19-0227 Wednesday “Daily Bugle'”

19-0227 Wednesday “Daily Bugle”

Wednesday, 27 February 2019

  1. Treasury Seeks Industry Feedback Concerning Iranian Financial Sanctions Regulations Report on Closure by U.S. Financial Institutions of Correspondent Accounts and Payable-Through Accounts
  1. Items Scheduled for Publication in Future Federal Register Editions
  2. Commerce/BIS: (No new postings.)
  3. DHS/CBP Releases Harmonized System Update 1902
  4. DHS/CBP Releases Update Concerning TFTEA Drawback Deployment Calls and ACE Bi-Weekly Trade Call
  5. Justice: “Two Malaysian Nationals Indicted for Conspiring to Illegally Export Firearm Parts to Hong Kong”
  6. State/DDTC: (No new postings.)
  7. Treasury/OFAC Issues OCE’s Data Delivery Standards Guidance
  8. EU Amends Regulation Concerning Export and Import of Hazardous Chemicals
  9. Singapore Customs Circulars of Interest: Transshipment and Transit Permits
  1. CNN: “Exclusive Report: ‘Sold to an ally, Lost to an Enemy'”
  2. Deutsche Welle: “Saudi Coalition Uses German Arms in Yemen”
  3. Reuters: “How U.S. Bike Companies Are Steering Around Trump’s China Tariffs”
  1. M. Volkov: “CCO and CLO ‘Authority’: A Fundamental Requirement”
  2. T. Murphy: “Possible Delay in Scheduled Increase in Section 301 Duties”
  1. FCC Presents “An Introduction to EU / Dutch Dual-Use and Military Export Controls”, 7 May in Bruchem, the Netherlands
  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 (27 Feb 2019) 
  3. Weekly Highlights of the Daily Bugle Top Stories 


Treasury Seeks Industry Feedback Concerning Iranian Financial Sanctions Regulations Report on Closure by U.S. Financial Institutions of Correspondent Accounts and Payable-Through Accounts

Federal Register, 27 Feb 2019.) [Excerpts.] 
84 FR 6465: Agency Information Collection Activities; Submission for OMB Review; Comment Request; Iranian Financial Sanctions Regulations Report on Closure by U.S. Financial Institutions of Correspondent Accounts and Payable-Through Accounts
* AGENCY: Departmental Offices, U.S. Department of the Treasury.
* ACTION: Notice.
* SUMMARY: The Department of the Treasury will submit the following information collection requests to the Office of Management and Budget (OMB) for review and clearance in accordance with the Paperwork Reduction Act of 1995, on or after the date of publication of this notice. The public is invited to submit comments on these requests.
* DATES: Comments should be received on or before March 29, 2019 to be assured of consideration.
* ADDRESSES: Send comments regarding the burden estimate, or any other aspect of the information collection, including suggestions for reducing the burden, to (1) Office of Information and Regulatory Affairs, Office of Management and Budget, Attention: Desk Officer for Treasury, New Executive Office Building, Room 10235, Washington, DC 20503, or email at 
OIRA_Submission@OMB.EOP.gov and (2) Treasury PRA Clearance Officer, 1750 Pennsylvania Ave. NW, Suite 8100, Washington, DC 20220, or email at 
* FOR FURTHER INFORMATION CONTACT: Copies of the submissions may be obtained from Jennifer Quintana by emailing 
PRA@treasury.gov, calling (202) 622-0489, or viewing the entire information collection request at 
  – Title: Iranian Financial Sanctions Regulations Report on Closure by U.S. Financial Institutions of Correspondent Accounts and Payable-Through Accounts.
  – OMB Control Number: 1505-0243.
  – Type of Review: Extension without change of a currently approved collection.
  – Description: This application is submitted to extend the information collection authority pertaining to the Iranian Financial Sanctions Regulations set forth in 31 CFR part 561 (the “Regulations”). Section 561.504(b) of the Iranian Financial Sanctions Regulations, 31 CFR part 561 (the “IFSR”), specifies that a U.S. financial institution that maintained a correspondent account or payable-through account for a foreign financial institution whose name is added to the Part 561 List on OFAC’s website (
www.treasury.gov/ofac) as subject to a prohibition on the maintaining of such accounts must file a report with OFAC that provides full details on the closing of each such account within 30 days of the closure of the account. This collection of information assists in verifying that U.S. financial institutions are complying with prohibitions on maintaining correspondent accounts or payable through accounts for foreign financial institutions listed on the Part 561 List.
  – Form: None. … 
  Dated: February 21, 2019.
Spencer W. Clark, Treasury PRA Clearance Officer.

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OGS_a12. Items Scheduled for Publication in Future Federal Register Editions
(Source: Federal Register)


* Commerce/BIS; NOTICES; Agency Information Collection Activities; Proposals, Submissions, and Approvals: Procedures for Submitting Request for Exclusions from the National Security Adjustments of Imports of Steel and Aluminum [Pub. Date: 28 Feb 2019.]

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Commerce/BIS: (No new postings.)


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CSMS# 19-000088, 27 Feb 2019.) 

Harmonized System Update (HSU) 1902 was created on February 26, 2019 and contains 40 ABI records and 11 harmonized tariff records.

This update contains adjustments related to Section 301. Changes were made to extend the 10 percent duty rate on HTS 99038803. This will allow for pre-filing of entries at the 10 percent duty rate. Further updates are possible after the forthcoming Federal Register notice is published.

Modifications required by the verification of the 2019 Harmonized Tariff Schedule (HTS) are included as well.

The modified records are currently available to all ABI participants and can be retrieved electronically via the procedures indicated in the CATAIR. For further information about this process, please contact your client representative. For all other questions regarding this message, please contact Jennifer Keeling via email at 

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DHS/CBP Releases Update Concerning TFTEA Drawback Deployment Calls and ACE Bi-Weekly Trade Call

CSMS# 19-000089, 27 Feb 2019.)

On February 28, 2019, the TFTEA Drawback Deployment Calls will be held at 2:00-3:00 PM ET and the ACE Bi-Weekly Trade Call will be held at 3:00-4:00 PM ET. Please find call-in information below.

Dial-in Information:
  – Number: 1-877-336-1828
  – Code: 6124214

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Justice: “Two Malaysian Nationals Indicted for Conspiring to Illegally Export Firearm Parts to Hong Kong” 

Justice, 26 Feb 2019.) [Excerpts.] 
Two Malaysian nationals were indicted today for conspiring to illegally export firearm parts from the United States to Hong Kong.
Lionel Chan, 35, a resident of Brighton, and Muhammad Mohd Radzi, 26, who resides in Brooklyn, N.Y., were each indicted on one count of conspiring to violate the Arms Export Control Act. Chan was also indicted for obstruction of justice. On Jan. 31, 2019, Chan and Radzi were arrested and charged by criminal complaint.
According to the indictment, beginning in or around March 2018, Chan began purchasing a variety of U.S.-origin firearm parts online, including parts used to assemble AR-15 assault rifles and 9MM semi-automatic handguns, for a buyer located in Hong Kong. Many of the firearm parts that Chan purchased and exported to Hong Kong are defense articles that are designated on the United States Munitions List and therefore cannot be exported from the United States without first obtaining an export license or written authorization from the U.S. Department of State. Nonetheless, Chan allegedly shipped the firearm parts via Federal Express to the buyer in Hong Kong without first obtaining the necessary export licenses. Chan intentionally concealed the contents of the shipments by providing Federal Express with false information about the shipments, and by concealing the parts inside of each package. Between March and May 2018, Chan allegedly shipped at least 12 packages containing firearm parts from Brighton to the buyer in Hong Kong.
In or around April 2018, Radzi allegedly joined the conspiracy and began illegally exporting firearm parts to Hong Kong as well. Between May and October 2018, Radzi allegedly shipped 21 packages from Brooklyn, N.Y., to the buyer in Hong Kong. In October 2018, two of those packages were interdicted by Hong Kong authorities and found to contain numerous firearms parts, including a firing pin and gun sight, which are defense articles and controlled under Category I of the United States Munitions List. Like Chan, Radzi failed to obtain an export license for any of these shipments.
In addition to the conspiracy charge, Chan was also indicted for obstructing justice. According to the indictment, during a flight from Dublin, Ireland to Boston on January 2, 2019, Chan deleted text messages between himself and the buyer in Hong Kong regarding the illegal export of firearm parts from the United States to Hong Kong without the necessary export licenses.
The charge of conspiring to illegally export firearms provides for a sentence of no greater than five years in prison, one year of supervised release and a $250,000 fine. The charge of obstructing justice provides for a sentence of no greater than 20 years in prison, three years of supervised release, and a $250,000 fine. Sentences are imposed by a federal district court judge based upon the U.S. Sentencing Guidelines and other statutory factors. … 
Details contained in the charging documents are allegations. The defendants are presumed innocent unless and until proven guilty beyond a reasonable doubt in a court of law. 

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State/DDTC: (No new postings.)


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Treasury/OFAC Issues OCE’s Data Delivery Standards Guidance

Treasury/OFAC, 26 Feb 2019.)
The U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC) Office of Compliance and Enforcement (“OCE”) is issuing 
OCE’s Data Delivery Standards Guidance: Preferred Practices for Productions to OFAC (“OCE’s Data Delivery Standards”). OCE’s Data Delivery Standards provides guidance regarding submissions and the technical standards for the preferred format in which to submit electronic document productions to OCE, including administrative subpoena responses, self-disclosures, and other documents or reports. OCE has also updated the Data Delivery Standards to include sections addressing preferred practices for organizing document productions, file size and delivery instructions for electronic submissions, instructions for submitting specific types of files, and an addendum with additional technical document production specifications. This document supersedes and replaces in its entirety, OFAC Enforcement’s 2013 Data Delivery Standards.

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EU Amends Regulation Concerning Export and Import of Hazardous Chemicals

Official Journal of the European Union, 27 Feb 2019.) 

Commission Delegated Regulation (EU) 2019/330 of 11 December 2018 amending Annexes I and V to Regulation (EU) No 649/2012 of the European Parliament and of the Council concerning the export and import of hazardous chemicals.

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Singapore Customs Circulars of Interest: Transshipment and Transit Permits

Singapore Customs, 27 Feb 2019.) 
Singapore Customs has published the following document(s) on its website:


Circular No: 04/2019: Changes to the list of items requiring mandatory transshipment and transit permits under the Fourth and Fifth Schedules of the Strategic Goods Control Regulations

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 CNN: “Exclusive Report: ‘Sold to an ally, Lost to an Enemy'”

CNN, Feb 2019.) [Excerpts.]
The U.S. shipped weapons and secrets to the Saudis and Emiratis. Now, some are in the hands of fighters linked to al Qaeda and Iran.
Saudi Arabia and its coalition partners have transferred American-made weapons to al Qaeda-linked fighters, hardline Salafi militias, and other factions waging war in Yemen, in violation of their agreements with the United States, a CNN investigation has found.

The weapons have also made their way into the hands of Iranian-backed rebels battling the coalition for control of the country, exposing some of America’s sensitive military technology to Tehran and potentially endangering the lives of US troops in other conflict zones. … 

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Deutsche Welle: “Saudi Coalition Uses German Arms in Yemen”

Deutsche Welle, 26 Feb 2019.) [Excerpts.] 
Germany prides itself on its restrictive export policies, which ban arms sales to countries involved in armed conflict. But a DW exclusive shows the Saudi-led coalition at war in Yemen uses German-built weapons and tech.
German arms and technology play a far greater role in the Yemen war than previously known.
According to the findings of the investigative research project #GermanArms, the armies of the United Arab Emirates and Saudi Arabia are using German weapons and technology in Yemen for naval, ground and air operations. … 
Representatives of the German government have repeatedly denied having any knowledge of the use of German-made arms in Yemen. … 

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Reuters: “How U.S. Bike Companies Are Steering Around Trump’s China Tariffs”

Reuters, 26 Feb 2019.) [Excerpts.] 
U.S.-based bicycle manufacturer Kent International has found a way around President Donald Trump’s tariffs – by shifting production out of China.
Like almost all U.S. bike makers, Kent has long relied on low-cost Chinese labor and parts, but Trump’s tariffs have so far inflated his costs by about $20 million annually.
  “We have no choice but to – as rapidly as possible – look to move production away from China,” said Arnold Kamler, chief executive and majority owner of the Parsippany, N.J.-based bike company.
But Kent and other bike makers don’t have to move their manufacturing operations to the United States to avoid tariffs – nor do they have to stop using Chinese parts.
The company now plans to make bike frames in Cambodia while continuing to buy about half the components it will attach to those frames from producers in China. The resulting bicycles can enter the United States tariff-free because of U.S. rules that generally allow products to be designated as made-in-Cambodia as long as 35 percent of their costs for parts and labor are derived from that country.
Gaming the so-called rules of origin is a legal tariff-avoidance strategy being adopted by other major U.S. bike builders and explored across the industry, along with other manufacturing sectors, according to bike executives and supply chain consultants.
The shift in the $6 billion bike industry underscores how such rules allow manufacturers, despite tariffs, to continue sourcing large portions of their parts from China, undermining the Trump administration goal of boosting U.S. manufacturing employment. It further shows how quickly light manufacturers with less capital-intensive operations can move to Southeast Asia, which has seen a blitz of new investment since Trump launched his first tariffs last spring. … 

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M. Volkov: “CCO and CLO ‘Authority’: A Fundamental Requirement”

Volkov Law Group Blog, 27 Feb 2019. Reprinted by permission.) 
* Author: Michael Volkov, Esq., Volkov Law Group, 
mvolkov@volkovlaw.com, 240-505-1992. 
A basic compliance program control, which is often overlooked (or assumed to exist), is the requirement that a chief compliance officer (COO) and/or chief legal officer (CLO) have the authority to stop a specific contract or business transaction. To simplify this statement, compliance and legal have to approve certain business transactions before they can proceed. 
If a compliance officer or legal officer is consulted just for “advice,” the company’s ability to ensure compliance with laws and its code of conduct is jeopardized.  A company’s internal controls have to include (a must) the requirement that legal and/or compliance sign off on specific, high-risk or questionable transactions.
FCPA enforcement is replete with examples demonstrating my point.  In the sanctions context, which I am not addressing here, the major enforcement actions against global banks include instances where compliance officers raised concerns, objected to transactions and relationships, and wewre basically ignored by senior bank officers. 
Let’s start with last year’s FCPA settlement with United Technologies in which United Technologies agreed to pay $13.9 million for bribes paid by its elevator and aircraft engine businesses in Azerbaijan and China. 
In Azerbiajan, Otis Elevator, a United Technologies subsidiary, hired third-party agents without conducting any due diligence.  They hired agents who had no local experience or history in the elevator industry.  One of the agents was not even registered until after participating in the transactions.
In one scheme, Otis Elevator hired Liftremont, the state-owned entity responsible for purchasing elevators for municipal facilities in the city of Baku, as a distributor of its elevators to other areas outside Baku in order as a way to funnel bribes to government officials.  In the summer of 2014, a Liftremont senior official instructed Otis to replace one intermediary with a new intermediary. The head of the Otis Russia Legal Department initially refused to approve the contract, and elevated the issue to his supervisor, the head of Otis’s Regional Legal Department (“Regional lawyer”), who contacted the CFO of Otis Russia to express his opposition and request additional information.  After the Liftremont senior official provided a prefunctory explanation for the change in intermediaries, the regional lawyer eventually approved the contract but discovered that the contract had been executed four months earlier in August 2014, before Otis Legal even raised the issue.
In the Société Générale enforcement action under which the global bank paid $585 million for FCPA violations, compliance officers raised concerns about the payments to the Libyan intermediary and questioned the absence of a justification for such large payments. These concerns were ignored or addressed by minor non-substantive changes to the relationship. 
In another case, Elbit Imaging agreed to a $500,000 civil penalty for deficiencies in its internal controls, citing a series of agreements with two consultants, a sales agent and sub-agent that created significant risks of bribery.  In reaching the settlement, the SEC specifically cited “the legal department’s limited involvement and supervision of the contracts.”
These are just examples to prove my point.  In the absence of a firm control and requirement for legal and/or compliance approval, companies are certain to take unreasonable risks, which can result in FCPA (and sanctions) violations.

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(Source: Author, 26 Feb 2019.)
* Author: Ted Murhpy, Esq., Baker & Mckenzie. Contact Ted at:

As you have likely heard by now, President Trump announced this past Sunday that “substantial progress” has being made in the on-going trade talks with China; as a result, he will be delaying the scheduled increase in tariffs applicable to Chinese-origin goods included on List 3; and that both sides are planning “a Summit” at Mar-a-Lago (reportedly in late March) to “conclude an agreement.”  While additional details have yet to emerge, we wanted to share some initial thoughts with you on what to look for when they do.
First, the duty rate applicable to articles included on List 3 is scheduled to increase from 10% to 25% on March 2, 2019 (i.e., this coming Saturday).  We believe that a Federal Register notice, presidential proclamation, or some other official statement will be issued this week confirming the delay (i.e., we do not believe that the scheduled tariff increase can be delayed by tweet).
Second, in any deal, it will be important to pay particular attention to the enforcement mechanisms that are included.  If the Trump Administration’s goals include reducing the United States’ trade deficit with China, then including a unilaterally-imposable ‘snapback’ type of enforcement mechanism would help achieve that.  For example, if the United States reserves the right to re-impose duties if China fails to live up to its commitments in one or more areas (e.g., failing to stop engaging in cyber theft – something China has not admitted to doing in the first place), then that will create significant uncertainty for U.S. businesses, which should impact sourcing/investment decisions.  If duties of 25% could be imposed on the articles you purchase from a given country with little-to-no advance notice, would you continue sourcing from there, or would you look to eliminate that risk by sourcing from elsewhere?  Thus, even if a deal resolving the dispute is ultimately reached, it will be important to understand how the agreement will be enforced.  It is likely (in our view) that, even if a deal is reached, that trade with China will not return to what it was before.     
Finally, it seems strange that President Xi would be willing to come to the United States to conclude such a deal given the appearance it creates.  Where a “summit” like this is held matters, in terms of public/political perception.  This is why such summits are usually held in a third country, so as not to give the appearance that one side has ‘won,’ or is more powerful than the other (compare the Trump-Kim summits held in Singapore and in Vietnam; the Reagan-Gorbachev summit held in Iceland; etc., to Holy Roman Emperor Henry IV kneeling in the snow in front of Pope Gregory II’s castle in Canossa).  It is not clear why President Xi would be willing to come to the United States (and to one of President Trump’s golf resorts, in particular) to conclude such a deal.  The optics on that within China cannot be good (of course, if China thinks it is getting a very good deal…).

Time (and the terms of the deal) will tell.

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FCC Presents “An Introduction to EU / Dutch Dual-Use and Military Export Controls”, 7 May in Bruchem, the Netherlands

(Source: Full Circle Compliance, 
This 1-day training course is ideally suited for compliance professionals and those in a similar role who aim to gain a better understanding of EU and Dutch export control laws and regulations and industry’s best practices to ensure compliance.
  The course will cover multiple topics relevant for organizations subject to EU and Dutch dual-use and/or military export controls, including: the EU and Dutch regulatory framework; key concepts and definitions; practical tips regarding classification and licensing, and for ensuring a compliant shipment; identifying red flag situations and handling (potential) non-compliance issues; and the latest developments regarding Internal Compliance Program requirements in the EU an the Netherlands.
* Training Event: “An Introduction to EU / Dutch Dual-Use and Military Export Controls”
* Date: Tuesday, 7 May 2019
* Location: Full Circle Compliance, Landgoed Groenhoven, Dorpsstraat 6, Bruchem, The Netherlands
* Times:
  – Registration and welcome: 9.00 am – 9.30 am
  – Training course hours: 9.30 am – 4.00 pm
* Level: Awareness / Beginner.
* Target Audience: Compliance professionals or those in a similar role in any industry affected by EU/Dutch export controls (
e.g., manufacturing, logistics, research & development, aerospace & defense, government, etc.).
* Instructors: Marco F.N. Crombach MSc (Senior Manager) & Vincent J.A. Goossen MA (Program Manager). 
* Information & Registration: visit the 
event page or contact us at 
events@fullcirclecompliance.eu or 31 (0)23 – 844 – 9046. 

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Henry Wadsworth Longfellow (27 Feb 1807 – 24 Mar 1882; was an American poet and educator whose works include 
“Paul Revere’s Ride”, The Song of Hiawatha, and 
Evangeline. He was also the first American to translate Dante Alighieri’s 
Divine Comedy, and was one of the Fireside Poets from New England.)
 – “Perseverance is a great element of success. If you only knock long enough and loud enough at the gate, you are sure to wake up somebody.”

Hugo Black (Hugo Lafayette Black; 27 Feb 1886 – 25 Sep 1971; was an American politician and jurist who served in the United States Senate from 1927 to 1937, and as an Associate Justice of the Supreme Court of the United States from 1937 to 1971.)
– “The layman’s constitutional view is that what he likes is constitutional and that which he doesn’t like is unconstitutional.”
  – “Our Constitution was not written in the sands to be washed away by each wave of new judges blown in by each successive political wind.”

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


DHS CUSTOMS REGULATIONS: 19 CFR, Ch. 1, Pts. 0-199.  Implemented by Dep’t of Homeland Security, U.S. Customs & Border Protection.

  – Last Amendment: 14 Jan 2019: 84 FR 112-116: Extension of Import Restrictions Imposed on Certain Archaeological and Ecclesiastical Ethnological Material from Bulgaria; and 84 FR 107-112: Extension of Import Restrictions Imposed on Certain Archaeological Material From China 

DOC EXPORT ADMINISTRATION REGULATIONS (EAR): 15 CFR Subtit. B, Ch. VII, Pts. 730-774. Implemented by Dep’t of Commerce, Bureau of Industry & Security.
  – Last Amendment: 20 Dec 2018: 83 FR 65292-65294: Control of Military Electronic Equipment and Other Items the President Determines No Longer Warrant Control Under the United States Munitions List (USML); Correction [Concerning ECCN 7A005 and ECCN 7A105.]
* DOC FOREIGN TRADE REGULATIONS (FTR): 15 CFR Part 30.  Implemented by Dep’t of Commerce, U.S. Census Bureau.
  – Last Amendment: 24 Apr 2018: 83 FR 17749-17751: Foreign Trade Regulations (FTR): Clarification on the Collection and Confidentiality of Kimberley Process Certificates
  – HTS codes that are not valid for AES are available here.
  – The latest edition (1 Jan 2019) of Bartlett’s Annotated FTR (“BAFTR”), by James E. Bartlett III, is available for downloading in Word format. The BAFTR contains all FTR amendments, FTR Letters and Notices, a large Index, and approximately 250 footnotes containing case annotations, practice tips, Census/AES guidance, and explanations of the numerous errors contained in the official text. Subscribers receive revised copies in Microsoft Word every time the FTR is amended. The BAFTR is available by annual subscription from the Full Circle Compliance website.  BITAR subscribers are entitled to a 25% discount on subscriptions to the BAFTR. Government employees (including military) and employees of universities are eligible for a 50% discount on both publications at www.FullCircleCompiance.eu.   


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

* DOJ ATF ARMS IMPORT REGULATIONS: 27 CFR Part 447-Importation of Arms, Ammunition, and Implements of War.  Implemented by Dep’t of Justice, Bureau of Alcohol, Tobacco, Firearms & Explosives.
  – Last Amendment: 15 Jan 2016: 81 FR 2657-2723: Machineguns, Destructive Devices and Certain Other Firearms; Background Checks for Responsible Persons of a Trust or Legal Entity With Respect To Making or Transferring a Firearm.  


DOS INTERNATIONAL TRAFFIC IN ARMS REGULATIONS (ITAR): 22 C.F.R. Ch. I, Subch. M, Pts. 120-130. Implemented by Dep’t of State, Directorate of Defense Trade Controls.
  – Last Amendment: 4 Oct 2018: 83 FR 50003-50007: Regulatory Reform Revisions to the International Traffic in Arms Regulations.
  – The only available fully updated copy (latest edition: 1 Jan 2019) of the ITAR with all amendments is contained in Bartlett’s Annotated ITAR (“BITAR”), by James E. Bartlett III. The BITAR contains all ITAR amendments to date, plus a large Index, over 800 footnotes containing amendment histories, case annotations, practice tips, DDTC guidance, and explanations of errors in the official ITAR text. Subscribers receive updated copies of the BITAR in Word by email, usually revised within 24 hours after every ITAR amendment. The BITAR is available by annual subscription from the Full Circle Compliance website. BAFTR subscribers receive a $25 discount on subscriptions to the BITAR, please contact us to receive your discount code.
* DOT FOREIGN ASSETS CONTROL REGULATIONS (OFAC FACR): 31 CFR, Parts 500-599, Embargoes, Sanctions, Executive Orders. 

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

  – Last Amendment: 15 Nov 2018: 83 FR 57308-57318: Democratic Republic of the Congo Sanctions Regulations
* USITC HARMONIZED TARIFF SCHEDULE OF THE UNITED STATES (HTS, HTSA or HTSUSA), 1 Jan 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: 27 Feb 2019: 
Harmonized System Update 1902 
[contains 40 ABI records and 11 harmonized tariff records.]

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

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Weekly Highlights of the Daily Bugle Top Stories

(Source: Editor) 

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

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* The Ex/Im Daily Update is a publication of FCC Advisory B.V., compiled by: Editor, James E. Bartlett III; Assistant Editors, Alexander P. Bosch and Vincent J.A. Goossen; and Events & Jobs Editor, Alex Witt. The Ex/Im Daily Update is emailed every business day to approximately 6,500 readers of changes to defense and high-tech trade laws and regulations. We check the following sources daily: Federal Register, Congressional Record, Commerce/AES, Commerce/BIS, DHS/CBP, DOE/NRC, DOJ/ATF, DoD/DSS, DoD/DTSA, FAR/DFARS, State/DDTC, Treasury/OFAC, White House, and similar websites of Australia, Canada, U.K., and other countries and international organizations.  Due to space limitations, we do not post Arms Sales notifications, Denied Party listings, or Customs AD/CVD items.

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

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

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