19-0711 Thursday “Daily Bugle'”

19-0711 Thursday “Daily Bugle”

Thursday, 11 July 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. Treasury/OFAC Amends North Korea Sanctions Regulations
  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 Sanctions Venezuela’s Military Counterintelligence Agency
  5. Dutch Government Releases New Report on Export of Military Goods
  6. German BAFA Updates Guidance on Trade with Russia
  7. UK OFSI Updates Guidance Documents Concerning Financial Sanctions Lists
  8. Singapore Customs Publishes Advisory Concerning Customs Requirements & Best Practices
  1. Aviation Week: “U.S. Probe Links Libyan Rebel Javelin Missiles To France”
  2. BloombergLaw: “U.S. Says Huawei Still Blacklisted, Suppliers Can Seek Licenses”
  3. Deutsche Welle: “German Arms Export Approvals Spike”
  4. MLP: “Export Licensing: Tips U.S. Exporters Shouldn’t Overlook”
  1. D. Sikes: “Interpretation of International Trade Regulations to Come Under Greater Scrutiny”
  2. J. Suetomi: “Additional Restrictions Added to METI’s Licensing Policies and Procedures on Exports of Controlled Items to the Republic of Korea”
  3. L. Truyens & S. Loosveld: “Could Sanctions Against Iran be Reintroduced?”
  1. ECTI Presents Not Your Everyday Investigation: Authorizing, Managing and Conducting Internal Investigations into Potential Violations of U.S. Export Controls and Sanctions
  2. FCC Presents “Designing an ICP for Export Controls & Sanctions”, 1 Oct in Bruchem, the Netherlands
  1. Bartlett’s Unfamiliar Quotations 
  2. Are Your Copies of Regulations Up to Date? Latest Amendments: DHS/Customs (5 Apr 2019), DOC/EAR (27 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 (26 Jun 2019) 
  3. Weekly Highlights of the Daily Bugle Top Stories 


EXIM_a11. Treasury/OFAC Amends North Korea Sanctions Regulations

(Source: Federal Register, 11 July 2019.)
84 FR 33002: Rules: North Korea Sanctions
In rule document 2019-13652, appearing on pages 30868 through 30870, in the issue of Friday, June 28, 2019 make the following correction: On page 30869, in the first column, in the second paragraph, on the twelfth line, “Sec. Sec. ” should read “sections”.

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OGS_a12. Items Scheduled for Publication in Future Federal Register Editions
(Source: Federal Register, 27 June 2019.)

[No items of interest noted today.]

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Commerce/BIS (No new postings.)

(Source: Commerce/BIS)

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State/DDTC: (No new postings.)


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OGS_a45. Treasury/OFAC Sanctions Venezuela’s Military Counterintelligence Agency

Treasury/OFAC, 11 July 2019.)
The following entity has been added to OFAC’s SDN List: 

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OGS_a56Dutch Government Releases New Monthly Report on Export of Military Goods

Rijksoverheid, 11 July 2019.)
The document can be downloaded
here (in Dutch).

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OGS_a67 German BAFA Updates Guidance on Trade with Russia

German BAFA, 11 Jul 2019.) [Excerpts. Unofficial translation by A. Witt of Full Circle Compliance.]
This guidance document is intended to provide an overview of the trading restrictions and financial sanctions within the scope of the
by the European Union (EU) against the Russian Federation.
The Federal Office of Economics and Export Control (BAFA) is responsible for all issues related to prohibitions and licensing obligations in relation to the trade of goods with the Russian Federation. In particular with regard to the prohibitions and licensing requirements newly introduced by the embargo regulations.
For all administrative issues related to the financial sanctions imposed by the EU (so-called Lis of individuals, companies and other entities, and entities), the Deutsche Bundesbank is the competent authority. The contact person here is the Financial Sanctions Service Centre (Tel. 089 2889-3800). Further information on financial sanctions can be found in Chapter 7.
The second edition of this guidance document updates this and reflects the legal situation as of 1 June 2019. The main provisions taken into account are the Regulation (EU) No 833/2014 of 31 July 2014 [last amended by Council Regulation (EU) 2017/2212 of 30 June 2017 November 2017]. …

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OGS_a78UK OFSI Updates Guidance Documents Concerning Financial Sanctions Lists 

UK OFSI, 10 July 2019.)
The UK Office of Financial Sanctions Implementation (OFSI) has published the following updates on its website:
– Who is subject to financial sanctions in the UK? The document can be found
– Current list of designated persons, terrorism and terrorist financing. The document can be found
– Financial sanctions, Venezuela. The document can be found

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OGS_a89Singapore Customs Publishes Advisory Concerning Customs Requirements & Best Practices

Singapore Customs, 11 July 2019.)
Singapore Customs has released the following document(s) on its website:

Circular No: 11/2019; Advisory: Customs Requirements & Best Practices for Import of Goods

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. Aviation Week: “U.S. Probe Links Libyan Rebel Javelin Missiles To France”

Aviation Week, 10 July 2019.) [Excerpts.]
The French government is under investigation for a possible violation of U.S. export control terms after a cache of Javelin missiles originally delivered to France were discovered inside a Libyan rebel compound, a State Department official said on July 10. Original reports after Libyan government forces seized the Javelin missiles linked the anti-tank weapons to the U.A.E., a close ally of rebel forces in Libya led by Khalifa Haftar. But an ongoing investigation by …

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BloombergLaw: “U.S. Says Huawei Still Blacklisted, Suppliers Can Seek Licenses”

BloombergLaw, 10 July 2019.) [Excerpts.]
The U.S. said it would grant licenses allowing companies to export goods to Huawei Technologies Co. but won’t remove the Chinese technology giant from an export blacklist, as talks between the world’s two biggest economies resumed.
The Department of Commerce will “issue licenses where there is no threat to U.S. national security,” though Huawei will continue to face export controls, Commerce Secretary Wilbur Ross said on July 9 in Washington.
The move clarifies President Donald Trump’s remarks that he would. …

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Deutsche Welle: “German Arms Export Approvals Spike”

Deutsche Welle, 11 July 2019.) [Excerpts.]
Permits for German arms exports soared in the first half of 2019, defying dips and restraint over the past three years, government data has shown. Hungary is the top destination for new weapons exports.
German Economy Ministry data obtained by opposition Greens foreign policy spokesman Omid Nouripour itemized €5.3 billion ($6 million) worth of government approvals for arms sales between January and June.
That total for the first half of 2019 surpasses the €4.8 billion in arms export approvals for the whole of 2018.
Hungary topped the 2019 current recipient list with €1.76 billion in arms sales, followed by Egypt receiving €800 million and South Korea €278 million. Sixth on the list was the United Arab Emirates with €206 million. …

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MLP: “Export Licensing: Tips U.S. Exporters Shouldn’t Overlook”

Maritime Logistics Professional, 10 July 2019.) [Excerpts.]
… When it comes to determining whether your export might need a license, there are a few sometimes overlooked aspects that U.S. businesses should be aware of before they export. …
– Don’t make any assumptions. For example, just because you are exporting a small amount of a commodity, sending it to a friendly country or e-mailing software doesn’t mean you shouldn’t check to see if an export license is needed. Screen all the parties to your transaction.
– Review the control lists carefully.
 The USML and the BIS-administered Commerce Control List (CCL) include not only complete systems and key parts and components, but also raw materials, production equipment, and other related items. For marine technology exporters, key entries can be found in USML categories VI (surface vessels of war), XI (underwater electronics and acoustic systems), XII (optical and inertial sensors) and XX (submersible vessels); and CCL categories 5 (telecommunications), 6 (acoustic sensors), 7 (inertial sensors and navigation), and 8 (marine).

– Different levels of technology can affect where you can export.
 The level of a product’s technology and market destination can be important factors as to whether an export license might be needed. For example, BIS authorized one U.S. exporter of high-end infrared technology to sell a certain level of its technology to Country A, but denied the company’s request for a license to export the same level of technology to Country B. The company received authorization to export a less technologically sophisticated product to Country B instead. …

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D. Sikes: “Interpretation of International Trade Regulations to Come Under Greater Scrutiny” 

Akin Gump, 9 July 2019.) [Excerpts.]
* Author: Devin S. Sikes, Esq., dsikes@akingump.com, +1 202 887 4336, of Akin Gump.
Several federal agencies-including most notably the U.S. Department of Commerce, U.S. Customs and Border Protection, the U.S. International Trade Commission and the U.S. Trade Representative-administer an ever-expanding body of regulatory law that addresses a broad range of issues arising in U.S. administration of various statutes governing international trade.
What happens when a dispute arises between an agency and a private party over the meaning of a regulation’s terms? Since the late nineteenth century, the Supreme Court of the United States has issued a series of opinions holding that courts should generally defer to an agency’s interpretation of its own ambiguous regulation. That principle is known today as “Auer deference.”
Over time, concerns arose over whether Auer afforded too much power to federal agencies to interpret and declare the meaning of regulatory law. The Supreme Court’s recent decision in Kisor v. Wilkie establishes firm limits to Auer‘s reach that will require federal courts to more scrupulously review a federal agency’s interpretation of international trade regulation. …

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J. Suetomi: “Additional Restrictions Added to METI’s Licensing Policies and Procedures on Exports of Controlled Items to the Republic of Korea”

(Source: BakerMcKenzie, 10 July 2019.)

METI (the Ministry of Economy, Trade and Industry) announced two amendments to the export control regulations on 1 July 2019.
1. Bulk license applicability: individual export licenses now
required for certain items and related technologies
METI announced partial amendments to four guidelines related to the implementation of export control regulations, including the Export Trade Control Order.
Starting on 4 July 2019, Japanese exporters will be required to apply for individual export licenses to export Hydrogen Fluoride, Fluorinated polyimide, Resist and their relevant technologies, which may include technology transferred with exports of manufacturing equipment to the Republic of Korea, as the bulk licenses for these three materials will no longer be applicable.
The office responsible for receiving export license applications for exports of these materials to the Republic of Korea has been changed from a METI bureau or branch office to the Security Export Licensing Division of METI’s main office.
This announcement is available here.
2. Republic of Korea no longer white-listed
METI also announced on 1 July 2019 that it has initiated the process of revising the so-called “White Countries” in Appendix 3 of the Export Trade Control Order to remove the Republic of Korea and that it is seeking public comment on this amendment.
This announcement is available here.
Details of the submission of public comments are available here.
Market impact
1. Bulk license applicability
Japanese exporters that are currently exporting products containing Hydrogen Fluoride, Fluorinated polyimide or Resist or that are transferring technologies related to these materials to the Republic of Korea under relevant bulk licenses may no longer do so and will now need to apply for individual export licenses for each contract (transaction).
Frequent and higher-volume exporters/transferors of these products/technologies to the Republic of Korea may be delayed by the need to obtain individual export licenses.
This amendment may affect the global semiconductor supply chain, as semiconductors are manufactured from various materials and parts obtained from interconnected suppliers.
2. Removal from “White Countries” list
Exports to “White Countries” are subject to simpler export licensing requirements and rarely require an export license unless they involve the export or transfer of so-called “listed products/technologies.”
If the destination is a non-White Country, an export license is sometimes required even when the products/technologies at issue are not listed products/technologies. Exporter to Republic of Korea may need to make a self judgment of whether an export license is required or not.
This amendment may delay exports of the relevant products/technologies from Japan to the Republic of Korea and may disrupt the supply chain.

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L. Truyens & S. Loosveld: “Could Sanctions Against Iran be Reintroduced?”

Linklaters, 8 July 2019.)
* Authors: Liesbeth Truyens, Esq.,
liesbeth.truyens@linklaters.com, +32 25019471, Stefaan Loosveld, Esq.,
stefaan.loosveld@linklaters.com, +32 25019521, both of Linklaters.
The Joint Comprehensive Plan of Action or “JCPOA” is an agreement reached in 2015 between Iran, the United States, Russia, China, France, the United Kingdom, Germany and the EU, pursuant to which the nuclear-related sanctions against Iran issued by the UN Security Council, the EU and the United States were lifted. On 8 May 2018 the United States have withdrawn from the JCPOA and have re-imposed the previously lifted US sanctions. The remaining signatories to the JCPOA have continued their commitment to the agreement and have continued the sanctions lifting.
However, Iran has now exceeded the limit of its uranium stockpile set at 300 kg and has announced that, by 7 July 2019, it will have enriched uranium beyond the 3.67 percent fissile purity in violation of its commitments in the JCPOA. 
This could culminate in the return of the UN and EU sanctions against Iran that have remained lifted in a matter of weeks (the so-called “sanctions snapback”).
What is a sanctions snapback?
UN snapback
In the event of a snapback, which any of the remaining signatories could trigger, the UN sanctions in relation to Iran’s nuclear activities would be re-imposed [FN/1] and the UN members, as well as the EU would have to re-implement them. [FN/2]
These sanctions include amongst others an asset freeze and visa or travel ban in relation to a number of natural persons and entities designated by the UN, as well as prohibitions and restrictions in relation to proliferation-sensitive nuclear activities, the provision of financial services, the opening of new branches, subsidiaries, or representative offices of Iranian banks, the establishing by Iranian banks of new joint ventures, the establishing or maintaining of correspondent relationships, and prohibitions in relation to the provision of financial services. 

EU snapback

Besides the UN sanctions, the EU could also autonomously re-impose the EU sanctions that were lifted under the JCPOA. [FN/3]
These sanctions include amongst others, an asset freeze and visa or travel ban in relation to a number of natural persons and entities designated by the EU, as well as prohibitions and restrictions in relation to proliferation-sensitive nuclear activities, the oil, gas and petrochemical sector, certain trade with Iran, the shipping, shipbuilding and transport sector, and prohibitions and restrictions in relation to financial transfers to and from Iran, banking and insurance activities, financial messaging services, and financial support for trade with Iran.
The reintroduced EU sanctions would be directly applicable in all EU Member States.
What is required for a sanctions snapback?
UN snapback
The JCPOA sets forth a dispute resolution mechanism, which could be triggered by any of the remaining participants to the JCPOA (the “complaining participant”) if it believed that another participant to the JCPOA is not meeting its commitments.
First, the complaining participant would refer the dispute to the Joint Commission consisting of Iran, Russia, China, France, Germany, the UK and the EU. The Joint Commission would then have 15 days to resolve the matter, unless the time period was extended by consensus.
Second, any participant could then refer the dispute to the Ministers of Foreign Affairs of the parties to the JCPOA if it believes that it has not been resolved. The Ministers would then have another 15 days to resolve the dispute, unless the time period was extended by consensus. At the same time, or instead of, the review by the Ministers of Foreign Affairs, the complaining participant, or the participant that is allegedly in breach of the JCPOA, could request that the dispute be considered by a three-member Advisory Board. The Advisory Board’s opinion is not binding and would have to be provided within this same 15 days’ time period.
Third, if the dispute is not resolved after this 30-day process, the Joint Commission would have 5 additional days to consider the opinion of the Advisory Board.
Fourth, if the dispute still has not been resolved to the satisfaction of the complaining participant, and if the complaining participant deems the breach by the other party to constitute significant non-performance, then the latter could treat the unresolved matter as grounds to cease performing its commitments under the JCPOA in whole or in part, or notify the UN Security Council that it believes the breach constitutes significant non-performance.[FN/4]
Finally, upon notification by the complaining participant, the UN Security Council must vote, within 30 days, on a resolution to continue the sanctions lifting. Such resolution would need nine votes in favour – and no vetoes by the US, Russia, China, the UK or France – to be adopted. If this resolution is not adopted within 30 days of the notification, then the provisions of the old UN Security Council resolutions would be re-imposed, unless the UN Security Council decides otherwise.
EU snapback
The Information Note on EU sanctions to be lifted under the JCPOA of 23 January 2016 (the “Information Note”) clarifies that the EU will reintroduce the lifted EU sanctions in the event of a significant non-performance by Iran and after having exhausted all recourse possibilities under the above-mentioned dispute resolution mechanism. 
The EU sanctions would be reintroduced through a decision by the Council of the EU, based on a recommendation by the High Representative of the EU for Foreign Affairs and Security Policy, France, Germany and the United Kingdom and in accordance with regular EU procedures for the adoption of restrictive measures.
What happens with existing contracts in case of a snapback?
UN snapback
In case of a snapback, the re-imposed UN sanctions would not apply with retroactive effect to contracts signed between any party and Iran or Iranian individuals and entities prior to the date of application, provided that the activities contemplated under and in execution of these contracts are consistent with the JCPOA and the previous and current UN Security Council resolutions. 
EU snapback
The EU has clarified in its Information Note that, in case of an EU snapback, the EU sanctions would not apply with retroactive effect. The execution of contracts concluded in accordance with the JCPOA while the sanctions were lifted would be permitted consistent with previous provisions when sanctions were originally imposed in order to allow companies to wind down their activities. Details about the period of time allowed for the execution of prior contracts would be specified in the legal acts providing for the reintroduction of the EU sanctions. 
The EU furthermore clarified by way of example that the reintroduction of sanctions on investment activities would not retroactively penalise investments made before the date of snapback, and the execution of investment contracts concluded before the reintroduction of sanctions would be permitted consistent with previous provisions when sanctions were originally imposed. 
Contracts that were permitted when the sanctions regime was still in place would not be targeted by the reintroduction of sanctions.
[FN/1] See the UN Security Council Resolutions 1696 (2006), 1737 (2006), 1747 (2007), 1803 (2008), 1835 (2008), 1929 (2010) and 2224 (2015).

[FN/2] It is notable that, pursuant to Article 236 of the Belgian omnibus law of 2 May 2019 including various financial provisions, an asset freeze that is imposed by the UN Security Council is directly applicable in Belgium (without the need for implementation by the EU).

[FN/3] A consolidated version of the EU Regulation 267/2012 of 23 March 2012 concerning restrictive measures against Iran as applicable prior to the sanctions lifting is 

[FN/4] The JCPOA does not provide for a definition of “significant non-performance”. Accordingly, it appears that the qualification of a breach as “significant” is discretionary.

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TE_a117. ECTI Presents Not Your Everyday Investigation: Authorizing, Managing and Conducting Internal Investigations into Potential Violations of U.S. Export Controls and Sanctions Laws: September 10, 2019

(Source: Danielle Hatch, 
* WhatNot Your Everyday Investigation: Authorizing, Managing and Conducting Internal Investigations into Potential Violations of U.S. Export Controls and Sanctions Laws
* When: September 10, 2019 1:00 p.m. (EDT)
* Where: Webinar
* Sponsor: Export Compliance Training Institute (ECTI)
* ECTI Speaker: Timothy O’Toole

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TE_a218. FCC Presents “Designing an ICP for Export Controls & Sanctions”, 1 Oct in Bruchem, the Netherlands

This training course is designed for compliance officers, managers, and other professionals who aim to enhance their organization’s compliance efforts. The course will cover multiple topics and tackle various key questions, including but not limited to:
– Setting the Scene: ensuring compliance in the export control and sanctions arena
– What is expected from your organization? A closer look at the official frameworks and guidelines from U.S. and European government agencies
– Key elements of an ICP
– Best practice tips for enhancing your current compliance efforts  
– Internal controls samples (policies, procedures, instructions)
– Strategic benefits of having an ICP.
* What: Designing an Internal Compliance Program (ICP) for Export Controls & Sanctions
* Date: Tuesday, 1 Oct 2019
* Location: Full Circle Compliance, Landgoed Groenhoven, Dorpsstraat 6, Bruchem, The Netherlands
* Times:
  – Registration and welcome: 9.00 am – 9.30 am
  – Training course hours: 9.30 am – 4.30 pm
* Level: Intermediate
* Target Audience:  the course provides valuable insights for both compliance professionals, employees and (senior / middle) management working in any industry subject to U.S. and/or EU (member state) export control laws and sanctions regulations.
* Instructors: Drs. Ghislaine C.Y. Gillessen RA and Marco M. Crombach MSc.
* Information & Registration: click
here or contact us at 
events@fullcirclecompliance.eu or 31 (0)23 – 844 – 9046.  

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John Quincy Adams (11 Jul 1767 – 23 Feb 1848; was an American statesman, diplomat, and lawyer who served as the sixth president of the United States from 1825 to 1829.  He was the eldest son of John Adams, who served as the second US president from 1797 to 1801.)
 – “Patience and perseverance have a magical effect before which difficulties disappear and obstacles vanish.”
  – “Always vote for principle, though you may vote alone, and you may cherish the sweetest reflection that your vote is never lost.”

James Whistler
 (James Abbott McNeill Whistler; 11 Jul 1834  – 17 Jul 1903; was an American artist, active during the American Gilded Age and based primarily in the United Kingdom. His most famous painting is Arrangement in Grey and Black No. 1 (1871), commonly known as Whistler’s Mother, the revered and often parodied portrait of motherhood.  Whistler affected a posture of self-confidence and eccentricity. He often was arrogant and selfish toward friends and patrons. A constant self-promoter and egoist, he relished shocking friends and enemies.)
  – “I can’t tell you if genius is hereditary, because heaven has granted me no offspring.”
E. B. White (Elwyn Brooks White; 11 July 11 – 1 Oct 1985; was an American writer. For more than fifty years, he was a contributor to The New Yorker magazine. He was also a co-author of the English language style guide 
The Elements of Style. In addition, he wrote books for children, including 
Stuart Little (1945), 
Charlotte’s Web (1952), and 
The Trumpet of the Swan (1970). In a 2012 survey of School Library Journal readers, 
Charlotte’s Web was voted the top children’s novel.)
  – “Prejudice is a great time saver. You can form opinions without having to get the facts.”
– “Old age is a special problem for me because I’ve never been able to shed the mental image I have of myself – a lad of about 19.”

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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:27 June 2019: 84 FR 30593-30595: Revisions to the Unverified List

* 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: 26 June 2019: 
Harmonized System Update 1912  

  – 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.

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