19-0619 Wednesday “Daily Bugle'”

19-0619 Wednesday “Daily Bugle”

Wednesday, 19 June 2019

The 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 

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  1. DHS/CBP Corrects Comment Request of 5 June Concerning C-TPAT and Trusted Trader Program 
  2. Justice/ATF Seeks Comments Concerning Application and Permit for Importation of Firearms, Ammunition, and Defense Articles 
  1. Items Scheduled for Publication in Future Federal Register Editions 
  2. Commerce/BIS: (No new postings.)
  3. State/DDTC: (No new postings.)
  4. Hong Kong Posts Lists of Officers Authorized to Sign Strategic Commodities Licenses
  1. American Shipper: “U.S. Export Controls to Dam Huawei’s Revenue”
  2. The Epoch Times: “Air China Pilots Involved in Scheme to Send US Technology with Military Applications to China, Authorities Allege”
  3. Telesur: “Cuban Private Sector Hit Hard by Recent US Sanctions”
  1. A. Riley: “Nord Stream 2: From EU Law to US Sanctions Law”
  2. W. Wysong, H. Schommer & N. Turner: “Sanctions with Chinese Characteristics: PRC Government Threatens to Brand ‘Unreliable’ Foreign Companies”
  1. FCC Presents “The ABC of FMS”, 28 Nov in Bruchem, the Netherlands
  1. Bartlett’s Unfamiliar Quotations 
  2. Are Your Copies of Regulations Up to Date? Latest Amendments: DHS/Customs (5 Apr 2019), DOC/EAR (5 June 2019), DOC/FTR (24 Apr 2018), DOD/NISPOM (18 May 2016), DOE/AFAEC (23 Feb 2015), DOE/EINEM (20 Nov 2018), DOJ/ATF (14 Mar 2018), DOS/ITAR (19 Apr 2018), DOT/FACR/OFAC (5 June 2018), HTSUS (6 Jun 2019) 
  3. Weekly Highlights of the Daily Bugle Top Stories 


DHS/CBP Corrects Comment Request of 5 June Concerning C-TPAT and Trusted Trader Program
(Source: Federal Register, 19 June 2019.) [Excerpts.]
84 FR 28572: Agency Information Collection Activities: Customs-Trade Partnership Against Terrorism (C-TPAT) and the Trusted Trader Program; Correction
* AGENCY: U.S. Customs and Border Protection (CBP), Department of Homeland Security.
* ACTION: 30-Day notice and request for comments; Extension of an existing collection of information; correction.
* SUMMARY: On June 5, 2019, U.S. Customs and Border Protection (CBP) published a document in the Federal Register requesting comments from the public and affected agencies on Customs-Trade Partnership Against Terrorism (C-TPAT) and the Trusted Trader Program. That document contained an error in the subject heading. This document corrects the June 5, 2019 document to reflect the correct subject heading.
* FOR FURTHER INFORMATION CONTACT: … Please note that the contact information provided here is solely for questions regarding this notice. Individuals seeking information about other CBP programs should contact the CBP National Customer Service Center at 877-227-5511, (TTY) 1-800-877-8339, or CBP website.
On June 5, 2019, U.S. Customs and Border Protection (CBP) published in the Federal Register a document requesting comments from the public and affected agencies on Customs-Trade Partnership Against Terrorism (C-TPAT) and the Trusted Trader Program. 84 FR 26130. That document contained an error in the subject heading by referring to the “Trusted Trader Program” as the “Trusted Traveler Program.” This correction is being issued to clarify that the agency information collection relates to the Customs-Trade Partnership Against Terrorism (C-TPAT) and the Trusted Trader Program.
In the Federal Register of June 5, 2019, in the document at 84 FR 26130, in the first column, correct the subject heading to read: Subject Heading: Agency Information Collection Activities: Customs-
Trade Partnership Against Terrorism (C-TPAT) and the Trusted Trader Program.
Dated: June 13, 2019.

Seth D. Renkema, Branch Chief, Economic Impact Analysis Branch, U.S. Customs and Border Protection.

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Justice/ATF Seeks Comments Concerning Application and Permit for Importation of Firearms, Ammunition, and Defense Articles

(Source: Federal Register, 19 June 2019.) [Excerpts.]
84 FR 28589: Agency Information Collection Activities; Proposed eCollection eComments Requested; Application and Permit for Importation of Firearms, Ammunition and Defense Articles–ATF Form 6–Part II (5330.3B)
* AGENCY: Bureau of Alcohol, Tobacco, Firearms and Explosives, Department of Justice.
* ACTION: 30-Day notice.
* SUMMARY: The Department of Justice (DOJ), Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF), will submit the following information collection request to the Office of Management and Budget (OMB) for review and approval in accordance with the Paperwork Reduction Act of 1995.
* DATES: The proposed information collection was previously published in the Federal Register, on April 10, 2019, allowing for a 60-day comment period. Comments are encouraged and will be accepted for an additional 30 days until July 19, 2019.
Overview of This Information Collection
(1) Type of Information Collection: Extension, with change, of a currently approved collection.
(2) The Title of the Form/Collection: Application and Permit for Importation of Firearms, Ammunition and Defense Articles.
(3) The agency form number, if any, and the applicable component of the Department sponsoring the collection:
– Form number: ATF Form 6–Part II (5330.3B).
– Component: Bureau of Alcohol, Tobacco, Firearms and Explosives, U.S. Department of Justice.
(4) Affected public who will be asked or required to respond, as well as a brief abstract:
– Primary: Individuals or households.
– Other: Federal Government, State, Local or Tribal Government.
– Abstract: The information on the Application and Permit for Importation of Firearms, Ammunition and Defense Articles–ATF Form 6–Part II (5330.3B) is used to determine if the article(s) described in the application qualifies for importation by the importer, and to serve as the authorization for the importer.
(5) An estimate of the total number of respondents and the amount of time estimated for an average respondent to respond: An estimated 400 respondents will utilize this form, and it will take each respondent approximately 30 minutes to complete this form.
(6) An estimate of the total public burden (in hours) associated with the collection: The estimated annual public burden associated with this collection is 200 hours, which is equal to 400 (# of respondents) * 1 (# of times per response) * .5 (30 minutes).
If additional information is required contact: Melody Braswell, Department Clearance Officer, United States Department of Justice, Justice Management Division, Policy and Planning Staff, Two Constitution Square, 145 N Street NE, 3E.405A, Washington, DC 20530.
Dated: June 14, 2019.
Melody Braswell, Department Clearance Officer for PRA, U.S. Department of Justice.

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OGS_a13. Items Scheduled for Publication in Future Federal Register Editions
(Source: Federal Register, 19 June 2019.)

* President; ADMINISTRATIVE ORDER; Western Balkans; Continuation of National Emergency (Notice of June 18, 2019)
[Pub. Date: 20 June 2019.]

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Commerce/BIS (No new postings.)

(Source: Commerce/BIS)

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OGS_a46Hong Kong Posts Lists of Officers Authorized to Sign Strategic Commodities Licenses  

The List of Officers Authorized to Sign on Strategic Commodities Licences and Delivery Verification Certificates under Import and Export Ordinance, Cap 60 Import and Export (Strategic Commodities) Regulations can be found here.

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. American Shipper: “U.S. Export Controls to Dam Huawei’s Revenue

American Shipper, 18 June 2019.) [Excerpts.]
The U.S. government’s recent placement of Huawei Technologies Co. Ltd. of China and its 68 overseas affiliates on the Commerce Department’s Entity List is expected to take a steep financial toll on the Chinese telecom company during 2019.
According to various news outlets, the company’s founder and CEO Ren Zhengfei forecast the overall reduction in revenue for this year to be about $30 billion, mostly due to U.S. technology export restrictions and the ongoing trade dispute between China and the U.S. …
In mid-May, President Donald Trump issued an executive order aimed at preventing foreign companies from gaining access to certain U.S.-made technologies that could pose a threat to national security.
The Commerce Department responded by adding Huawei Technologies Co. Ltd. and its affiliates to the Entity List, which is enforced by the Bureau of Industry and Security. …

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. The Epoch Times: “Air China Pilots Involved in Scheme to Send US Technology with Military Applications to China, Authorities Allege”

The Epoch Times, 19 June 2019.) [Excerpts.]
An elaborate scheme to send U.S. technology with military applications to China at one point involved using Air China pilots, U.S. authorities allege.
In January 2018, the FBI arrested Americans Yi-Chi Shih and Kiet Anh Mai for allegedly buying microchips that can be used for military applications from a U.S. company under the pretense that they were for domestic use, while scheming to send the technology to China. A third suspect, Canadian Ishiang Shih-a professor at McGill University and Yi-Chi Shih’s brother-is also charged by U.S. authorities in relation to the case, although he hasn’t yet been extradited and is free in Canada. …
Among the evidence included in the court case is a PowerPoint presentation from 2012 which authorities say contains the names of both Shih brothers. Prosecutors allege the presentation was a “business plan for the development of a semiconductor foundry in the PRC to manufacture MMICs [monolithic microwave integrated circuits].” …

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Telesur, 19 June 2019.) [Excerpts.]
In May, Trump fully enforced the Helms-Burton Act’s Titles III and IV, suspended since 1996 that will expand the U.S. commercial and financial blockade against Cuba.
The non-state sector in Cuba is already registering a significant blow as a result of the U.S. sanctions implemented by President Donald Trump, with craftmanship dropping by about 60 to 80 percent in sales, according to local media.
In May, Trump fully enforced the Helms-Burton Act’s Titles III and IV, suspended since 1996 that will expand U.S. commercial and financial blockade against Cuba. In 1996, former U.S. president Bill Clinton approved the Helms-Burton Act under the idea that the blockade against Cuba had an extra-territorial scope and was not limited just to the island. …
In addition, the Trump administration has announced more travel restrictions to the island, rolling back measures made by the Barack Obama administration, and is limiting remittances to US$1,000 per person per fiscal quarter. As of June 5, U.S. citizens are prohibited from making group educational and cultural trips known as “people to people” travel to Cuba, Secretary of Commerce Steve Mnuchin of the U.S. Treasury Department announced on March. …

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A. Riley: “Nord Stream 2: From EU Law to US Sanctions Law”

Atlantic Council, 13 June 2019.) [Excerpts.]
* Author: Dr. Alan Riley, Senior Fellow, Atlantic Council,
Rainer Seele, the chief executive officer of Austrian energy company OMV and corporate ally of Gazprom,
recently called on Europe to defend itself from the proposed US sanctions aimed to stop Nord Stream 2. It is far from clear to which ‘Europe’ Seele is referring. In December 2018, the European Parliament
voted 433 to 105 in favour of a resolution calling for the construction of Nord Stream 2 to be cancelled. Furthermore, in February 2019, twenty-four of the twenty-eight member states
were prepared to vote to extend the 2009 EU Gas Directive formally to import pipelines such as Nord Stream 2, creating uncertainty in the current financing, business structure, and commercial logic of the project.
Germany had too few votes from other member states to block the amendment to the Directive. It ended up bargaining with Paris for convoluted face-saving wording to cover up the fact that it had to substantively accept the application of the Directive to import pipelines.
As a consequence, Nord Stream 2 is now struggling with how to deal with the application of the Gas Directive. It faces, for example, having to unbundle the pipeline. Gazprom, which has a 100 percent shareholding in Nord Stream 2, can either own the pipeline or provide the gas; in any event, access to the pipeline will have to opened up to via the EU’s third-party access rules and a transparent cost reflective tariff regime would have to be applied. In addition, Gazprom would face having to endure a security of supply certification process. … 
The degree of Gazprom’s distress can be seen in the April 12, 2019, letter from Nord Stream 2 Chief Executive Officer Matthias Warnig to Jean-Claude Juncker, president of the European Commission. Warnig threatened to sue the EU under the Energy Charter Treaty’s
investment protection regime. He alleged that the adoption of the Amended Directive targeted the pipeline in a discriminatory fashion. … 
If Warnig does follow through with yet more litigation, the European Commission is likely to respond robustly. …
Arguments in support of Nord Stream 2 suggest that, as the pipes for Nord Stream 2 have been constructed in German waters, the pipeline is consequently ‘complete’ in EU territory, even if it is not complete elsewhere (only
40 percent of the pipeline has actually been laid so far). … 
A substantial majority of member states have already
dealt a significant blow to Nord Stream 2 through both the
European Parliament’s support for the pipeline’s cancellation and support for the amendment to the Gas Directive. This is the true European response to Nord Stream 2. In reality, Seele and his German allies represent only a small subset of European opinion. …
experts suggest that the Act could impact Western corporate allies of Nord Stream 2 such as OMV, Wintershall, and Shell. It is difficult to see how this could be the case. … 
Seele also is not supportive of the US sanctions, on the grounds that they are a US attempt to increase its access to European gas markets by blocking Russian access. … 
Another questionable argument lays out the decrease in natural gas production in Europe as a justification for Nord Stream 2 and a reason why the pipeline should not be sanctioned. …
EU member states have already shown willingness to take measures against Nord Stream 2 in the shape of European Parliament support for the cancellation of the pipeline and the adoption of the amendment to the Gas Directive. The US Congress can now take an additional step that will underpin rather than undermine the transatlantic relationship: deploying the targeted sanctions proposed in the Protecting Europe’s Energy Security Act to help secure the collective interests of the EU and the United States and stop Nord Stream 2.

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W. Wysong, H. Schommer & N. Turner: “Sanctions with Chinese Characteristics: PRC Government Threatens to Brand “Unreliable” Foreign Companies” 

Corporate Compliance Insights
, 17 June 2019.)

* Authors: Wendy Wysong, Esq.,
wendy.wysong@cliffordchance.com, +852 2826 3460; Hena Schommer, Esq.,
hena.schommer@cliffordchance.com, +1 202 912 5447; and Nick Turner, Esq.,
nicholas.turner@cliffordchance.com, +8 522 825 8854, all of Clifford Chance.
The government of China recently announced its intentions to publish a list of foreign entities that harm the interests of Chinese companies. In this article, attorneys from Clifford Chance discuss the particulars and how the “unreliable entity list” will have immediate impact to the businesses listed therein.
China’s Ministry of Commerce (MOFCOM) introduced a new layer of complexity for companies doing business with Chinese companies with the announcement of its new “Unreliable Entity List” (UEL) on May 31, 2019. According to the announcement, the UEL will include foreign enterprises, organizations or individuals that fail to abide by market rules and discriminate against Chinese companies for noncommercial purposes. Examples given include boycotts, cutting off supplies or restricting or blocking trade transactions in ways that cause serious damage to Chinese enterprises.
The names of the UEL entities and the specific restrictions applicable to them have not yet been published. To export control practitioners, the UEL might sound similar to the U.S. Entity List, with a less ambiguous nomenclature and purpose. For foreign companies put on the UEL, impact will no doubt be immediately felt.
Official Statements About the UEL
While official regulations spelling out the UEL procedures and the actual list are not yet public, MOFCOM’s spokesperson explained in a press conference on June 1, 2019 that the agency would take into account the totality of the circumstances in adding an entity to the UEL. Factors would include, inter alia, the specific measures taken by the foreign entity against the Chinese companies, the underlying purpose for the discriminatory measures, the damage caused to Chinese companies and related industries and the actual or potential threat to Chinese national security.
MOFCOM is expected to undertake an investigative procedure before adding companies to the UEL. While companies will have the opportunity to object to a UEL listing, it is not clear whether that will occur prior to the listing or as an “off-ramp” for delisting. According to statements made during the press conference, companies will have an opportunity to defend themselves and present arguments to MOFCOM about the possible consequences that a UEL listing would have on their and their Chinese counterparties’ businesses. It is most likely that companies threatened with listing will need to offer compromises to avoid being designated as unreliable.
A company on the UEL will be subject to “any necessary legal and administrative measures” that MOFCOM imposes, while the public will be advised to be cautious to avoid risks associated with the designated foreign entities.
Official Policy
In case the motivation and target of the UEL were not clear from its name and terms, the PRC government also issued an accompanying background statement.
China decided to establish the UEL because “certain countries have been abusing the concept of national security, the measures of export control and their long-arm jurisdictions, which actions have severely harmed the security and stability of the global industrial chain, supply chain and value chain, destroyed the international economic orders and multilateral trading rules and caused injuries to the global economy and national interests of countries including China.” The phrase “long-arm jurisdiction,” in particular, has been used by the PRC government to challenge the use of extraterritorial sanctions by the United States against Chinese companies.
Whether the list will be a long one and work to essentially shut off trade with companies, particularly from the United States, is a matter of speculation. The initial UEL might also be short, consisting of companies that have publicly announced they have stopped doing business with U.S. listed entities. In that case, the UEL may have little additional impact. In any event, companies contemplating business in China and with Chinese companies will need to factor in the UEL, ensuring commercial rather than regulatory reasons guide their decisions not to do business with other Chinese entities, subject to U.S. restrictions with which China disagrees and considers discriminatory and abusive.

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TE_a112. FCC Presents “The ABC of FMS”, 28 Nov in Bruchem, the Netherlands

This training course is specifically designed for compliance professionals and those in a similar role working for government agencies or companies (temporarily) obtaining U.S. export-controlled articles and technology procured through government-to-government Foreign Military Sales (FMS), and authorized by the Arms Export Control Act (AECA) (22 U.S.C. 2751, et. seq.).
The course will cover multiple topics relevant for organizations outside the U.S. working with U.S. export-controlled articles and technology procured through FMS, including: the U.S. regulatory framework, with a special focus on the AECA, key concepts and definitions, and practical compliance tips to ensure the proper handling of FMS-acquired articles and technology. Participants will receive a certification upon completion of the training.
* What: The ABC of Foreign Military Sales (FMS)
* When: Thursday, 28 Nov 2019
– Welcome and Registration: 9.00 am – 9.30 am
– Training hours: 9.30 am – 4.00 pm
* Where: Full Circle Compliance, Landgoed Groenhoven, Dorpsstraat 6, Bruchem, the Netherlands
* Information & Registration:
or contact FCC at
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 “U.S. Export Controls: The Export Administration Regulations (EAR) from a non-U.S. Perspective” (27 Nov 2019). Please, see the
event page
for our combo deals. 

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* Blaise Pascal (19 Jun 1623 – 19 Aug 1662; was a French mathematician, physicist, inventor, writer and Catholic theologian. Pascal’s earliest work was in the natural and applied sciences where he made important contributions to the study of fluids, and clarified the concepts of pressure and vacuum by generalizing the work of Evangelista Torricelli. Pascal also wrote in defence of the scientific method.)
  – “Small minds are concerned with the extraordinary, great minds with the ordinary.”
* King James I (James Charles Stuart; 19 June 1566 – 27 Mar 1625; was King of Scotland as James VI from 24 July 1567, and King of England and Ireland as James I from the union of the Scottish and English crowns in 1603 until his death in 1625. James himself was a talented scholar, the author of several academic works. He sponsored the translation of the Bible into English that would later be named after him: the 
Authorised King James Version.)
  – “I can make a lord, but only God can make a gentleman.”

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


DHS CUSTOMS REGULATIONS: 19 CFR, Ch. 1, Pts. 0-199.  Implemented by Dep’t of Homeland Security, U.S. Customs & Border Protection.

  – Last Amendment: 5 Apr 2019:
84 FR 13499-13513: Civil Monetary Penalty Adjustments for Inflation

: 15 CFR Subtit. B, Ch. VII, Pts. 730-774. Implemented by Dep’t of Commerce, Bureau of Industry & Security.
  – Last Amendment: 5 June 2019: 
84 FR 25986-25989
: Restricting the Temporary Sojourn of Aircraft and Vessels to Cuba

* DOC FOREIGN TRADE REGULATIONS (FTR): 15 CFR Part 30.  Implemented by Dep’t of Commerce, U.S. Census Bureau.
  – Last Amendment: 24 Apr 2018: 83 FR 17749-17751: Foreign Trade Regulations (FTR): Clarification on the Collection and Confidentiality of Kimberley Process Certificates
  – HTS codes that are not valid for AES are available here.
  – The latest edition (1 Jan 2019) of Bartlett’s Annotated FTR (“BAFTR”), by James E. Bartlett III, is available for downloading in Word format. The BAFTR contains all FTR amendments, FTR Letters and Notices, a large Index, and approximately 250 footnotes containing case annotations, practice tips, Census/AES guidance, and explanations of the numerous errors contained in the official text. Subscribers receive revised copies in Microsoft Word every time the FTR is amended. The BAFTR is available by annual subscription from the Full Circle Compliance website.  BITAR subscribers are entitled to a 25% discount on subscriptions to the BAFTR. Government employees (including military) and employees of universities are eligible for a 50% discount on both publications at www.FullCircleCompiance.eu.   


  – Last Amendment: 18 May 2016: Change 2: Implement an insider threat program; reporting requirements for Cleared Defense Contractors; alignment with Federal standards for classified information systems; incorporated and cancelled Supp. 1 to the NISPOM (Summary here.)
DOE ASSISTANCE TO FOREIGN ATOMIC ENERGY ACTIVITIES: 10 CFR Part 810; Implemented by Dep’t of Energy, National Nuclear Security Administration, under Atomic Energy Act of 1954.
  – Last Amendment: 23 Feb 2015: 80 FR 9359, comprehensive updating of regulations, updates the activities and technologies subject to specific authorization and DOE reporting requirements. This rule also identifies destinations with respect to which most assistance would be generally authorized and destinations that would require a specific authorization by the Secretary of Energy.
DOE EXPORT AND IMPORT OF NUCLEAR EQUIPMENT AND MATERIAL; 10 CFR Part 110; Implemented by Dep’t of Energy, U.S. Nuclear Regulatory Commission, under Atomic Energy Act of 1954.
  – Last Amendment: 20 Nov 2018, 10 CFR 110.6, Re-transfers.

* DOJ ATF ARMS IMPORT REGULATIONS: 27 CFR Part 447-Importation of Arms, Ammunition, and Implements of War.  Implemented by Dep’t of Justice, Bureau of Alcohol, Tobacco, Firearms & Explosives.
  – Last Amendment: 14 Mar 2019: 84 FR 9239-9240: Bump-Stock-Type Devices 


DOS INTERNATIONAL TRAFFIC IN ARMS REGULATIONS (ITAR): 22 C.F.R. Ch. I, Subch. M, Pts. 120-130. Implemented by Dep’t of State, Directorate of Defense Trade Controls.
  – Last Amendment: 19 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 contains all ITAR amendments to date, plus a large Index, over 800 footnotes containing amendment histories, case annotations, practice tips, DDTC guidance, and explanations of errors in the official ITAR text. Subscribers receive updated copies of the BITAR in Word by email, usually revised within 24 hours after every ITAR amendment. The BITAR is available by annual subscription from the Full Circle Compliance website. BAFTR subscribers receive a $25 discount on subscriptions to the BITAR, please contact us to receive your discount code.

* DOT FOREIGN ASSETS CONTROL REGULATIONS (OFAC FACR): 31 CFR, Parts 500-599, Embargoes, Sanctions, Executive Orders.
Implemented by Dep’t of Treasury, Office of Foreign Assets Control.

– Last Amendment: 5 June 2019: 84 FR 25992 – June 2019 Amendments to the Cuban Assets Control Regulations [amendment of 31 CFR Part 515] 


, 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: 13 June 2019: 
Harmonized System Update (HSU) 1911 

  – HTS codes for AES are available here.

  – HTS codes that are not valid for AES are available here.

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Weekly Highlights of the Daily Bugle Top Stories

(Source: Editor) 

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

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* The Ex/Im Daily Update is a publication of FCC Advisory B.V., compiled by: Editor, James E. Bartlett III; and Assistant Editors, Alexander 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 of this newsletter cannot be relied upon as legal or expert advice.  Consult your own legal counsel or compliance specialists before taking actions based upon news items or opinions from this or other unofficial sources.  If any U.S. federal tax issue is discussed in this communication, it was not intended or written by the author or sender for tax or legal advice, and cannot be used for the purpose of avoiding penalties under the Internal Revenue Code or promoting, marketing, or recommending to another party any transaction or tax-related matter.

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