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19-0412 Friday “Daily Bugle”

19-0412 Friday “Daily Bugle”

Friday, 12 April 2019

TOPThe Daily Bugle is a free daily newsletter from Full Circle Compliance, containing changes to export/import regulations (ATF, DOE/NRC, Customs, NISPOM, EAR, FACR/OFAC, FAR/DFARS, FTR/AES, HTSUS, and ITAR), plus news and events. Subscribe here for free subscription.

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  1. USTR Initiates Investigation to Enforce U.S. WTO Rights in Large Civil Aircraft Dispute 
  1. Items Scheduled for Publication in Future Federal Register Editions 
  2. Commerce/BIS: (No new postings.) 
  3. DoD/DSS Announces Knowledge Center PCL Inquiries Closure 
  4. State/DDTC: (No new postings.) 
  5. EU Amends Restrictive Measures Concerning Iraq 
  6. EU Commission Releases Detailed Information on Requirements for EU Goods Exported to The UK in Case of a Hard Brexit 
  7. Belgium/FIT Publishes Guidance for Flemish Exporters in Case of Brexit 
  8. UK/OFSI Publishes Three Guidance Documents Concerning Sanctions Against the Republic of Guinea-Bissau, South Sudan, and Counter-terrorism 
  1. Deutsche Welle: “Germany Exporting Weapons to Saudi Arabia And UAE – Reports” 
  2. The Statesman: “Bill Introduced in U.S. Congress Aims to Put India on Par with NATO Allies” 
  1. F. Rense & C. Roosen: “Export Restrictions and Sanction Regulations: What Are Prohibitions of Circumvention and How Can You Assess and Prevent Their Violation?” 
  2. K. Wolf, T. Savio & S. Emme: “Commerce Adds 50 Foreign Entities to the Unverified List (and Removes 10)” 
  1. ECS Presents “ITAR/EAR Bootcamp: Achieving Compliance” on 8-9 Jul in Seattle, WA 
  2. FCC Presents “An Introduction to EU / Dutch Dual-Use and Military Export Controls”, 7 May in Bruchem, the Netherlands 
  3. List of Approaching Events: 147 Events Posted This Week, Including 11 New Events 
  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 2019), DOS/ITAR (19 Mar 2018), DOT/FACR/OFAC (15 Mar 2019), HTSUS (2 Apr 2019) 
  3. Weekly Highlights of the Daily Bugle Top Stories 

EXIMITEMS FROM TODAY’S FEDERAL REGISTER

EXIM_a1

1. USTR Initiates Investigation to Enforce U.S. WTO Rights in Large Civil Aircraft Dispute

(Source: Federal Register, 12 Apr 2019.) [Excerpts.]


 

FR 84 15028-15036: Initiation of Investigation; Notice of Hearing and Request for Public Comments: Enforcement of U.S. WTO Rights in Large Civil Aircraft Dispute
 
* AGENCY: Office of the United States Trade Representative.
* ACTION: Notice of initiation of investigation, hearing, and request for comments.
* SUMMARY: The United States Trade Representative (Trade Representative) is initiating an investigation to enforce U.S. rights in the World Trade Organization (WTO) dispute against the European Union (EU) and certain EU member States addressed to EU subsidies on large civil aircraft. The Trade Representative proposes determinations that the EU and certain member States have denied U.S. rights under the WTO Agreement and have failed to implement WTO Dispute Settlement Body recommendations. The Trade Representative proposes to take action in the form of additional duties on products of the EU or certain member States, to be drawn from the preliminary list annexed to this Notice. The interagency Section 301 Committee is seeking public comments and will hold a public hearing in connection with the proposed determinations.
* DATES: To be assured of consideration, the following schedule applies: May 6, 2019: Due date for submission of requests to appear at the public hearing and summary of testimony May 15, 2019: The Section 301 Committee will convene a public hearing in the Main Hearing Room of the U.S. International Trade Commission, 500 E Street SW, Washington, DC 20436 beginning at 9:30 a.m. May 28, 2019: Due date for submission of written comments, including post-hearing rebuttal comments.
* ADDRESSES: You should submit written comments through the Federal eRulemaking Portal:
http://www.regulations.gov. Follow the instructions for submitting comments in sections E and F below. The docket number is USTR-2019-0003. For issues with on-line submissions, please contact the Office of the United States Trade Representative (USTR) Section 301 line at (202) 395-5725.
* FOR FURTHER INFORMATION CONTACT: For questions about this investigation or proposed determinations, contact Megan Grimball, Assistant General Counsel, at (202) 395-5725. For questions on customs classification of products identified in the Annex to this Notice, contact Traderemedy@cbp.dhs.gov. 
* SUPPLEMENTARY INFORMATION: …
In early 2012, the United States and the EU entered into a procedural agreement pursuant to which the arbitration would be suspended until after WTO compliance panel and any appellate proceedings determined whether the EU had implemented the DSB recommendations. On May 28, 2018, the DSB adopted compliance panel and Appellate Body reports confirming that launch aid to the Airbus A380 and A350 XWB aircraft continued to cause WTO-inconsistent adverse effects to U.S. interests. At the request of the United States, and in accordance with the procedural agreement, on July 13, 2018, the WTO Arbitrator resumed its work in determining the level of countermeasures to be authorized as a result of the WTO inconsistencies. USTR anticipates that the WTO Arbitrator will issue its report regarding the level of countermeasures in the summer of 2019. …

   The Trade Representative proposes to determine, in accordance with the outcome of the WTO dispute settlement proceedings, that the EU and certain member States have breached their WTO obligations by providing subsidies on the manufacture of large civil aircraft and by failing to withdraw the subsidies or remove their adverse effects. In particular, under section 301(a), section 304(a)(1)(A), and section 306(b)(2), the Trade Representative proposes to determine that the EU and certain member States have denied U.S. rights under the WTO Agreement, and in particular, under Articles 5 and 6.3 of the SCM Agreement, and have failed to comply with the DSB recommendations to bring the WTO-inconsistent subsidies into compliance with WTO obligations. Upon determining that U.S. rights under a trade agreement are being denied, section 301(a) provides that the Trade Representative shall take all appropriate and feasible action authorized under section 301(c), subject to the specific direction, if any, of the President regarding such action, and all other appropriate and feasible action within the power of the President that the President may direct the Trade Representative to take to enforce such rights. Pursuant to sections 301(a), 301(c), 304(a)(1)(B), and 306(b)(2), the Trade Representative proposes that appropriate action would include the imposition of additional ad valorem duties of up to 100 percent on products of the EU or certain member States, to be drawn from the preliminary list of HTS numbers in the attached Annex. In accordance with section 306(b)(2) of the Trade Act, the Annex includes reciprocal goods of the affected industry. The final list of products subject to increased duties will take into account the report of the Arbitrator on the appropriate level of countermeasures to be authorized by the WTO.

 

  The Annex to this Notice contains a list of 317 tariff subheadings and 9 Harmonized Tariff Schedule statistical reporting numbers being considered for additional duties. The value of the list is approximately $21 billion in terms of the estimated import trade value for calendar year 2018. The products listed in Section 1 of the Annex are being considered for additional duties if they are the product of Germany, France, the United Kingdom, or Spain. The products listed in Section 2 of the Annex are being considered for additional duties if they are the product of any of the 28 member States of the EU.

 

(D) Request for Public Comments

 

 In accordance with sections 304(b) and 306(c), USTR invites comments from interested persons with respect to the proposed determination and proposed action. USTR invites comments with respect to any aspect of the proposed action, including: The specific products to be subject to increased duties, including whether products listed in the Annex should be retained or removed, or whether products not currently on the list should be added. The level of the increase, if any, in the rate of duty. The appropriate aggregate level of trade to be covered by additional duties. Whether increased duties on particular products might have an adverse effect upon U.S. stakeholders, including small businesses and consumers. …  

 

(F) Procedures for Written Submissions 

 

All submissions must be in English and sent electronically via www.regulations.gov. To submit comments via www.regulations.gov, enter docket number USTR-2019-0003 on the home page and click “search.” The site will provide a search results page listing all documents associated with this docket. …

 

Stephen Vaughn, General Counsel, Office of the U.S. Trade Representative. 

 

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OGSOTHER GOVERNMENT SOURCES

OGS_a12
. Items Scheduled
for Publication in Future Federal Register Editions

(Source:
Federal Register
)

 

* Commerce/BIS; NOTICES; Agency Information Collection Activities; Proposals, Submissions, and Approvals: Chemical Weapons Convention Declaration and Report Handbook and Forms [Pub. Date: 15 Apr 2019.]
 
* State; NOTICES; Designations as Foreign Terrorist Organizations: Islamic Revolutionary Guard Corps (and other aliases) [Pub. Date: 15 Apr 2019.]
 
* U.S.-China Economic and Security Review Commission; NOTICES; Hearing [Pub. Date: 15 Apr 2019.]

    

 
back to top
 
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OGS_a23
. Commerce/BIS: (No new postings.)

(Source: Commerce/BIS)

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

OGS_a34. DoD/DSS Announces Knowledge Center PCL Inquiries Closure

(Source: DoD/DSS, 12 Apr 2019.)
 
The DSS Knowledge Center, Personnel Security (PCL) inquiries (option #2), to include e-QIP authentication resets will be closed Friday April 12, 2019, through Monday April 15, 2019. Normal business hours will resume Tuesday April 16, 2019.

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

OGS_a45.
State/DDTC: (No new postings.)
(Source:
State/DDTC)

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

OGS_a5
6.
EU Amends Restrictive Measures Concerning Iraq

(Source: Official Journal of the European Union, 12 Apr 2019.)
 
Regulations 
* 
Commission Implementing Regulation (EU) 2019/596
of 11 April 2019
amending Council Regulation (EC) No 1210/2003 concerning certain specific restrictions on economic and financial relations with Iraq

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

OGS_a6
7. EU Commission Releases Detailed Information on Requirements for EU Goods Exported to The UK in Case of a Hard Brexit

(Source: European Commission, 8 Apr 2019.)
 
The European Commission has included in its Market Access Database detailed information on the rules that the UK would apply on its imports from the EU in the event of a hard Brexit. It is based on information made publicly available by the United Kingdom authorities.
 
This is a part of the Commission’s efforts to help industry be prepared in case the United Kingdom leaves the European Union without a negotiated deal.
 
The Market Access Database provides detailed information on duties and taxes that apply to exports to a given country, as well as on import procedures and formalities that must be accomplished for customs clearance. The database contains information for 121 countries, and as of today, it also provides the same level of information for exports to the UK as for any other EU trade partners such as the US or China.
 

Access the Market Access Database here.

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

OGS_a7
8.
Belgium/FIT Publishes Guidance for Flemish Exporters in Case of Brexit

(Source: Flanders Investment and Trade, 11 Apr 2019.)
 

Download the Publication in PDF format here (in Dutch). 

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

OGS_a8
9. UK/OFSI Publishes Three Guidance Documents Concerning Sanctions Against the Republic of Guinea-Bissau, South Sudan, and Counter-terrorism

(Source: UK OFSI, 11 Apr 2019.)  
 
The UK Office of Financial Sanctions Implementation (OFSI) provides guidance on the UK’s sanctions regime on the Republic of Guinea-Bissau, South Sudan, and guidance of use to any organization or individual working in a region where terrorist organizations operate.
 
 
 

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

NWSNEWS

(Source: Deutsche Welle, 11 Apr 2019.) [Excerpts.]
 
Germany’s secret security council has allowed weapons shipments to members of the war coalition in Yemen. European nations have called for Germany to lift their ban on weapons exports to the Middle East.
 
Germany’s National Security Council, a secret security council consisting of Chancellor Angela Merkel and her chief ministers, has approved shipments of weapons parts to countries directly involved in the war in Yemen, including Saudi Arabia and the United Arab Emirates, according to several German media sources.
 
The approvals come two weeks after the German government extended a ban on arms sales to Saudi Arabia, which was originally put in place after the death of journalist Jamal Khashoggi. That extension, however, made a conditional exception for systems developed jointly with other countries amid anger at the German ban among some European partners, notably France and Britain. …
 

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

NWS_a211. The Statesman: “Bill Introduced in U.S. Congress Aims to Put India on Par with NATO Allies”

(Source: The Statesman, 12 Apr 2019.) [Excerpts.]
 
A bipartisan group of half a dozen influential American lawmakers has reintroduced an important legislation in the House of Representatives which seeks to advance the US-India strategic relationship. If enacted, the legislation would ensure that the US State Department treat India as a NATO ally for the purposes of the Arms Export Control Act.
 
It would send a powerful signal that defense sales to India should be prioritized according to U.S.-India Strategic Partnership Forum, which had worked on this important legislation.
 
The bill HR 2123 was introduced this week by Congressman Joe Wilson, a senior member of the House Foreign Affairs Committee. …
 
The National Defense Authorization Act (NDAA) for fiscal 2017 included special language recognizing the unique US-India defense relationship that designated India as a “Major Defense Partner” of the United States.
 
The language seeks unique consideration for trade and technology sharing with India and increased attention and support to advance this relationship in the areas of defense trade and technology sharing. …

 

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COMCOMMENTARY

COM_a112. F. Rense & C. Roosen: “Export Restrictions and Sanction Regulations: What Are Prohibitions of Circumvention and How Can You Assess and Prevent Their Violation?”

(Source: Nauta Dulith, 8 Apr 2019.)
 
* Authors: Francien Rense, Esq., Francien.Rense@nautadutilh.com; and Cindy Roosen, Esq., Cindy.Roosen@nautadutilh.com. Both of Nauta Dulith.
 
In part 1 of this diptych we discussed how to identify dual-use goods and we examined the catch-all provisions in EU export and sanction regulations. In part 2 we examine the so-called ‘prohibitions of circumvention’ in those same regulations. The purpose of prohibitions of circumvention is to protect the objectives of sanction regulations and export regulations – for example those concerning the export of dual-use goods to sanctioned countries – as best as possible, including protection against direct and indirect circumvention. This blog gives some helpful tips for conducting an initial check as to whether a prohibition of circumvention has been violated.
 
Sanction regulations often include general prohibitions of circumvention while more specific prohibitions are included in the export regulations and the EU regulations that establish the lists of dual-use and military goods.
 
Prohibitions of circumvention in sanction regulations
 
Sanction regulations almost always include general prohibitions of circumvention, which also concern the sanctions that apply to dual-use goods. General prohibitions of circumvention are often phrased as follows (this particular example is taken from Sanction Regulation (EU) 833/2014 regarding Russia):
 
“It shall be prohibited to participate, knowingly and intentionally, in activities the object or effect of which is to circumvent the prohibitions referred to in Articles (…).”
 
Sanction provisions concerning dual-use goods also often include veiled prohibitions of circumvention, which, for example, prohibit the direct and indirect performance of certain acts: ‘It shall be prohibited to sell, supply, transfer or export, directly or indirectly (…) to any natural or legal person, entity or body in Russia or for use in Russia, if those items are or may be intended, in their entirety or in part, for military use or for a military end-user’ (Article 2(1) of the aforementioned regulation).
 
Factual circumvention
 
How are sanctions in practice circumvented? This happens, for example, when parties export goods to a sanctioned country via a non-sanctioned country (the so-called U-turn construction). A well-known example of a U-turn construction is to use Turkey as a non-sanctioned country to transport goods to Syria, which is a sanctioned country. This results in the circumvention of the sanctions against Syria. Another example is Saudi Arabia which is used as transit country to export goods to Yemen. A great deal of attention must also be paid to goods that are exported to the free zone in Dubai, as that in many cases is not the final destination of the goods but merely a transit hub used to subsequently export the goods to a country that is potentially subject to sanctions. In the latter case, the initial destination (the free zone) is not the place where the end-user is based: the goods are first supplied to an intermediary, such as a distributor, which subsequently exports the goods to the ultimate owner, also called ‘end-user’.
 
Monitoring compliance with sanctions and export restrictions
 
In terms of monitoring compliance with sanctions and export restrictions (including prohibitions of circumvention), it is therefore of the utmost importance to establish and identify the ultimate acquirer or user of the goods, since the prohibitions of circumvention mean that it is prohibited to supply goods to sanctioned parties via intermediaries. Such supplies are prohibited if you know, or could and should have known, that this was the case. Wilful ignorance is no longer allowed. Parties may not turn a blind eye: based on the sanction risk, parties are expected to take measures to find out and check, as much as possible, where, for what purpose and by whom the goods (or services) will be used. The greater the sanction risk, the more in depth the control must be (risk-based). This could mean, for instance, that it must be determined who is behind a particular party, for example for whom an intermediary is acting, but also who the shareholders of the client are. Especially in the case of red flags, i.e. possible indications that a sanction may be violated, you must keep asking questions and delve deeper into the matter. For example, where incorrect, conflicting or insufficient information or answers are given regarding the envisaged use of a product, where the use stated does not match the product or the client, or in situations where it is unclear why the services of an intermediary were engaged or where the intermediary receives a disproportionate fee for its services.
 
Prohibitions of circumvention in the Dual-use Regulation
 
A specific example of a circumvention prohibition concerning the export of dual-use goods with SGP codes 1C001 and 1C002 in the Dual-use Regulation (see part 1 of this blog for an explanation of the SGP codes) reads as follows:
 
“The object of the control should not be defeated by the export of non-listed forms alleged to be finished products but representing in reality crude forms or semi-fabricated forms.”
 
Under this prohibition of circumvention, goods may not be designated as ‘finished products’ to circumvent the export prohibition applicable to the export of ‘semi-fabricated forms’.
 
Furthermore, a prohibition of circumvention is included in the General Notes to Annex 1 to the Dual-use Regulation, i.e. the list of dual-use goods that is part of the Regulation, which reads as follows:
 
“The object of the controls contained in this Annex should not be defeated by the export of any non-controlled goods (including plant) containing one or more controlled components when the controlled component or components is/are the principal element of the goods and can feasibly be removed or used for other purposes.”
 
The purpose of this prohibition of circumvention is to prevent goods that are subject to an export license from being processed in other goods which are not subject to an export license, thereby circumventing the obligation to have a license. That prohibition of circumvention applies if (i) the part is the principal element of the good, and (ii) can easily be removed or used for other purposes. Factors such as quantity, value and technological know-how must be assessed. The Dual-use Regulation does not state how ‘feasibly be removed’ must be construed. This can result in a great deal of discussion between companies and the authorities because the authorities often interpret that phrase broadly.
 

Prohibitions of circumvention raise important questions and checks and give the authorities extensive possibilities to take action. Please feel free to contact us if you have any questions about this matter or about compliance with sanction regulations and/or general export regulations and the export of dual-use and other goods.

 

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COM_a213. K. Wolf, T. Savio & S. Emme: “Commerce Adds 50 Foreign Entities to the Unverified List (and Removes 10)”

(Source: Akin Gump Strauss Hauer & Feld LLP, 11 Apr 2019.) 

 
* Authors: Kevin Wolf, Esq., 
kwolf@akingump.com
, +1 202-887-4051; Tatman Savio, Esq.,
tatman.savio@akingump.com, +852 3694.3015; and Steve Emme, Esq., semme@akingump.com, +1 202.887.4368. All of Akin Gump Strauss Hauer & Feld LLP.
 
Key Points
 
   – The Commerce Department’s Bureau of Industry and Security (BIS) has added 50 entities to its Unverified List (UVL). Thirty-seven of the newly listed entities are in China. BIS also removed 10 entities from the list that had appealed their listings in accordance with a process set out in the Export Administration Regulations (EAR). View full report here.
 
   – Entities on the Unverified List are not subject to embargoes. Rather, U.S. and foreign persons must conduct additional due diligence before exporting, reexporting, or transferring to listed entities commodities, software, or technology subject to U.S. jurisdiction that do not normally require a license. For items that could normally be shipped to the entities under a license exception, one must now apply for and receive a license before proceeding. Also, U.S. exporters must file Electronic Export Information (EEI) for exports of tangible items to entities on Unverified List, regardless of value or destination.
 
   – As a result of this development, U.S. and non-U.S. companies and others should update their internal control program screens to ensure compliance with the new requirements.
 
The Unverified List (UVL) contains the names and addresses of foreign entities about which the Commerce Department’s Bureau of Industry and Security (BIS) has concerns. The list is in Supplement Number 6 to Part 744 of the Export Administration Regulations (EAR). BIS has not alleged that the UVL entities have violated the EAR and has not added the entities to the Entity List. Rather, BIS has questions about their bona fides, such as whether they are legitimate organizations. As described in EAR section 744.15(c), BIS has the authority to add entities to the UVL if, for example, BIS was not allowed to conduct an on-site verification of items exported or to be exported to the entity.
 
For those exporting, reexporting, or transferring to a listed entity commodities, software, or technology subject to the EAR, but that do not require a BIS license, they must treat the entity’s inclusion on the UVL as a “red flag.” (Commodities, software, and technology are “subject to the EAR” if they are (i) made in the United States, (ii) shipped from the United States, regardless of origin, (iii) foreign-made items containing more than a de minimis amount of U.S.-origin controlled content, or (iv) the direct product of certain types of U.S.-origin controlled software or technology.) The presence of a “red flag” triggers additional due diligence obligations, such as needing to verify that the transaction does not violate the EAR.
 
The primary regulatory due diligence obligation is to obtain from the UVL entity a “UVL statement” before proceeding with an export, reexport, or transfer of an item subject to the EAR. The UVL statement must be signed by the UVL entity and contain specific obligations described in EAR section 744.15(b). For example, the UVL entity must agree in its statement to (i) comply with the EAR, (ii) identify the end use, end user, and ultimate destination of the items being shipped, (iii) cooperate with BIS end-use checks, and (iv) provide copies of records the EAR require be maintained.
 
Also, EAR section 758.1(b)(8) requires U.S. exporters to file Electronic Export Information (EEI) for exports of tangible items involving UVL entities, regardless of value or destination.
 
In addition, as described in EAR section 740.2(a)(17), U.S. and foreign persons may not use an EAR license exception to export, reexport, or transfer to a UVL entity items subject to the EAR. One must apply to and receive from BIS a license to export, reexport, or transfer such items.
 
In section 744.15(d), the EAR describes a process for a listed entity to request removal from the UVL. In essence, the entity must demonstrate in writing its bona fides to BIS enforcement officials, such as why it is a legitimate and reliable party to a transaction involving items subject to the EAR.
 
The implications of being on the UVL are not as dramatic as being on the Entity List, which results in effective prohibitions on the ability of U.S. and foreign persons to export, reexport, or transfer any commodity, software, or technology subject to the EAR. The regulatory obligations related to transactions with and by entities on the UVL are nonetheless significant in that failure to abide by them can result in civil and criminal penalties, even with respect to transactions that historically would not have required specific authorizations.
 
BIS created the UVL in 2002 and updated the rules pertaining to it in 2013 to provide the U.S. Government with increased visibility into exports, reexports, and transfers of items subject to the EAR that involve entities whose bona fides could not be verified for reasons beyond BIS’s control. Click here for more information.

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TEEX/IM TRAINING EVENTS & CONFERENCES

TE_a0
14.
ECS Presents “ITAR/EAR Bootcamp: Achieving Compliance” on 8-9 Jul in Seattle, WA

 
* What: ITAR/EAR Bootcamp:  Achieving Compliance; Seattle, WA
* When: July 8-9, 2019
* Where:
Sheraton Grande
* Sponsor: Export Compliance Solutions & Consulting (ECS)
* ECS Speaker Panel:  Suzanne Palmer, Mal Zerden
* Register here or by calling 866-238-4018 or e-mail

 

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TEC_a2
15.
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. 

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TE_a316. 
List of Approaching Events: 147 Events Posted This Week, Including 11 New Events
(Sources: Editor and Event Sponsors)

Published every Friday or last publication day of the week, o
ur overview of Approaching Events is organized to list c
ontinuously available training, training events, s
eminars & conferences, and 
webinars. 
   
If you wish to submit an event listing, please send it to to
events@fullcirclecompliance.eu
, composed in the below format:
 
    
#
 * Date: Location; “Event Title”; <Weblink>”; EVENT SPONSOR
 
   ”
*” = New or updated listing  

 
Continuously Available Training
 

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

* Webinar: ”
Company-Wide US Export Controls Awareness Program“; Export Compliance Training Institute;
danielle@learnexportcompliance.com 

* E-Seminars: “ITAR/EAR Awareness“; Export Compliance Solutions;
spalmer@exportcompliancesolutions.com

* Webinar Series: “Complying with US Export Controls“; Commerce/BIS

* E-Seminars: “Webinars On-Demand Library“; Sandler, Travis & Rosenberg, P.A.
* Online: “International Trade Webinars“; Global Training Center
*
 
Online: “On-Demand Webinars“; “General Training“; Center for Development of Security Excellence; Defense Security Service (DSS)
* Online: “ACE Reports Training and User Guide“; DHS/CBP

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

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

 

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

Apr 17: Miami, FL; “
CBP COMPLIANCE & ENFORCEMENT
“; Diaz Trade Consulting
*
 Apr 17-18; Miramar, FL; “
11th Maritime Forwarding, Freight Logistics & Global Chain Supply Workshop
“; ABS Consulting;


Apr 17-18: Scottsdale, AZ; “
Complying with U.S. Export Controls
“; Commerce/BIS

*
 
April 18: Sheffield, UK; “
International Trade Operations and Procedures (ITOPS)
; Sheffield Chamber of Commerce

* Apr 23: Anaheim, CA; “Export Controls Essentials: What Finance Personnel Need to Know“; California State University

* Apr 23-24: Portsmouth, NH;

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

#
Apr 25: Amersfoort, the Netherlands; “Rusland en de onderliggende risico’s bij export“; EvoFenedex

Apr 25: Portsmouth, NH;

Technology Controls
“; Commerce/BIS
*
 
Apr 25: London, UK; “
Making better License Applications
“; 
UK/DIT

* Apr 25: Minneapolis, MN; “Importing 201: Advanced Import Compliance“; Global Training Center

* Apr 30: Tirana, Albania; “Nothing to declare? A complete overview of Trade Compliance“; International Chamber of Commerce Albania

*
Apr 30-May 1: Dallas, TX; “Compliance Officer Training“; Globaleyes; 

*
 
Apr 30-May 1: Irvine, CA: “
Complying with U.S. Export Controls
“; Commerce /BIS

*
 Apr 30-May 1: Nashville, TN: “Mastering ITAR/EAR Challenges“; Export Compliance Solutions (ECS);
*
 
May 1: Leeds, UK; “
Understanding Exporting & Incoterms
“; Chamber International

* May 2-3: Washington DC; “Economic Sanctions Enforcement and Compliance;” American Conference Institute

* May 3: Lowell, MA; “Best Practices for Export Enforcement Management“; Massachusetts Export Center; 617-973-6610

*
 
May 5: Munich, Germany; “
European and German Export Controls
“; AWA;

* May 5-7: Savannah, GA;2019 Spring Seminar“; National Association of Foreign Trade Zones (NAFTZ)

May 6-7: Atlanta, GA; “
2019 Spring Conference
“; SIA
* 
May 7: Bruchem, The Netherlands; “
An Introduction to EU / Dutch Dual-Use and Military Export Controls
“; Full Circle Compliance
*
 
May 8: Southampton, UK; “
Strategic Export Control: Intermediate Practitioners course
“; UK/DIT
*
 
May 9: Southampton, UK; “
Strategic Export Control: Foundation Workshop
“; UK/DIT
*
 
May 9: Southampton, UK; “
Strategic Export Control: Licenses Workshop
“; UK/DIT
*
 
May 9: Sheffield, UK; “
Essential Incoterms – Getting it Rights
“; Sheffield Chamber of Commerce

* May 13: Miami, FL; “Automated Commercial Environment (ACE) Export Compliance Seminar (Spanish)“; South Florida DEC  

#
May 13: The Hague, the Netherlands; “Seminar exportcontrole strategische goederen“; Ministerie van Buitenlandse Zaken

* May 14: Miami, FL; “Automated Commercial Environment (ACE) Export Compliance Seminar“; South Florida DEC

*
 
May 15: Bristol, UK; “
A Foundation Course in Importing
“; BusinessWest
*
 
May 15-17; London, UK; “ICPA European Conference“; ICPA

* May 16: Bellevue, WA; “The Ever-Changing International Trade Landscape“; Baker McKenzie

* 
May 16: Bristol, UK; “
Export Controls and Licensing
; BusinessWest
*
 
May 16: Bristol, UK; “
Inward Processing Relief
“; BusinessWest
*
 May 16: Hamburg, Germany; “
U.S. Export Controls and Embargoes & Sanctions for European Companies
“; Hamburger Zollakademie
*
 
May 16-17; Toronto, Canada; “ICPA Canada Conference“; ICPA

* May 17: Milwaukee, WI; “Importing 201: Advanced Import Compliance“; Global Training Center

* May 19: Traverse City, MI; “Export Compliance Overview Traning“; Foster Swift Collins & Smith PC   

#
May 20: Schiphol, the Netherlands; “Voorlichting Export licenties, sanctielijsten en Dual use goederen“; ACN
#
May 20-21; Trier, Germany; “Sanctions in EU External Relations“; ERA Academy of European Law

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

* Jun 5-6: Seattle, WA; “
Complying with U.S. Export Controls
“; Commerce/BIS
*
 
Jun 7: Upper Marlboro, MD; “
2019 Spring Golf Outing
“; SIA

*
 
Jun 10: Cleveland, OH; “
Letters of Credit
“; Global Training Center
*
 
Jun 11: Cleveland, OH; “
Export Doc & Proc
“; Global Training Center
*
 
Jun 11: Sheffield, UK; “
Customs Procedures and Compliance in International Trade
“; Sheffield Chamber of Commerce


Jun 11-12: Detroit, MI; “
Complying with U.S. Export Controls
“; Commerce/BIS

*
 
Jun 12: Cleveland, OH; “
Tariff Classificatio
n“; Global Training Center
*
 
Jun 12: Derby, UK; “
Strategic Export Control: Intermediate Practitioners course
“; UK/DIT
*
 
Jun 13: Cleveland, OH; “
NAFTA Rules of Origin
“; Global Training Center
*
 
Jun 13: Derby, UK; “
Strategic Export Control: Foundation Workshop
“; UK/DIT
*
 
Jun 13: Derby, UK; “
Strategic Export Control: Licenses Workshop
“; UK/DIT
*
 
Jun 13: Detroit, MI; “
How to Build an Export Compliance Program
“; Commerce/BIS
*
 
Jun 14: Cleveland, OH; “
Incoterms® 2010 Rules
“; Global Training 
* Jun 17-20: San Diego, CA; “ITAR Defense Trade Controls / EAR Export Controls“; ECTI
*
 
Jul 3: Bristol, UK; “
Introduction to Export Procedures – Export Training
“; BusinessWest
*
 
Jul 3: Cambridge, UK;
Strategic Export Control: Intermediate Practitioners Course
“; UK/DIT
*
 
Jul 4: Cambridge, UK;
Strategic Export Control: Foundation Workshop
“; UK/DIT
*
 
Jul 4: Cambridge, UK; “
Strategic Export Control: Licenses Workshop
“; UK/DIT
*
 
Jul 4: Bristol, UK;
Using Documentary Letters of Credit, Drafts and Bills”; 
BusinessWest
*
 
Jul 4: Sheffield, UK; “
An Introduction to Export
“; Sheffield Chamber of Commerce
*
 
Jul 8-9: Seattle, WA: “
Boot Camp: Achieving ITAR/EAR Compliance
“; Export Compliance Solutions (ECS);

Jul 8 – 10: National Harbour, MD; “
2019 Summer Back to Basics Conference
“; SIA

* Jul 9-11: Washington; “
BIS 2019 Annual Conference on Export Controls and Policy
“; Commerce/BIS

*
 
July 10: Sheffield, UK; “
Export Documentation – How and Why?” 
; Sheffield Chamber of Commerce

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

#
Jul 23-25; Washington D.C.; “Anti-Corruption Compliance for High Risk Markets“; American Conference Institute

*
Jul 24-25: St. Louis, MO; “
 Complying with U.S. Export Controls
“; Commerce/BIS

* Aug 20-21: Cincinnati, OH;

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

* Aug 20-21: Milpitas, CA;

Complying with U.S. Export Controls
“;
Commerce/BIS
* Aug 22: Milpitas, CA:

Encryption Controls
“;
Commerce/BIS

* Sep 2, 9, 16: Rotterdam, the Netherlands; “Awareness training Export Control, Dual-use en Sancties“; FENEX

* Sep 8-11: Chicago, IL; “2019 Annual Conference and Exposition“; National Association of Foreign Trade Zones (NAFTZ)

* Sep 16-19: Austin, TX; “
ITAR Controls / EAR & OFAC Export Controls (Sep 18-19) Seminar Series
“; ECTI
; 540-433-3977
*
 
Sep 17: Sheffield, UK; “
Customs Procedures and Compliance in International Trade
“; Sheffield Chamber of Commerce


Sep 17-19: Annapolis, MD; “
The ECS 2nd Annual ITAR/EAR Symposium
“; ECS
*
 Sep 20: Las Vegas, NV; “
EAR and OFAC Fundamentals: Export Control Of Dual-Use Equipment
“; Barnes & Thornburg LLP
*
 
Sep 25: Bristol, UK; “
Classification of Goods – Using Commodity and Tariff Codes”; 
BusinessWest
* 
Sep 25: Bristol, UK; “
Incoterms® Rules 2010
“; BusinessWest
*
 
Sep 25: London, UK; “
US & UK Export Controls: A Basic Understanding
; The Institute of Export and International Trade
*
 
Sep 25: Sheffield, UK; “
Essential Incoterms – Getting it Rights
“; Sheffield Chamber of Commerce
*
 
Sep 26: Bristol, UK; “
Understanding The Paperwork
“; BusinessWest

* Sep 30 – Oct 3; Amsterdam, NL; “
ITAR Controls / EAR/OFAC Commercial and Military Controls
“; ECTI
; 540-433-3977

* Oct 3; Rotterdam, the Netherlands; “Trade Compliance Congres 2019“; Sdu

*
 
Oct 7: Munich, Germany; “
European and German Export Controls
“; AWA

* Oct 14-17; Columbus, OH; “
University Export Controls Seminar
“; ECTI

#
Oct 15: Singapore; “
5th Asia Pacific Summit on Economic Sanctions Compliance and Enforcement
“; 
American Conference Institute

*
Oct 17: Sheffield, UK; “
Export Documentation – How and Why?” 
; Sheffield Chamber of Commerce


Oct 28-29: Washington D.C.; “
2019 Fall Advanced Conference
“; SIA

* Oct 28-31; Phoenix, AZ; “
ITAR Controls / EAR & OFAC Export Controls Seminar Series
“; ECTI
* Nov 11-14; Washington, DC; “
ITAR Controls / EAR & OFAC Export Controls Seminar Series
“; ECTI
*
 
Nov 20: Bristol, UK; “
Introduction to Export Procedures – Export Training
“; BusinessWest
*
 
Nov 21: Bristol, UK; “
A Foundation Course in Importing
“; BusinessWest

*
 
Nov 26: Bruchem, The Netherlands; “The International Traffic in Arms Regulations (EAR) from a non-U.S. Perspective“; Full Circle Compliance
* 
Nov 27: Bruchem, The Netherlands; ” The Export Administration Regulations (EAR) from a non-U.S. Perspective“; Full Circle Compliance
 
*
 
Nov 27: Manchester, UK; “
US & UK Export Controls: A Basic Understanding
“; The Institute of Export and International Trade
*
 
Dec 4-5: Washington, DC; “
36th International Conference on the Foreign Corrupt Practices Act
“; American Conference Institute

* Dec 9-12; Miami, FL; “
ITAR Controls / EAR & OFAC Export Controls Seminar Series
“; ECTI
# Dec 10-11: New York, NY; ” 10th Annual New York Forum on Economic Sanctions“; American Conference Institute 
*
 Dec 12-13; Washington D.C.; “
Coping with U.S. Export Controls and Sanctions 2019
“; Practicing Law Institute
 
2020

 
*
 
Jan 30-31: Houston, TX; “
14th Forum on the Foreign Corrupt Practices Act
“; 
American Conference Institute

* Feb 5-6; Munich, Germany; “Export Compliance in Europe Conference“; NielsonSmith

 
Webinars 


 


Apr 16: Webinar: “
CFIUS Update: New Requirements to Meet, New Industries Affected
“; ECTI; 540-433-3977

* Apr 16: Webinar: “Importing 201: Advanced Import Compliance“; Global Training Center

#
Apr 17: Webinar: “U.S. Export Compliance 101” Livingston

* Apr 18: Webinar: “Sanctions & Export Controls for Non-U.S. Companies“; Akin Gump


Apr 23: Webinar: “
How to Improve Export Compliance with Effective Audits
“; ECTI; 540-433-3977

* Apr 23: Webinar: “ITAR Training Basics – For Compliance Executives April“; CVG Strategy

* Apr 23: Webinar: “Switzerland’s Export Control and Customs Regimes: a webinar“; WorldECR in association with MME

* Apr 25: Webinar: “Best Practices for Voluntary and Required Self Disclosures“; Massachusetts Export Center   

* April 30: Webinar; “Conducting investigations and making disclosures“; Baker McKenzie


* May 1: Webinar: “Sanctions Update“; Reed Smith LLP

#
May 2: Webinar: “CFIUS, FIRRMA & ECRA?” Arent Fox

* May 9: Webinar: “Duty Drawback: Your Secret Weapon in the Tariff War“; Massachusetts Export Center; 617-973-6610
* May 17: Webinar: “Foreign Investment & Export Control Update:  Next Steps Under the FIRRMA & ECRA“; Massachusetts Export Center; 617-973-6610

* May 22: Webinar: “ITAR“; Global Training Center
* May 23: Webinar: “EAR“; Global Training Center

* Jun 6: Webinar: “China Trade Update“; Massachusetts Export Center; 617-973-6610

#
Jun 12: Webinar: “EU Export Controls“; BDP

* Jul 19: Webinar: “Managing Export Operations and Compliance“; Massachusetts Export Center; 617-973-6610

* Oct 29: Webinar: “Key updates on export controls and sanctions“; Baker McKenzie
* Dec 17: Webinar: “Managing Emerging Compliance Risks“; Baker McKenzie

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

ENEDITOR’S NOTES

EN_a117
. Bartlett’s Unfamiliar Quotations

(Source: Editor)

 

Henry Clay (11 Apr 1777 – 29 Jun 1852; was an American attorney and statesman who represented Kentucky in both the United States Senate and United States House of Representatives, served as 7th speaker of the U.S. House of Representatives, and served as the 9th U.S. secretary of state.)
 – “Courtesies of a small and trivial character are the ones which strike deepest in the grateful and appreciating heart.”
 
*
 Thomas Jefferson (13 Apr 1743 – 4 Jul 1826; was an American statesman, diplomat, lawyer, architect, and Founding Father who served as the third president of the United States from 1801 to 1809.)
– “Determine never to be idle. No person will have occasion to complain of the want of time who never loses any. It is wonderful how much may be done if we are always doing.”
 
Friday’s funnies:
* The attorney tells the accused, “I have some good news and some bad news.” “What’s the bad news?” asks the accused.  “The bad news is that DNA tests prove that it is your blood 
all over the crime scene.  But there is good news, too… Your cholesterol is only 130.”

* A lady was being tried on a disturbing the peace charge from a neighbor who complained about her barking dog.  At one point, the judge asked the neighbor a question, but got no answer. “Sir, are you going to answer me?”, said the judge.  The bailiff tapped the neighbor on the shoulder and pointed at judge.  The neighbor said. “Judge, are you talking to me?” “Sorry; I’m nearly deaf.  I can’t hear a darn thing.”  The case was dismissed.

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

EN_a218. Are Your Copies of Regulations Up to Date?
(Source: Editor)

The official versions of the following regulations are published annually in the U.S. Code of Federal Regulations (C.F.R.), but are updated as amended in the Federal Register.  The latest amendments to applicable regulations are listed below.
 

*
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:
 
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
.  
 

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 the Atomic Energy Act of 1954.
  – Last Amendment: 23 Feb 2015:

80 FR 9359
, comprehensive updating of regulations, updates the activities and technologies subject to specific authorization and DOE reporting requirements. This rule also identifies destinations with respect to which most assistance would be generally authorized and destinations that would require a specific authorization by the Secretary of Energy.
 

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 the 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 March 2019) of the ITAR with all amendments is contained in 
Bartlett’s Annotated ITAR 
(“BITAR”), by James E. Bartlett III. The BITAR is a 361-page Word document containing 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 download, 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].

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

EN_a319
. Weekly Highlights of the Daily Bugle Top Stories
(Source: Editor)
 

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

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

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

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