;

19-0416 Tuesday “Daily Bugle'”

19-0416 Tuesday “Daily Bugle”

Tuesday, 16 April 2019

[No items of interest noted today.] 

  1. Items Scheduled for Publication in Future Federal Register Editions 
  2. Commerce/BIS: (No new postings.)
  3. DHS/CBP Deactivates ITAR Exemption Code 22 CFR 126.5C
  4. DHS/CBP Posts Updated Drawback CATAIR
  5. State/DDTC: (No new postings.)
  6. Treasury/OFAC Publishes “Important Technical Notice” Concerning Sanctions List Data Files
  7. EU Publishes Implementing Regulations Concerning CN, Correction Regarding EU Dual-Use Regulation
  1. Reuters: “Canada Expands Sanctions, Adds 43 People Close to Venezuela’s Maduro” 
  2. Science Business: “EU to Vote on Renewing Scientific Relations with Russia” 
  1. L.B. Meyer, A.W. Craig & E.K. Lowe: “U.S. Prepares Another $11.2 Billion in Tariffs on EU Products”
  2. O. Gonzalez: “Trump Tariffs Update — One way to avoid paying Section 232 or Section 301 Tariffs”
  3. R. Bunner, K. Fässler & P. Henschel: “What Do Swiss Companies Have to Take into Account Regarding Customs and Export Control?”
  1. ICPA Presents “2019 EU Conference”, 15-17 May in London
  2. FCC Presents “Designing an Internal Compliance Program for Export Controls & Sanctions”, 1 Oct 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 (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 

EXIMITEMS FROM TODAY’S FEDERAL REGISTER

EXIM_a1 
[No items of interest noted today.]  
* * * * * * * * * * * * * * * * * * * *

OGSOTHER GOVERNMENT SOURCES

OGS_a11. Items Scheduled for Publication in Future Federal Register Editions
(Source: Federal Register)

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

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OGS_a33.
DHS/CBP Deactivates ITAR Exemption Code 22 CFR 126.5C
(Source: CSMS #19-000193, 16 Apr 2019.)
 
Effective immediately Directorate of Defense Trade Controls DDTC International Trade Arms Regulations ITAR Exemption code 22 CFR 126.5C has been deactivated and will not be accepted in Electronic Export Information EEI submissions. The ITAR lists 22 CFR 126.5C as [reserved]. This change is effective immediately.
 
Appendix O of the Automated Export System Trade Interface Requirement AESTIR will also be updated to have the code removed.
 
For questions please contact the Directorate of Defense Trade Controls (DDTC) Response Team with inquiries at:
– Phone: 202-663-1282
 
For inquiries related to electronic applications and the use of other DTAS systems, the public can contact:
– Phone: 202-663-2838      

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

OGS_a44.
DHS/CBP Posts Updated Drawback CATAIR
(Source:
CSMS# 19-000191
, 15 Apr 2019.)
 
An updated Drawback CATAIR (V14) is now posted on 
CBP.GOV
 at the following location:
here
.

This version of the CATAIR has added an indicator in the 43-record for those wishing to claim drawback on quarterly HMT. This new indicator is tentatively scheduled to be available in the PRODUCTION environment in late May of 2019. A follow-up CSMS will be issued when this indicator is made available for testing in the CERTIFICATION environment.

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OGS_a55.
State/DDTC: (No new postings.)
(Source:
State/DDTC
)

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On or about May 16th, OFAC will be expanding the “Program” field found in OFAC’s legacy data files (DEL, PIP, FF, and CSV) from 50 to 200 characters.  Users of OFAC’s XML files should not be affected by this update.  A full list of affected files is provided below.     

   

– SDN.DEL
– SDN.PIP
– SDN.FF
– SDN.CSV
– CONS_PRIM.DEL
– CONS_PRIM.PIP
– CONS_PRIM.FF
– CONS_PRIM.CSV
 
Here are updated Data Specification files for both the SDN and Consolidated Lists that OFAC will publish on May 16th as part of this update.   
Users with questions about this update are welcome to contact OFAC at O_F_A_C@treasury.gov or contact OFAC’s technical support hotline at 1-800-540-6322 – Menu Option 8 for assistance. 

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OGS_a77.
EU Publishes Implementing Regulations Concerning CN, Correction Regarding EU Dual-Use Regulation
(Source:
Official Journal of the European Union
, 16 Apr 2019.)
 
Regulations
*
Commission Implementing Regulation (EU) 2019/612
of 9 April 2019 concerning the classification of certain goods in the Combined Nomenclature (CN)
*
Commission Implementing Regulation (EU) 2019/613
of 9 April 2019 concerning the classification of certain goods in the Combined Nomenclature (CN)
 
Decisions
*
Council Decision (CFSP) 2019/615
of 15 April 2019 on Union support for activities leading up to the 2020 Review Conference of the Parties to the Treaty on the Non-Proliferation of Nuclear Weapons (NPT)
 
Corrigenda
*
Corrigendum to Commission Delegated Regulation (EU) 2018/1922
of 10 October 2018 amending Council Regulation (EC) No 428/2009 setting up a Community regime for the control of exports, transfer, brokering and transit of dual-use items (OJ L 319, 14.12.2018)

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NWSNEWS

NWS_a18
.
Reuters: “Canada Expands Sanctions, Adds 43 People Close to Venezuela’s Maduro”

(Source:
Reuters
, 15 Apr 2019.) [Excerpts.]
 
Canada expanded sanctions against the Venezuelan government of President Nicolas Maduro on Monday, according to a statement from Foreign Minister Chrystia Freeland, targeting an additional 43 people close to the disputed leader.
 
While the statement did not give names, it said they were “high ranking officials of the Maduro regime, regional governors and/or directly implicated in activities undermining democratic institutions”.
 
Canada had already sanctioned 70 others. …
 
“The Maduro dictatorship must be held accountable for this crisis and depriving Venezuelans of their most basic rights and needs,” Freeland said in a statement. “Canada is committed to supporting the peaceful restoration of constitutional democracy in Venezuela.” …

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NWS_a29
.
Science Business: “EU to Vote on Renewing Scientific Relations with Russia”

(Source:
Science Business, 16 Apr 2019.) [Excerpts.]
 
… On Wednesday the European Parliament is expected to renew the EU’s science and technology cooperation with Russia for a five-year period. That is despite a sharp and ongoing deterioration in relations between the two, which has seen cooperation fall “far below its potential” in recent years, the text of the agreement says. …
 
But “political circumstances” have also hampered collaboration, the Commission says. Following Russia’s military intervention in Ukraine and annexation of Crimea in 2014, the EU responded with economic sanctions. These included banning the export of dual-use and sensitive technology, and deterring investments in areas such as offshore oil and gas exploration. In addition, research organizations in Crimea were banned from participating in EU R&D projects. …

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COMMCOMMENTARY

COM_a1
10.
L.B. Meyer, A.W. Craig & E.K. Lowe: “U.S. Prepares Another $11.2 Billion in Tariffs on EU Products”

(Source: Venable LLP, 11 Apr 2019.)
 
* Author: Lindsay B. Meyer, Esq.,
lbmeyer@Venable.com
; Ashley W. Craig, Esq.,
awcraig@Venable.com
; and Elizabeth K. Lowe, Esq.,
eklowe@Venable.com
. All of Venable LLP.
 
On April 8, 2019, the Office of the United States Trade Representative (USTR) announced that it is preparing a list of European Union products on which it intends to impose retaliatory tariffs of $11.2 billion per year, in response to the European subsidies given to Airbus. The preliminary list of products on which USTR is considering imposing additional import duties includes a wide variety of items, such as certain new aircraft and aircraft parts, seafood, yogurt, butter, cheese, citrus fruits, virgin olive oil, wine, printed books, threads, carpets and other textiles, men’s and women’s apparel, iron and steel articles, such as nails, and parts and accessories of bicycles. The full list of items USTR proposes to include in this round of tariffs is available
here
.
 
Today, USTR announced, and plans to publish on April 12, notice of the initiation of a Section 301 investigation addressing this issue. As part of the investigation, titled “Enforcement of U.S. WTO Rights in Large Civil Aircraft Dispute,” USTR is seeking public comments regarding the proposed new tariffs. While public comments can address any aspect of the proposed action, USTR provided the following specific examples as potential topics to be covered in public comments:
 
– 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; and
– Whether increased duties on particular products might have an adverse effect upon U.S. stakeholders, including small businesses and consumers.
 
A public hearing has also been scheduled, and interested parties can submit requests to testify at the hearing. The relevant dates, as currently set, are listed below:


 
Action:  
– Request to Appear and Submission of Summary of Testimony (Due Date: May 6, 2019)
– Publich Hearing (Due Date: May 15, 2019)
– Submission of Public Comments (Due Date: May 28, 2019) 
 
This new round of planned tariffs stems from a World Trade Organization (WTO) ruling last May, which found that Boeing rival Airbus had received illegal funding for several of its aircraft models. In the dispute, which began in 2004, the United States argued that the EU gave Airbus billions of dollars of “launch aid” that resulted in an unfair advantage for Airbus. Specifically, the United States asserted that the aid allowed Airbus to gain market share in Europe, Australia, China, South Korea, and elsewhere at Boeing’s expense. The WTO’s finding in its favor prompted the United States to request authorization to impose retaliatory tariffs of $11.2 billion per year on the EU. The WTO is expected to rule on the request this summer, and is widely expected to grant the request. The USTR indicated that it is prepared to put the proposed new tariffs into effect as soon as the WTO’s ruling is issued.
 
In response, the European Union announced that it was also readying a list of tariffs to counter U.S. subsidies to Boeing. It is anticipated that the WTO will also rule soon on a parallel dispute brought by the EU against the United States for allegedly providing illegal subsidies to Boeing. Last month, the WTO found that Boeing received tax breaks in Washington state and incentives in South Carolina that amounted to subsidies. The EU has further alleged that government research contracts granted to Boeing through agencies like the Defense Department and NASA, as well as tax breaks, are also subsidies.
 
The announcement of the proposed imposition of new tariffs comes amid tense trade relations between the United States and the EU. While both sides have indicated a desire to negotiate to relieve the current tensions and normalize trade, there has been little progress to date, and continued threats from the United States to impose auto tariffs, along with the corresponding threats from the EU to retaliate, are further exacerbating the situation. Should the proposed new tariffs take effect, we are likely to see a continued, and potentially prolonged, escalation of trade tensions across the Atlantic.

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COM_a2
11
. O.
Gonzalez: “Trump Tariffs Update — One way to avoid paying Section 232 or Section 301 Tariffs”

(Source: Author, 12 Apr 2019.)
 


Let’s say you manufacture in China, but you do not want to pay the Section 301 duties that apply to merchandise from that country. Can you further process your merchandise in another country and thereby claim that the merchandise originated in that third country and not China?  It may be possible to change the country of origin from China to this third company. You may be able to add or subtract components and functions. You may be able to tinker with the packaging. The processing should be enough so that the country of origin is now the third country and not China.   
 
But how much processing in the third country is enough? Unfortunately, CBP gives conflicting guidance. In N298549 issued on July 31, 2018, steel tubing manufactured in the United States was exported to Mexico where stuff was done to the steel tubing, like painting, before being imported back to the United States.  CBP applied the NAFTA “essential character” rule of origin test, i.e., the country where the raw piping came from, in this instance, the USA.  Since it was a domestic-origin product, the importer did not owe customs duties, including not owing the Section 232 tariffs that would have applied if the country of origin had been Mexico. The NAFTA rule of origin determined whether the tariff was owed.     
 
Now let’s look at HQ H301619, a second ruling from CBP, but this one issued on November 6, 2018 to completely different results, and this time as applied to Section 301 tariffs, not Section 232.  CBP concluded that there are actually two different kinds of country of origins:  for marking and for Section 301 tariffs. Here the components were produced in China, but then shipped to Mexico where they were assembled into electric motors. For marking purposes, CBP found the country of origin under NAFTA was now Mexico and no longer China. However, CBP also found that product did not undergo sufficient substantial transformation so that the country of origin for Section 301 purposes remained China with the 25% tariff, even as the importer had to mark the electric motors with Made in Mexico. CBP echoed this bifurcated reasoning but to different results in N302987, a ruling issued in March 11, 2019.  Thus, country of origin for marking purposes may not always be synonymous with NAFTA country of origin and, furthermore, substantial transformation, instead of NAFTA country of origin, may have to be used to figure out if Section 301 tariffs apply.  

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COM_a3
12.
R. Bunner, K. Fässler & P. Henschel: “
What Do Swiss Companies Have to Take into Account Regarding Customs and Export Control?”
(Source:
MME
, 15 Apr 2019.) [Excerpts.]
 
* Authors: Raphael Bunner, Esq.,
raphael.brunner@mme.ch
; Karl Fässler, Esq.,
karl.faessler@mme.ch
; and Peter Henschel, Esq.,
peter.henschel@mme.ch
. All of MME, Zurich, Switzerland.
 
(I) Introduction to Brexit
 
At present, relations between Switzerland and the United Kingdom are largely based on the bilateral agreements with the European Union (EU), which will no longer apply to the United Kingdom following its exit from the EU (possibly after a transitional period). In its relationship with the United Kingdom, Switzerland intends to safeguard and, if necessary, extend existing mutual rights and obligations following the United Kingdom’s withdrawal from the EU.
 
The exit agreement negotiated between the United Kingdom and the EU provides for a transitional period that would last from March 29, 2019 to at least December 31, 2020 (“deal scenario”). During this transitional period, the United Kingdom would remain part of the European internal market and customs union. The provisions of the bilateral agreements between Switzerland and the EU would therefore continue to apply to relations between Switzerland and the United Kingdom, i.e. nothing would change compared to the current situation.
 
Since it remains uncertain whether the negotiated withdrawal agreement between the United Kingdom and the EU will be ratified, it is possible that the transition phase will not come into effect and the United Kingdom will leave the EU in a “disorderly” manner (“no-deal”; “hard Brexit”). Switzerland signed a trade agreement with the United Kingdom on February 11, 2019. This text lays the foundations for future economic and trade relations between the two countries, both in the event of the United Kingdom’s disorderly withdrawal from the EU (“no deal”) and in the event of the United Kingdom’s orderly withdrawal from the EU (“Deal”) at the end of the transition period.
 
(II) Current Status
 
The relationship between Switzerland and the United Kingdom will change after a hard Brexit. The United Kingdom was originally due to leave the EU on March 29, 2019. The EU offered the UK to postpone Brexit until May 22, 2019 provided that the House of Commons agrees to the withdrawal agreement. Otherwise, the extension would only be applied until April 12, 2019.
 
Should the United Kingdom leave the EU in a disorderly manner (“no deal”; “hard Brexit”), the bilateral trade agreement between Switzerland and the United Kingdom will be applied provisionally as of the date of the exit.
 
(III) Impact on Customs Duties …
 
(IV) Effects on Export Monitoring
 
The United Kingdom’s withdrawal from the EU has also brought about changes in the area of export-monitoring. In contrast to many other areas, however, necessary legal preparatory measures were taken as a precautionary measure in the area of export control.
 
(A) Relationship United Kingdom – EU
 
The United Kingdom will implement the European Dual-Use Regulation into national law at the time of Brexit. The foundation for this is laid within the European Union (Withdrawal) Act 2018. After Brexit, the United Kingdom will be able to perform adjustments to national legislation with regard to the “Trade etc. in Dual-Use Items Firearms and Torture etc. Goods (Amendment) (EU Exit) Regulations 2019”. There likely will be a drift away from the EU regime in the medium term. Already in the “Sanctions and Anti-Money Laundering Act 2018”, a new national element deviating from the international and EU standard has been included in United Kingdom law, namely the listing of persons or organizations by a description (“designation by description”).
 
In preparation for a “no-deal” scenario, the United Kingdom published a new Open General Export License” (OGEL) on February 1, 2019 (here), which allows the export of dual-use goods from the United Kingdom to the EU without a costly license application. Prerequisite is a registration in the license system SPIRE with the corresponding documentation for transaction auditing. The new OGEL would come into force at 11pm on the day of departure.
 
The EU, on the other hand, has already submitted a proposal for the adaptation of Council Regulation 428/2009. Accordingly, in a “no-deal” scenario, the United Kingdom is included in the EU001, the list of “safe” third countries to which exports of most dual-use goods with only low compliance requirements are possible.
 
(B) Relationship United Kingdom-Switzerland
 
For Swiss exporters, the withdrawal of the United Kingdom from the EU leads to few changes within the area of export monitoring. The export of dual-use goods to the United Kingdom has always required a license. The United Kingdom is already explicitly listed in Annex 7 of the Goods Control Regulation and is therefore one of the countries covered by a general export license under Article 12(1). Adjustments for exports from Switzerland to the United Kingdom after a Brexit are therefore not necessary within this scope. Furthermore, in regard to transactions to which individual license-requests apply, practically nothing changes.
 
The United Kingdom, on the other hand, initially incorporates the EU export monitoring regime into national law. Switzerland is currently listed on the safe countries list of the EU 001 general export licenses and can therefore continue to benefit from a simplified export with low compliance requirements, probably as UK001. Here, too, the Brexit may result in only marginal changes to the designation and the corresponding declaration and documentation.
 
(C) Operational Effects on Export Monitoring
 
Although the necessary regulatory adjustments in the area of
export monitoring have already been planned, in practice there will probably be delays, especially in the registration and authorization of exports from the United Kingdom, as the authorities will have to process a large number of new registrations and license applications. Operational delays are also expected in the declaration and clearance of dual-use consignments at UK customs for both import and export.
 
(V) Effects on Trading Relations …

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TEEX/IM TRAINING EVENTS & CONFERENCES

TE_a113. ICPA Presents “2019 EU Conference”, 15-17 May in London

(Source:
ICPA)
 
* 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
here.
* * * * * * * * * * * * * * * * * * * *

TE_a214.
FCC Presents “Designing an Internal Compliance Program for Export Controls & Sanctions”, 1 Oct in Bruchem, the Netherlands

 
This training course is designed for compliance officers, managers, and other professionals who aim to enhance their organization’s compliance efforts. The course will cover multiple topics and tackle various key questions, including but not limited to:
  – Setting the Scene: ensuring compliance in the export control and sanctions arena
  – What is expected from your organization? A closer look at the official frameworks and guidelines from U.S. and European government agencies
  – Key elements of an ICP
  – Best practice tips for enhancing your current compliance efforts  
  – Internal controls samples (policies, procedures, instructions)
  – Strategic benefits of having an ICP.
 
* What: Designing an Internal Compliance Program for Export Controls & Sanctions”
* Date: Tuesday, 1 Oct 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 – 4.30 pm
* Level: Intermediate
* Target Audience:  the course provides valuable insights for both compliance professionals, employees and (senior / middle) management working in any industry subject to U.S. and/or EU (member state) export control laws and sanctions regulations.
* Instructors: Drs. Ghislaine C.Y. Gillessen RA and Marco M. Crombach MSc.
* Information & Registration: click
here or contact us at 
events@fullcirclecompliance.eu or 31 (0)23 – 844 – 9046. 

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ENEDITOR’S NOTES

*
Anatole France (born François-Anatole Thibault, 16 Apr 1844 – 12 Oct 1924; was a French poet, journalist, and successful novelist with several best-sellers. Ironic and skeptical, he was considered in his day the ideal French man of letters. He was a member of the Académie Française, and won the 1921 Nobel Prize in Literature “in recognition of his brilliant literary achievements, characterized as they are by a nobility of style, a profound human sympathy, grace, and a true Gallic temperament”.)
  – “An education isn’t how much you have committed to memory, or even how much you know. It’s being able to differentiate between what you know and what you don’t.”
  – “You learn to speak by speaking, to study by studying, to run by running, to work by working; in just the same way, you learn to love by loving.”

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EN_a316
. 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.   

 

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_a0317
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

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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.


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