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19-0426 Friday “Daily Bugle”

19-0426 Friday “Daily Bugle”

Friday, 26 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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.

[No items of interest noted today.] 

  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 Published Update Regarding Foreign Interference in U.S. Elections Sanctions Regulations
  5. EU Amends Restrictive Measures Concerning ISIL (Da’esh) and Al-Qaida
  1. Breaking Defense: “Build A ‘Five Eyes’ for Military Tech Sharing: Greenwalt”
  2. IE&IT Launches “Export Control Profession” for UK Compliance Professionals
  3. The National Post: “Should Canadian Technology Be Used to Stifle Free Speech?”
  1. F. Kenlon: “Big News in Defense Exportability”
  2. K. Meloni, T. Petch & S. Powell: “Brexit Essentials: Is a Customs Union the Path to Brexit? (Part II of II)”
  3. M. Volkov: “DOJ and OFAC Announce Another Sanctions Settlement – UniCredit Group Banks Pay Over $1.3 Billion and Subsidiary Bank Agrees to Plead Guilty for Violating Iran Sanctions”
  4. The FAQ of the Day: Export Control Reform and Foreign Military Sales
  1. ECS Presents “ITAR/EAR Bootcamp: Achieving Compliance” on 8-9 Jul in Seattle, WA
  2. FCC Presents “U.S. Export Controls: The Export Administration Regulations (EAR) from a non-U.S. Perspective”, 27 November in Bruchem, the Netherlands
  3. List of Approaching Events: 138 Events Posted This Week, Including 6 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 Apr 2019), DOT/FACR/OFAC (15 Mar 2019), HTSUS (18 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.] 

back to top
 

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OGSOTHER GOVERNMENT SOURCES

OGS_a11
. Items Scheduled
for Publication in Future Federal Register Editions

(Source:
Federal Register
)

 

* Treasury/OFAC; RULES; Foreign Interference in U.S. Elections Sanctions Regulations [Pub. Date: 29 Apr 2019.]   

 
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OGS_a22
. Commerce/BIS: (No new postings.)

(Source: Commerce/BIS)

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OGS_a33.
State/DDTC: (No new postings.)

(Source:
State/DDTC)

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OGS_a4
4.
Treasury/OFAC Published Update Regarding Foreign Interference in U.S. Elections Sanctions Regulations

(Source:
Treasury/OFAC, 26 Apr 2019.)
 
The Office of Foreign Assets Control (OFAC) is
issuing regulations to implement Executive Order 13848 of September 12, 2018 (“Imposing Certain Sanctions in the Event of Foreign Interference in a United States Election”). These regulations are currently available for public inspection with the Federal Register and will take effect upon publication in the Federal Register on April 29, 2019. OFAC intends to supplement this part 579 with a more comprehensive set of regulations, which may include additional interpretive and definitional guidance and additional general licenses and statements of licensing policy.

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OGS_a5
5
.
EU Amends Restrictive Measures Concerning ISIL (Da’esh) and Al-Qaida

(Source:
Official Journal of the European Union, 26 Apr 2019.)
 
Regulations
*
Commission Implementing Regulation (EU) 2019/663 of 25 April 2019 amending for the 300th time Council Regulation (EC) No 881/2002 imposing certain specific restrictive measures directed against certain persons and entities associated with the ISIL (Da’esh) and Al-Qaida organizations

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NWSNEWS

NWS_a016.
Breaking Defense: “Build A ‘Five Eyes’ for Military Tech Sharing: Greenwalt”
(Source:
Breaking Defense, 23 Apr 2019.) [Excerpts.]
 
As the U.S. and its allies scramble to stay ahead of China and Russia, a bold proposal for a massive revamp of tech sharing emerges.
 
A new report calls for a major revamp of the rules for how the U.S. and a handful of allies develop and share critical military technologies, one modeled on the storied Five Eyes intelligence-sharing agreement between Washington and a several friendly governments.
 
The paper, set to be released Tuesday afternoon during an event at the Atlantic Council, outlines an ambitious new policy of “harmonizing policies and practices in areas including regulating direct foreign investment, technology transfer, research and development, supply chain, and communications and information-technology infrastructure security,” to ensure that the US and allies are rowing in the same direction on sensitive new technologies, writes Bill Greenwalt, former deputy Defense undersecretary for industrial policy. …
 
The report also contains several legislative reforms Congress would have to undertake.
 
  – The first is establishing a National Technology Industrial Base Quadrilateral Council, whose chairman would meet regularly with allies to focus on how to integrate policies and procedures.
  – Next, expand the “Canadian Exemptions” in the ITAR law to include the UK and Australia. The exemptions in part
allow defense materials to be moved across the U.S.-Canadian border without licenses, subject to review by the Defense Secretary.
  – Allowing defense articles and services classified at the Secret, Confidential, and Unclassified to be transferred between countries in the [National Technology and Industrial Base (NTIB)]. …

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NWS_a27.
IE&IT Launches “Export Control Profession” for UK Compliance Professionals

(Source:
IE&IT, 26 Apr 2019.) [Excerpts.]
 
The UK Institute of Export & International Trade (IE&IT) is delighted to be launching a new ”
Export Control Profession” for people involved in export and import control and trade sanctions compliance.
 
To mark the soft launch of this new body, the Institute will be running an “Open to Export webinar” about the importance of professional knowledge around Export Controls, which will be taking place at 14.00 – 15.00 (BST) on Thursday 2nd May 2019.
 
Speaking on the webinar will be Claire Harrison (Department for International Trade – Export Control Joint Unit) and Roger Arthey (formerly Head of Export Control Compliance, Rolls-Royce plc). Both speakers were involved in the formation of the new profession, and sit on its leadership board.
 
More information and registration details for the webinar can be found
here.
 

The new body will be officially launched at the Department for International Trade’s Export Controls Symposium on Thursday 30th May 2019. Read more about the new profession here. …  

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

NWS_a38.
The National Post: “Should Canadian Technology Be Used to Stifle Free Speech?”

(Source:
The National Post, 25 Apr 2019.) [Excerpts.]
 
A successful Canadian-founded tech company may have helped the Egyptian government block upwards of 34,000 internet domains in Egypt, as part of a coordinated state effort to silence opposition during Egypt’s constitutional referendum. …
 
The blockage was made possible by Deep Packet Inspection (DPI) devices, produced by the Waterloo, Ont.-based company Sandvine, according to a report from the University of Toronto’s Citizen Lab in March 2018. Deep Packet Inspection technology allows the content of data packets that are being processed and transferred across the internet to be identified and redirected. DPI can be used benignly, to ensure data is free of viruses, but it can also be used for censorship. …
 
The DPI device marketplace, like many emerging technologies, is unregulated. There are no export controls for devices like those Sandvine may have sold to the Egyptian state. The Wassenaar Arrangement, established to control conventional arms and dual-use technologies, exempts these devices from export controls. This places an added burden on countries that produce these technologies to develop regulatory frameworks of their own. Canada cannot tackle this problem alone; indeed, Sandvine itself is now owned by an American firm. Any effective international agreement would need widespread support across the globe to prevent companies from just setting up subsidiaries in countries with weaker or non-existent regulation. …

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COMCOMMENTARY

COM_a09.
F. Kenlon: “Big News in Defense Exportability”

(Source: Author’s LinkedIn page, 24 Apr 2019.)
 
* Author: Frank Kenlon, Professor of Int’l Acquisition (Intermittent) at Defense Acquisition University.
 
The Chairman of the Joint Requirements Oversight Council (JROC) published a Memo establishing new Joint Capability Integration and Development System (JCIDS) requirements for building defense exportability on April 15, 2019 (JROCM 025-19). This JROCM establishes three new defense exportability policy principles and practices that will be implemented from this point onward in the DoD JCIDS capability requirements development, evaluation, and approval process:
 
a) DoD international engagement stakeholders – both DoD Component International Program Organizations (IPOs) and three key DoD-level organizations involved in International Cooperative Programs, Security Cooperation, and Technology Security and Foreign Disclosure – will be included in the formal staffing and coordination for all JCIDS documents.
 
b) Allied/partner interoperability will be included in the CONOPS section of JCIDS Initial Capabilities Documents (ICDs).
 
c) Standard defense exportability language will be included as a Key System Attribute (KSA) in JCIDS Capability Development Documents (CDDs) for systems with export potential as determined by the Milestone Decision Authority (MDA) at Milestone A.
 
The JROC Memo encourages DoD Components to begin incorporating these Defense Exportability aspects into current and future JCIDS requirements documents. The next issuance of the JCIDS Manual will be updated to reflect these changes.
 
Why Now?
 
The publication of this new JROCM was a direct result of the Administration’s Conventional Arms Transfer (CAT) policy implementation efforts, specifically Line of Effort 2.7, “Build-in exportability, coalition interoperability & standardization.” In addition to these JCIDS Manual modifications on defense exportability in the requirements management area, changes to DoD 5000 series acquisition policy documents to strengthen its exportability policy precepts and practices are reportedly under consideration within the Office of Secretary of Defense/Acquisition & Sustainment organization.
 
Potential Impact?
 
Proponents of defense exportability have been advocating for this JCIDS policy change for many years. The logic behind this change is simple but powerful – the DoD acquisition community and resource allocation process establish priorities based on JCIDS capability requirements. Up to this point, JCIDS consideration of defense exportability in the capability requirements development and approval process has been generally viewed as “optional” rather than “mandatory.”
 
As a result, defense exportability has often ended up as a “nice to have” unfunded area rather a high priority requirement that the DoD acquisition community must accomplish. This occurred despite the fact that historical analysis of past DoD acquisition programs shows that nearly 90% of DoD weapon systems and equipment are exported to allied/friendly nations at some point in the life-cycle. As a result, International Cooperative Program and Defense Sales & Transfers initiatives intended to support the USG’s National Strategy and Security Cooperation policy objectives often take longer (and are more expensive) than necessary. Even worse, in some cases U.S. defense sales opportunities are lost, with a corresponding negative impact on coalition interoperability and government/industry economic and industrial base benefits.
 
Will this JCIDS change actually improve DoD’s acquisition program defense exportability performance to help achieve the U.S. Government National Security and National Defense Strategy guidance that emphasizes the importance of strengthening alliances and attracting new partners? While it’s still “early days” it’s a great first step.
 
Way Ahead
 
Let’s hope that in this era of Agile Acquisition, DoD Program Managers and Integrated Product Teams start to tackle this new challenge immediately rather than wait for publication of revised DoD 5000 series policy guidance. There are several defense exportability success stories out there – and numerous Defense Exportability Features (DEF) Pilot Programs that are available as potential models – that could be used to expand defense exportability efforts across the DoD enterprise. Why wait? Let’s get started today!

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COM_a110.
K. Meloni, T. Petch & S. Powell: “Brexit Essentials: Is a Customs Union the Path to Brexit? (Part II of II)”

(Source:
Slaughter and May, 18 Apr 2019.)
 
* Authors: Katherine Meloni, Esq.,
kathrine.meloni@slaughterandmay.com
; Tolek Petch, Esq.,
tolek.petch@slaughterandmay.com
; and Stephen Powell, Esq.,
stephen.powell@slaughterandmay.com.
All of Slaughter and May.  


 
Could the UK pursue an independent trade policy on goods if it entered into a customs union with the EU?
 
No. The UK would be prohibited from concluding free trade agreements on goods with countries with which the EU did not have a free trade agreement, or from offering more advantageous terms to such countries. The EU would remain free to negotiate free trade agreements with countries that did not wish to enter into a free trade agreement with the UK.
 
As services are excluded from a customs union, the UK could negotiate free trade agreements with third countries on services. This would also be the case for any goods that are not covered by a customs union.
 
Would the UK have a say in free trade agreements negotiated by the EU?
 
Under the EU Treaties the Council authorises the Commission to open negotiation on free trade agreements as it is an exclusive EU competence. The Commission is an organ of the EU and cannot represent non-Member States, so the UK would need to negotiate free trade agreements in parallel. Whilst the terms of an EU-UK customs union could require the EU to consult with the UK, this would be a matter for political negotiation. In the context of the EU-Turkey customs union, the EU looks at its own commercial interests and has no duty to take into account the interests of Turkey.
 
Would a customs union ensure frictionless trade between the UK and EU?
Of itself, the answer is no. Unless the customs union covered all goods, and the regulatory standards were the same in the UK and EU, there would need to be regulatory checks to ensure that imports from the EU into the UK comply with UK requirements and vice versa. As a result of its partial nature, there are considerable delays at the EU- Turkish border while regulatory checks are carried out in areas not harmonised by the customs union. These relate mainly to certain “technical barriers to trade” (i.e. those EU regulatory standards which Turkey does not apply) and sanitary and phytosanitary checks (i.e. animal and plant welfare and standards) as the EU-Turkey customs union excludes agricultural (other than processed agricultural) products. Unless the UK agreed to form a common regulatory area with the EU, and a common veterinary area, checks would be inevitable absent mutual recognition of standards (which is not current international or EU practice).
 
Would a customs union obviate the need for customs declarations and customs checks?
 
The EU’s view would seem to be no and customs declarations would need to be filled out as is the current practice between the EU and Turkey. Customs checks would be simplified, but checks for illegal immigration, people smuggling, contraband and fraud would presumably be needed. If there is no common veterinary area, then current EU law requires plant and animal checks to take place at the border.
 
Would a customs union entail free movement of people?
 
No.
 
Would a customs union eliminate the need for visas for business travel or other permits?
 
No. This would be a matter for negotiation between the EU Member States and the UK. The EU Member States currently require visas for Turkish nationals entering the EU and may require UK business visitors (including UK truckers) to obtain visas. For Schengen area countries this would be a common decision. Countries outside of Schengen (such as Ireland and Cyprus) would make their own decision as immigration is a national competence. EU Member States currently place quotas on Turkish vehicles entering the EU, while Turkey maintains a monopoly on loading at Turkish ports. As these are national competences, the UK would need to negotiate appropriate arrangements with the Schengen countries and individually with each other EU Member State.
 
Would a customs union give the UK access to EU agencies?
 
No. Access to EU agencies such as the European Medicines Agency or the European Aviation Safety Agency (EASA) would not be part of a EU-UK customs union and would need to be separately negotiated. Turkey is not a member of EASA or the European Medicines Agency, although the EFTA Member States are members of EASA.
 
Are there additional steps the UK could take to facilitate free trade in goods or services beside a customs union?
 
Yes. If the UK wished to secure free trade in goods and services it could, in addition to forming a customs union, participate in the single market. There is no existing model that incorporates single market membership with a customs union, but there would not seem to be any legal impediment to such an arrangement being negotiated provided that the parties agreed (including Iceland, Liechtenstein, Norway and Switzerland). It would, however, require not only UK compliance with EU trade policy, but also regulatory alignment with the EU in areas covered by the single market. The UK would not have any vote on single market measures that would apply to the UK.
 
Would an EU-UK customs union avoid the need from the EU’s perspective for the Irish backstop?
 
This is most unlikely as an EU-UK customs union could be terminated by the UK giving notice. The EU is therefore likely to insist on a backstop in the case that, on the expiry of any transition period, alternative arrangements have not been found to maintain a frictionless border on the island of Ireland.
 
Would the UK need to contribute to the EU budget under a customs union?
 
Not directly, but, under a customs union, it would be a matter for negotiation how customs receipts were allocated.
 
What would be the role of the Court of Justice of the European Union (CJEU) in interpreting the common rules applicable under a customs union?
 
The CJEU takes the view that the autonomy of EU law means that it must have the exclusive right to interpret EU law. This is reflected in the draft Withdrawal Agreement negotiated by the UK with the EU. That said, under the customs union with Turkey, Turkey has to agree for a dispute to be submitted to the CJEU. The EU is unhappy with the existing dispute settlement mechanism with Turkey.
 
Will the EU negotiate a customs union with the UK without ratification of the draft Withdrawal Agreement?
 
The EU has stated publicly that ratification of the Withdrawal Agreement is a precondition to negotiations on the future relationship between the EU and the UK.

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COM_a211. M. Volkov: “DOJ and OFAC Announce Another Sanctions Settlement – UniCredit Group Banks Pay Over $1.3 Billion and Subsidiary Bank Agrees to Plead Guilty for Violating Iran Sanctions”

(Source:
Volkov Law Group Blog, 24 Apr 2019. Reprinted by permission.)
 
* Author: Michael Volkov, Esq., Volkov Law Group,
mvolkov@volkovlaw.com, 240-505-1992.
 
The Justice Department and the Treasury Department’s Office of Foreign Asset Control (OFAC) are on a roll. Global banks are facing renewed prosecutions, along with aggressive sanctions prosecutions of companies for integrating acquisitions and supply chain missteps.
 
In the latest billion-dollar plus settlement, UniCredit Bank S.p.A UC Group), based in Milan, Italy and two subsidiaries, UniCredit Bank AG (UCB AG), a German bank (aka HypoVereinsbank), and UniCredit Bank Austria (BA), which is located in Vienna, Austria, settled with DOJ, OFAC, the New York District Attorney’s Office, the New York State Department of Financial Regulation Services, and the Federal Reserve, for its pervasive conduct violating the US Iran sanctions program and OFAC’s prohibition against entities designated as a weapons of mass destruction proliferator.
 
UCB AG agreed to plead guilty to violating the International Emergency Economic Powers Act (IEEPA) and to defraud the United States by processing $393 million dollars of transactions through the US financial system for the Islamic Republic of Iran Shipping Lines, which is designated as a weapons of mass destruction proliferator, and other Iranian entities subject to US sanctions. Under the plea agreement, UCB AG agreed to pay approximately $316.5 million and a fine of $468.35 million. UCB AG also entered into a plea agreement with the New York District Attorney’s Office and agreed to pay $316.5 million
 
UniCredit Bank Austria (BA), which is located in Vienna, Austria), and is another bank in the UC Group, agreed to a non-prosecution agreement and to forfeit $20 million for its violations of IEEPA involving Iran and other sanctions programs.
 
UC Group, UCB AG and BA entered in settlement agreements with OFAC, the Federal Reserve and the NY State Department of Financial Services under which they will pay penalties totaling $660 million, consisting of $611 million to OFAC (which will be satisfied in part by payments to DOJ and the Federal Reserve), $157 million to the Federal Reserve, and $405 million to NY DFS.
 
Reviewing the Illegal Conduct
 
Sometimes companies make no attempt to even try to comply with US Sanctions. When the financial benefit on the other side of ledger is high, greed can take over reason, compliance and any pretense of ethical commitment. It is rare to see such blatant conduct formalized in written policies and procedures, and some may scoff at my focus on this by rationalizing that sometimes companies do not put a culture of violation in writing but adhere to an unwritten code of conduct that sanctions such illegal conduct.   I cannot help but wonder how a compliance officer can even attempt to operate in a business where the policies and procedures dictate a control designed to violate the law.
 
UCB AG created a policy manual that instructed employees to process transactions with Sanctioned Entities in an “OFAC-neutral” manner so that “no US bank can see OFAC contents” in any payment message processed through U.S. financial institutions. UCB AG employees removed names and other identifying information relating to sanctioned entities.
 
In particular, UCB AG opened US dollar accounts for the Islamic Republic of Iran Shipping Lines and automatically transferred amounts from related entities to the IRISL primary account.
 
Interestingly, the written policies and procedures were not subject to legal review and implemented with the authorization and knowledge of senior management, a specific steering committee implementing the manual and the involvement of numerous employees. OFAC specifically noted that UCB AG conducted a cost-benefit analysis of its customers involved in OFAC prohibited transactions to determine whether to continue to process these transactions based on whether a customer was a “profitable” customer, stating that “customer relationships which generate no earning should not be continued. The employee stated that transactions related to profitable business should “be structured in a way that they will not become conspicuous.”
 
OFAC designated IRISL, its related companies and vessels in September 2008 because of their involvement in weapons of mass destruction proliferation activity. Starting in October 2008, UCB AG processed a $3.6 million-dollar transaction by concealing the sanctioned entity from the US bank. Overall, OFAC noted that between January 3, 2007 and December 27, 2011, UCB AG processed 2,158 payments totaling $527 million through US financial institutions in violation of various sanctions programs. In addition to the IRISL transactions, UCB AG processed a number of transactions where documentation contained references to shipment of oil to Iran.
 
Bank Austria’s violations involved 127 transactions that violated the Iran, Sudan, Burma, Cuba and Syria Sanctions Programs, respectively. Bank Austria processed illegal transactions up to and including 2012 and relied on nontransparent payment practices to process transactions to or through the United States to disguise the involvement of the sanctioned parties.
 
UC Group violated OFAC regulations by conducting 612 transactions in violation of the Cuba, Iran, Burma, Sudan and Syrian Sanctions programs.

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COM_a312.
The FAQ of the Day: Export Control Reform and Foreign Military Sales

(Source:
State/DDTC, 27 Apr 2018.)
 
Q: For the last 10 years, our company has been responsible for exporting several defense articles under a particular Foreign Military Sales (FMS) contract. However, with the recent revisions to USML categories, nearly all of the items we manufacture have transitioned from USML- to Commerce Control List (CCL)-control. Provided the scope of the Letter of Offer and Acceptance (LOA) has not changed, how does the transition of our articles to the CCL impact the manner in which we may continue to fulfill our FMS obligations?
 
A: In general, the effect Export Control Reform has had on the FMS program has been minimal. Per the EAR, §734.3(b)(1)(vi), “… items that would otherwise be subject to the EAR and that are sold, leased or loaned by the Department of Defense to a foreign country or international organization under the Foreign Military Sales (FMS) Program of the Arms Export Control Act, pursuant to a Letter of Offer and Acceptance (LOA) authorizing such transfers, are not ‘subject to the EAR’ but rather, are subject to the authority of the Arms Export Control Act.”

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TEEX/IM TRAINING EVENTS & CONFERENCES

TE_a013
. ECS Presents “ITAR/EAR Bootcamp: Achieving Compliance” on 8-9 Jul in Seattle, WA 

(Source: S. Palmer,
spalmer@exportcompliancesolutions.com
.)
 
* 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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TE_a214
.
FCC Presents “U.S. Export Controls: The International Traffic in Arms Regulations (ITAR) from a non-U.S. Perspective”, 27 November in Bruchem, the Netherlands

 
This intermediate-level training course is specifically designed for compliance professionals and those in a similar role who aim to stay up-to-date with the latest Export Administration Regulations (EAR) requirements that apply to non-U.S. transactions.
 
The course will cover multiple topics relevant for organizations outside the U.S. that are subject to the Export Administration Regulations, including but not limited to: the U.S. regulatory framework, key EAR concepts and definitions, tips regarding classification and licensing, essential steps to ensure an EAR compliant shipment, how to handle a (potential) non-compliance issue, recent enforcement trends, and the latest regulatory amendments, including the latest U.S. Export Control Reform developments. Participants will receive a certification upon completion of the training.
 
Details
* What: U.S. Export Controls: The Export Administration Regulations (EAR) from a non-U.S. Perspective
* When: Wednesday, 27 Nov 2019
  – Welcome and Registration: 9.00 am – 9.30 am
  – Training hours: 9.30 am – 4.30 pm
* Where: Full Circle Compliance, Landgoed Groenhoven, Dorpsstraat 6, Bruchem, the Netherlands
* Information & Registration:
here or contact FCC at
events@fullcirclecompliance.eu or + 31 (0)23 – 844 – 9046
* This course can be followed in combination with “U.S. Export Controls: The International Traffic in Arms Regulations (ITAR) from a non-U.S. Perspective” (26 Nov 2019), and/or “The ABC of Foreign Military Sales” (29 Nov 2019). Please, look at our website for combo deals.

 

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TE_a315. 
List of Approaching Events: 138 Events Posted This Week, Including 6 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
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 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 9: Traverse City, MI; “Export Control Overview Compliance Training“; Networks Northwest

* 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: Chicago, IL; “Trade Compliance & Policy” C.H. Robinson

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

* May 30: London, UK; “London Export Control Symposium“; UK/DIT
* May 30: London, UK; “Post Brexit Documentation and Compliance“; 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

* Jun 25: London, UK; “Introduction to Export Licensing Controls“; The Institute of Export and International Trade
* Jun 26-28: Washington D.C.; “American Association of Exporters and Importers (AAEI) Conference“; AAEI

*
 
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 1-2: Torrance, CA; “Customs Compliance for Import Personnel” Foreign Trade Association

* 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 25-26: Amsterdam, the Netherlands; “Defence Exports Annual Conference“; SMI

*
 
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

* Feb 24-26; Las Vegas, NV; “Winter Back to Basics Conference“; Society for International Affairs

 
Webinars 



* 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_a116
. Bartlett’s Unfamiliar Quotations

(Source: Editor)

 

* Ludwig Wittgenstein (Ludwig Josef Johann Wittgenstein; 26 Apr 1889 – 29 Apr 1951; was an Austrian philosopher who worked primarily in logic, the philosophy of mathematics and the philosophy of language. His Philosophical Investigations appeared as a book in 1953, and has since come to be recognized as one of the most important works of philosophy in the 20th century. His teacher, Bertrand Russell, described Wittgenstein as “the most perfect example I have ever known of genius as traditionally conceived; passionate, profound, intense, and dominating”.)
  – “Philosophy is not a theory but an activity.” 
  – “A philosopher who is not taking part in discussions is like a boxer who never goes into the ring.”
 
* Henry Wadsworth Longfellow (27 Feb 1807 – 24 Mar 1882; was an American poet and educator whose works include Paul Revere’s Ride, The Song of Hiawatha, and Evangeline. He was also the first American to translate Dante Alighieri’s Divine Comedy.)
  – “The heights by great men reached and kept were not attained by sudden flight, but they, while their companions slept, were toiling upward in the night.”
 

Friday’s funnies:

Did you hear about the Buddhist who refused Novocaine during a root canal? His goal: transcend dental medication.
* The only difference in my life when I’m on a diet is instead of saying, “I ate nachos,” I say, “I accidentally ate nachos.”
* Q. What is the most frequent lie nowadays?  A. “I have read and agree to the Terms & Conditions.”

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

EN_a217. 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 Apr 2019: 84 FR 16398-16402: International Traffic in Arms Regulations: Transfers Made by or for a Department or Agency of the U.S. Government 
  – 
The only available fully updated copy (latest edition: 19 Apr 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:
18 Apr 2019:
Harmonized System Update (HSU) 1906

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

EN_a318
. 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, Vincent J.A. Goossen and Alex 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 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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