19-0215 Friday “Daily Bugle”

19-0215 Friday “Daily Bugle”

Friday, 15 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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. [The Daily Bugle will not be published on Monday, 18 February 2019, a U.S. Federal Holiday.]

  1. U.S.-China Economic and Security Review Announces Open Public Hearing on 29 Feb in Washington DC
  1. Items Scheduled for Publication in Future Federal Register Editions 
  2. Commerce/BIS: (No new postings.)
  3. State/DDTC: (No new postings.)
  4. Treasury/OFAC Assesses Civil Monetary Penalty Against AppliChem GmbH for Cuba Sanctions Violations
  5. EU Council to Reinforce Rules on Marketing and Use of Explosive Precursors
  1. Bloomberg: “How to Win a Tech Cold War”
  2. The Epoch Times: “Texas Man Sentenced to 8 Years in Prison for 3-D Gun”
  3. Rotor & Wing International: “Aerospace Industries Association Urges Flexibility on Export Controls on UAS”
  4. VOA: “Norwegian Airline’s Plane Stuck in Iran Awaiting Parts”
  5. WorldECR: “‘Lack of Control Over Emerging Technology’ Concerns Australian Lawmaker”
  1. M. Volkov: “Corruption Risks and the Issue of Foreign Government Officials”
  2. T. Cosgrove: “Geopolitical Risk: How Sanctions Increase Supply Chain Risks”
  3. UAE-Based University Publishes Comparative Analysis of UAE and UK Export Control Regulations
  1. FCC Presents U.S. Export Controls Awareness Course: “ITAR & EAR from a non-U.S. Perspective”, 9 April in Bruchem, the Netherlands
  2. List of Approaching Events: 115 Events Posted This Week, Including 31 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 (12 Feb 2019)
  3. Weekly Highlights of the Daily Bugle Top Stories 



U.S.-China Economic and Security Review Announces Open Public Hearing on 29 Feb in Washington DC

Federal Register, 15 Feb 2019.) [Excerpts.]
84 FR 4609-4610: Notice of Open Public Hearing 
* AGENCY: U.S.-China Economic and Security Review Commission.
* ACTION: Notice of open public hearing.
* SUMMARY: Notice is hereby given of the following hearing of the U.S.-China Economic and Security Review Commission.
  The Commission is mandated by Congress to investigate, assess, and report to Congress annually on “the national security implications of the economic relationship between the United States and the People’s Republic of China.” Pursuant to this mandate, the Commission will hold a public hearing in Washington, DC on February 28, 2019 on “Risks, Rewards, and Results: U.S. Companies in China and Chinese Companies in the United States.”
* DATES: The hearing is scheduled for Thursday, February 28, 2019 at 9:30 a.m.
* ADDRESSES: TBD, Washington, DC. A detailed agenda for the hearing will be posted on the Commission’s website at 
www.uscc.gov. Also, please check the Commission’s website for possible changes to the hearing schedule. Reservations are not required to attend the hearing.
* FOR FURTHER INFORMATION CONTACT: Any member of the public seeking further information concerning the hearing should contact Leslie Tisdale Reagan, 444 North Capitol Street NW, Suite 602, Washington DC 20001; telephone: 202-624-1496, or via email at 
lreagan@uscc.gov. Reservations are not required to attend the hearing.
* SUPPLEMENTARY INFORMATION: … This is the second public hearing the Commission will hold during its 2019 report cycle. This hearing seeks to evaluate two sets of relationships. In the first panel, hearing witnesses will review Chinese companies’ participation in the U.S. economy, and in the second panel, hearing witnesses will review U.S. companies’ participation in the Chinese economy. Both panels will assess implications of this participation for U.S. businesses, workers, consumers, and investors. The hearing will be co-chaired by Vice Chairman Robin Cleveland and Commissioner Michael Wessel. Any interested party may file a written statement by February 28, 2019, by mailing to the contact above. A portion of each panel will include a question and answer period between the Commissioners and the witnesses. … 
  Dated: February 12, 2019.
Daniel W. Peck, Executive Director, U.S.-China Economic and Security Review Commission.

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. Items Scheduled for Publication in Future Federal Register Editions

Federal Register)

* Commerce/BIS; NOTICES; Agency Information Collection Activities; Proposals, Submissions, and Approvals: Chemical Weapons Convention Declaration and Report Handbook and Forms [Pub. Date: 19 Feb 2019.]
* ITC; NOTICES; Investigations; Determinations, Modifications, and Rulings, etc.:
  – U.S. SME Exports: Trade-Related Barriers Affecting Exports of U.S. Small- and Medium-Sized Enterprises to the United Kingdom; 
  – U.S.-Japan Trade Agreement: Advice on the Probable Economic Effect of Providing Duty-free Treatment for Currently Dutiable Imports; and 
  – United States-Mexico-Canada Agreement: Likely Impact on the U.S. Economy and on Specific Industry Sectors [Pub. Dates: 19 Feb 2019.]
* Treasury/OFAC; NOTICES; Blocking or Unblocking of Persons and Properties [Pub. Date: 19 Feb 2019.]

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Commerce/BIS: (No new postings.)


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4. State/DDTC: (No new postings.)
(Source: State/DDTC)
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Treasury/OFAC Assesses Civil Monetary Penalty Against AppliChem GmbH for Cuba Sanctions Violations 

Treasury/OFAC, 14 Feb 2019.) 
The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) today announced a $5,512,564 penalty against AppliChem GmbH (“AppliChem”) of Darmstadt, Germany for 304 violations of the Cuban Assets Control Regulations, 31 C.F.R. part 515.  Between May 2012 and February 2016, AppliChem violated § 515.201 of the Cuban Assets Control Regulations when it fulfilled Cuba orders of chemical reagents on 304 invoices.  OFAC determined that AppliChem’s U.S. parent voluntarily self-disclosed the apparent violations, and that the apparent violations constitute an egregious case.

For more information on this action, please visit the following web notice

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EU Council to Reinforce Rules on Marketing and Use of Explosive Precursors

Council of the European Union, 14 Feb 2019.)
According to the new Regulation, the access to explosive precursors by members of the general public is to become subject to even tighter controls. The Council’s Permanent Representatives’ Committee today endorsed the provisional agreement reached on 4 February between the Romanian presidency of the Council and representatives of the European Parliament on a draft Regulation imposing stricter rules regarding the marketing  and use of explosive precursors throughout the EU, with a view to limiting their availability to the general public, and ensuring the appropriate reporting of suspicious transactions throughout the supply chain.
Explosives precursors are chemical substances that can be used for legitimate purposes, but can also be misused for the illicit manufacture of homemade explosives.
The new rules will limit the availability of explosive precursors to the general public and ensure the appropriate reporting of suspicious transactions throughout the supply chain.
The proposed regulation provides for two distinct categories of explosive precursors:
  – “restricted”, which cannot be made available, introduced, possessed or used by members of the general public above certain concentration levels, and
  – “regulated”, for which suspicious transactions should be reported by economic operators, including online marketplaces.
Subject to the conditions set out in the regulation, member states retain the possibility of setting up licensing schemes, which would enable certain restricted explosive precursors to continue to be made available to the general public.
Subject to control by the Commission, member states will also be able to apply the rules relating to restricted explosive precursors to chemical substances not covered by the regulation.
The new rules also impose a number of training and awareness-raising obligations on:
  – economic operators engaging in the manufacturing or selling explosive precursors and
  – national inspection authorities.
The regulation shall apply eighteen months after its entry into force, which is expected to take place before the end of 2020.
Next Steps
The agreed text, following the usual legal/linguistic scrutiny, will be submitted for formal adoption to the European Parliament and the Council.
With a view to preventing the illicit manufacture of explosives, regulation (EU) No 98/2013 on the marketing and use of explosives precursors restricts the availability, introduction, possession and use of selected explosives precursors to the general public and sets up rules on the reporting of suspicious transactions.
The existing restrictions and controls have proved to be insufficient to prevent the illicit manufacture of homemade explosives. For instance, the requirement of registering transactions does not deter or prevent criminals from acquiring explosives precursors.
Furthermore, the existing regulation is not clear enough as regards several of the obligations it imposes, including those that seek to ensure transmission of information along the supply chain.

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Bloomberg, 14 Feb 2019.) [Excerpts.] 
Carving out areas of American technology that are off-limits to China requires a scalpel, not a chainsaw.
If a digital Iron Curtain is falling between the U.S. and China, America seems increasingly eager to yank its side down. A hasty and excessive response, however, runs the risk of undermining its own technological advantage.
The most visible assault is the one the U.S. has launched against Huawei Technologies Co. Ltd., the world’s leading telecommunications equipment business. American officials have pressured Western allies to ban Huawei technology from forthcoming 5G wireless networks, which will connect everything from mobile phones to autonomous cars. The Justice Department has indicted Huawei for corporate espionage and wants to prosecute Chief Financial Officer Meng Wanzhou for allegedly misleading banks about Huawei’s business dealings in Iran. …

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The Epoch Times, 15 Feb 2019.) [Excerpts.] 
A Texas man has been sentenced to eight years in federal prison after police found him in the woods with a partially 3-D printed AR-15 rifle and a list of federal lawmakers’ addresses in his backpack.
Eric McGinnis was convicted last summer of possessing an unregistered short-barreled rifle. He also was found guilty of unlawfully possessing ammunition while subject to an active protective order that had been issued because of a 2015 altercation with a girlfriend. … 
Under the proposed changes to ITAR, weapons like pistols that are available to American citizens would be taken out of the State Department’s purview and put under that of the Commerce Department. The difference is pertinent to Wilson’s case, as the Commerce Department is more concerned with intellectual property than national security. … 

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Rotor & Wing International, 14 Feb 2019.) [Excerpts.] 
The Aerospace Industries Association (AIA) is urging policy makers to consider the weight, speed, and range of unmanned aircraft systems (UAS) so as to allow U.S. company exports of such systems without running the risk that foreign countries could use some of the exports to proliferate cruise missiles.
Eric Fanning, the president and CEO of AIA, on Feb. 14 called for full implementation of the reforms in the Conventional Arms Transfer Policy, including ensuring that export controls on UAS “reflect market conditions and technology trends.”
In the past, countries, such as the UAE, Jordan and Saudi Arabia, were denied in their purchase request for U.S. drones, and China stepped in to become a supplier. Under the Missile Technology Control Regime, the Trump administration has advocated facilitating the export of any UAS, such as the General Atomics MQ-9 Reaper, that flies under 650 kilometers per hour.

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VOA, 5 Jan 2019.) [Excerpts.] 
Norwegian Air Shuttle said Friday one of its Boeing 737s has been stuck in Iran for three weeks after an unscheduled landing because of engine problems, as U.S. restrictions reportedly create headaches for the airline and possibly passengers.
The aircraft was en route from Dubai to Oslo with 192 passengers and crew members when it carried out a “safety landing” in Shiraz in southwestern Iran because of engine trouble Dec. 14, a Norwegian Air Shuttle spokesman, Andreas Hjornholm, told AFP.

While passengers were able to fly on to Oslo the following day on another aircraft, the Boeing 737 Max has been stuck on Iranian soil where the airline’s mechanics are trying to repair it, Hjornholm said. ..

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WorldECR, 15 Feb 2019.) 
Australia’s Defense Export Control Organization (“DECO”) has given its backing to all the recommendations made by an independent parliamentary review of the Defense Trade Control Act (‘DTC Act’).
Amongst the gaps identified in the DTC Act are “the lack of control over the transfer of technology not captured by the DTC Act’s existing provisions but which, if transferred to foreign entities with interests contrary to Australia’s, could prejudice Australia’s security, defense and international relations.”
The review also identified ‘the inadequate control of emerging and sensitive military and dual-use technology’ as something that needs to be addressed.
In its response to the review, the government has said that “the Defense Exports Controls Branch (DEC) will establish a working group, led by an independent person, to develop options to address the identified gaps in the Defense Trade Controls Act 2012 (DTC Act).  The working group will consist of representatives from Defense and other relevant government agencies and university, industry and SME representatives to develop practical, risk-based legislative proposals to amend the DTC Act to enhance the government’s ability to prevent the transfer of defense and dual-use technology to entities that may use it in a manner contrary to Australian interests or who are acting on behalf of a foreign power.”
Further information is available 

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Volkov Law Group Blog, 13 Feb 2019. Reprinted by permission.) 
* Author: Michael Volkov, Esq., Volkov Law Group, 
mvolkov@volkovlaw.com, 240-505-1992. 
Global companies are expending more time and resources to understanding their relationships with foreign officials.  This is a key focus of every anti-corruption compliance program.
Foreign government officials create different risks dep[ending on the relationship and the nature of the interactions.  A helpful way to examine the issue is by dividing government officials into two categories – foreign government official (FGO) owners and FGOs that interact with your company and/or third-party representatives.  Each scenario presents unique and significant risks.
Let’s start with FGO owners. 
If Company A retains a third-party Company B, which is partially or wholly-owned by an FGO owner, that creates a real risk.  In fact, corrupt FGOs have been using this scheme as a way to avoid their presence in specific high-risk transactions.  FGO owners may disguise their ownership in a third-party entity to secure payments through its equity ownership and distribution of proceeds. 
One of the more significant examples was Manuel Vicente, the then-head of Sonangol, Angola’s state-owned oil and gas business, hidden interest of 10 percent equity in a third-party employed by a US-based drilling company.  I often cite this example as a reason for companies to secure beneficial ownership of their third parties. 
There are other examples involving Russian Oligarchs and FGO owners in entities exposed in the Panama papers scandal.  The list of disguises and schemes goes on and on.  An ownership interest of as little as 1 percent in an entity may be part of a bribery scheme.  As a result, global companies have to screen, identify and assess corruption risks with an intense examination of all beneficial owners.
Now, let’s turn to FGO interactions.  In this risk area, we are focused on FGOs with whom our company or our third parties interact on our behalf. 
A common example is an FGO who is conducting or responsible for a competitive RFP.  In this situation, our risk is clear – if we pay money or provide an item(s) of value to the FGO, and we do so with corrupt intent, i.e. the intent to influence the FGO to act contrary to his or her officials’ duties and responsibilities, we may violate the FCPA.  There are a large number of these risky interactions beyond government-run RFPs. 
For example, our company may retain a third-party tax professional to interact on our behalf with an FGO responsible for collecting taxes from our company in China.  Such interactions are high-risk and we need to isolate, assess and build controls around such interactions to protect against illegal bribery schemes.
The complications arise in this specific area based on the nature and number of FGO interactions. Our company’s sales department, lobbyists and other employees may interact with FGOs on a regular basis – monitoring each and every interaction is impossible and impracticable.  The issue begs various questions:
  – What interactions are riskiest?
  – Which types of interactions should be subject to monitoring?
  – How would a company effectively monitor such interactions?
  – What strategies would work best to ensure that such interactions do not veer off into potential corrupt transactions?
These are interesting issues and compliance officers face difficult questions in developing effective strategies.
Some adopt a “train and pray” approach – train the company employees and pray they nothing bad happens. Other companies may employ proactive monitoring of expenditures connected to the company employees and potentially benefiting FGOs.
But the issue becomes even more difficult when companies retain a third-party to handle such interactions.  Global companies do not have  the requisite control and oversight of these third parties to prevent and detect corrupt schemes, and have to adopt robust training, monitoring and auditing strategies.
This is no easy task and companies are developing new and innovative strategies in this area, with the assistance of vendors offering automated solutions that incorporate data analytics and other new, cutting-edge solutions.

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Dub & Bradstreet, 12 Feb 2019.) 
* Author: T. Cosgrove, Global Head of Strategy, Supply and Compliance, Dun & Bradstreet.
Learn How to Assess Compliance Implications When Supply Chain Disruptions are Possible. Get the First Steps to Protecting Against Geopolitical Risk
In the current geopolitical climate, dealing with compliance issues under the present US administration has become a challenge not just for domestic compliance officers, but also for those in the UK, Europe, Canada, and Mexico.
Sanctions have significant implications for companies everywhere. In 2018, the US withdrew from the Iran nuclear deal, restricting various persons and entities from generally doing business with Iran. Companies with business interests in the country will be required to cease business activities within a certain “wind-down” period, after which, if the goods and services of their contracts have not been fully provided or delivered, either the subsidiary or Iranian company will have extremely limited remedies by which to recoup their losses. The implications of this are far reaching, and it will be important to adapt quickly in the coming year.
How Sanctions Increase Supply Chain Risks
You may not think you’re at risk from sanctions imposed on other countries. However, the impact can have a domino effect, and companies need to look beyond their Tier 1 suppliers. Their suppliers likely conduct business with thousands of smaller companies around the world, all linking back to the primary corporation. Global sanctions require corporations to have visibility into their supplier base at the secondary and tertiary levels – and even beyond. Aside from the legal ramifications and loss of goods and services, further consequences could include the loss of financing by US banks, the loss of US shareholders, and the inability to continue US operations. You can clearly see the devastating effect violations can have not only on the entity at fault but throughout its entire supply chain. It’s important to be prepared for sudden political changes and foreign policy pivots. Every organization should have a plan for adapting to change in a volatile political environment.
How to Assess Compliance Implications
Compliance Week‘s Joe Mont identifies three things companies should do to begin to formulate a plan for Iran sanctions in 
Navigating the Unchartered Waters of Geopolitical Risk:
Identify touchpoints. The first step companies should take is to identify their Iran-related touchpoints, both direct and indirect. Questions to consider include:
  – Do any non-US subsidiaries conduct business with Iranian counterparties?
  – Where do your ships port?
  – Are you transacting in US dollars?
  (2) Assess touchpoints. “What companies should do is take an inventory of their activities related to Iran,” said Theodore Kassinger, a partner at law firm O’Melveny. That involves not only assessing existing contracts, but also having solid answers to these questions:
  – What delivery schedules exist, and how do they fit into the wind-down period?
  – What’s in the pipeline for potential contracts that could be awarded?
  – What payments are owed?
  – Which operational processes have been put in place to handle business with Iran?
(3) Review existing contracts. Companies should also review existing contracts with Iranian counterparties and any other agreements that touch Iran to assess how to fulfill the terms of the contract, or terminate it, before the wind-down period ends. For goods or services not fully provided or delivered to an Iranian counterparty, “suppliers should be in discussions with their Iranian customers on how to handle matters already contracted for that may not be completed within the wind-down periods,” Kassinger said.
If your 
due diligence strategy can’t quickly adapt to changes in the geopolitical landscape, your organization is at risk.
You need to ensure your compliance risk program screens for the beneficial ownership of all parties you do business with and that it includes a documentable audit trail. That information should also be communicated clearly to relevant stakeholders, including employees, subsidiaries, portfolio companies, and other business partners.
The First Step to Protecting Against Geopolitical Risk
Steve Klemash, Americas Leader for the EY Center for Board Management, recommends that leaders ask themselves the following questions to guard against risk:
  – Am I addressing geopolitical risk in a comprehensive fashion?
  – What is the most comprehensive approach around strategic implications, financial reporting and compliance implications?
  – What analysis tools should I be using?
  – Is management supporting actions taken regarding these risks?
Making an honest appraisal of where your organization stands and what changes need to be made to be responsive to any shifts in the geopolitical environment is the first step in protecting yourself against geopolitical risk.

To learn more about the implications of geopolitical risk, click here to download the [free] Compliance Week e-book.

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UAE-Based University Publishes Comparative Analysis of UAE and UK Export Control Regulations 

Author of the article is Bashar H. Malkawi, Dean and Professor of Law, University of Sharjah, United Arab Emirates. Read the full article 
Abstract: Governments across the world appreciate the need for checks on the transfer or exportation of commodities, information, software, and technology considered of strategic value. In order to control exports, countries rely on laws, treaties, international arrangements and other related instruments. In the current case, the UAE is largely dependent on Federal Law No. 12 of 2008 while the UK depends on the Export Control Act of 2002. It is established that the legislations enact amendments to reflect the dynamic nature of the state environment. However, the entry into international arrangements supports the view that the fight against trading in dual-use, military, or sensitive products require cooperative efforts from state parties in order to attain success. The current paper assesses export controls in the United Arab Emirates (UAE) and the United Kingdom.

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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, 
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 
Register before 18 February and get a 10% Early Bird discount on the course fee!

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List of Approaching Events: 115 Events Posted This Week, Including 31 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 
Please, submit your event announcement to Alexander Witt, Events & Jobs Editor (email: 
), composed in the below format:

#” = New or updated listing  

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

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

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

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

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

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

* 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 25: Leeds, UK; “
How to complete Export Declarations
“; Chamber International

Feb 26: Leeds, UK; “
Export Documentation & Import Procedures
; Chamber International

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

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

Feb 27: New York; “
Avoiding Trump’s Tariffs New York City Seminar
“; International Trade Law

 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

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

Mar 5: Leeds, UK; “
Understanding Incoterms
“; Chamber International

* 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: McLean, VA; “
International Trade, Export Compliance & Customs Update
“; KPMG LLP; cdonahue@kpmg.com; +1 703-286-8131;

* 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
* Mar 14: Birmingham, UK; “
Strategic Export Control: Foundation Workshop
* Mar 14: Birmingham, UK; “
Strategic Export Control: Licenses Workshop

Mar 15: Leeds, UK; “
How to Complete Export Declarations
“; Chamber International

* Mar 18-21: Las Vegas, NV; “
ITAR Defense Trade Controls / EAR Export Controls Seminar
 Mar 20: Miami, FL; “
“; Diaz Trade Consulting
* Mar 24-27: Orlando, FL; ICPA Annual Conference, https://bit.ly/2GtRDu7 
* Mar 25-27: San Francisco; “
Global Encryption, Cloud and Cyber Trade Controls Conference
“; Thomsen & Burke LLP;

Mar 26: Leeds, UK; “
Understanding Exporting
“; Chamber International

 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 (ECS)


Mar 27: Bristol, UK; “
Classification of Goods – Using Commodity and Tariff Codes
“; BusinessWest

Mar 27: Bristol, UK; “
Incoterms® Rules 2010
“; BusinessWest

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

Mar 28: Bristol, UK; “
Introduction to Export Procedures
“; BusinessWest

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

Apr 2: Brussels, Belgium; “
Dual-Use, Military Research & Misuse
“; Vrije Universiteit Brussel

* 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 16: Leeds, UK; “
Export Documentation
“; Chamber International

Apr 17: Miami, FL; “
“; 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 1: Leeds, UK; “
Understanding Exporting & Incoterms
“; Chamber International

* 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 15: Bristol, UK; “
A Foundation Course in Importing
“; BusinessWest

May 16: Bristol, UK; “
Export Controls and Licensing
; BusinessWest

May 16: Bristol, UK; “
Inward Processing Relief
“; BusinessWest

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

May 21: London, UK; “
US & UK Export Controls: A Basic Understanding
“; The Institute of Export and International Trade

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

Jun 7: Upper Marlboro, MD; “
2019 Spring Golf Outing
“; SIA

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 3: Bristol, UK; “
Introduction to Export Procedures – Export Training
“; BusinessWest

Jul 4: Bristol, UK; “
Using Documentary Letters of Credit, Drafts and Bills”; 

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);

Jul 11: Birmingham, UK; “
US & UK Export Controls: A Basic Understanding
“; The Institute of Export and International Trade

* Aug 20-21: Cincinnati, OH;

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

* Aug 20-21: Milpitas, CA;

Complying with U.S. Export Controls
* Aug 22: Milpitas, CA:

Encryption Controls

* 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
; 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 25: Bristol, UK; “
Classification of Goods – Using Commodity and Tariff Codes”; 

Sep 25: Bristol, UK; “
Incoterms® Rules 2010
“; BusinessWest

Sep 25: London, UK; “
US & UK Export Controls: A Basic Understanding
; The Institute of Export and International Trade

Sep 26: Bristol, UK; “
Understanding The Paperwork
“; BusinessWest

* Sep 30 – Oct 3; Amsterdam, NL; “
ITAR Controls / EAR/OFAC Commercial and Military Controls
; 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
; 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
; 540-433-3977
* Nov 11-14; Washington, DC; “
ITAR Controls / EAR & OFAC Export Controls Seminar Series
; 540-433-3977

Nov 20: Bristol, UK; “
Introduction to Export Procedures – Export Training
“; BusinessWest

Nov 21: Bristol, UK; “
A Foundation Course in Importing
“; BusinessWest

Nov 26: Bruchem, The Netherlands; “The International Traffic in Arms Regulations (EAR) from a non-U.S. Perspective“; Full Circle Compliance

Nov 27: Manchester, UK; “
US & UK Export Controls: A Basic Understanding
“; The Institute of Export and International Trade

* 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
; 540-433-3977
 Dec 12-13; Washington D.C.; “
Coping with U.S. Export Controls and Sanctions 2019
“; Practicing Law Institute




 Feb 28: Webinar: “
Control Tower: timely response to your supply chain disruptions
“; Amber Road

Feb 28: Webinar: “
Economic Sanctions after Brexit with Maya Lester QC”; 
Brick Court Chambers

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

Mar 8: Webinar: “
Managing Export Compliance and Export Controls Risk”; 
Online Compliance Panel

 Mar 12: Webinar;
DIY Encryption Classification 2019 Edition“;
 ECTI; 540-433-3977;
 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

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


. Bartlett’s Unfamiliar Quotations

(Source: Editor)

Galileo (Galileo Galilei; 15 Feb 1564 – 8 Jan 1642; was an Italian astronomer, physicist, and engineer, sometimes described as a polymath. Galileo has been called the “father of observational astronomy”, the “father of modern physics”, the “father of the scientific method”, and the “father of modern science”.)
  – “Measure what is measurable, and make measurable what is not so.”
  – “I have never met a man so ignorant that I couldn’t learn something from him.”
This week’s proverbs:
* Do not rejoice at my grief, for when mine is old, yours will be new. | Spanish Proverb
* What you see in yourself is what you see in the world. | Afghan Proverb
* Examine what is said, not who speaks. | Arab Proverb

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

EN_a218. 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.

: 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.

: 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.]
: 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
  – 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 
.  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 

: 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 

: 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.

; 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.

: 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

: 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 
. BAFTR subscribers receive a $25 discount on subscriptions to the BITAR, please
contact us
to receive your discount code.
: 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 Update: 12 Feb 2019: Harmonized System Update 1901 [contains 397 ABI records and 89 harmonized tariff records.] 

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

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

. 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.

* RIGHTS & RESTRICTIONS: This email contains no proprietary, classified, or export-controlled information. All items are obtained from public sources or are published with permission of private contributors, and may be freely circulated without further permission, provided attribution is given to “The Export/Import Daily Bugle of (date)”. Any further use of contributors’ material, however, must comply with applicable copyright laws.  If you would to submit material for inclusion in the The Export/Import Daily Update (“Daily Bugle”), please find instructions here.

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

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

* BACK ISSUES: An archive of Daily Bugle publications from 2005 to present is available HERE.

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