19-0402 Tuesday “Daily Bugle'”

19-0402 Tuesday “Daily Bugle”

Tuesday, 2 April 2019

  1. Justice/ATF Seeks Comments Concerning Furnishing of Samples
  1. Items Scheduled for Publication in Future Federal Register Editions 
  2. Commerce/BIS: (No new postings.)
  3. DHS/CBP Creates Harmonized System Update 1905
  4. DHS/CBP Publishes Updated 5106 (TP/TT) CATAIR and Error Dictionary
  5. State/DDTC: (No new postings.)
  6. EU Publishes Decision Supporting OPCW Activities, Amends Restrictive Measures Concerning Libya
  7. German BAFA Publishes Annual Report 2018
  1. Euronews: “Jamal Khashoggi: EU Divided Over Arms Sales to Saudi Arabia Six Months After Murder”
  2. Reuters: “U.S. Halts F-35 Equipment to Turkey, Protests its Plans to Buy From Russia”
  1. B.J. Fleming, P. O’Toole & A.S. Hussain: “Trade Compliance Flash: Let the Buyer Beware: OFAC Penalizes a Third Company for Post-Acquisition Sales by Non-U.S. Subsidiary to Countries Subject to U.S. Sanctions”
  2. International Trade Compliance Blog: “Singapore – Changes to Strategic Goods Transshipment and Transit Permit requirements”
  3. The FAQ of the Day: TAAs and Export Control Reform
  1. ECTI Presents “Importing Done Right – Grasping and Implementing the Core Elements of U.S. Customs Compliance” Webinar on 30 April
  2. ICPA Presents “2019 EU Conference”, 15-17 May in London
  1. Bartlett’s Unfamiliar Quotations 
  2. Are Your Copies of Regulations Up to Date? Latest Amendments: DHS/Customs (12 Mar 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 (14 Mar 2018), DOS/ITAR (19 Mar 2018), DOT/FACR/OFAC (15 Mar 2018), HTSUS (2 Apr 2019) 
  3. Weekly Highlights of the Daily Bugle Top Stories 


Justice/ATF Seeks Comments Concerning Furnishing of Samples

Federal Register, 2 Apr 2019.) [Excerpts.]
FR 84 12635-12636: Agency Information Collection Activities; Proposed eCollection eComments Requested; Furnishing of Samples
* AGENCY: Bureau of Alcohol, Tobacco, Firearms and Explosives, Department
of Justice.
* ACTION: 30-Day notice.
* SUMMARY: The Department of Justice (DOJ), Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF), will submit the following information collection request to the Office of Management and Budget (OMB) for review and approval in accordance with the Paperwork Reduction Act of 1995.
* DATES: The proposed information collection was previously published in the Federal Register, on February 5, 2019, allowing for a 60-day comment period. Comments are encouraged and will be accepted for an additional 30 days until May 2, 2019.
* FOR FURTHER INFORMATION CONTACT: If you have additional comments, particularly with respect to the estimated public burden or associated response time, have suggestions, need a copy of the proposed information collection instrument with instructions, or desire any other additional information, please contact: Anita Scheddel, Program Analyst, Explosives Industry Programs Branch, either by mail 99 New York Ave NE, Washington, DC 20226, or by email at
eipb-informationcollection@atf.gov or by telephone at 202-648-7158. Written comments and/or suggestions can also be directed to the Office of Management and Budget, Office of Information and Regulatory Affairs, Attention Department of Justice Desk Officer, Washington, DC 20503 or sent to
  – Type of Information Collection: Revision of a currently
approved collection.
  – The Title of the Form/Collection: Furnishing of Samples.
  – Form number: None.
  – Component: Bureau of Alcohol, Tobacco, Firearms and Explosives, U.S. Department of Justice. …
  – Abstract: Pursuant to 18 U.S.C. Chapter 40 Sec. 843 (i) (1), ATF requires licensed manufacturers and importers and persons who manufacture or import explosives materials or ammonium nitrate to submit samples at the request of the Director. …
Dated: March 27, 2019.
Melody Braswell, Department Clearance Officer for PRA, U.S. Department of Justice.

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


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

[No items of interest noted today.] 
* * * * * * * * * * * * * * * * * * * * 

Commerce/BIS: (No new postings.)

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

DHS/CBP Creates Harmonized System Update 1905

CSMS# 19-000173
, 2 Apr 2019.)

Harmonized System Update (HSU) 1905 was created on April 1, 2019 and contains 792 ABI records and 176 harmonized tariff records.

This update contains the additional changes made to accommodate new TSCA certification requirements for composite wood products, set forth in EPA’s TSCA Title VI Formaldehyde Emission Standards for Composite Wood Products (81 FR 89674). The remaining associated HTS records have been flagged with an EP7 (TSCA certification ‘may be required’) code, and are included.  

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 

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

DHS/CBP Publishes Updated 5106 (TP/TT) CATAIR and Error Dictionary

CSMS# 19-000174, 2 Apr 2019.)

The latest Importer/Consignee Create/Update CATAIR is now posted on 
CBP.GOV under the “Chapters” tab at the following location: 

An updated 5106 Error Dictionary is also now posted on 
CBP.GOV under the “Supporting Documents” tab at the following location: 

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

State/DDTC: (No new postings.)


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

EU Publishes Decision Supporting OPCW Activities, Amends Restrictive Measures Concerning Libya

Council Decision (CFSP) 2019/538 of 1 April 2019 in support of activities of the Organisation for the Prohibition of Chemical Weapons (OPCW) in the framework of the implementation of the EU Strategy against Proliferation of Weapons of Mass Destruction
Council Decision (CFSP) 2019/539 of 1 April 2019 amending Decision (CFSP) 2015/1333 concerning restrictive measures in view of the situation in Libya

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

German BAFA Publishes Annual Report 2018

German BAFA, 2 Apr 2019.)  
The German Federal Office for Economic Affairs and Export Control (BAFA) published its Annual Report for the year 2018.


The Annual Report 2018 provides a good overview of the work of the BAFA in 2018 in the areas of foreign trade, energy, business and SME promotion, and the
auditor oversight body

Regarding export control, the Annual Report 2018 covers the following topics in detail:
– The Chemical Weapons Convention (CWC)
– Test Procedures for Visiting Scientists dnd Proliferation Risks
– Import
– Cross-Border Movement of Radioactive Materials
– Satellite Data Security
– Vessel Security and Patrol
The Annual Report can be downloaded
here (In German).

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


Euronews: “Jamal Khashoggi: EU Divided Over Arms Sales to Saudi Arabia Six Months After Murder”

Euronews, 2 Apr 2019.) [Excerpts.]
The brutal murder of journalist Jamal Khashoggi – which happened six months ago today – triggered a wave of condemnations and soured relations between Saudi Arabia and European countries.
Then, in the weeks after the killing, MEPs called for the imposing of an EU-wide arms embargo on the kingdom.
Now, half a year on from the Khashoggi’s slaying, we take a look at how much of Europe’s words were put into concrete action. …

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

Reuters: “U.S. Halts F-35 Equipment to Turkey, Protests its Plans to Buy From Russia”

Reuters, 1 Apr 2019.) 
The United States has halted delivery of equipment related to the stealthy F-35 fighter aircraft to Turkey, marking the first concrete U.S. step to block delivery of the jet to the NATO ally in light of Ankara’s planned purchase of a Russian missile defense system.
U.S. officials told their Turkish counterparts they will not receive further shipments of F-35 related equipment needed to prepare for the arrival of the stealthy jet, two sources familiar with the situation told Reuters on Monday.
The Pentagon confirmed the Reuters report that the equipment delivery had been stopped.
  “Pending an unequivocal Turkish decision to forgo delivery of the S-400, deliveries and activities associated with the stand-up of Turkey’s F-35 operational capability have been suspended,” Air Force Lieutenant Colonel Mike Andrews, a Defense Department spokesman, said in a statement.
Turkish President Tayyip Erdogan has refused to back down from Ankara’s planned purchase of a Russian S-400 missile defense system that the United States has said would compromise the security of F-35 aircraft.
The disagreement over the F-35 is the latest of a series of diplomatic disputes between the United States and Turkey including Turkish demands that the United States extradite Islamic cleric Fethullah Gulen, differences over Middle East policy and the war in Syria, and sanctions on Iran.
The sources, who spoke on condition of anonymity, told Reuters the next shipment of training equipment, and all subsequent shipments of F-35 related material, had been canceled. The aircraft is built by Lockheed Martin Corp.
A Pentagon official had told Reuters in March that the United States had a number of items it could withhold in order to send Turkey a signal that the United States was serious about Ankara dropping its ambition to own the S-400.
Turkish officials in Ankara were not immediately available for comment. Turkey has said it will take delivery of the S-400s in July.
The U.S. decision on the F-35s was expected to complicate Turkish Foreign Minister Mevlut Cavusoglu’s visit to Washington this week for a NATO summit. On Sunday, Erdogan suffered one of his biggest electoral losses in decades in local elections.
  “Certain Russian weapon systems are seen as inherently threatening to the United States regardless of who is operating them and for what purpose,” Andrew Hunter, a fellow at the Center for Strategic and International Studies, said.
  “Because Turkey is not just an F-35 purchaser, but an industrial partner, blocking delivery of these systems represents a major escalation by the United States as it threatens to impose serious costs on both sides,” Hunter said.
Reuters reported last week that Washington was exploring whether it could remove Turkey from production of the F-35. Turkey makes parts of the fuselage, landing gear and cockpit displays. Sources familiar with the F-35’s intricate worldwide production process and U.S. thinking on the issue last week said Turkey’s role can be replaced.
The United States and other NATO allies that own F-35s fear the radar on the Russian S-400 missile system will learn how to spot and track the jet, making it less able to evade Russian weapons.
In an attempt to persuade Turkey to drop its plans to buy the S-400, the United States offered the pricier American-made Patriot anti-missile system in a discounted deal that expired at the end of March. Turkey has shown interest in the Patriot system, but not at the expense of abandoning the S-400.
Turkey has engaged with U.S. negotiators in recent days about buying the Patriot system, a person familiar with the matter said on condition of anonymity. The system is made by Raytheon Co.
Turkish Defense Minister Hulusi Akar in March said that despite some issues, Turkish pilots were continuing their training at an air base in Arizona on the F-35, each of which costs $90 million, and that Ankara was expecting the aircraft to arrive in Turkey in November.
By halting jet deliveries, the Pentagon could subsequently delay training of Turkish pilots. Two additional jets are scheduled to arrive in Arizona in April and a significant delay could impact Turkey’s November target date for operations.
U.S. lawmakers also have expressed alarm over Turkey’s planned purchase of the Russian system. Four U.S. senators last week introduced a bipartisan bill that would prohibit the transfer of F-35s to Turkey until the U.S. government certifies that Ankara will not take delivery of the S-400 system.
Following news of the halt, U.S. Senator Jeanne Shaheen, one of the bill sponsors, said she was glad to hear the administration was “to delay the transfer of F-35 equipment to Turkey to help ensure U.S. military technology and capabilities cannot fall into the hands of the Kremlin.”

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


B.J. Fleming, P. O’Toole & A.S. Hussain: “Trade Compliance Flash: Let the Buyer Beware: OFAC Penalizes a Third Company for Post-Acquisition Sales by Non-U.S. Subsidiary to Countries Subject to U.S. Sanctions”

Miller & Chevalier, 4 Apr 2019.)
* Authors: Brian J. Fleming,
bfleming@milchev.com, 202-626-5871; Timothy P. O’Toole,
totoole@milchev.com, 202-626-5552; Aiysha S. Hussain,
ahussain@milchev.com, 202-626-1497. All of Miller & Chevalier.
On March 27, 2019, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) entered into a
settlement agreement in which Stanley Black & Decker, Inc., (Stanley Black & Decker) and its foreign subsidiary, Jiangsu Guoqiang Tools Co., Ltd. (GQ), agreed to pay $1.869 million to settle its potential civil liability for 23 apparent violations of the Iranian Transactions and Sanctions Regulations, 31 C.F.R. Part 560 (ITSR). The apparent violations arose after Stanley Black & Decker acquired a 60 percent interest in GQ in 2013. During due diligence in the two years before the purchase, Stanley Black & Decker learned that GQ sold its products to Iran and made discontinuance of these sales a condition of the purchase. Immediately after the purchase, Stanley Black & Decker implemented some training and policy changes concerning sanctions compliance, but apparently did not implement procedures to monitor or audit GQ’s operations to ensure that its Iran-related sales did not recur post-acquisition.
As a result, GQ continued to make sales to Iran for another two years, despite knowledge that these activities violated Stanley Black & Decker’s policies and U.S. sanctions. After Stanley Black & Decker learned of these sales, it initiated an internal investigation and ultimately reported the matter to OFAC. Stanley Black & Decker’s internal investigation determined various GQ board members and senior management participated in the Iran sales and appear to have engaged in what OFAC labeled as “non-routine business practices” with regard to GQ’s Iran sales. In particular, GQ apparently utilized trading companies in the United Arab Emirates and China as conduits for these Iran sales; GQ also created fictitious bills of lading with incorrect ports of discharge and places of delivery and instructed their customers not to write “Iran” on business documents, such as bills of lading.
Apart from the $1.869 million penalty, the settlement agreement also mandates detailed OFAC-related compliance reforms, including (1) structural reforms evincing a management commitment to sanctions compliance, (2) the performance of a comprehensive sanctions risk assessment, (3) improved internal controls tailored to address sanctions risk, (4) testing and audit procedures to validate the effectiveness of the internal controls, and (5) an expansive sanctions training program. All U.S. companies would be wise to review these compliance reforms, as they appear to reflect OFAC’s expectations for how U.S. companies with a multi-national footprint will structure their U.S. sanctions compliance policies going forward.
This penalty action is the third one this year that arises out of sales to an embargoed country by a non-U.S. subsidiary after acquisition, despite contractual clauses designed to ensure that the non-U.S. subsidiary ceased post-acquisition operations in countries subject to U.S. sanctions. The others were the
Kollmorgen Corporation penalty on February 7, 2019 and the
AppliChem GmbH penalty on February 14, 2019. In each of these other enforcement actions, the U.S. acquiring company spotted sales to embargoed countries during sanctions due diligence and directed these sales to cease. However, in each action, the non-U.S. company continued the sales, and the U.S. parent was penalized and directed to implement serious compliance reforms. With three penalty actions in a two-month period, OFAC is attempting to send a loud message to U.S. companies: it is not enough to identify sanctions risk during the purchase of a non-U.S. company-that risk must be effectively and meaningful addressed. U.S. companies that fail to do so act at their peril.

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

International Trade Compliance Blog: “Singapore – Changes to Strategic Goods Transshipment and Transit Permit requirements”
Baker McKenzie
, 29 Mar 2019.)
Effective 1 May 2019, the list of strategic goods being transshipped in or in transit in Singapore needing a strategic goods permit will be expanded.
Currently, under the Strategic Goods (Control) Act (“SGCA”) strategic goods permits must be obtained when strategically controlled military and dual-use goods are being exported from, transshipped in or brought in transit in Singapore. For trade facilitation, the regime also provides strategic goods permit exemptions when certain items are transshipped or brought into transit in Singapore’s Free Trade Zones (“FTZs”) and meet the applicable transshipment / transit requirements.
The list of dual-use items ineligible for FTZ transshipment and transit strategic goods permit exemptions will be expanded from 1 May 2019. There will also be an expansion to military goods in transit ineligible for strategic goods permit exemptions. Items that are not eligible for permit exemption when transshipping or transiting in an FTZ are listed in the Fourth Schedule (Transshipment) and Fifth Schedule (Transit) to the Strategic Goods (Control) Regulations. On 25 February 2019, Singapore Customs released Circular Number 04/2019 detailing a further list of items across several code categories that will be added to the Fourth and Fifth Schedules (effective 1 May 2019). We include a link to the circular here.
Examples of items needing a permit for transshipment or transit from 1 May
For military goods ­- naval vessels and components along with military aircraft and components will no longer be eligible for transit permit exemptions. For dual-use goods – specific codes under the special materials and related equipment, materials processing, sensors and lasers, navigation and avionics, and aerospace and propulsion categories will no longer be eligible for transshipment and transit exemptions. From 1 May 2019, transshipment or transit (as applicable) of the added items will require strategic goods permits under the SGCA, even if their shipment activity is confined to FTZs.
Action to take
Most new additions to the Fourth and Fifth Schedules are specific to the sub-category code level. Supply chains with sensitive technology and utilizing Singapore FTZs will need to check if they currently rely on SGCA strategic goods permit exemptions and if this changes 1 May 2019. If the goods fall under the newly added category codes in the Fourth and Fifth Schedules, from 1 May 2019, strategic goods permits will need to be obtained.

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

The FAQ of the Day: TAAs and Export Control Reform
State/DDTC, 27 Apr 2018.)
Q: My company is considering removing some items (that recently transitioned to the EAR) out from under an existing Technical Assistance Agreement (TAA) in order to support an effort that was not envisioned as part of the original scope of the TAA. Provided we comply with Bureau of Industry and Security licensing requirements, as the consignee must we first terminate the agreement before we can reexport/re-transfer these items?
A: If the desire of the applicant is to preserve the integrity of the TAA for all other items, services, etc. described within the agreement (
i.e., leave it active), then the applicant must amend the TAA to remove reference to those items that are being re-transferred to the separate effort. This change must be effected prior to the
re-transfer referenced above. However, should the proposed re-transfer be deemed an extension of the effort described in the TAA, but outside the existing scope of the TAA, then the applicant has two options: (1) the applicant may submit an amendment to expand the scope of the agreement, or (2) the applicant may seek Commerce authorization for the re-export/re-transfer. Be advised that Commerce re-export/re-transfer authorization only applies to the paragraph (x) items; any expansion of territory for USML defense services, technical data, or hardware must be approved by State via the amendment process.

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


TE_a114. ECTI Presents “Importing Done Right – Grasping and Implementing the Core Elements of U.S. Customs Compliance” Webinar on 30 April  

(Source: D. Hatch, 

* What: Importing Done Right – Grasping and Implementing the Core Elements of U.S. Customs Compliance
* When: April 30, 2019 1:00 p.m. (EDT)
* Where: Webinar
* Sponsor: Export Compliance Training Institute (ECTI)
* ECTI Speaker: Melissa Proctor
* Register: 
here or contact Danielle Hatch, 540-433-3977,

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

ICPA Presents “2019 EU Conference”, 15-17 May in London

* What: 2019 EU Conference
  – Import and Export Track (click
here for the agenda)
Professional Speakers
  – Hot Industry Topics
* When: 15-17 May 2019
* Where:
The Tower Hotel, London, United Kingdom.
* Sponsor: International Compliance Professionals Association (ICPA)
* Information & Registration: Click

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


Giacomo Casanova (Giacomo Girolamo Casanova; 2 Apr 1725 – 4 Jun 1798; was an Italian adventurer and author from the Republic of Venice. His autobiography, 
Histoire de Ma Vie (Story of My Life), is regarded as one of the most authentic sources of the customs and norms of European social life during the 18th century.  He has become so famous for his often complicated and elaborate affairs with women that his name is now synonymous with “womanizer”.)
  – “Real love is the love that sometimes arises after sensual pleasure: if it does, it is immortal; the other kind inevitably goes stale, for it lies in mere fantasy.”
   – ”
Marriage is the tomb of love.” 
Hans Christian Andersen (2 Apr 1805 – 4 Aug 1875; was a Danish author. Although a prolific writer of plays, travelogues, novels, and poems, Andersen is best remembered for his fairy tales. Andersen’s fairy tales, of which no fewer than 3,381 works have been translated into more than 125 languages, have become culturally embedded in the West’s collective consciousness. His most famous fairy tales include 
“The Emperor’s New Clothes”, “The Little Mermaid”, “The Nightingale”, “The Snow Queen”, “The Ugly Duckling”, “The Little Match Girl” and
 “Thumbelina”. His stories have inspired ballets, plays, and films.)
– “Being born in a duck yard does not matter if you are hatched from a swan’s egg.”

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

. 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: 12 Mar 2019: 84 FR 8807-8809: Extension of Import Restrictions Imposed on Archaeological and Ecclesiastical Ethnological Material From Honduras

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: 14 Mar 2019: 84 FR 9239-9240: 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: 19 Mar 2019: 84 FR 9957-9959: Department of State 2019 Civil Monetary Penalties Inflationary Adjustment. 
  – The only available fully updated copy (latest edition: 19 Mar 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 Mar 2019: 84 FR: 9456-9458: List of Foreign Financial Institutions Subject to Correspondent Account or Payable-Through Account Sanctions (CAPTA List) 
* 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: 2 Apr 2019: Harmonized System Update (HSU) 1905 [contains 792 ABI records and 176 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 the Daily Bugle Top Stories” published 

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


* The Ex/Im Daily Update is a publication of FCC Advisory B.V., compiled by: Editor, James E. Bartlett III; Assistant Editors, Vincent J.A. Goossen and Alexander Witt; and Events & Jobs Editor, Sven Goor. The Ex/Im Daily Update is emailed every business day to approximately 7,000 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.

* 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.

* TO UNSUBSCRIBE: Use the Safe Unsubscribe link below.

Scroll to Top