexander Witt, Events & Jobs Editor (email: 
awitt@fullcirclecompliance.eu
), composed in the below format:
 
# DATE: LOCATION; “EVENT TITLE”; EVENT SPONSOR; WEBLINK; CONTACT DETAILS (email and/or phone number)
 

#” = New or updated listing  

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

* Webinar: ”
Company-Wide US Export Controls Awareness Program“; Export Compliance Training Institute;
danielle@learnexportcompliance.com 

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

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

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

 
 
 


#
Feb 12: Madison, WI;
Trade Compliance in 2019“; Madison International Trade Ass’n (MITA); Speakers Include Jim Bartlett 


* Feb 11-12: Orlando, FL; “
Boot Camp: Achieving ITAR/EAR Compliance
“; Export Compliance Solutions (ECS)

* Feb 12-13: Washington, D.C.;
2019 Legislative Summit
“; National Association of Foreign Trade Zones (NAFTZ)
 

* Feb 13: Arlington, VA; “
2019 Volunteer of the Year and Speaker of the Year Luncheon
“; SIA

* Feb 13: Plymouth, UK; “
Strategic Export Control: Intermediate Practitioners course
“; UK/DIT

* Feb 13: Southampton; “
UK Export Control Awareness Breakfast
“; Hampshire Chamber of Commerce, ECJU, and Trethowans LLP

* Feb 14: Plymouth, UK; “
Strategic Export Control: Foundation Workshop
“; UK/DIT
* Feb 14: Plymouth, UK; “
Strategic Export Control: Licenses Workshop
“; UK/DIT

* Feb 18-21: Orlando, FL; “
ITAR Defense Trade Controls / EAR Export Controls Seminar
“; ECTI

* Feb 20-22: Houston, TX; “
Advanced Topics in Customs Compliance 2019 Conference
“; Braumiller;
*
 Feb 20: Miami, FL; “
ABC’s of Protecting Your Brand
“; Diaz Trade Consulting

#
Feb 21: Vernon Hills, IL; “
Export Controls and Enforcement Share
“; Highland Park Chamber of Commerce

* Feb 26-27; Chicago, IL; “
CTPAT Training
“; SCS America

* Feb 26-27: Miami, FL; “
Complying with U.S. Export Controls
“; Commerce/BIS

#
Feb 28; San Bruno CA; “
Introduction to Import and Export Compliance
“; Skyline College

* Feb 28; Liverpool, UK; “
You Can Export: How to Manage Agents & Distributors
“; UK/DIT


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

* Mar 5-6: San Diego, CA; “
Complying with U.S. Export Controls
“; Commerce/BIS

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

* Mar 6-7: San Diego, CA;

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

* Mar 7-8: Dallas, TX; “
CTPAT Training
“; SCS America

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

* Mar 11: Hoofddorp, NL; “
Export Control, Dual-use en Sancties
“; Fenex

* Mar 12-14: Dallas, TX;

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

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

#
Mar 12: Hasselt, Belgium; “
Wegwijs in exportcontrole, dual-use goederen & embargo
“; Vlams Netwerk van Ondernemingen

* Mar 13: Birmingham, UK; “
Strategic Export Control: Intermediate Practitioners course
“; UK/DIT
* Mar 14: Birmingham, UK; “
Strategic Export Control: Foundation Workshop
“; UK/DIT
* Mar 14: Birmingham, UK; “
Strategic Export Control: Licenses Workshop
“; UK/DIT

* Mar 18-21: Las Vegas, NV; “
ITAR Defense Trade Controls / EAR Export Controls Seminar
“; ECTI
*
 Mar 20: Miami, FL; “
CHINA TARIFFS/AD/CVD 101
“; Diaz Trade Consulting

* Mar 25-27: San Francisco; “
Global Encryption, Cloud and Cyber Trade Controls Conference
“; Thomsen & Burke LLP;

#
Mar 26-27: Pittsburgh, PA; “
Complying with U.S. Export Controls
“; Commerce/BIS

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

* Mar 27-28: San Francisco, CA; “Global Encryption, Cloud & Cyber Trade Controls;” American Conference Institute

* Apr 1: Eindhoven, NL; “
Export Control, Dual-use en Sancties
“; Fenex

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

* Apr 3-4: Denver, CO;

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

* Apr 4-5; Miami, FL; “
CTPAT Training
“; SCS America

*
 
Apr 9: Bruchem, The Netherlands; “Awareness Course U.S. Export Controls: ITAR & EAR from a Non-U.S. Perspective“; Full Circle Compliance

Apr 17: Miami, FL; “
CBP COMPLIANCE & ENFORCEMENT
“; Diaz Trade Consulting
*
 Apr 17-18; Miramar, FL; “
11th Maritime Forwarding, Freight Logistics & Global Chain Supply Workshop
“; ABS Consulting;
* Apr 23-24: Portsmouth, NH;

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

Technology Controls
“; Commerce/BIS

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

* May 2-3: Washington DC; “Economic Sanctions Enforcement and Compliance;” American Conference Institute

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

May 6-7: Atlanta, GA; “
2019 Spring Conference
“; SIA
*
 
May 7: Bruchem, The Netherlands; “An Introduction to EU / Dutch Dual-Use and Military Export Controls“; Full Circle Compliance

#
May 16: Hamburg, Germany; “
U.S. Export Controls and Embargoes & Sanctions for European Companies
“; Hamburger Zollakademie

* Jun 5-6: Seattle, WA; “
Complying with U.S. Export Controls
“; Commerce/BIS

*
 
Jun 10: Cleveland, OH; “
Letters of Credit
“; Global Training Center
*
 
Jun 11: Cleveland, OH; “
Export Doc & Proc
“; Global Training Center
*
 
Jun 12: Cleveland, OH; “
Tariff Classificatio
n“; Global Training Center
*
 
Jun 13: Cleveland, OH; “
NAFTA Rules of Origin
“; Global Training Center
*
 
Jun 14: Cleveland, OH; “
Incoterms® 2010 Rules
“; Global Training 
* Jun 17-20: San Diego, CA; “ITAR Defense Trade Controls / EAR Export Controls“; ECTI

Jul 8 – 10: National Harbour, MD; “
2019 Summer Back to Basics Conference
“; SIA

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

* Aug 20-21: Cincinnati, OH;

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

* Aug 20-21: Milpitas, CA;

Complying with U.S. Export Controls
“;
Commerce/BIS
* Aug 22: Milpitas, CA:

Encryption Controls
“;
Commerce/BIS

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

* Sep 16-19: Austin, TX; “
ITAR Controls / EAR & OFAC Export Controls (Sep 18-19) Seminar Series
“; ECTI
; 540-433-3977


Sep 17-19: Annapolis, MD; “
The ECS 2nd Annual ITAR/EAR Symposium
“; ECS

#
Sep 20: Las Vegas; “
EAR and OFAC Fundamentals: Export Control Of Dual-Use Equipment
“; Barnes & Thornburg LLP

* Sep 30 – Oct 3; Amsterdam, NL; “
ITAR Controls / EAR/OFAC Commercial and Military Controls
“; ECTI
; 540-433-3977

*
 
Oct 1: Bruchem, The Netherlands; “The Export Administration Regulations (EAR) from a non-U.S. Perspective“; Full Circle Compliance

* Oct 14-17; Columbus, OH; “
University Export Controls Seminar
“; ECTI
; 540-433-3977


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

* Oct 28-31; Phoenix, AZ; “
ITAR Controls / EAR & OFAC Export Controls Seminar Series
“; ECTI
; 540-433-3977
* Nov 11-14; Washington, DC; “
ITAR Controls / EAR & OFAC Export Controls Seminar Series
“; ECTI
; 540-433-3977

*
 
Nov 26: Bruchem, The Netherlands; “The International Traffic in Arms Regulations (EAR) from a non-U.S. Perspective“; Full Circle Compliance
* Dec 4-5: New York, NY; “10th Annual New York Forum on Economic Sanctions;” American Conference Institute

* Dec 9-12; Miami, FL; “
ITAR Controls / EAR & OFAC Export Controls Seminar Series
“; ECTI
; 540-433-3977

#
Dec 12-13; Washington D.C.; “
Coping with U.S. Export Controls and Sanctions 2019
“; Practicing Law Institute

 

Webinars 


 

* Feb 14: Webinar: “Asia Pacific Export Control Update 2019“; ECTI; danielle@learnexportcompliance.com; 540-433-3977

* Feb 14: Webinar: “ITAR Training Basics – For Compliance Executives February“; CVG Strategy

*
 Feb 28: Webinar: “
The Fundamentals of Product Classification
“; ECTI; 540-433-3977

#
Mar 12: Webinar; DIY Encryption Classification 2019 Edition“; ECTI; 540-433-3977; danielle@learnexportcompliance.com

*
 Mar 13: Webinar: “
Cornerstones of ITAR Compliance: Licenses and Agreements
“; ECTI; 540-433-3977

* Mar 14: Webinar: “ITAR Training Basics – For Compliance Executives March“; CVG Strategy

*
 Mar 20: Webinar: “
Cornerstones of ITAR Compliance: Administration, Documentation and Shipping
“; ECTI; 540-433-3977

* Apr 23: Webinar: “ITAR Training Basics – For Compliance Executives April“; CVG Strategy

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

ENEDITOR’S NOTES

EN_a115
. Bartlett’s Unfamiliar Quotations

(Source: Editor)

* Jules Verne (Jules Gabriel Verne; 8 Feb 1828 – 24 Mar 1905; was a French novelist, poet, and playwright.  His novels include novels include Journey to the Center of the Earth, Twenty Thousand Leagues Under the Sea, and Around the World in Eighty Days.)
  – “Solitude, isolation, are painful things and beyond human endurance.”
  – “‘Movement is life;’ and it is well to be able to forget the past, and kill the present by continual change.”
 
Friday’s proverbs:
* Turn your face toward the sun and the shadows fall behind you. – Maori proverb
* Some men go through a forest and see no firewood. – English proverb


To be willing is only half the task. –
 Armenian Proverb 

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

EN_a216. Are Your Copies of Regulations Up to Date?
(Source: Editor)

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

*
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 the 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 the 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: 26 Dec 2018: 
83 FR 66514-66554
: Bump-Stock-Type Devices
 

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 2019: 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: 1 Jan 2019: 2019 Basic Edition of the HTS
  – HTS codes for AES are available here.
  – HTS codes that are not valid for AES are available here.

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

EN_a317
. Weekly Highlights of the Daily Bugle Top Stories
(Source: Editor)
 

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

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

* The Ex/Im Daily Update is a publication of FCC Advisory B.V., compiled by: Editor, James E. Bartlett III; Assistant Editors, Alexander P. Bosch and Vincent J.A. Goossen; and Events & Jobs Editor, Alex Witt. The Ex/Im Daily Update is emailed every business day to approximately 6,500 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.

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* CAVEAT: The contents cannot be relied upon as legal or expert advice.  Consult your own legal counsel or compliance specialists before taking actions based upon news items or opinions from this or other unofficial sources.  If any U.S. federal tax issue is discussed in this communication, it was not intended or written by the author or sender for tax or legal advice, and cannot be used for the purpose of avoiding penalties under the Internal Revenue Code or promoting, marketing, or recommending to another party any transaction or tax-related matter.

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