;

19-0408 Monday “Daily Bugle'”

19-0408 Monday “Daily Bugle”

Monday, 8 April 2019

  1. DHS/CBP Extends Information Collection Activities Concerning Administrative Rulings
  2. Justice/ATF Amends 27 CFR Parts 478, 479, and 555; Removes Expired, Obsolete Regulations
  3. NRC Issues Clarification Concerning Export Reporting Requirements for Nuclear Facilities, Equipment, and Non-Nuclear Materials
  1. Items Scheduled for Publication in Future Federal Register Editions 
  2. Commerce/BIS: (No new postings.)
  3. DoD/DSS Extends PSI Requirements for Industry Data Collection Through NISS
  4. State/DDTC Seeks Attorney Candidates
  5. EU Amends Restrictive Measures Concerning ISIL (Da’esh) and Al-Qaida
  6. EU Extends Iran Sanctions as Response to Human Rights Violations
  1. DutchNews.nl: “Dutch Ministers Divided on China Strategy, May Deadline Set for a Deal”
  2. ST&R Trade Report: “China Tariff Exclusion Reviews Accelerate as Denials Continue to Outpace Approvals”
  3. WorldECR: “Export Controls Might Be Dangerous: Nuclear Group”
  1. K. Wymbold, P. Kiesselbach & A. Crockett: “U.S. Sanctions Enforcement Action Highlights the Importance of Human Rights Due Diligence”
  2. M. Volkov: “Episode 83 – Managing Hotlines and Reporting Systems”
  3. The FAQ of the Day: Retransfer Request and Export Control Reform
  1. Monday List of Ex/Im Job Openings: 144 Openings Posted This Week, Including 20 New Openings 
  1. ECTI Presents “U.S. Export Control (ITAR/EAR/OFAC) Seminar Series” in Singapore on 27-30 May
  2. 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 (5 Apr 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 

EXIMITEMS FROM TODAY’S FEDERAL REGISTER

EXIM_a1
1.
DHS/CBP Extends Information Collection Activities Concerning Administrative Rulings
(Source:
Federal Register, 8 Apr 2019.) [Excerpts.]
84 FR 13948: Agency Information Collection Activities: Administrative Rulings
 
* AGENCY: U.S. Customs and Border Protection (CBP), Department of Homeland Security.
* ACTION: 60-Day notice and request for comments; extension of an existing collection of information.
* SUMMARY: The Department of Homeland Security, U.S. Customs and Border
Protection will be submitting 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 (PRA). The information collection is published in the Federal Register to obtain comments from the public and affected agencies.
* DATES: Comments are encouraged and must be submitted (no later than June 7, 2019) to be assured of consideration.
* ADDRESSES: Written comments and/or suggestions regarding the item(s) contained in this notice must include the OMB Control Number 1651-0085 in the subject line and the agency name. To avoid duplicate submissions, please use only one of the following methods to submit comments:
(1) Email. Submit comments to:
CBP_PRA@cbp.dhs.gov.
(2) Mail. Submit written comments to CBP Paperwork Reduction Act Officer, U.S. Customs and Border Protection, Office of Trade, Regulations and Rulings, Economic Impact Analysis Branch, 90 K Street NE, 10th Floor, Washington, DC 20229-1177.
* FOR FURTHER INFORMATION CONTACT: Requests for additional PRA information should be directed to Seth Renkema, Chief, Economic Impact Analysis Branch, U.S. Customs and Border Protection, Office of Trade, Regulations and Rulings, 90 K Street NE, 10th Floor, Washington, DC 20229-1177, Telephone number 202-325-0056 or via email
CBP_PRA@cbp.dhs.gov. Please note that the contact information provided here is solely for questions regarding this notice. Individuals seeking information about other CBP programs should contact the CBP National Customer Service Center at 877-227-5511, (TTY) 1-800-877-8339, or CBP website at
https://www.cbp.gov/.
* SUPPLEMENTARY INFORMATION: …
  – Title: Administrative Rulings.
  – OMB Number: 1651-0085.
  – Abstract: The collection of information in 19 CFR part 177 is necessary in order to enable Customs and Border Protection (CBP) to respond to requests by importers and other interested persons for the issuance of administrative rulings. These rulings pertain to the interpretation of applicable laws related to prospective and current transactions involving classification, marking, and country of origin. The collection of information in Part 177 of the CBP Regulations is also necessary to enable CBP to make proper decisions regarding the issuance of binding rulings that modify or revoke prior CBP binding rulings. This collection of information is authorized by 19 U.S.C. 66, 1202, (General Note 3(i), Harmonized Tariff Schedule of the United States). The application to obtain an administrative ruling is accessible at:
https://apps.cbp.gov/erulings.
  – Action: CBP proposes to extend the expiration date of this information collection with no increase or decrease in the overall estimated burden hours. However there was a reduction in the Appeals respondent group and an increase in the Administrative Rulings respondent group due to updated agency estimates, in addition there was a decrease in the estimated time per response for the Appeals respondent group. There is no change to the information being collected
  – Type of Review: Extension (without change).
  – Affected Public: Businesses. …
 
  Dated: April 3, 2019.
Seth D. Renkema, Branch Chief, Economic Impact Analysis Branch, U.S. Customs and Border Protection.

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

EXIM_a2
2.
Justice/ATF Amends 27 CFR Parts 478, 479, and 555; Removes Expired, Obsolete Regulations
(Source:
Federal Register, 8 Apr 2019.) [Excerpts.]
84 FR 13798-13800: Removal of Expired Regulations
 
* AGENCY: Bureau of Alcohol, Tobacco, Firearms, and Explosives, Department of Justice.
* ACTION: Final rule.
* SUMMARY: This final rule makes technical amendments to the Bureau of Alcohol, Tobacco, Firearms, and Explosives (ATF) regulations in the Code of Federal Regulations (CFR). These technical changes are being made to remove expired, obsolete, or unnecessary regulations; correct dates, titles, addresses, and telephone numbers; and to reflect changes to nomenclature resulting from the transfer of ATF to the Department of Justice from the Department of the Treasury pursuant to the Homeland Security Act of 2002. The changes are designed to update and provide clarity throughout these regulations.
* DATES:
This rule is effective April 8, 2019.
* FOR FURTHER INFORMATION CONTACT: Shermaine Kenner, Office of Regulatory Affairs, Enforcement Programs and Services, Bureau of Alcohol, Tobacco, Firearms, and Explosives, U.S. Department of Justice, 99 New York Avenue NE, Washington, DC 20226; telephone: (202) 648-7070 (this is not a toll-free number).
* SUPPLEMENTARY INFORMATION: … ATF administers regulations published in 27 CFR part 555, concerning commerce in explosives. ATF identified several technical amendments that are needed to update and to provide clarity to these regulations.
  Rather than make substantive changes to the regulations, these amendments focus on improving the clarity and accuracy of the regulations. Many of the technical changes reflect the removal of expired or obsolete regulations; removal of regulations that are no longer necessary; and the correction of dates, titles, addresses, and telephone numbers. Additionally, technical changes to Sec. 555.11 reflect a change in nomenclature resulting from the transfer of ATF to the Department of Justice from the Department of the Treasury pursuant to the Homeland Security Act of 2002.
  Section 555.11 is being amended to remove paragraph (a) and revise paragraph (b) in the definitions of “ATF”, “ATF Officer”, “Bureau”, and “Director” as the information in the regulations is obsolete, to revise the definition of “Director, Industry Operations” for accuracy, and to replace “Bureau of Alcohol, Tobacco and Firearms” with “Bureau of Alcohol, Tobacco, Firearms, and Explosives, Department of Justice” in the definition of “Region” as the current definition references the name of the agency under the Department of the Treasury, prior to the Homeland Security Act of 2002.
  Section 555.27 is being removed and reserved as the requirement in the statute that this regulation implemented is expired and obsolete.
  Section 555.30 is being amended to reflect the correct nationwide toll-free telephone number, and the reference to Form 4712 is being removed as this information is no longer necessary and is obsolete.
  Sections 555.33, 555.142, and 555.165 are being amended to remove the effective dates, which are no longer necessary.
  Sections 555.41, 555.49, 555.51, 555.103, and 555.125 are being amended to remove and reserve paragraph (a) in each of these sections as the information in those paragraphs is obsolete.
  Section 555.45 is being amended to remove and reserve paragraphs (a) and (b) as the information in those paragraphs is obsolete.
  Section 555.57 is being amended to remove “For all licenses or permits issued on and after May 24, 2003” as this delineation is no longer necessary.
  Section 555.102 is being amended to remove paragraph (b)(1) and revise paragraph (b)(2) as the information in those paragraphs is obsolete.
  Section 555.105 is being amended to remove the reference to nonlicensees and nonpermittees in the heading of the section, and to remove and reserve paragraph (a) as the information in the regulation is obsolete.
  Section 555.126 is being amended to revise the heading of the section, and to remove and reserve paragraph (a) as the information in the regulation is obsolete.
  Section 555.201 is being amended to remove and reserve paragraph (e) as the application of this paragraph is obsolete.
  Section 555.202 is being amended to remove “See also Sec. 555.201(e).” as the referenced sentence is obsolete.
  Section 555.218 is being amended to remove the date “July, 1991” from the table title and replace it with “June 1991”, the correct date.
  Section 555.219 is being amended to add the title of the table, as the title was incorrectly added to the table in 555.220 when published in the Federal Register.
  Section 555.220 is being amended to remove the title above the table and remove the address for the Fertilizer Institute, as this information is incorrect.
  Section 555.224 is being amended to remove “(30 days from the date of publication of the final rule in the Federal Register)” and to add the effective date in the third footnote. …
 
  Dated: April 2, 2019.
William P. Barr, Attorney General.

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

EXIM_a33.
NRC Issues Clarification Concerning Export Reporting Requirements for Nuclear Facilities, Equipment, and Non-Nuclear Materials
(Source:
Federal Register, 2 Apr 2019.) [Excerpts.]
 
84 FR 12483-12484: Clarification of Export Reporting Requirements for Nuclear Facilities, Equipment, and Non-Nuclear Materials
 
* AGENCY: Nuclear Regulatory Commission.
* ACTION: Regulatory issue summary; issuance.
* SUMMARY: The U.S. Nuclear Regulatory Commission (NRC) is issuing Regulatory Issue Summary (RIS) 2019-01, “Clarification of Export Reporting Requirements for Nuclear Facilities, Equipment, and Non-Nuclear Materials.” This RIS is intended to clarify the reporting requirements for certain exports of nuclear facilities, equipment, and non-nuclear materials. The NRC’s regulations state, in part, that licensees exporting nuclear facilities, equipment, and certain non-nuclear materials under a general or specific license during the previous quarter must submit reports by January 15, April 15, July 15, and October 15 of each year on DOC/NRC Forms AP-M or AP 13, and associated forms. The RIS includes information relating to this reporting requirement and clarifies that the quarterly reporting requirement is in addition to, and not obviated by, the separate NRC annual reporting requirement in its regulations.
* DATES: The RIS is available as of April 2, 2019.
* ADDRESSES: Please refer to Docket ID NRC-2018-0113 when contacting the NRC about the availability of information regarding this document. You may obtain publicly-available information related to this document using any of the following methods:
   Federal Rulemaking Website: Go to
http://www.regulations.gov and search for Docket ID NRC-2018-0113. Address questions about Docket IDs in
Regulations.gov to Jennifer Borges; telephone: 301-287-9127; email:
Jennifer.Borges@nrc.gov. For technical questions, contact the individual listed in the FOR FURTHER INFORMATION CONTACT section of this document.
   NRC’s Agencywide Documents Access and Management System (ADAMS): You may obtain publicly-available documents online in the ADAMS Public Documents collection
here. To begin the search, select “Begin Web-based ADAMS Search.” For problems with ADAMS, please contact the NRC’s Public Document Room (PDR) reference staff at 1-800-397-4209, 301-415-4737, or by email to
pdr.resource@nrc.gov. The ADAMS accession number for each document referenced (if it is available in ADAMS) is provided the first time that it is mentioned in this document. This RIS is available under ADAMS Accession No. ML18269A254.
   NRC’s PDR: You may examine and purchase copies of public documents at the NRC’s PDR, Room O1-F21, One White Flint North, 11555 Rockville Pike, Rockville, Maryland 20852.
   This RIS is also available on the NRC’s public website
here (select “2018” and then select “2019-01”).
* FOR FURTHER INFORMATION CONTACT: Andrea Jones, Office of International Programs, U.S. Nuclear Regulatory Commission, Washington DC 20555-0001; telephone: 301-287-9072; email:
Andrea.Jones2@nrc.gov.
* SUPPLEMENTARY INFORMATION: The NRC published a notice of opportunity for public comment on this RIS in the Federal Register (83 FR 26611) on June 8, 2018. The agency received comments from one commenter. The staff considered all comments, which resulted in changes to the RIS. The evaluation of these comments and the resulting changes to the RIS are discussed in a publicly available memorandum in ADAMS under Accession No. ML18269A255. As noted in 83 FR 20858 (May 8, 2018), this document is being published in the Rules section of the Federal Register to comply with publication requirements under Title 1 of the Code of Federal Regulations, Chapter I.
 
   Dated at Rockville, Maryland, this 28th day of March 2019.
   For the Nuclear Regulatory Commission.
Tara Inverso, Chief, ROP Support and Generic Communications Branch, Division of Inspection and Regional Support, Office of Nuclear Reactor Regulation.

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

OGSOTHER GOVERNMENT SOURCES

OGS_a14. Items Scheduled for Publication in Future Federal Register Editions
(Source: Federal Register)

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

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

OGS_a36. DoD/DSS Extends PSI Requirements for Industry Data Collection Through NISS

(Source:
DoD/DSS, 5 Apr 2019.)
 
The Defense Security Service (DSS) is responsible for projecting Personnel Security Investigations (PSI) requirements each year. The data collection for PSI projection requirements is open and has been extended until April 19, 2019, through the National Industrial Security System (NISS) Submission Site. Annual projections acquired from Industry through this collection are the key component in DoD program planning and budgeting for NISP security clearances.
 
Our Industry partners are highly encouraged to register for their NISS accounts in order to participate in the collection. Registration instructions are found on the
NISS website under the Registration section.
 
We look forward to your participation. If you have any questions, please contact:
dss.ncr.dss.mbx.psiprogram@mail.mil. If you have any problems with the system usage, please contact the Knowledge Center at: 888-282-7682, options 1 and then 2.

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

OGS_a47. State/DDTC Seeks Attorney Candidates

(Source:
State/DDTC, 25 Mar 2019.) [Reposted at DDTC’s request.]
 
The Office of the Legal Adviser of the Department of State seeks attorneys with at least 3 years of relevant experience to provide counsel to the Bureau of Political-Military Affairs Directorate of Defense Trade Controls (DDTC), handling issues related to export controls and administrative law.  This advertisement is for two non-rotational specialist positions within the Office of the Legal Adviser.  Salary: GS Level 12-15, commensurate with experience. Applicant must be a U.S. citizen, and have a J.D. degree.
 
Applicants should have significant legal experience in the area of export control law, including with the Arms Export Control Act and International Traffic in Arms Regulations, and/or significant legal experience in administrative law, including the promulgation and civil and/or criminal enforcement of federal regulations.  Applicants must have an outstanding record of academic and professional achievement.  They must be able to handle a wide variety of assignments with short, time-critical deadlines, as well as design and execute substantial analytical projects.  They must also possess exceptional analytical, writing, organizational, and interpersonal communications skills, suitable for successfully working with policy makers and senior-level officials as well as licensing officers and compliance personnel.
 
Preferred:
  – At least 3 years of relevant experience.  Ideally 5+.
  – Experience and ability to work in a regulatory environment is key (e.g. knowledge of administrative law, self-starter, limited support).
  – Experience with enforcement/criminal law.
 
Ability to obtain security clearance is required. Applicants should send a current detailed resume, law school transcript, and reference information by email to the attention of Barbara Barrett Spencer at 
legaljobs@state.gov. Applications must be received by Friday, April 19, 2019.

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

OGS_a58. EU Amends Restrictive Measures Concerning ISIL (Da’esh) and Al-Qaida

 
Regulations
*
Commission Implementing Regulation (EU) 2019/555 of 5 April 2019 amending for the 298
th time Council Regulation (EC) No 881/2002 imposing certain specific restrictive measures directed against certain persons and entities associated with the ISIL (Da’esh) and Al-Qaida organizations.

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

OGS_a69. EU Extends Iran Sanctions as Response to Human Rights Violations

 
The Council today extended until 13 April 2020 its
restrictive measures responding to
serious human rights violations in Iran. These measures consist of:
  – a travel ban and an asset freeze against 82 people and one entity.
  – a ban on exports to Iran of equipment which might be used for internal repression and of equipment for monitoring telecommunications.
 
These measures were first put in place in 2011 and have been extended ever since on an annual basis.

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

NWSNEWS

NWS_a110
. DutchNews.nl: “Dutch Ministers Divided on China Strategy, May Deadline Set for a Deal”

(Source:
DutchNews.nl, 5 Apr 2019.)
 
The Dutch government is struggling to draw up formal strategy to deal with China and its economic interests, broadcaster
NOS said on Friday.
 
The strategy should be completed by May, but ministers have differing opinions about what that strategy should be and some have been described as naive by civil servants involved in the talks,
NOS said.
 
For example, the justice ministry and the AIVD security service say the Netherlands should be as independent as possible from China, because of the risk of industrial espionage.

But the economic affairs ministry,
NOS says, is only interested in the economic interests and has been described as “naïve” by officials. The foreign ministry, by contrast, is concerned that a tough statement will have an impact internationally,
NOS said.

 
One thorny issue on the table is that of the
5G telecoms network. Last month,
RTLZ reported that KPN was poised to hook up with Chinese telecoms giant Huawei to build the network, stealing a march on the government’s plans to take an official position on Chinese involvement. Neither company has commented on the claim.
 
Earlier this week, the
AIVD security service warned about the risks of using Chinese equipment for crucial infrastructure and said digital attacks and espionage by countries such as China, Iran and Russia pose a real threat.
 
In the U.S. Huawei has been accused of espionage on behalf of the Chinese authorities and the U.S. ambassador to the Netherlands, Pete Hoekstra, told
Trouw last month that the company should be kept out of the Dutch market. “This is very, very important to us,” Hoekstra is quoted as saying.

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

NWS_a2
11
. ST&R Trade Report: “China Tariff Exclusion Reviews Accelerate as Denials Continue to Outpace Approvals

 
The Trump administration has denied hundreds more requests for exclusions from the additional tariffs it has imposed on imports from China but has approved additional requests as well, according to information made available by the Office of the U.S. Trade Representative. Most such requests are still under consideration but USTR is making progress in conducting its reviews.
 
Importers should be aware that approved exclusions are available for any product that meets the specific product description, regardless of whether the importer filed an exclusion request. In addition, the scope of each exclusion is governed by the scope of the 10-digit subheading or the specific product description to which it applies, not by the product descriptions set out in any particular request. Sandler, Travis & Rosenberg can help companies understand whether their products are among those that have been excluded from these tariffs.
 
Background. Following a Section 301 determination that China’s acts, policies, and practices related to technology transfer, intellectual property, and innovation are unreasonable and discriminatory, the Trump administration has levied higher tariffs on Chinese goods in stages. The first phase imposed a 25 percent additional tariff on $34 billion worth of imports as of July 6, and exclusion requests were due by Oct. 9. The administration extended that tariff to another $16 billion worth of goods as of Aug. 23 and accepted exclusion requests through Dec. 18.
 
A ten percent additional tariff was imposed on so-called List 3 goods (valued at about $200 billion) as of Sept. 24. A scheduled March 2 increase in this tariff to 25 percent has been indefinitely postponed. Administration officials have said they will not provide any exclusion request process for these goods unless that increase occurs, although Congress has directed USTR to create such a process. The White House has also warned of an as-yet-unspecified tariff hike on an additional $267 billion worth of Chinese goods if Beijing “takes retaliatory action against our farmers or other industries.”
 
(
Click here for more detailed information on affected products and other aspects of the Section 301 process.)
 
Update on Exclusions. Information from USTR indicates that as of March 29 nearly 11,000 exclusion requests had been submitted for List 1 goods. USTR has denied 5,311 of these requests (up from 4,535 a month earlier) and granted 1,091 (up from 984;
click here for a full list of approved exclusions).
 
The remainder of the List 1 requests are listed as being at one of four stages. Of these, 1,133 are undergoing an initial review of whether the request should be granted based on specified criteria (down from 2,075), and 3,299 are being reviewed with U.S. Customs and Border Protection to determine whether the exclusion would be administrable (up from 3,226). None are currently in the first stage, in which comments are accepted, or the final stage, in which the exclusion has been granted and is being prepared for publication in the 
Federal Register.
 
USTR has also received 2,931 exclusion requests for List 2 goods. Of these, 1,790 are undergoing substantive review (down from 2,921) and 1,141 (up from zero) are being reviewed for administrability. None are currently listed as having been approved or denied or as being in either the first or final stage.

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

NWS_a3
12. WorldECR: “Export Controls Might Be Dangerous: Nuclear Group” 

(Source:
WorldECR, 4 Apr 2019.)
 
WANO: “Restrictions resulting from export controls can hamper … safety.”
 
Individual countries’ interpretations of multilateral export controls may hinder the ability of nuclear operators to “conduct activities focused on the safe operation of existing commercial nuclear power plants.” So says the World Association of Nuclear Operators (‘WANO’) in a recent press release.
 
WANO says that its policy is “to avoid exchanging information that is subject to export controls. WANO is primarily focused on assessing management processes and behaviors relating to safety – and not technology transfer. However in recent years, there have been increasing instances where some WANO employees – depending on their own nation’s policies – are unable to participate in WANO peer reviews and member support missions at other member plants. WANO’s peer review teams requires a mix of nationalities, experience and expertise to deliver the best possible safety oversight of and support to individual nuclear power plants.”
 
According to Peter Prozesky, Chief Executive Officer at WANO: “WANO is not a commercial entity, it has no political affiliation and has worked effectively with nuclear operators to improve safety and reliability of power plants for almost 30 years. Restrictions resulting from export controls can hamper WANO’s ability to conduct its important safety mission. We are keen to continue to engage and work with national governments to develop an appropriate, risk based approach to export controls laws.”
 
For more on the work of WANO, see
www.wano.info.

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

COMMCOMMENTARY

COM_a1
13. K. Wymbold, P. Kiesselbach & A. Crockett: “U.S. Sanctions Enforcement Action Highlights the Importance of Human Rights Due Diligence”

(Source:
Herbert Smith Freehills
, 6 Mar 2019.)


 
* Authors: Kyle Wombolt, Esq.,
kyle.wombolt@hsf.com
; Pamela 


Kiesselbach, Esq.,
pamela.kiesselbach@hsf.com
; and Anthony


Crockett, Esq.,
Antony.Crockett@hsf.com
. All of Herbert Smith Freehills, Hong Kong.
 
A recent enforcement action by the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) has highlighted the importance of human rights due diligence as part of an effective sanctions compliance program.
 
The U.S. action reflects a global trend of increased regulatory focus on supply chains in relation to a range of business conduct issues, including corruption, modern slavery, and other human rights violations.
 
The company, e.l.f Cosmetics Inc (ELF), faced a maximum penalty in excess of US$40 million but agreed to pay US$996,080 to settle its potential civil liability for 156 apparent violations of US sanctions on North Korea after their compliance program failed to detect that approximately 80% of the false eyelash kits it imported from two suppliers in China contained materials sourced from North Korea.
 
This action is a reminder to businesses to implement effective supply chain due diligence and audits to verify the country of origin of goods and services. Companies that do not conduct thorough supply chain due diligence when sourcing products and services, particularly from higher risk regions, are at an increased risk of sanctions violations.
 
An OFAC/Homeland Security Advisory issued around six months prior to the ELF enforcement action advises companies to implement human rights due diligence processes as described in the 2011 United Nations Guiding Principles on Business and Human Rights (UNGP). The Advisory and OFACs observations regarding the inadequacies of ELF’s due diligence processes show that while international standards such as the UNGP are, in and of themselves, not legally binding, failure to implement those standards may be taken into account by prosecutors and other regulators.

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

COM_a2
14
. M. Volkov: “Episode 83 – Managing Hotlines and Reporting Systems”

(Source:
Volkov Law Group Blog, 31 Mar 2019. Reprinted by permission.)
 
* Author: Michael Volkov, Esq., Volkov Law Group,
mvolkov@volkovlaw.com, 240-505-1992.
 
Corporations have to invest in their Speak Up Culture.  A critical component is a company’s hotline and incident reporting system.  An effective hotline reporting channel(s) depends on responsive and timely investigations of potential wrongdoing.
 
In
this Episode, Michael Volkov discusses best practices for hotline and reporting systems.

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

COM_a3
15. The FAQ of the Day: Retransfer Request and Export Control Reform

(Source: 
State/DDTC, 27 Apr 2018
 
Q: Our foreign company plans to submit a retransfer request to provide the prime contractor an operations and maintenance manual for a USML-controlled aircraft. However, in addition to containing technical data controlled under the USML, the manual also features technology for items that have moved to the jurisdiction of the Department of Commerce. Will DDTC authorize the transfer of the entire manual, pursuant to an ITAR §123.9 retransfer request?
 
A: In general, DDTC will authorize the transfer of the entire manual. However, the form of the requirement will differ depending upon how your foreign company received the data initially. If it was received via DSP-5 or an expired agreement, ITAR §123.9 is the appropriate vehicle. However, if it was received via a Technical Assistance Agreement (TAA) and the TAA is still in effect, then a retransfer request pursuant to ITAR §123.9 may not be used. Instead, the TAA scope must be increased via an amendment.

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

MSEX/IM MOVERS & SHAKERS

MS_a116. Monday List of Ex/Im Job Openings: 144 Openings Posted This Week, Including 20 New Openings 

(Source: Events & Jobs Editor) 
 

Published every Monday or first business day of the week. Please, send job openings in the following format to 
 
jobs@fullcirclecompliance.eu
.

 
* COMPANY; LOCATION; POSITION TITLE (WEBLINK); CONTACT INFORMATION; REQUISITION ID
 

#
” New or amended listing this week

 

#
Abbott; Abbott Park, IL; Customs and Trade Technician

* Adient; Plymouth, MI;
Director Americas Regional Compliance
; Requisition ID: R-03478
*
 
AeroVironment; Simi Valley, CA; Trade Compliance Specialist II; Requisition ID: 333;

*
Agility; Houston, TX; Ocean Export Team Leader;

#
Airbus; Getafe, Spain; Export Control Officer; Requisition ID: 10447448 XX EN EXT 1
#
Airbus; Munich, Germany;
Internship within Legal & Compliance: Data Protection Mapping
; Requisition ID: 10436096 NK EN EXT 4
#
Ajilon; Bedford Park, IL; Import / Export Logistics Coordinator; Requisition ID: US_EN_7_849116_2650289


*
Allnex; Drogenbos, Belgium; Head of Trade Compliance EMEA;

*
 
AM General; Auburn Hills, MI; 
International Compliance Analyst
*
 
Amazon Web Services; Seattle, WA; Trade Compliance Manager, Export Controls & Classification; Requisition ID: 787194;

* Analog Devices, Inc.; Singapore; 
Asia Trade Compliance Manager
; Requisition ID: 12456
* Ansys; Pittsburgh, PA;
Paralegal – Compliance and Trade Compliance
; Requisition ID: 7535

* Autodesk; San
Rafael, CA (SF Bay Area) or Portland, OR; 
Export Compliance Officer
; Requisition ID: 19WD31812
* Axis Communications; Lund, Sweden;
Export Control Advisor – Operations
; Requisition ID: 2629


*
 
BAE Systems; Nashua, NH; 
Procurement Compliance
; Requisition ID: 44996BR
*
 
BAE Systems; Sterling Heights, MI; 
Senior Procurement Compliance Analyst
; Requisition ID: 43034BR


*
 
Beiersdorf; Hamburg, Germany; International Trade Expert;

*
Bell Flight; Fort Worth, TX; Trade Compliance Specialist; Requisition ID: 273691

* Bloomberg; London, United Kingdom; 
Trade Compliance Specialist
; Requisition ID: 71755

#
Boeing; Everett, WA; Export Compliance Specialist-Senior Level; Requisition ID: 1900055642

* Bosch USA; Owatonna, MN; Import/Export Compliance Analyst

* Bristol-Myers Squibb; New Brunswick, NJ; 
Director Global Customs & Trade
; Requisition ID: R1509390_EN

* Carnegie Mellon University; Pittsburgh, PA; Export Compliance Manager;

* Danaher – Beckman Coulter Diagnostics; Brea, CA;
Global Export Compliance Manager
; Requisition ID: BEC014282

#
Danaher – Leica Microsystems; Wetzlar, Germany; Trade Compliance Manager – EMEA (m/f/d); Requisition ID: LEI004901

* Danaher – VIQUA; Kitchener, Canada; 
Trade Compliance and Logistics Specialist
; Requisition ID: VIQ000105

#
Dell; Bukit Mertajam, Malaysia; Analyst, Import/Export; Requisition ID: R60622

*
DHL Supply Chain; United Kingdom; Compliance Analyst; Requisition ID: req74130


EDCO; Eindhoven, the Netherlands; Customs & Trade Compliance Coordinator

* Elbit Systems of America; Merrimack, NH; 
Licenses & Agreements Officer
; Requisition ID 2019-6948
* Element; Edinburgh, United Kingdom; 
Group Compliance and Communications Assistant
; Requisition ID: 2019-3094

* Engenium; Orlando, FL;
Import/Export Compliance Specialist 

*
 
Erickson Inc.; Portland or Central Point, OR; 
Import Specialist

Susan Colletto
; Requisition ID 927130;

* Esri; Redlands, CA; Export Compliance Specialist;

*
 Expeditors; Krefeld, Germany; 
Clerk Import / Export
;
*
 Expeditors; Bedfont, United Kingdom; 
Customs Brokerage Clerk
;

* Expeditors; Sunnyvale, CA, USA; Customs Compliance Specialist;

*
Five Below; Philadelphia, PA; Custom Trade & Compliance Analyst;

#
Flexport; Amsterdam, the Netherlands; Regional Compliance Manager;

# FLIR; Arlington, VA, Elkridge, MD, and Nashua, NH;
Senior Manager, Global Export Licensing (Commercial); Requisition ID: REQ12110

#
FLIR; several locations, Canada; Global Trade Compliance (GTC) Country Manager; Requisition ID: REQ12085

* Fortive – Tektronix; Beaverton, OR; Chief Compliance Counsel;

* Fourstar Group USA; Milford, MA; 
Import Manager/Customs Compliance/Classification Specialist
;


GCP Applied Technologies; Cambridge, MA; 
Trade Compliance Manager

* General Atomics; San Diego, CA; 
Compliance Specialist
; Requisition ID: 22119BR

* General Atomics; San Diego, CA; 
Trade Compliance Classification Leader
; Requisition ID: 22671BR

* General Atomics; San Diego, CA; 
Export Controls Leader – Technology
; Requisition ID: 22644BR

* General Atomics; San Diego, CA; Import/Export Compliance Specialist; Requisition ID: 23069BR

*
GKN Aerospace; Tallassee, AL; International Trade Compliance Manager;

* Gulfstream Aerospace; Savannah, GA;
Trade Compliance Project Manager Sr
; Requisition ID: 142611  
*
Haemonetics; Braintree, MA; Global Trade Compliance Manager; Requisition ID: R1516 

* Harley-Davidson; Milwaukee, WI; Logistics Lead – Trade Compliance; Requisition ID: 826  

*
Harris Corporation; Van Nuys, CA; Trade Compliance Senior Specialist; Richard Wellbrock; Requisition ID: ES20192103-30606

*
Harry Winston; New York, NY; Analyst, Logistics and Trade Compliance;

*
HBM; Marlboro, MA; Export Compliance Manager;

* Henderson Group Unlimited, Inc; State Dept, DDTC; Washington, DC; 
Defense Trade Control Compliance Analyst
;
* Henderson Group Unlimited, Inc; State Dept, DDTC; Washington, DC; 
Commodities Jurisdiction Analyst
;

* Henkel; Rocky Hill, CT;
Global Trade Manager
; Requisition ID: 190001EB

* Honeywell; multiple locations, United States; Export Compliance Manager (North America); Requisition ID: HRD45798;
* Honeywell; Prague, Czech Republic; Export Compliance Officer; Requisition ID: req179383;

* Honeywell International Inc.; Sunnyvale, CA or Lincolnshire, IL; Sr. Import/Export Analyst; HRD32371
 

* Illumina; Great Abington, United Kingdom; 
Trade Compliance Manager
; Requisition ID: 16204-JOB 
* Illumina; San Diego, CA; 
Associate Director, Global Trade Compliance
; Requisition ID: 16094-JOB
* Illumina; Woodlands, Singapore; Manager, Trade Compliance; Requisition ID: 16361-JOB

*
 Infineon; El Segundo, CA; 
Manager, Export Control
; Requisition ID: 33841

* Infineon Technologies; Tijuana, Mexico; Import-Export Manager;

*
 
IPG Photonics; Oxford, MA; 
Global Director Trade Compliance
;
*
 IPG Photonics; Oxford, MA;
 
Global Director Trade Compliance 

* Johnson Controls; Milwaukee, WI; Director, Global Trade Compliance; Requisition ID: WD30055791295;

*
 
Keeco Home; Hayward, CA; Director Customs and Compliance

* Kirkland’s; Brentwood, TN; 
Customs Compliance Program Manager
; Requisition ID: 2019-8158

*
Koch Chem Tech; Tulsa, OK; Import/Export Compliance Specialist; Requisition ID: 052017

* KPMG; Chicago, IL or New York, NY or Washington D.C.;
Export and Sanctions Compliance Manager
; Requisition ID: 41146

* Kubota; Grapevine, TX; 
Manager, Import & Export Compliance
; Requisition ID: 228

*
 
Leidos; Columbia, MD; International Trade Manager / Export Compliance; Req. ID: R-00005745;

* Leonardo DRS; Melbourne, FL; 
Senior Supply Chain Analyst – Small Business Compliance
; Requisition ID: 91669

* Lockheed Martin; Arlington, VA; International Licensing Analyst; Requisition ID: 468160BR;


* Lockheed Martin; Orlando, FL; 
International Trade Compliance Specialist / International Licensing Analyst
; Requisition ID: 467458BR

#
Lockheed Martin Aeronautics; Palmdale, CA; Export Compliance Site Lead; Requisition ID: 477630BR

* Lockheed Martin Missile and Fire Controls; Orlando, FL;
International Trade Compliance Staff
; Contact: Marjorie Alquist, +1 407-356-9061; Requisition ID: 473481BR
* Lockheed Martin Missile and Fire Controls; Orlando, FL or Dallas, TX;
International Trade Compliance Engineer Staff
; Contact: Brian Taylor, +1 407-356-3833; Requisition ID: 462509BR

* Lutron Electronics Co; Lehigh Valley, PA; Trade Compliance Coordinator; Requisition ID: 4025;

* Masonite; Charlotte, NC;
Customs Compliance Specialist
; Requisition ID: 2019-16989

* Meggitt; Miami, FL; 
Trade Compliance Coordinator
; Requisition ID: 37514
* Meggitt; Rockmart, GA; 
Trade Compliance Coordinator
; Requisition ID: 37846

#
Mercury Systems; multiple locations; Trade Compliance Specialist; Requisition ID: 19-203

*
 
Mohawk Global Trade Advisors; Chicago, IL; 
Vice President and General Manager of Consulting Division
; Contact: CSardella@mohawkglobal.com;  
 
 

*
 Newell Brands; Norwalk, CT; 
Manager of Trade Operations

* Northrop Grumman; Herndon, VA;
Principal International Trade Compliance Analyst Level 3 or 4
; Requisition ID: 19007160  

* Northrop Grumman; Rancho Bernardo, CA; Sr. Manager, International Trade Compliance; Contact: Fred Czarske at 310-332-7606, fred.czarske@ngc.com; Requisition ID: 19008010

* NXP Semiconductors; Eindhoven, The Netherlands; (Senior) Manager Customs Compliance; Requisition ID: R-10013630;

* Parexel; Kiev, Ukraine; Trade Compliance Specialist; Requisition ID: 51579BR

* PCC Forged Products – Wyman-Gordon; Houston, TX;
Division Trade Compliance Manager
; Requisition ID: 20961
* PerkinElmer; Shelton, CT or Boston, MA or Hopkinton, MA or Waltham, MA;
Senior Director Global Transportation and Logistics
; Requisition ID: JR-004907

* Philips; Best, the Netherlands;
Head of Trade Compliance
; Requisition ID: 308818

* Pinpoint Pharma; Lincolnshire,IL; Export Compliance Specialist; Requisition ID: 351;

* PwC; Houston, TX; Customs and International Trade Director; Requisition ID: 38150WD;

#
Raytheon; El Segundo, CA; Global Trade Authorization Owner; Requisition ID: 137660BR
#
Raytheon; El Segundo & Goleta, CA; Global Trade Licensing Analyst I; Requisition ID: 136372BR
#
Raytheon; El Segundo, CA; Global Trade Licensing Analyst II; Requisition ID: 136372BR

* Raytheon; El Segundo, CA; Import Ctl&Compliance Advisor; Requisition ID:136269BR

#
Raytheon; El Segundo, CA/McKinney, TX/Rosslyn, VA; Senior Analyst Global Trade Management; Requisition ID: 136411BR
#
Raytheon; El Segundo, CA/McKinney, TX; Senior Manager, Global Trade Strategy; Requisition ID: 135692BR
#
Raytheon; McKinney, TX: Senior Analyst Global Trade Licensing; Requisition ID: 136939BR

* Raytheon; Tuscon, AZ;
Manager Export-Import Control
; Requisition ID: 134614BR


* Raytheon; Tuscon, AZ;
Senior Export Licensing and Compliance Specialist
; Requisition ID: 135002BR;

* Richemont; Fort Worth, TX; Import/Export Manager; Requisition ID: 8837;

*
 
Rohde Schwarz; Munich, Germany; 
Spezialist Exportkontrolle (m/w) 

* Rolls-Royce; Derby, United Kingdom; Export Control Manager; Requisition ID: JR6042437

*
 SABIC; Houston TX; 
Senior Analyst, Trade Compliance
;
Danielle.Cannata@sabic.com
; Requisition ID: 8411BR

* Shell; Krakow, Poland; Trade Compliance Manager; Requisition ID: 100384BR;
* Siemens; München, Germany; Director (m/f) Compliance Audit – Export Controls and Customs (ECC); Requisition ID: 104465 

* Sierra Nevada Corporation; Arlington, VA; International Trade Compliance Analyst I; Requisition ID: R0007830

* Sierra Nevada Corporation; Arlington, VA;
International Trade Compliance Analyst II
; Requisition ID: R0007508
* Signify; Eindhoven or Amsterdam, the Netherlands;  
Legal Export Control Officer
; Requisition ID: 289784

* Solenis; Wilmington, DE; Global Trade Compliance Specialist II; Requisition ID: R0002807

* StanleyBlack&Decker; Southington, CT; 
Trade Compliance Specialist/Analyst
; Requisition ID: 58390BR


TE Connectivity; El Cajon, CA or Middletown, PA; Licensing Specialisttbaker@te.com; Requisition 40514 

* Teledyne Semiconductors; Saint-Egrève/Grenoble, France; Trade Compliance Manager; Requisition ID: 2019-8459;

* Teledyne Technologies; Mountain View, CA;
Trade Compliance Import Administrator
;
Janice Whitaker; Requisition ID: 2019-9078;  

* Textron Aviation; Wichita, KS; 
Trade Compliance Analyst
; Requisition ID: 269127

* Thales; Stuttgart, Germany;
Trade Compliance Spezialist (M/W/D)
; Requisition ID: R0054290

* ThermoFisher Scientific; Monza, Italy; Trade Compliance Specialist – Pharma; Requisition ID: 88807BR

* ThermoFisher Scientific; Loughborough, United Kingdom;
Global Trade Compliance Manager
; Requisition ID: 90337BR

* Trek Bicycle; Waterloo, WI;  
Trade Compliance Manager  

* U.S. Department of State; Washington D.C.; Compliance Specialist; Requisition ID: PM-2019-0011
* U.S. Department of State; Washington D.C.; Compliance Specialist; Requisition ID: PM-2019-0012
* U.S. Department of State/Directorate of Defense Trade Controls; Washington D.C.;  Attorney [Multiple positions]; legaljobs@state.gov.  

* U.S. Department of the Army – U.S. Army Security Assistance Command; Redstone Arsenal, AL; Security Assistance Policy Specialist; Requisition ID: 60590  
* United Technologies – Collins Aerospace; Danbury, CT;
Fall CO-OP, International Trade Compliance
; Requisition ID: 01295830

* United Technologies – Pratt & Whitney; East Hartford, CT; 
ITC Licensing Specialist
; Requisition ID: 01289652

*
 
University of California; San Francisco, CA; 
Export Control Officer
; Requisition ID: 51010;

* UPS; Münchenstein, Switzerland; Customs & Trade Compliance Coordinator; Requisition ID: 052228

* Velocity Electronics; Austin, TX; 
Director of Global Trade Compliance 
* Veridos GmbH; München, Germany; 
Ausfuhrbeauftragter (Export Control Officer m/w/d
; Requisition ID: 1677

#
Vigilant GTS; Remote Position, U.S.; Global Trade Compliance Account Manager;

* VT iDirect; Herndon, VA;
 
Manager, Global Logistics
; Requisition ID: 2018R-3120-1;
 
psingh@idirect.net 
* Walt Disney; Kissimmee, FL; Export Compliance Analyst; Requisition ID: 634260BR

#
Walt Disney; Kissimmee, FL; Trade Compliance Analyst (Project Hire); Requisition ID: 654599BR

* Wealth Ocean; Newport Beach, CA; Marketing & International Trade Specialist;

* Xilinx; San Jose, CA;
 
Trade Compliance Specialist
; Requisition ID: 155901

* Xpand Group: Hong Kong, China; 
Compliance Analyst
; Requisition ID: G-REQ-00169936

* YETI Coolers; Austin, TX; Inbound Logistics and Trade Compliance Manager  


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


TEEX/IM TRAINING EVENTS & CONFERENCES

TE_a117. ECTI Presents “U.S. Export Control (ITAR/EAR/OFAC) Seminar Series” in Singapore on 27-30 May

(Source: Jill Kincaid, 
jill@learnexportcompliance.com
.
)
 
* What: United States Export Control (ITAR/EAR/OFAC) Seminar Series in Singapore (for Asia-Pacific and other non-U.S. Companies)
* When: ITAR Seminar: May 27-28, 2019; EAR/OFAC Seminar: May 29-30, 2019
* Where: Singapore, Novatel Clarke Quay; 177A River Valley Road, Singapore
* Sponsor: Export Compliance Training Institute (ECTI)
* ECTI Speaker Panel: John Black, Scott Gearity, and Scott Anderson.
* Register:
 
here
, or contact Jessica Lemon, 540-433-3977,
 
* * * * * * * * * * * * * * * * * * * *

TE_a218. FCC Presents “An Introduction to EU / Dutch Dual-Use and Military Export Controls”, 7 May in Bruchem, the Netherlands 

 
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” (in Dutch)
* 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 (Senior Associate). 
* Information & Registration: click
here or contact us at 
events@fullcirclecompliance.eu or 31 (0)23 – 844 – 9046.  

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

ENEDITOR’S NOTES


William Wordsworth (7 Apr 1770 – 23 Apr 1850; was a major English Romantic poet who, with Samuel Taylor Coleridge, helped to launch the Romantic Age in English literature with their joint publication, 
Lyrical Ballads (1798).
  – 
“In modern business it is not the crook who is to be feared most, it is the honest man who doesn’t know what he is doing.”
 
Monday is pun day:
* Two birds are sitting on a perch and one says “Do you smell fish?”
* Did you hear about the cheese factory that exploded in France?  Des brie was everywhere!
* Do you know sign language? You should learn it, it’s pretty handy.

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

EN_a320
. 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: 5 Apr 2019:
84 FR 13499-13513: Civil Monetary Penalty Adjustments for Inflation
 

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

 

DOD NATIONAL INDUSTRIAL SECURITY PROGRAM OPERATING MANUAL (NISPOM): DoD 5220.22-M. Implemented by Dep’t of Defense.
  – Last Amendment: 18 May 2016: Change 2: Implement an insider threat program; reporting requirements for Cleared Defense Contractors; alignment with Federal standards for classified information systems; incorporated and cancelled Supp. 1 to the NISPOM (Summary here.)
 
 
DOE ASSISTANCE TO FOREIGN ATOMIC ENERGY ACTIVITIES: 10 CFR Part 810; Implemented by Dep’t of Energy, National Nuclear Security Administration, under Atomic Energy Act of 1954.
  – Last Amendment: 23 Feb 2015: 80 FR 9359, comprehensive updating of regulations, updates the activities and technologies subject to specific authorization and DOE reporting requirements. This rule also identifies destinations with respect to which most assistance would be generally authorized and destinations that would require a specific authorization by the Secretary of Energy.
 
DOE EXPORT AND IMPORT OF NUCLEAR EQUIPMENT AND MATERIAL; 10 CFR Part 110; Implemented by Dep’t of Energy, U.S. Nuclear Regulatory Commission, under Atomic Energy Act of 1954.
  – Last Amendment: 20 Nov 2018, 10 CFR 110.6, Re-transfers.
 

* DOJ ATF ARMS IMPORT REGULATIONS: 27 CFR Part 447-Importation of Arms, Ammunition, and Implements of War.  Implemented by Dep’t of Justice, Bureau of Alcohol, Tobacco, Firearms & Explosives.
  – Last Amendment: 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.

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

EN_a0321
Weekly Highlights of the Daily Bugle Top Stories

(Source: Editor) 

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

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

EPEDITORIAL POLICY

* 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.

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