;

19-0607 Friday “Daily Bugle”

19-0607 Friday “Daily Bugle”

Friday, 7 June 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. Contact us for advertising  

inquiries and rates
[Correction:  Yesterday’s Daily Bugle contained an error in the Table of Contents and first line for Item #2, which should have read: “2. State Debars 23 Individuals for Violating or Conspiring to Violate the AECA”.]

[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 Announces Maintenance Outage for 8-9 June 
  4. DHS/CBP Publishes Guidance Fifth Round of Products Excluded from Section 301 Duties 
  5. DHS/CBP Updates ACE Cargo Release Status Notification Guide 
  6. State/DDTC: (No new postings.) 
  7. Western Union Financial Services to Pay $401,697 to Settle OFAC Charges of Sanctions Regulations
  1. Deutsche Welle: “The EU Stands by Cuba Despite US Sanctions”
  2. Financial Times: “Google Warns of US National Security Risks from Huawei Ban”
  3. HLP: “Resolutions Introduced to Impose Conditions on Weapons Sales to Saudi Arabia, UAE”
  4. Reuters: “New U.S. Sanctions Target Iran’s Petrochemical Industry”
  1. D. Noah: “How Exporters Can Identify Import Country Requirements”
  2. M. Volkov: “Putting Together Your Sanctions Compliance Program: Management Commitment (Part I of IV)”
  1. FCC Presents “U.S. Export Controls: The EAR from a non-U.S. Perspective”, 27 Nov in Bruchem, the Netherlands 
  2. List of Approaching Events: 160 Events Posted This Week, Including 13 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 (24 May 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 (5 Jun 2019), HTSUS (21 May 2019) 
  3. Weekly Highlights of the Daily Bugle Top Stories 

EXIMITEMS FROM TODAY’S FEDERAL REGISTER

  
[No items of interest noted today]
 
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OGSOTHER GOVERNMENT SOURCES

OGS_a11
. Items Scheduled
for Publication in Future Federal Register Editions

(Source:
Federal Register
)

 

* Commerce/BIS; RULES; Implementation of New Commerce Section 232 Exclusions Portal [Pub. Date: 10 June 2019.]
 
* Treasury; NOTICES; Agency Information Collection Activities; Proposals, Submissions, and Approvals: OFAC Application for the Release of Blocked Funds [Pub. Date: 10 June 2019.]
 
* USTR; NOTICES; Additional Implementing Modification to Section 301 Action: China’s Acts, Policies, and Practices Related to Technology Transfer, Intellectual Property, and Innovation [Pub. Date: 10 June 2019.]

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

(Source: Commerce/BIS)

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OGS_a33
. DHS/CBP Announces Maintenance Outage for 8-9 June

(Source: CSMS #19-000285, 6 June 2019.)
 
There will be an extended ACE maintenance outage this weekend from 9 PM 6/8/2019 until 4 AM 6/9/2019.

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OGS_a44
. DHS/CBP Publishes Guidance Fifth Round of Products Excluded from Section 301 Duties

(Source: CSMS #19-000289, 7 June 2019.)
 
The purpose of this memorandum is to provide guidance regarding the submission of entries for
imported products covered under the fifth round of the Section 301 product exclusions.
 
BACKGROUND:
 
On June 4, 2019, the U.S. Trade Representative published Federal Register (FR) Notice 84 FR 11573 announcing the decision to grant the fifth round of certain exclusion requests from the 25 percent duty assessed under the Section 301 investigation related to goods from China (Tranche 1). The product exclusions announced in this notice will apply as of the July 6, 2018 effective date and will extend for one year after the publication of this notice.
 
As set out in the Annex to this notice (84 FR 11573), the exclusions are established in two different formats: (1) as an exclusion for an existing 10-digit subheading from within an 8-digit subheading covered by the $34 billion action, or (2) as an exclusion reflected in specially prepared product descriptions. In particular, the exclusions take the form of one 10-digit HTSUS subheading, and 88 specially prepared product descriptions.
 
In accordance with the 83 FR 67463 notice, the exclusions are available for any product that meets the description in the Annex, regardless of whether the importer filed an exclusion request. Further, the scope of each exclusion is governed by the scope of the product descriptions in the Annex to this notice, and not by the product descriptions set out in any particular request for exclusion.
 
The functionality for the acceptance of the fifth round of products excluded from Section 301 duties is available in the Automated Commercial Environment (ACE) as of June 11, 2019.
 
INSTRUCTIONS FOR FILING ENTRIES SUBJECT TO PRODUCT EXCLUSIONS:
 
Instructions on submitting entries to CBP containing products granted exclusions by the USTR from the Section 301 measures in 84 FR (11573) are as follows:
 
In addition to reporting the regular Chapters 84, 85 & 90 classifications of the Harmonized Tariff Schedule of the United States (HTSUS) for the imported merchandise, importers shall report the HTSUS classification 9903.88.10 (Articles the products of China, as provided for in U.S. note 20(m) to this subchapter, each covered by an exclusion granted by the U.S. Trade Representative) for imported merchandise subject to the exclusion.
 
Importers shall not submit the corresponding Chapter 99 HTS number for the Section 301 duties when HTS 9903.88.10 is submitted.
 
ADDITIONAL INFORMATION:
 
Duty exclusions granted by the USTR are retroactive on imports to the initial effective date of July 6, 2018. To request an administrative refund for previous imports of duty-excluded products granted by the USTR, importers may follow the same entry filing instructions as above to file a PSC on unliquidated entry summaries. If the entry has already liquidated, importers may protest the liquidation.
 
Reminder: When submitting an entry summary in which a heading or subheading in Chapter 99 is claimed on imported merchandise, importers should refer to CSMS 18-000657 (Entry Summary Order of Reporting for Multiple HTS in ACE).
 
Imports which have been granted a product exclusion from the Section 301 measures, and which are not subject to the Section 301 duties, are not covered by the Foreign Trade Zone (FTZ) provisions of the Section 301 Federal Register notices, but instead are subject to the FTZ provisions in 19 CFR part 146.
 
For more information, please refer to the June 4, 2019 Federal Register notice 84 FR 11573.
 

Questions from the importing community concerning ACE entry rejections involving product exclusion numbers should be referred to their CBP Client Representative. Questions related to Section 301 entry filing requirements should be emailed to Traderemedy@cbp.dhs.gov. 

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OGS_a55
.
DHS/CBP Updates ACE Cargo Release Status Notification Guide

(Source: CSMS #19-000281, 6 June 2019.)
 
An updated ACE Cargo Release Status Notification Guide is now available here.
 
The Automated Commercial Environment (ACE) is the system through which the trade community reports imports and exports and the government determines admissibility.

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OGS_a66.
State/DDTC: (No new postings.)

(Source:
State/DDTC
)

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OGS_a7
7
. Western Union Financial Services to Pay 
$401,697 to Settle OFAC Charges of Sanctions Regulations
(Source: Treasury/OFAC), 7 June 2019.)
 
The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) today announced a $401,697 settlement with Western Union Financial Services, Inc. (“Western Union”), of Denver, Colorado. Western Union has agreed to settle its potential civil liability for 4,977 apparent violations of the Global Terrorism Sanctions Regulations, 31 C.F.R. part 594 (GTSR). Between December 9, 2010, and March 13, 2015, Western Union processed 4,977 transactions totaling approximately $1.275 million, which were paid out to third-party, non-designated beneficiaries who chose to collect their remittances at a Western Union Sub-Agent in The Gambia, Kairaba Shopping Center (KSC), an entity that was designated by OFAC pursuant to the GTSR on December 9, 2010. OFAC determined that Western Union voluntarily self-disclosed the apparent violations and that the apparent violations constitute a non-egregious case.
 

For more information, please visit the following
web notice

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NWSNEWS

NWS_a018
.
Deutsche Welle: “The EU Stands by Cuba Despite US Sanctions”
(Source: Deutsche Welle, 7 June 2019.) [Excerpts.]
 
At a recent symposium bringing together Cuban officials and EU investors, both sides pledged to support each other, despite US sanctions aimed at economically choking the island.
 
Watch the video here.

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NWS_a29
. Financial Times: “Google Warns of US National Security Risks from Huawei Ban”
(Source: Financial Times, 7 June 2019.) [Excerpts.]
 
Google has warned the Trump administration it risks compromising US national security if it pushes ahead with sweeping export restrictions on Huawei, as the technology group seeks to continue doing business with the blacklisted Chinese company.
 
Senior executives at Google are pushing US officials to exempt it from a ban on exports to Huawei without a licence approved by Washington, according to three people briefed on the conversations.
 
The Trump administration announced the ban after the US-China trade talks collapsed, prompting protests from some of the biggest US technology companies who fear they could get hurt in the fallout. …

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NWS_a310.
HLP: “Resolutions Introduced to Impose Conditions on Weapons Sales to Saudi Arabia, UAE”
(Source: Homeland Preparedness News, 7 June 2019.) [Excerpts.]
 
A group of lawmakers recently introduced 22 separate Joint Resolutions of Disapproval outlining Congress’ role of approving arms sales to foreign governments. …
 
Sens. Todd Young (R-IN), Bob Menendez (D-NJ), Lindsey Graham (R-SC), Chris Murphy (D-CT), Rand Paul (R-KY), Patrick Leahy (D-VT), and Jack Reed (D-RI) said the action stems from Secretary of State Mike Pompeo declaring an emergency waiving the congressional review process for 22 separate arms sales to Saudi Arabia and the UAE – a total of $8.1 billion.
 
“Congress has an essential oversight role in the decision to sell weapons and we must ensure proper procedures are in place in any weapons transfer,” Young said.” In light of the ongoing humanitarian crisis in Yemen, we have an obligation to ensure the adequate guardrails are in place and that weapons transfers to Saudi Arabia and the United Arab Emirates do not exacerbate the conflict.” …

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NWS_a411
. Reuters: “New U.S. Sanctions Target Iran’s Petrochemical Industry”
(Source: Reuters, 7 June 2019.) [Excerpts.]
 
The United States targeted Iran’s petrochemical industry in new sanctions imposed on Friday, including the country’s largest petrochemical holding group over its financial support for the Islamic Revolutionary Guard Corps, the Treasury Department said.
 
The new sanctions come as Washington keeps up pressure against Iran over its ballistic missile program and for waging proxy wars in other Middle Eastern countries.
 
The sanctions target Persian Gulf Petrochemical Industries Company (PGPIC) for providing financial support the economic arm of the IRGC, Iran’s elite military unit in charge of Iran’s ballistic missile and nuclear programs.
 
Treasury also designated the holding group’s network of 39 subsidiary petrochemical companies and foreign-based sales agents. PGPIC and its subsidiaries hold 40% of Iran’s petrochemical production capacity and are responsible for 50% of Iran’s total petrochemical exports, it said. …

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COMCOMMENTARY

COM_a012. D. Noah: “How Exporters Can Identify Import Country Requirements”  

(Source: Shipping Solutions, 5 June 2019.)
 
* Author: David Noah, Founder and President, Shipping Solutions, daven@shipsolutions.com.

 

One of the most costly mishaps an exporter can face is to get their goods to the destination and realize that something was overlooked. Either they made a mistake, the deal was structured incorrectly, or responsibility was overlooked.
 
Often, this happens because sellers get seduced by the thought of a sale and put on blinders for the realities of it. Unfortunately, they end up in a difficult and costly situation because they didn’t think about what steps needed to be taken.
We spoke with EJ Clyman, business development manager at Apex Logistics International, to find out how exporters can avoid this situation by identifying import country requirements. Here’s what he shared.
 
A Look at Import Country Requirements
 
Import country regulations vary widely from country to country. Just as exporters in the U.S. are subject to the nuance of U.S. regulations, countries across the world have varying requirements for importing-many of which begin on the originating side. Requirements extend to shipping (hazmat, dangerous goods, routing, etc.), customs, and beyond, and at customs, different agencies require different things.
 
And while some of these requirements are harmonized, many are not. So how do you identify import country requirements for nearly 200 countries around the world?
 
How to Identify Import Country Requirements
 
Fortunately there are a number of different resources exporters can use to identify import requirements in the countries to which they ship. We identify several of these below:
 
Export.gov
 
The Export.gov website is an amazing resource for finding people who can help you with import country requirements. It’s also a virtual home base for resources from across the U.S. government that assist American businesses and exporters in planning their international sales strategies.
 
The U.S. Commercial Service
 
The U.S. Commercial Service and Export Assistance Centers are priceless resources for companies of every size. They offer a lot of no-cost information and advice and can stand behind you as you begin exporting. The Commercial Service also has offices overseas that can help you find information about destination countries. You can find your local Export Assistance Center or search for international locations using their search tool.
 
State Export Trade Offices
 
Your state may also have trade offices that can help you identify specific requirements for the countries you’re interested in exporting to.
 
Your Freight Forwarder
 
After you review the resources listed above, a good freight forwarding partner will have their offices overseas contact the seller’s client and vet them out. Freight forwarders are “boots on the ground” across the world. They offer a line of communication and local experts who know the culture, language and process and can get you information quickly.
 
A trusted freight forwarder can also confirm what you may or may not know about the client and country and make sure details about the shipment are not overlooked.
 
Chambers of Commerce and Trade Mission Websites
Chambers of commerce and foreign trade mission websites in partner countries can direct you to official channels for import requirements and be excellent sources for networking.
 
Foreign Embassies or Consulates
 
Robert Feke, senior director at Kentetsu World Express (USA), sent me an email after this blog post was first published with a few more suggestions for identifying import requirements. His first suggestion is to check with the foreign embassy or consulate of the country where you will be sending the items. You’ll find a complete list of foreign embassies in the U.S. on the State Department website.
 
Your Customer or Customer’s Broker
 
Feke also suggested asking the ultimate consignee or their broker for their documentation and other import requirements. This should really be the first place you go for this information, since the importer will typically know what they need. In fact, in the blog post, Without an International Sales Contract, You’re Setting Yourself Up for Failure, I identified documentation as one of the key items that should be addressed in your sales contracts. …
 
A Note of Caution
 
Before you start Googling, keep in mind that there is a ton of information on the internet, but much of it is noise. Before you trust a site you’ve searched, make sure you vet out the source. You don’t want to trust outdated, incorrect sites.
 
The Consequences of Ignoring Import Country Requirements
 
Not Getting Paid
 
If a transaction can’t be completed, a sale can’t be completed, and the seller won’t get paid.
 
Being Out of Compliance
 
If you ignore and are out of compliance with U.S. regulations, you may face harsh fines and penalties from the U.S. government. This is the same for your destination country. You could subject your own company or clients to fees or liabilities with their own government. By following import country requirements, you reduce your risk profile altogether.
 
By knowing where to look for information about import country requirements, you can be proactive about making sure your exports arrive on time-and you’ll get paid more quickly.
 
This article was first published in October 2016 and has been updated to include current information, links and formatting.

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COM_a113
. M. Volkov: “Putting Together Your Sanctions Compliance Program: Management Commitment (Part I of IV)”

(Source: Volkov Law Group Blog, 3 June 2019. Reprinted by permission.)
 
* Author: Michael Volkov, Esq., Volkov Law Group, mvolkov@volkovlaw.com, 240-505-1992.
 
If you follow my blog, you know I am not one to embrace hyperbole. So, forgive me for stretching a little here, but the OFAC Framework for Sanctions Compliance Programs is a game changer. Let me explain why I am saying that.
 
When it comes to sanctions compliance programs, most companies are well behind the curve; I am not saying they do nothing, but most companies have a less than mature program. OFAC’s new framework raises the bar by creating a well-crafted framework for companies to assess their current program and then provides some important objectives. OFAC has provided a helpful document.
 
However, to the extent that a company’s sanctions compliance program operates as part of an overall ethics and compliance program (which it should), a company should already be well positioned in a number of areas that are generally applicable to all ethics and compliance programs.
 
My point is that the general OFAC framework requirements should be already satisfied. When it comes to some of the more specific sanctions risks, the definition of these sanctions’ risks, and the prescriptive elements of OFAC’s framework, that is where companies need to get to work and implement improvements.
 
Let me see if I can help map this point out.
 
As a general matter, OFAC has “strongly encourage[d]” companies and individuals subject to OFAC jurisdiction to implement a “risk- based approach to sanctions compliance by developing, implementing and routinely updating a SCP.”
 
OFAC’s Framework is based on five essential components
 
(1) Management Commitment
(2) Risk Assessment
(3) Internal Controls
(4) Testing & Audit
(5) Training
 
Within Element 1, Management Commitment, OFAC requires that:
 
– The company’s board and senior leaders demonstrate its commitment and support of the organization’s SCP.
 
– The company’s SCP receives “adequate resources and is fully integrated into the day-to-day operations;”
 
– Management support includes the provision of adequate resources to the compliance unit(s) and support for compliance personnel’s authority within an organization.
 
– Senior management has to establish direct reporting lines between SCP functions and senior management, including routine and periodic meetings between these two elements of the organization.
 
– Senior management promotes a “culture of compliance” through the organization by encouraging personnel to report sanctions related misconduct without fear of reprisal; and
 
– Senior management messages and takes actions that discourage misconduct and prohibited activities, and highlight the potential repercussions of non-compliance with OFAC sanctions; and
 
These tasks are general enough to the overall ethics and compliance function that companies should already have satisfied these elements. If not, I suspect the company’s ethics and compliance program is suffering.
 
Now, let’s look at some prescriptive elements that OFAC added to the equation, some of which may already be satisfied but some which may require new efforts.
 
Under the Management Commitment prong, here are some prescriptive, specific items:
 
– Senior management has reviewed and approved the organization’s SCP.
 
– The organization has appointed a dedicated OFAC sanctions compliance officer (who can also be responsible for other compliance programs);
 
– SCP personnel have the requisite quality and experience to understand complex financial and commercial activities, apply their OFAC knowledge, and identify OFAC-related issues, risks and prohibited activities;
 
– The organization has appropriate information technology software and systems for its SCP.
 
There is nothing significant here except for maybe the requirement that the board or senior executives review and approve the SCP. If the company has a trade compliance policy and has been screening transactions for OFAC compliance, it is likely that these issues are already satisfied.
 
[Part II of this series will be published on 10 June 2019.]

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TEEX/IM TRAINING EVENTS & CONFERENCES

TE_1
14
.
FCC Presents “U.S. Export Controls: The EAR from a non-U.S. Perspective”, 27 Nov in Bruchem, the Netherlands 

(Source:
Full Circle Compliance

events@fullcirclecompliance.eu
.)

 
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: via
event page
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, see the
event page
for our combo deals.

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

TE_List15. 
List of Approaching Events: 160 Events Posted This Week, Including 13 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

 

*
 
Jun 10: Cleveland, OH; “
Letters of Credit
“; Global Training Center
*
 
Jun 11: Cleveland, OH; “
Export Doc & Proc
“; Global Training Center

* Jun 11: Philadelphia, PA; “Automated Commercial Environment (ACE) Export Compliance Seminar“; U.S. Commercial Service

*
 
Jun 11: Sheffield, UK; “
Customs Procedures and Compliance in International Trade
“; Sheffield Chamber of Commerce

* Jun 11: Sydney, Australia; “Defence Export Controls Outreach“; DEC


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 12-13: Shanghai, China; “China Forum for Legal and Compliance Officers“; American Conference Institute

*
 
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 13: Huntsville, AL; “STOPfakes.gov Intellectual Property Protection Seminar“; Alabama District Export Council, U.S. Department of Commerce & North Alabama International Trade Association (NAITA); naita@naita.org, 256-532-3505

* Jun 13: Leeds, UK; “
Understanding Exporting & Incoterms
“; Chamber International

*
 
Jun 14: Cleveland, OH; “
Incoterms® 2010 Rules
“; Global Training 

* Jun 14: London, UK; “Sanctions & Embargoes” Financial Crime Limited

* Jun 17-20: San Diego, CA; “ITAR Defense Trade Controls / EAR Export Controls“; ECTI

* Jun 17-21: Los Angeles, CA; “Certified Classification Specialist (CCLS)“; Amber Road

* Jun 19-20: Washington DC;
 Export Controls & Technology Transfer Conference“; Squire Patton Boggs
* Jun 20: Kansas City, MO; “
Trade Compliance & Policy” C.H. Robinson

* Jun 25: London, UK; “Introduction to Export Licensing Controls“; The Institute of Export and International Trade

* Jun 25: Melbourne, Australia; “ITAR/EAR/AU Export Control Awareness“; Goal Group

#
* Jun 25-26: Washington DC; “Advanced Forum on DCAA & DCMA Cost, Pricing, Compliance & Audits“; American Conference Institute

* Jun 26: London, UK; “Making Better Licence Applications“; UK/DIT

* 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 3: Leeds, UK; “New-to-Exporting Workshop“; Chamber International

*
 
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

 
* Jul 10: New York, NY; “EU Financial Regulatory Round-Up: What U.S. Firms Should Know“; Akin Gump

*
 
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 16: Atlanta, GA; “
Trade Compliance & Policy” C.H. Robinson

* Jul 16-19; Chicago, IL; “Export Boot Camp“; Amber Road

#
* Jul 17-18: Miami, FL; “
CTPAT Internal Auditor Training
“; Supply Chain Security International Inc.
#
* Jul 22: Adelaide, Australia; “Defence Export Controls Outreach“; Defence Export Controls

* Jul 23: Laredo, TX; “
Trade Compliance & Policy” C.H. Robinson

#
* Jul 23-24; TBA; “
Trade Symposium“;
U.S. CBP

*
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
* Jul 25: Dallas, TX; “Trade Compliance & Policy” C.H. Robinson 

* Jul 29-30: New Orleans, LA; “Global Trade Educational Conference“; NCBFAA Educational Institute  

* Jul 31: Leeds, UK; “Export Documentation” Chamber International 
* Jul 31-Aug 1: Seattle WA; “11th Annual Pacific Northwest Export Control Conference: Export Risks and Threats in the Cyber Domain“; DoC/U.S. Commercial Service, DHS/Homeland Security Investigations, Seattle University, Dorsey & Whitney LLP

* 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: Los Angeles, CA; “
Trade Compliance & Policy” C.H. Robinson

* Aug 22: Milpitas, CA:

Encryption Controls
“;
Commerce/BIS

* Sep 2: Edinburgh, UK; “
Strategic Export Control: Intermediate Practitioners course“; UK/DIT

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

* Sep 3: Edinburgh, UK; “
Strategic Export Control: Foundation Workshop“; UK/DIT
* Sep 3: Edinburgh, UK; “
Strategic Export Control: Licenses Workshop“; UK/DIT

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

* Sep 10: Minneapolis, MN; “
Trade Compliance & Policy” C.H. Robinson

* Sep 10-11: Portland, OR; “Complying with U.S. Export Controls“; Commerce/BIS

#
* Sep 12: Nashville, TN; “
6th Annual Compliance and Government Investigations Seminar
“; Bass, Berry & Sims

* Sep 16-18: Winchester, UK; “
From EAR to ITARnity: Ever-challenging US Export Controls Compliance
” Squire Patton Boggs

* Sep 16-19: Austin, TX; “
ITAR Controls / EAR & OFAC Export Controls (Sep 18-19) Seminar Series
“; ECTI
; 540-433-3977

#
* Sep 17: Chicago, IL; “
Automated Commercial Environment (ACE) Export Compliance Seminar
“; U.S. Census Bureau

*
 
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 18: Leeds, UK; “Export Documentation & Import Procedures“; Chamber International

 
* Sep 18-19: Los Angeles, CA; “Complying with U.S. Export Controls“; Commerce/BIS

*
 Sep 20: Las Vegas, NV; “
EAR and OFAC Fundamentals: Export Control Of Dual-Use Equipment
“; Barnes & Thornburg LLP

* Sep 24: Boston, MA; “
Trade Compliance & Policy” C.H. Robinson

* Sep 24-25: Minneapolis, MN; “Complying with U.S. Export Controls“; Commerce/BIS
* Sep 24-25: San Francisco, CA; “West Coast Conference on FCPA Enforcement and Compliance“; American Conference Institute

* Sep 24-26: Los Angeles, CA; “Export Controls Specialist – Certification“; Amber Road

*
 
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: Washington DC; “National Forum on FARA“; American Conference Institute

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

* Sep 26: Amsterdam, The Netherlands; “Global Trade Management: Turning trade challenges into opportunities” Amber Road

*
 
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 2-3: Toronto, Canada; “Canadian Forum on Global Economic Sanctions Compliance & Enforcement“; The Canadian Institute

* Oct 3: Chicago, IL; “
Trade Compliance & Policy” C.H. Robinson

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

* Oct 3-4: London, UK; “The WorldECR Export Controls & Sanctions Forum 2019“; WorldECR

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

* Oct 8: New York, NY; “Trade Compliance & Policy” C.H. Robinson* 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 15-16: Washington DC; “The WorldECR Export Controls & Sanctions Forum 2019“; WorldECR
* Oct 17: Leeds, UK; “
Strategic Export Control: Foundation Workshop“; UK/DIT
* Oct 17: Leeds, UK; “
Strategic Export Control: Licenses Workshop“; UK/DIT

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

* Oct 21-25: Chicago, IL; “Certified Classification Specialist (CCLS)“; Amber Road

* Oct 22: Indianapolis, IN; “
Trade Compliance & Policy” C.H. Robinson

# * Oct 24: New York, NY; “The Fundamentals of Export Regulatory Compliance“; NEXCO 

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

* Oct 29: Montreal, Canada; “
Trade Compliance & Policy” C.H. Robinson

* Oct 29-30; Tysons Corner, VA; “Conducting an internal Import/Export Audit“; Amber Road
* Oct 31: Toronto, Canada; “Trade Compliance & Policy” C.H. Robinson 

* Nov 11-14; Washington, DC; “
ITAR Controls / EAR & OFAC Export Controls Seminar Series
“; ECTI

* Nov 19-21: Tysons Corner, VA; “Export Controls Specialist – Certification“; Amber Road

*
 
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 2-6: Tysons Corner, VA; “Certified Classification Specialist (CCLS)“; Amber Road

*
 
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 20-21; Berlin, Germany; “
14. Exportkontrolltag
“; ZAR

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

* Mar 3-5; Vienna, Austria; “Lehrgang Exportkontrolle & Export Compliance“; OPWZ

 
Webinars 



* Jun 10: Webinar: “
Export Controls: Key Issues and Compliance Best Practices
“; Society of Corporate Compliance and Ethics
* Jun 11: Webinar: “Exporting Mechanisms II: Export Licenses“; NCBFAA  

#
* Jun 11: Webinar: “Understanding the False Claims Act Risks Facing U.S. Importers“; Crowell Moring

* Jun 12: Webinar: “E-2 Investor Visas: What Israeli Nationals Need to Know“; Steptoe 

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


* Jun 12: Webinar: “
OFAC Sanctions Update: What the Compliance Practitioner Needs to Know
“; Society of Corporate Compliance and Ethics

* Jun 12: Webinar: “The Challenges of Implementing a Global Screening Program“; Sandler, Travis & Rosenberg

* Jun 13: Webinar: “Supply Chain & Global Trade Analytics“; Amber Roa 
* Jul 10: Webinar: “
EAR
“; Global Training Center

* Jul 11: Webinar: “ITAR“; Global Training Center 
* Jul 19: Webinar: “Managing Export Operations and Compliance“; Massachusetts Export Center; 617-973-6610

#
* Jun 19: Webinar: “
Update on U.S. Export Controls and Sanctions Enforcement
“; DrinkerBiddle

* Sep 25: Webinar: “
EAR
“; Global Training Center
* Sep 26: Webinar: “
ITAR
“; Global Training Center

* 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)

 
* Dean Martin (Dino Paul Crocetti; 7 Jun 1917 – 25 Dec 1995; was an American singer, actor, and comedian. He and Jerry Lewis formed the comedy duo Martin and Lewis, with Martin serving as the straight man to Lewis’ slapstick hi-jinks. A member of the “Rat Pack”, Martin went on to become a star of concert stages, nightclubs, audio recordings, motion pictures and television.)
 – “I feel sorry for people who don’t drink. When they wake up in the morning, that’s as good as they’re going to feel all day.”  

This week’s proverbs:
* To learn another language is to have one more window from which to look at the world. | Chinese proverb
* A new language is a new life. | Persian proverb
* If you want people to understand you, speak their language. | African proverb

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

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:
24 May 2019: 84 FR 24018-24021: Revisions to Country Group Designations for Venezuela and Conforming Changes for License Requirements; and 84 FR 24021: Addition of Certain Entities to the Entity List, Revision of an Entry on the Entity List, and Removal of an Entity From the Entity List [Correction to 14 May 2019 Entity List Amendment.]    

 
*
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: 5 Jun 2019: 84 FR 25992; June 2019 Amendments to the Cuban Assets Control Regulations [amendment of 31 CFR Part 515].
  
*
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: 
21 May 2019: Harmonized System Update (HSU) 1908

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

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; and Assistant Editors, Alex Witt and 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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