19-0411 Thursday “Daily Bugle'”

19-0411 Tuesday “Daily Bugle”

Thursday, 11 April 2019

  1. Commerce/BIS Amends EAR by Updating the Unverified List (15 CFR Part 775) 
  1. Items Scheduled for Publication in Future Federal Register Editions 
  2. Commerce/BIS: (No new postings.)
  3. State/DDTC: (No new postings.)
  4. Treasury/OFAC Announces Settlement Agreement with Acteon Group, Ltd., 2H Offshore Engineering Ltd., KKR & Co. Inc., and Seatronics Ltd.
  5. German BAFA Publishes Report on Activities Concerning EU Anti-Torture Regulation
  1. Defense News: “How Turkey’s Industry Could Suffer from the S-400 Deal with Russia”
  2. Reuters: “ASML Says it Suffered Intellectual Property Theft, Rejects ‘Chinese’ Label”
  1. D. Osler: “Greater Sanctions Due Diligence Urged After U.S. Labels Iran Troops as Terrorists”
  2. R. Whitten & L. Mays: “A Wave of Export Regulation to Hit U.S. Technologies”
  1. 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 (5 Apr 2019), DOC/EAR (11 Apr 2019), 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 


Federal Register
, 11 Apr 2019.) [Excerpts.]

84 FR 14608-14614: Revisions to the Unverified List (UVL)
* AGENCY: Bureau of Industry and Security, Commerce.
* ACTION: Final rule.
* SUMMARY: The Bureau of Industry and Security (BIS) is amending the Export Administration Regulations (EAR) by adding fifty (50) persons to the Unverified List (“UVL”), removing ten (10) persons, and adding an additional address for one (1) person currently listed on the UVL. The fifty persons are added to the UVL on the basis that BIS could not verify their bona fides because an end-use check could not be completed satisfactorily for reasons outside the U.S. Government’s control. BIS is adding a new address for one person as BIS has determined that this person is receiving exports from the United States at an additional address.
This rule is effective: April 11, 2019.
* FOR FURTHER INFORMATION CONTACT: Kevin Kurland, Director, Office of Enforcement Analysis, Bureau of Industry and Security, Department of Commerce, Phone: (202) 482-4255 or by email at
This rule adds fifty (50) persons to the UVL by amending Supplement No. 6 to Part 744 of the EAR to include their names and addresses. BIS adds these persons in accordance with the criteria for revising the UVL set forth in Sec. 744.15(c) of the EAR. The new entries consist of thirty-seven persons located in China, six in Hong Kong, four in the United Arab Emirates, two in Malaysia, and one in Indonesia. Each listing is grouped within the UVL by country with each party’s name(s) listed in alphabetical order under the country; each entry includes available alias(es) and address(es), as well as the Federal Register citation and the date the person was added to the UVL. The UVL is included in the Consolidated Screening List, available at
  This rule also adds one additional address for one person currently listed on the UVL, Ling Ao Electronic Technology Co. Ltd, a.k.a. Voyage Technology (HK) Co., Ltd., a.k.a. Xuan Qi Technology Co. Ltd., as BIS has determined that this person is receiving exports from the United States at an additional address. Further, this rule fixes minor typographical errors in two of the existing addresses for the same company.
Finally, this rule removes ten persons from the UVL. BIS is removing these persons pursuant to information received by BIS pursuant to Sec. 744.15(d) of the EAR and further review conducted by BIS. This final rule implements the decision to remove the following three persons located in China, one person located in Finland, five persons located in Russia, and one person located in the United Arab Emirates from the UVL:
(1) Jiujiang Jinxin Nonferrous Metals Co., Ltd., Xunyang Chem. Bldg., Materials Factory, Xunyang District, Jiujiang City, China,
(2) Liupanshui Normal University, 19 Minhu Road, Zhongshan District, Liupanshui, Guizhou, 553004, China, and
(3) Yantai Salvage Bureau, No. 100 Zhifudao East Road, Zhifu District, Yantai, Shandong, 264012, China
(1) Net Logistics JVM OY, a.k.a. Net Logistic JVM OY, Eskolantie 1, Helsinki, Finland, 00720 and Merituulentie 486, Port Mussalo, Kotka, Finland 48310
(1) Eltech Ltd., 3A, pl. Konstitutsii, Saint Petersburg 196247, Russia,
(2) MT Systems, Kalinina Street 13, Saint Petersburg 198099, Russia,
(3) Romona Inc., Prospekt Mira 426, Yuzhno-Sakhalinsk 693004, Russia,
(4) Sakhalin Energy Investment Company Ltd., Dzerzhinskogo Street 35, Yuzhno-Sakhalinsk 693020, Russia, and
(5) SIC Dipaul, Bolshaya Monetnaya Street 16, Saint Petersburg 197101, Russia, and 5B, Rentgena ul., Saint Petersburg 197101, Russia
United Arab Emirates
(1) GenX Middle East FZE, a.k.a. GenX Systems LLC, #510-511 Le Solarium Building, Dubai Silicon Oasis, Dubai, UAE, and P.O. Box 121225, Office M07, Al Zahra, Khaleed Bin Al Waleed Road, Bur Dubai, Dubai, UAE. …
  Dated: April 5, 2019.
Nazak Nikakhtar, Assistant Secretary for Industry & Analysis, Performing the Non-Exclusive Duties of the Under Secretary for Industry and Security.

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

 * USTR; NOTICES; Investigations; Determinations, Modifications, and Rulings, etc.: Enforcement of U.S. WTO Rights in Large Civil Aircraft Dispute; Hearing and Request for Public Comments [Pub. Date: 12 Apr 2019.]
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Commerce/BIS: (No new postings.)
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State/DDTC: (No new postings.)

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Treasury/OFAC Announces Settlement Agreement with Acteon Group, Ltd., 2H Offshore Engineering Ltd., KKR & Co. Inc., and Seatronics Ltd.

Treasury/OFAC, 11 Apr 2019.)
The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced a
$227,500 settlement with Acteon Group Ltd. (“Acteon”), and Acteon’s subsidiary 2H Offshore Engineering Ltd. (“2H Offshore” that has two Malaysian affiliates: 2H Offshore Engineering Sdn Bhd and 2H Offshore Engineering (Asia Pacific) Sdn Bhd (collectively “2H KL”).  Acteon, a subsea service provider in the oil and gas industry based in the United Kingdom (UK), and 2H Offshore, an engineering contractor based in the UK that specializes in services used in offshore oil and gas drilling production, have agreed to settle their potential civil liability for seven apparent violations of the Cuban Assets Control Regulations, 31 C.F.R. part 515 (CACR).  Specifically, between on or about May 18, 2011 and on or about October 18, 2012, 2H KL performed engineering design analyses for oil well drilling projects in Cuban territorial waters, and sent its engineers to Cuba to conduct workshops on these analyses.  OFAC determined that 2H Offshore voluntarily self-disclosed the apparent violations, and that these apparent violations constitute an egregious case.
Separately, OFAC announced a $213,866 settlement with KKR & Co. Inc. (“KKR”), Acteon, and Acteon’s subsidiaries Seatronics Ltd., Seatronics, Inc., and Seatronics Ptd. Ltd. (collectively “Seatronics”).  Acteon has agreed to settle: (1) it and Seatronics’, a geophysical services company based in the UK, potential civil liability for 13 apparent violations of the CACR; and (2) KKR’s, a global investment firm based in New York City, potential civil liability for three apparent violations of the Iranian Transactions and Sanctions Regulations, 31 C.F.R. part 560 (ITSR).  Specifically, between on or about August 12, 2010 and on or about March 16, 2012, Acteon appears to have violated § 515.201 of the CACR when Seatronics rented or sold equipment for oil exploration projects in Cuban territorial waters, and sent company engineers to service equipment on vessels operating in Cuban territorial waters.  In addition, between on or about September 10, 2014 and on or about November 11, 2014, Seatronics appears to have violated §§ 560.215 and § 560.204 of the ITSR when Seatronics Ltd.’s Abu Dhabi, United Arab Emirates branch rented or sold equipment to customers who appear to have embarked the equipment on vessels that operated in Iranian territorial waters.  OFAC determined that Acteon voluntarily self-disclosed the apparent violations, and that these apparent violations constitute a non-egregious case.
For more information, please see this
web notice. 

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OGS_a56. German BAFA Publishes Report on Activities Concerning EU Anti-Torture Regulation

(Source: German BAFA, 10 Apr 2019.)
[Excerpts. Unofficial translation by Alexander Witt.]
The German Federal Office for Economic Affairs and Export Control (BAFA) published the 12th Report on Activities of the Federal Republic of Germany pursuant to Article 26 (3) of Council Regulation (EU) 2019/125 (Anti-Torture Regulation).
The Anti-Torture Regulation contains prohibitions and licensing requirements for foreign trade in goods that may be used for capital punishment, torture or other cruel, inhuman or degrading treatment or punishment. …
Article 26 (3) of Council Regulation (EU) 2019/125 (Anti-Torture Regulation)
states that “
Member States, if 
in cooperation with the Commission, shall make a public, annual activity report, providing information on the number of applications received, on the goods and countries concerned by these applications, and on the 
decisions, they
have taken on these applications. This report shall not include information the disclosure of which a Member State considers to be contrary to the essential interests of its security.
” …
The Report of the Federal Republic of Germany can be downloaded here (In German). 

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Defense News: “How Turkey’s Industry Could Suffer from the S-400 Deal with Russia”
Defense News, 11 Apr 2019.) [Excerpts.]
After experiencing a decade of growth, Turkey’s increasingly vibrant defense industry may fall victim to the government’s quest to purchase the Russian S-400 surface-to-air missile defense system, a deal that will make Turkey the first NATO ally to deploy the system on its soil.
Turkey announced in December 2017 it would acquire the Russian system for long-range air and anti-missile defense. Ankara has since ignored NATO allies’ calls to scrap the S-400 deal, citing its sovereign right to deploy any air defense architecture it chooses. Turkish President Recep Tayyip Erdoğan emphasized this point during a state visit to Moscow on April 8, saying that the S-400 deal is irrevocable.
Turkey risks severe U.S. sanctions under the Countering America’s Adversaries Through Sanctions Act.
Top U.S. lawmakers are threatening to pass legislation that would bar Turkey from buying the F-35 fighter jet, and sanction the country if it buys the Russian S-400.
If Turkey accepts the S-400, “no F-35s will ever reach Turkish soil. And Turkish participation in the F-35 program, including manufacturing parts, repairing and servicing the fighters, will be terminated, taking Turkish companies out of the manufacturing and supply chain for the program,” wrote a bipartisan group of leaders of the Senate Armed Services Committee and Senate Foreign Relations Committee. …
A U.S. diplomatic source has told Defense News that the direct cost of U.S. sanctions on the Turkish industry could reach $10 billion. “And that excludes indirect costs,” he added.
Turkey is a partner is the multinational, American-led Joint Strike Fighter program that builds the F-35. Turkey has committed to purchase more than 100 new-generation jets. Several Turkish companies are producing parts for the JSF program, including airframe structure and assemblies, landing gear components, and more than 100 F135 engine production parts to include titanium-integrated blade rotors. …
U.S. sanctions could potentially target senior procurement officials and prominent Turkish companies participating in the S-400 contract. “That would create a second wave of sanctions … by curbing and halting Turkish companies’ international programs and deals, including know-how, with non-U.S. (but Western) defense entities,” the American source said. “Here we are talking about another heavy damage in addition to the dismissal from the F-35 program.”
Additionally, the U.S. may disrupt Turkey’s current and future systems export efforts, including those for the T129 attack helicopter, built by TAI under license from the Italian-British firm AgustaWestland. The T129, based on its predecessor, the A129 Mangusta, is a twin-engine multirole attack helicopter. …

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Reuters: “ASML Says it Suffered Intellectual Property Theft, Rejects ‘Chinese’ Label”

Reuters, 11 Apr 2019.) [Excerpts.]
Dutch ASML said on Thursday it had been the victim of corporate espionage in 2015 involving employees from countries including China but said it had not been the target of any “national conspiracy”.
ASML said the perpetrators took “large files” on memory sticks from its Silicon Valley software subsidiary that develops software for machine optimization. It said it had since taken action to make such theft much more difficult.
Following publication of a story in Dutch daily newspaper
Financieele Dagblad (FD) that said ASML had been struck by Chinese espionage, the company took issue with that label.
  “The suggestion that we were somehow victim of a national conspiracy is wrong,” CEO Peter Wennink said in a statement.
  “We resent any suggestion that this event should have any implication for ASML conducting business in China. Some of the individuals (involved) happened to be Chinese nationals,” he added.
The Dutch company welcomed a Sino-European agreement earlier this week, which promised that Beijing would no longer force foreign companies to share sensitive know-how when operating in China.
  “Can we prudently do business in China? Yes of course. This was a rotten apple,” ASML said in an earlier statement. …
The Dutch intelligence agency has included warnings in its annual threat assessments for the past several years, saying that China is targeting tech companies in the Netherlands, as it does in other countries, for intellectual property theft.
In a reaction, the intelligence agency AIVD said it could not comment on individual cases.
  “In a broader sense, the greatest threat of economic espionage comes from China,” it said in an email to Reuters.
  “The Netherlands is an attractive target, other countries are interested in our information in science and technical expertise.”

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. D. Osler: “Greater Sanctions Due Diligence Urged After US Labels Iran Troops as Terrorists”
(Source: Llyod’s List, 9 Apr 2019.) [Excerpts.]  
* Author: David Osler, Finance Editor, Informa, david.osler@informa.com.
Shipping companies doing business with Iran need to step up due diligence after the US designated the Islamic Revolutionary Guard Corps a terrorist organization, according to a London shipping lawyer.
  “It is not possible to go to the Iranian equivalent of Companies House and check shareholdings. And even if you could, you would not find a shareholder called IRGC, because front companies will be used,” says Nigel Kushner of law firm W Legal.
Shipping companies that continue to do business with Iran need to step up due diligence in the wake of the US designating the country’s elite Islamic Revolutionary Guard Corps a terrorist organization, according to a London lawyer who has represented Iranian tanker operator NITC.
At issue is the involvement of IRGC in many Iranian companies, potentially including ports and logistics concerns, said Nigel Kushner, chief executive of W Legal. …  

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R. Whitten & L. Mays: “A Wave of Export Regulation to Hit U.S. Technologies”

(Source: Sheppard Mullen, 10 Apr 2019.)
* Authors: Reid Whitten, Esq., rwhitten@sheppardmullin.com; and Lisa Mays, Esq., lmays@sheppardmullin.com. Both of Sheppard Mullen.
Key Takeaways:
A wave is coming. An enormous wave of regulation will soon crash on Silicon Valley, Boston and other tech centers around the United States, and very few people have their surfboards ready.
Major technologies in exciting emerging fields (among them, biomedicines, virtual reality, and robotics) will soon be subject to strict export controls that will limit who can receive the technologies, who can use them, and even who can research them.
Forthcoming export controls will disrupt logistics planning, information sharing, R&D, and acquisition strategies for companies in the United States and all around the world.
A swell on the horizon: the coming controls
In the past, export controls and other regulations have tended to lag a step or two behind the times. That trend has accelerated with the pace of technological advancement. As a result, for many years, commercial technical innovations in fields like data analytics, microprocessors and navigation could be freely exported without significant restrictions because they had simply gone beyond what regulators could think to name in their regulations. As long as the items were not designed for military applications, and no significant encryption technology was involved, new ideas developed in the United States were simply unaccounted for by the export controls in the US Export Administration Regulations (EAR).
However, the US Department of Commerce, Bureau of Industry and Security (BIS) is about to make up a lot of ground in a single, large leap. The tsunami it will unleash in its regulatory overhaul will splash down on sectors like biotech, computing, artificial intelligence, positioning and navigation, data analytics, additive manufacturing, robotics, brain-machine interface, advanced materials, and surveillance.
Controlling the break: commenting on the rules before they take effect
BIS is in the process of writing the regulations. Since the regulations are not yet set in stone, you may formulate and submit the arguments to BIS that may help limit the impact of these regulations on your business.
On 19 November 2018, BIS published an invitation to comment on the criteria for establishing new export controls on what it calls “emerging and foundational technologies”. The new controls are authorized under the Export Control Reform Act of 2018 and the Foreign Investment Risk Review Modernization Act of 2018 (FIRRMA).
The list of technology fields targeted for review is as follows:
(i) biotechnology;
(ii) artificial intelligence (AI) and machine learning technology;
(iii) position, navigation and timing (PNT) technology;
(iv) microprocessor technology;
(v) advanced computing technology;
(vi) data analytics technology;
(vii) quantum information and sensing technology;
(viii) logistics technology;
(ix) additive manufacturing;
(x) robotics;
(xi) brain-computer interfaces;
(xii) hypersonics;
(xiii) advanced materials; and
(xiv) advanced surveillance technologies.
Interested parties submitted public comments on the proposed rule before 10 January 2019 deadline.
This rule was an Advance Notice of Proposed Rulemaking (ANPRM), so before finalizing the regulations, BIS will likely publish a Notice of Proposed Rulemaking, again inviting interested parties to comment on the proposed regulations. In addition, BIS will issue a separate ANPRM regarding identification of foundational technologies that may be important to US national security.
These rulemakings represent your opportunities to be heard. There is no guarantee that public comment will alter the course of the new restrictions, but it may be worth a try to argue for changes that may help preserve your options for the future.
Feeling the curl: understanding the coming controls
The controls are not yet in final form so we cannot predict in detail the implications of those controls. However, we have seen and ridden waves before. Based upon our experience and the information BIS provided in its request for comments and industry chatter, we can provide the following information.
General implications
. If your company creates technology or products in an emerging technology sector, new export restrictions will not only limit who can receive your exports, but will also restrict the disclosure of technology to foreign nationals even within the United States. If the controls follow the pattern of most EAR controls, the export of products and the disclosure of related technology and know-how will require licenses, depending on the destination, end-user and end-use of the product or information. Where technologies are already widely available outside the United States, BIS may not be able to restrict that technology.
Implications for collaboration
. Depending on the criteria BIS develops for these controls, persons who are not US citizens or green-card holders may need licenses to participate in researching and developing some of these emerging technologies.
Implications for exports
. As the new regulations are developed, exports of your products, parts and components in these sectors may require export controls. This may be true for final shipments as well as for movements throughout your manufacturing supply chain. For example, if your logistics chain includes fabrication in Mexico, or assembly, testing and packaging in China, you may need to plan for the potential impacts on your manufacturing process.
Implications for mergers, acquisitions and investments
. The emerging technology sector continues to see historic volumes of investment and M&A activity in a vibrant US economy. The new regulations will also affect US national security review of foreign investments in these sectors. Specifically, when the list of technologies is finalized, many types of foreign investments in these sectors (including not only outright acquisitions of US companies, but also certain minority investments) will be subject to review by the Committee on Foreign Investment in the United States (CFIUS). CFIUS has the power to halt or unwind a deal, and the power to impose restrictions on a foreign acquirer’s access to technology. This development has the potential to radically alter the structuring, timing and valuation of foreign investments in these sectors.
Getting ready to ride: planning for the controls
Recently, we have seen companies caught off guard by the rapid pace of regulatory change in the Trump administration. This has been the case even when the president and the administration have clearly signaled policy changes in advance (as in the case of the immigration ban, tariffs on China and changes to NAFTA).
BIS’s announcement of these forthcoming rules signals a real and substantive movement toward limiting foreign access to leading-edge technologies. Companies in the affected sectors could gain an advantage over their competition if they act early. They can paddle a bit ahead and ride this coming wave, rather than tumbling in its wash.
Your company may wish to consider adjustments to your research, manufacturing, export and investment strategies to handle the forthcoming changes. In our view, this wave of regulation will have a big impact on US advanced technology sectors. Companies should continue to monitor and consider submitting comments and implementing internal controls to account for the upcoming changes.

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TE_a111. 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

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George Canning (11 Apr 1770-8 Aug 1827; was a British Tory statesman who served as Prime Minister of the United Kingdom from April to August 1827).
“Indecision and delays are the parents of failure.”

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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: 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: 11 Apr 2019: 84 FR 14608-14614: Revisions to the Unverified List (UVL) 
* 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.

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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, 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.

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