;

19-0712 Friday “Daily Bugle”

19-0712 Friday “Daily Bugle”

Friday, 12 July 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. (The Daily Bugle was not published yesterday, 4 July 2019.)

[No items of interest.]
  1. Items Scheduled for Publication in Future Federal Register Editions 
  2. Commerce/BIS: (No new postings.) 
  3. DHS/CBP Announces ACE Production Scheduled Maintenance, 14 Jul
  4. Justice: “Palm Beach County Resident Charged with Export Control Violations for Illegally Exporting Hundreds of Parts for AR-15 Assault Rifles”
  5. State/DDTC: (No new postings.) 
  1. IUS: “Enthusiasm Builds for U.S. Military Drone Exports After Rule Change”
  2. NBC: “U.S. Tech on Guard Against China ss Scrutiny Increases on Security, Human Rights”
  1. A.V. Capobianco, A. Doussin & A. Dukic: ” U.S. Sanctions Regulator Outlines Expectations for Global Sanctions Compliance: Impact on Private Equity”
  2. M. Volkov: “The Critical Dataset: HR, Hotlines and Incident Management”
  1. ECTI Presents The New “Framework for OFAC Compliance Commitments: What You Need to Know”, July 24, 2019
  2. FCC Presents “The ABC of FMS”, 28 Nov in Bruchem, the Netherlands
  3. List of Approaching Events: 123 Events Posted This Week, Including 10 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 (27 Jun 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 (26 Jun 2019) 
  3. Weekly Highlights of the Daily Bugle Top Stories 

EXIMITEMS FROM TODAY’S FEDERAL REGISTER

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

OGSOTHER GOVERNMENT SOURCES

OGS_a11
. Items Scheduled
for Publication in Future Federal Register Editions

(Source: Federal Register, 12 July 2019.)

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

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

(Source: Commerce/BIS)

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

OGS_a33
.
DHS/CBP Announces ACE Production Scheduled Maintenance, 14 Jul
(Source: DHS/CBP, 12 Jul 2019.)
 
There will be ACE PRODUCTION Scheduled Maintenance Saturday evening, July 13, 2019 from 2200 ET to 0400 ET Sunday, July 14, 2019 for ACE Infrastructure maintenance and the following ACE Deployment:
 
ACE Quota
 
– CBP has made a system update to send out a new UC reject for any quota entry summary filings with a quantity of zero. Entry summary filings will still be accepted with a quantity of zero, but this new UC reject will be sent out to inform the trade as to why the quota is unable to process. A new Q15 error code with a description of ‘QTA QUANTITY MUST BE > 0’ will be sent out in this situation.
 
– Resolved an issue where UC Message for Agriculture Licenses were not implying 2 decimal places like regular CBP quota UC Messages were.
 
– Resolved an issue where UC Message would send out QUOTA FILLED, but SO would send out QUOTA RESERVED message; now UC Message will send out QUOTA FILLED and SO will send out QUOTA REJECTED to be consistent.

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

OGS_a44.
Justice: “Palm Beach County Resident Charged with Export Control Violations for Illegally Exporting Hundreds of Parts for AR-15 Assault Rifles”
(Source:
Justice, 12 Jul 2019.) [Excerpts.]
 
A Palm Beach County resident was arrested on July 11, 2019, based on a complaint charging him with conspiracy to violate and attempted violations of the Arms Export Control Act (AECA) and International Traffic in Arms Regulations (ITAR) (18 U.S.C.  371 and 22 U.S.C.  2778).
 
Ariana Fajardo Orshan, U.S. Attorney for the Southern District of Florida, and Anthony Salisbury, Special Agent in Charge, Homeland Security Investigations (HSI), Miami Field Office, made the announcement.
 
Cristian German Barrera, 47, was charged with conspiracy to violate the AECA and ITAR, and attempts to illegally export to Argentina defense articles, specifically, parts and components for AR-15 assault rifles, which were smuggled across international borders by a transnational weapons trafficking group in Argentina. He had an initial appearance before U.S. Magistrate Judge Jacqueline Becerra.
 
According to the complaint and other court documents, Barrera illegally exported without a required license from the U.S. Department of State, to the Argentine weapons trafficking organization, hundreds of AR-15 assault rifle parts. The investigative efforts of HSI agents in the Miami Field Office along with HSI agents stationed in Argentina, and their proactive cooperation with Argentine law enforcement officials between October and December 2019, led to the execution of search warrants in Florida and Argentina that resulted in the seizure of the equivalent of 52 AR-15 assault rifles in Florida and in Argentina: 189 long arms, 156 handguns, one mortar round, one hand grenade, over 30,000 rounds of assorted caliber ammunition, five vehicles, and $110,000 in cash. On June 26, 2019, Argentina’s National Gendarmeria conducted an operation that led to the arrest of additional subjects and the seizure of thousands of firearms and explosive materials. …

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

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

(Source:
State/DDTC
)

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

NWSNEWS

NWS_a16
.
IUS: “Enthusiasm Builds for U.S. Military Drone Exports After Rule Change”

(Source: Inside Unmanned Systems, 12 Jul 2019.) [Excerpts.]
 
The White House eased drone export rules in April 2018, responding to both strategic realities and pressure from U.S. firms that were losing out on lucrative deals. The revised rules have captured the attention of some defense companies, sharpening their focus on international sales and even inspiring design decisions that could make their drones both more competitive and easier to export-key factors in a sector where China has sold systems to at least a dozen countries and other new competitors are emerging. …
 
Triggering the change were American manufacturers of military drones who had long complained that U.S. export rules put them at a competitive disadvantage. Though the Obama administration made some revisions, the Trump administration decided to ease export controls more substantially after California-based General Atomics, which builds the Predator and Reaper unmanned aircraft systems (UAS), lost already-negotiated sales to Saudi Arabia and the United Arab Emirates to a Chinese competitor at the last minute. …


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NWS_a27.
NBC: “U.S. Tech on Guard Against China as Scrutiny Increases on Security, Human Rights”

(Source: NBC, 12 Jul 2019.) [Excerpts.]
 
It looked like the U.S. tech industry had been given a reprieve in late June when President Donald Trump reversed course on a decision to effectively bar companies from doing business with Chinese telecom giant Huawei.
 
But experts say that the cooling trade tensions with China mask a deeper change in how tech companies that once counted on China as an important partner and prospective market opportunity now approach doing business with companies like Huawei.
 
“The trade fight over tech isn’t going to stop,” said James Lewis, senior vice president at the Center for Strategic and International Studies, a Washington think tank. …

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COMCOMMENTARY

COM_a08.
A.V. Capobianco, A. Doussin & A. Dukic: ” U.S. Sanctions Regulator Outlines Expectations for Global Sanctions Compliance: Impact on Private Equity” 
 

(Source: Hogan Lovells, 3 Jul 2019.)
 
* Authors: Anthony V. Capobianco, Esq., anthony.capobianco@hoganlovells.com, +1 202 637 2568;Aline Doussin, Esq., aline.doussin@hoganlovells.com, +44 20 7296 2961; and Aleksandar Dukic, Esq., aleksandar.dukic@hoganlovells.com, +1 202 637 546, all of Hogan Lovells.
 
On 2 May 2019, the U.S. Treasury’s Office of Foreign Assets Control (“OFAC”), the agency responsible for enforcing economic sanctions, published “A Framework for OFAC Compliance Commitments” (the “Framework”) which outlines five components OFAC considers to be essential for an effective risk-based sanctions compliance program. OFAC also highlights “root causes” of sanctions violations in the Framework. The Framework offers private equity and other fund managers a detailed insight into OFAC’s expectations with respect to an organization’s sanctions compliance program for the first time.
 
What does this mean for private equity fund managers? …

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COM_a19.
M. Volkov: “The Critical Dataset: HR, Hotlines, and Incident Management”

(Source: Volkov Law Group Blog, 11 Jul 2019. Reprinted by permission.)
 
* Author: Michael Volkov, Esq., Volkov Law Group, mvolkov@volkovlaw.com, 240-505-1992.
 
It is easy to get swept up into compliance trends, prognosticators of the future, and future compliance terms such as “artificial intelligence,” or “blockchain.” Do not get me wrong, these are the terms for the future and eventually they will be part of common compliance conversations.
 
But sometimes we need to get back to basics. In some cases, Chief Compliance Officers need to remind themselves of important basic principles. In this way, consistent compliance foundations can be built and program expectations are manageable.
 
While much has been written about “operationalizing” a compliance program, the term leaves out some important concepts. Sometimes internal constituencies do not play well with others. I am always surprised when speaking to compliance professionals about the lack of cooperation and coordination among natural brothers/sisters in arms. …

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TEEX/IM TRAINING EVENTS & CONFERENCES

TE_1
10
. 
ECTI Presents The New “Framework for OFAC Compliance Commitments: What You Need to Know”, July 24, 2019
(Source: Danielle Hatch, danielle@learnexportcompliance.com)
 
* What: The New “Framework for OFAC Compliance Commitments”: What You Need to Know
* When: July 24, 2019 1:00 p.m. (EDT)
* Where: Webinar
* Sponsor: Export Compliance Training Institute (ECTI)
* ECTI Speaker: Timothy O’Toole
* Register here.

or Danielle Hatch, 540-433-3977, danielle@learnexportcompliance.com

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

TE_2
11
. 
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.
 
Details
* 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: here or contact FCC at events@fullcirclecompliance.eu or + 31 (0)23 – 844 – 9046
* This course can be followed in combination with “U.S. Export Controls: The International Traffic in Arms Regulations (ITAR) from a non-U.S. Perspective” (26 Nov 2019), and/or “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

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

TE_List12. 
List of Approaching Events: 123 Events Posted This Week, Including 10 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

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

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

#
* Jul 17; Pittsburgh, PA; “U.S. Export Controls: A Primer & Discussion of Recent Developments; Pittsburgh Technology Council

* Jul 17-18: Miami, FL; “
CTPAT Internal Auditor Training
“; Supply Chain Security International Inc.

* Jul 17-18: Port of Spain, Trinidad & Tobago; “Foreign Supplier Verification Programme“; ExporTT  

 
* Jul 18: Chippenham, UK; “The Second Defence Assets Subject to Special Controls (ASSC) and Export Controls Forum“; Team Defence Information

*
Jul 22: Adelaide, Australia; “Defence Export Controls Outreach“;
Australian DoD

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

* Jul 23-24; Chicago, IL; “
Trade Symposium“;
U.S. CBP

*
Jul 23-25; Washington D.C.; “Anti-Corruption Compliance for High Risk Markets“; American Conference Institute

* Jul 24: Darwin, Australia: “Defence Export Controls Outreach“; Australian DoD

*
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 25: Washington D.C.; “Export Controls: The Latest Developments“; USCBC

* 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

University, Dorsey & Whitney LLP
#
* Aug 1: Boston, MA; “Customs Broker Exam Prep Course – October 2019 Exam” Sandler, Travis & Rosenberg

* 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

* Aug 29: Berlin, Germany; “Informationsveranstaltung Beraterschulung“; BAFA

* 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: Brisbane, Australia; “Defence Export Controls Outreach“; Australian DoD

* 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: Perth, Australia; “Defence Export Controls Outreach“; Australian DoD

* 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 20-23; San Diego, CA; “ITAR Controls / EAR & OFAC Export Controls Seminar Series“, ECTI; 540-433-3977 
*
 
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 17-20; Huntsville, AL; “
ITAR Controls / EAR & OFAC Export Controls Seminar Series
“, ECTI; 540-433-3977

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

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

#
* Mar 2-5; Washington D.C.; “
ITAR Controls / EAR & OFAC Export Controls Seminar Series
“, ECTI; 540-433-3977

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

 
Webinars 


 

* Jul 16: Webinar: “Incoterms“; NCBFAA 
* 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

* Jul 23: Webinar: “Compliance…Just Okay Is Not Okay“; Amber Road

#
* Jul 23: Webinar: “Safeguarding Your First Sale Savings in a Section 301 Enforcement Environment“;Sandler, Travis & Rosenberg


* 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 10: Webinar: “ECCN Classification Numbers“; NCBFAA

* Dec 17: Webinar: “Managing Emerging Compliance Risks“; Baker McKenzie

 

2020
 
* Jan 14: Webinar: “Commodity Jurisdiction“; NCBFAA
* Apr 14: Webinar: “ACE Export Reports for Compliance“; NCBFAA

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

ENEDITOR’S NOTES

EN_a213
. Bartlett’s Unfamiliar Quotations

(Source: Editor)

 

* Henry David Thoreau (12 Jul 1817 – 6 May 1862; was an American essayist, poet, philosopher, abolitionist, naturalist, tax resister, development critic, surveyor, yogi, and historian. A leading transcendentalist, Thoreau is best known for his book Walden, a reflection upon simple living in natural surroundings, and his essay “Civil Disobedience” (originally published as “Resistance to Civil Government”), an argument for disobedience to an unjust state.)
  – “There is no value in life except what you choose to place upon it and no happiness in any place except what you bring to it yourself.”
  – “It’s not what you look at that matters, it’s what you see.”   
  
* Paul Prudhomme (13 Jul 13, 1940 – 8 Oct 2015; was an American celebrity chef whose specialties were Creole and Cajun cuisines, which he was also credited with popularizing.)
  – “We didn’t do wrong things because we didn’t want to embarrass our parents.”
 
Friday funnies – U.S. state jokes:
*
 Kentucky:  
How do you know the toothbrush was invented in Kentucky?  If it’d been invented anywhere else, it would have been called a teethbrush.
* Louisiana:  How is a zoo in Louisiana different from other zoos in other states? The Louisiana zoo has a description of the animal on the front of the cage, along with a recipe.
* Maine:  After surveying property along the New Hampshire and Maine border, state engineers decided the boundaries needed to be changed. So they stopped to tell a farmer that his farm was no longer in Maine, but in New Hampshire. “Good,” said the farmer. “I can’t take another one of those Maine winters.”

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EN_a314. 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: 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 (4 Jul 2019) of Bartlett’s Annotated FTR (“BAFTR”), by James E. Bartlett III, is available for downloading in Word format. The BAFTR is a 152-page Word document containing 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: 26 June 2019: Harmonized System Update (HSU) 1912
  – HTS codes for AES are available here.
  – HTS codes that are not valid for AES are available here.

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EN_a415
. 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.

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