19-0726 Friday “Daily Bugle”

19-0726 Friday “Daily Bugle”

Friday, 26 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.

  1. State/DDTC Seeks Comments to Consolidate Exemptions in the International Traffic in Arms Regulations 
  2. State/DDTC Updates Cuba Restricted List 
  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: “Issuance of Amended Venezuela-related General License”
  1. Expeditors News: “CBP Announces Section 321 Data Pilot”
  2. ZDNet: “GitHub Starts Blocking Developers in Countries Facing US Trade Sanctions”
  1. A. Sreekumar: “Transforming India into a Defence Export Powerhouse [Part I of II]”
  2. C. Gaetano: “OFAC Sanctions Compliance Fines Reach Decade-Long High”
  3. M. Volkov: “The Overwhelmed CCO”
  1. FCC Presents “The ABC of FMS”, 28 Nov in Bruchem, the Netherlands
  2. List of Approaching Events: 125 Events Posted This Week, Including 13 New Events 
  1. Bartlett’s Unfamiliar Quotations 
  2. Are Your Copies of Regulations Up to Date? Latest Amendments: DHS/Customs (5 Apr 2019), DOC/EAR (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 (24 Jul 2019), HTSUS (22 Jul 2019) 
  3. Weekly Highlights of the Daily Bugle Top Stories 


. State/DDTC Seeks Comments to Consolidate Exemptions in the International Traffic in Arms Regulations

(Source: Federal Register, 26 July 2019.) [Excerpts.]
84 FR 36040: Consolidation of Exemptions in the International Traffic in Arms Regulations
* AGENCY: Department of State.
* ACTION: Advance notice of proposed rulemaking.
* SUMMARY: As part of an ongoing effort to better organize the
International Traffic in Arms Regulations (ITAR), the Directorate of Defense Trade Controls (DDTC) seeks public comment on consolidating and clarifying the various exemptions located throughout the regulations. DDTC does not seek input on whether individual exemptions in the ITAR should be expanded or eliminated, but rather requests comments regarding: Which exemptions, if any, are redundant or could be consolidated; and which exemptions, if any, contain language that introduces significant ambiguity or hinders the exemption’s intended
* DATES: The Department of State will accept comments in response to this notice until August 26, 2019.
* ADDRESSES: Interested parties may submit comments by one of the following methods: Email:DDTCPublicComments@state.gov with the subject line,
“Request for Comments Regarding Consolidation of ITAR Exemptions.” Internet: At www.regulations.gov, search for this notice using its docket number, DOS-2019-0022. Comments submitted through www.regulations.gov will be visible to other members of the public; the Department will publish responsive comments on the DDTC website (www.pmddtc.state.gov). Therefore, commenters are cautioned not to include proprietary or other sensitive information in their comments.

* FOR FURTHER INFORMATION CONTACT: John Foster, Regulatory and Multilateral Affairs, Office of Defense Trade Controls Policy, Department of State, telephone (202) 663-2811 email DDTCResponseTeam@state.gov. ATTN: Consolidation of ITAR Exemptions.
* SUPPLEMENTARY INFORMATION: … The Department requests comment on the topics below. Excluding the exemptions currently located in Part 126 of the ITAR:
1. Which exemptions, if any, are redundant or could be
2. Which exemptions, if any, contain language that introduces
significant ambiguity or hinders the exemption’s intended use?

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. State Updates Cuba Restricted List

(Source, Federal Register, 26 July 2019.) [Excerpts.]
84 FR 36154-16156: Updating the State Department’s List of Entities and Subentities Associated With Cuba (Cuba Restricted List)
* AGENCY: Department of State
* ACTION: Updated publication of list of entities and subentities;
* SUMMARY: The Department of State is publishing an update to its List of Restricted Entities and Subentities Associated with Cuba (Cuba Restricted List) with which direct financial transactions are generally prohibited under the Cuban Assets Control Regulations (CACR). This Cuba Restricted List is also considered during review of license applications submitted to the Department of Commerce’s Bureau of Industry and Security (BIS) pursuant to the Export Administration Regulations (EAR).
* DATES: The Cuba Restricted List is updated as of July 26, 2019.
* FOR FURTHER INFORMATION CONTACT: Robert Haas, Office of Economic Sanctions Policy and Implementation, 202-647-7489; Office of the Coordinator for Cuban Affairs, tel.: 202-453-8456, Department of State, Washington, DC 20520.
* SUPPLEMENTARY INFORMATION: Below is the U.S. Department of State’s list of entities and subentities under the control of, or acting for or on behalf of, the Cuban military, intelligence, or security services or personnel with which direct financial transactions would disproportionately benefit such services or personnel at the expense of the Cuban people or private enterprise in Cuba. For information regarding the prohibition on direct financial transactions with these entities, please see 31 CFR 515.209. All entities and subentities were listed effective November 9, 2017, unless otherwise indicated. …

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. Items Scheduled
for Publication in Future Federal Register Editions

(Source: Federal Register, 26 July 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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NWS_a17. Expeditors News: “CBP Announces Section 321 Data Pilot”

Expeditors News, 23 July 2019.) [Excerpts.]
On July 23, 2019, U.S. Customs and Border Protection (CBP) announced in a Federal Register Notice (FRN) the beginning of a voluntary test to collect advance data related to shipments eligible for release under Section 321 of the Tariff Act of 1930.
Section 321 “provides for an administrative exemption from duty and taxes for shipments of merchandise…imported by one person on one day having an aggregate fair retail value of not more than $800.” According to CBP, they will use the advance information to “…improve CBP’s ability to effectively and efficiently identify and target high-risk shipments, including for narcotics, counter-proliferation, and health and safety risks.” …

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NWS_a28. ZDNet: “GitHub Starts Blocking Developers in Countries Facing US Trade Sanctions”

ZDNet, 26 July 2019.) [Excerpts.]
There’s a debate 
over free speech taking place after Microsoft-owned GitHub “restricted” the account of a developer based in the Crimea region of Ukraine, who used the service to host his website and gaming software. 
GitHub this week told Anatoliy Kashkin, a 21-year-old Russian citizen who lives in Crimea, that it had “restricted” his GitHub account “due to US trade controls”. 
Kashkin uses GitHub to host his website and 
GameHub, a launcher for Linux systems that combines games from Steam, 
GOG, and Humble Bundle in a single user interface.
Kashkin says GitHub advised him this week that it had restricted his account, pointing to its page about US trade controls, which lists Crimea, Cuba, Iran, North Korea, and Syria as countries facing US sanctions. 

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COM_a19. A. Sreekumar: “Transforming India into a Defence Export Powerhouse [Part I of II]”

Frost & Sullivan, 25 July 2019.)
* Author: Arjun Sreekumar, Senior Consultant at Frost & Sullivan.
As the government moves ahead with a second term, the nation’s defence export gambit needs to be refined. As a nation seeking to achieve self-reliance across defence segments by 2025, India presents a complex case of procurement and industry. For the past few years, policy and action were oriented toward increasing indigenous defence industrial capabilities through foreign original equipment manufacturer (OEM) linkages. This is a time-consuming process, but while the indigenous industry’s manufacturing and research and development (R&D) capabilities slowly build up, India must simultaneously construct an environment that facilitates defence export growth. SIPRI estimates indicate that over the past decade, India contributed to less than 0.1% of global defence exports, a figure that must be improved. It’s not that the country does not produce quality products; Indian defence electronics find their way into some of the most complex defence subsystems and platforms in the world today. However, there are fewer institutional mechanisms to promote exports and build the Indian brand compared to global defence majors-an area where interventions are required immediately.
Defence exports are a testament to a nation’s technological prowess and the proficiency of its industry. They are also valuable foreign exchange earners and key tools of geopolitical engagement. These are some of the drivers that propel India to transform itself from a majority importer of defence equipment into a self-reliant net exporter. To convert these drivers into results, India has two paths.
The first one is the long road, where new government policies are formulated, new industry engagements are initiated, engagements are analyzed post-initiation and then course-corrected following the analysis. The problem with this pathway is that it takes a substantial investment of time to deliver, and India does not have the luxury of time to stay competitive in the global defence market.
This brings us to the second path, a shorter and smarter approach that involves understanding the best practices of nations that have facilitated the establishment of leading defence companies with considerable exports and adapting them to the Indian milieu to leapfrog ahead. Frost & Sullivan, through this brief, explores this pathway in terms of enhancing and sustaining India’s defence exports.
Simplifying Regulatory Processes & Permits-Lessons from France
Regulation in defence exports is a multi-stakeholder process due to the sensitive nature of equipment. In India, exporters of lethal equipment need permissions from institutions such as the Concerned Service Headquarters, Ministry of External Affairs, Planning & Cooperation Wing (Ministry of Defence), Defence Research & Development Organization, Department of Space and Indian Space Research Organization. The Department of Defence Production coordinates the process. Submitting applications to multiple bodies, located at different locations and having differing mandates, is not the most efficient way to meet this objective. This is where France-one of the world’s leading defence exporters-stands out.
In France, the Inter-ministerial Commission for the Study of Military Equipment Exports (CIEEMG), a permanent body composed of representatives of ministries of defence, foreign affairs, economy and finance, screens and gives recommendations on permitting individual and global defence export licenses. The prime minister approves the recommendation of the CIEEMG or if the CIEEMG members cannot reach a consensus, a decision is made directly by the Prime Minister’s Office. This centralized decision-making coupled with the establishment of the générale de l’armement (DGA) in the early 1960s accelerated the nation’s exports. The first decade of functioning of the DGA-CIEEMG combine (1961-71) saw French exports increase by 140%.[FN/1] France’s integrated approach toward exports has cut multiplicity of channels between stakeholders and led to specialization. This permanent inter-ministerial engagement has enabled it to continuously refine its defence policies and processes.

As India expands its participation in global export control regimes, it needs to balance speedy export permission with strong non-proliferation and control. Here again, the French defence export system provides a model in maintaining a simple regulation system while not compromising on multilateral export control commitments. The French have done this by making it incumbent on the exporters to make periodic submissions of export and delivery details and also putting in place strong ex-post-facto controls involving the DGA and Ministry of Customs.
Exporting companies are required to send biannual reports to the Ministry of Defence (MoD), listing the equipment orders and the deliveries made for verification. Their customs department is also empowered to initiate control procedures; these may include interviews, seizure of documents, visits to company premises, recognition of an infringement or sanctions. This approach could prove useful to India in case of export of Non-Appendix II Munitions as government resources will be freed up and Indian OEMs get a certain degree of freedom because of a shift from external case-by-case regulation to batch processes, self-declaratory compliance and periodic checks.
The Institutional Driver-Lessons from Israel
The creation of a dedicated export promotion body has been mooted in India’s “Strategy for Defence Exports,” released by the Indian MoD, but has not yet been operationalized. Israel’s International Defence Cooperation Directorate (SIBAT)[FN/2] presents a case where a dedicated body has successfully worked with the Israeli defence industry to make the nation a defence exporter par excellence. SIBAT works closely with Israeli private industry to align its activities with Israel’s strengths and match customer requirements. The body is not just a facilitator for marketing Israeli products and companies but proactively identifies upcoming market opportunities and works through diplomatic and government-to-government (G2G) channels to promote sales of Israeli defence equipment. This way, the body helps local companies plan and execute their marketing and business development strategies.
Leveraging Diplomatic Assets-Lessons from France and the United States
The presence of dedicated divisions and personnel for trade promotion within diplomatic establishments can help nations competitively engage and promote local industry in overseas markets.
The French Diplomatic Establishment is proactive in its target markets for export promotion. Most embassies and even some consulates have a Regional Economic Service [FN/3] that supports exports by following up on foreign direct investments, public and private projects, and contracts in target markets. Its mandate also includes strengthening bilateral economic relationships and increasing the visibility of French companies within the target market. The wing also helps set up higher-level meetings with leaders to push an economic agenda, which includes defence-related propositions. The wing’s support was key in brokering the contract between Eurosam, Roketsan and Aselsan for a Turkish missile defence system as part of the LORAMIDS (Long-range Air and Missile Defence System) program initiated by Turkey.[FN/4] The Economic Service also routinely provides French companies with local market forecasts, trade policy updates and go-to-market advisory, as it has dedicated personnel for economic benchmarking. It also has dedicated defence export promotion attachés in high-value markets.
Setting up dedicated defence export promotion wings within diplomatic establishments has also helped the US in defence exports. Institutions such as Team Department of Defence (Team DoD)[FN/5] in Turkey and Offices of Defence Cooperation attached to embassies look into the operational aspects and act as a single point of contact for US Foreign Military Sales (FMS) programs. These offices support the US defence industry by providing liaising and networking services with target market officials. In many cases, host country professionals have local knowledge that could aid in business development, which is why the US Foreign Commercial Service [FN/6] has active professionals from both the US and the host country to help US businesses in commercial diplomacy, project advocacy and business-to-business (B2B) matchmaking. The service has previously helped US companies promote business in markets such as Turkey.
Our research indicates a direct correlation between a nation’s contribution to world defence exports and the number of specialized defence trade promotion personnel it has in its target markets. From an analysis of the top 15 defence export markets, Frost & Sullivan finds that the defence promotion agenda explicitly figures as key result areas of over 30% of US personnel involved in trade promotion. The figure goes up to 45% for the UK. India’s long-term defence export policies could benefit from a key expansion of specialized personnel or the creation of a dedicated institution such as Team DoD of the US.
Every diplomatic mission in a target market should have a defence business mandate, targets and clearly delineated responsibilities matched to departmental stakeholders to further defence exports. Indian defence OEMs today need support from diplomatic establishments similar to that provided by France and the US to grow its visibility in target markets and proactively engage prospective buyers. India’s diplomatic assets need to be briefed on indigenous industry capabilities, products, and upcoming opportunities in foreign markets and routes to market entry so they become active assets in soliciting business. The Indian government is currently putting in place a similar business development mandate across many of its overseas diplomatic institutions; however, certain elements in terms of market access and business potential (discussed later in the article) need to be considered for this approach to be effective.
Part II of II will be published in the Daily Bugle of 29 July 2019.

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COM_a210. C. Gaetano: “OFAC Sanctions Compliance Fines Reach Decade-Long High”

NYSSCPA, 25 July 2019.)
Fines issued by the Treasury Department’s Office of Foreign Assets Control (OFAC) have reached a 10-year high, reflecting the administration’s increased use of sanctions as a foreign policy tool, according to the 
Wall Street Journal. The mandate of OFAC is to administer and enforce “economic and trade sanctions based on U.S. foreign policy and national security goals.” Though the year is only a little more than halfway over, the haul brought in through settlements with sanctions violators, $1.3 billion, is already 17 times what was collected in all of 2018. The only year that came close to the current total was 2014, when the government collected $1.2 billion in penalties. This larger sum is also coming from a smaller number of entities: The year-to-date total is 18 settlements, as opposed to 22 in 2014. 

Beyond new programs, this year’s numbers could also be attributed to a backlog of cases finally coming to the fore, as well as speedier resolutions of these cases, according to the Journal. 

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 M. Volkov: “The Overwhelmed CCO”

Volkov Law Group Blog, 22 July 2019, Reprinted by permission.)
* Author: Michael Volkov, Esq., Volkov Law Group,
mvolkov@volkovlaw.com, 240-505-1992.
Chief compliance officers have a hard job.  CCOs know that fact and them fully embrace the challenges of their positions.  At the same time, CCOs have extraordinary expectations placed on their shoulders – they are rarely complemented about their programs while the company avoids any major controversies, but they are one of the first to be questioned when a compliance breakdown occurs.  
CCOs are always busy.  Everyone understands why – they have high expectations and often limited resources, outdated technologies, and competing, political demands on their activities.  
I often witness this phenomenon.  CCOs often explain that they rarely focus on their “to-do list” and spend most of their time “putting out fires” or responding to a senior executive’s demand.  CCOs regularly complain that they get to the end of the day and have had no time to focus on their priorities.
This can be a trap.  A CCOs performance is not measured by how busy they are – being busy does not necessarily translate into quality of performance.  To put it bluntly, running from fire to fire does not necessarily mean that a CCO is doing a good job.
CCOs have to apply a cost-benefit analysis to their own activities.  Warren Buffet and Bill Gates recently conceded that the most valuable commodity they have is their time. CCOs have to do the same analysis.  
For CCOs the danger of being overwhelmed is significant.  CCOs have a huge portfolio for which they are responsible and they often lack basic resources to carry out their job.  Their difficulties are compounded by the fact that CCOs are dependent on the cooperation and performance of related functions in the company over which the CCO has no authority, e.g. human resources, finance, information technology.
CCOs have examine their specific responsibilities and tasks, and turn a critical eye to each and ask some basic questions.
Responsibility: Is this a task that I should be responsible for?
If not, who should be responsible for completing the task?
Accountability:  Can I hold that person accountable?
Information: Do I need to know any information about the performance of that task?
Communication:  Have I adequately delegated this task to the appropriate person and communicated my expectations as to performance?
This basic framework provides a way for a CCO to prioritize his or her responsibilities and then make sure that any delegation of responsibility is properly executed.
CCOs need to rationalize their activities, delegate where they can do so, or address specific needs in other ways – e.g. seeking assistance from another function or securing additional resources (human or technology).
An overwhelmed CCO is a risk unto itself – and CCOs need to guard against such a threat.  It is easy to get lost in a job and it takes discipline to preserve a person’s ability to perform their job effectively. 

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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: 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

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List of Approaching Events: 125 Events Posted This Week, Including 13 New Events
(Sources: Editor and Event Sponsors)

Published every Friday or last publication day of the week, o
ur overview of Approaching Events is organized to list c
ontinuously available training, training events, s
eminars & conferences, and 
If you wish to submit an event listing, please send it to
, 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;

* E-Seminars: “ITAR/EAR Awareness“; Export Compliance Solutions;

* 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: “ITAR – Requirements for Government Contractors“; Williams Mullins, LLP

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 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 13: Leeds, United Kingdom; “Understanding Exporting & Incoterms Workshop”; Chamber International

* Aug 20-21: Cincinnati, OH;

Complying with U.S. Export Controls
“; Commerce/BIS

* Aug 20-21: Milpitas, CA;

Complying with U.S. Export Controls

* Aug 22: Los Angeles, CA; “
Trade Compliance & Policy” C.H. Robinson

* Aug 22: Milpitas, CA:

Encryption Controls

* Aug 22-23: Maputo, Mozambique; “Countering North Korean UN Sanctions Violations in Southern Africa“; CCSI

* 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 4: Long Beach, CA; “Automated Commercial Environment (ACE) Export Compliance Seminar“; U.S. Census Bureau

* 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: Leeds, United Kingdom; “Leeds World Trade Summit“; Institute of Export & International Trade

* 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
; 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 23-27: College Park, MD; “Defense and Dual-Use Export Controls“; The Strategic Trade Research Institute

* Sep 23-26: London, United Kingdom; “Annual Corporate Compliance Conference“; Baker McKenzie

* 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”; 
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
; 540-433-3977

* Oct 2: New York, NY; “Sanctions Compliance Think Tank“; American Conference Institute

* 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

* Oct 10: Rancho Mirage, CA; “WESCCON 2019 Conference“; Pacific Coast Council

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

* 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 7; Amsterdam, the Netherlands; “Annual International Trade & Compliance Conference“; Baker McKenzie
* Nov 11-13; London, United Kingdom; “International Trade Finance Training Course“; IFF

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

* Nov 13-14; Santa Clara, CA; “2019 Year-End Review of Import/Export Developments“; Baker McKenzie

* Nov 18: London, UK; “2nd Annual Navigating Russia Sanctions Complexities“; C5
* Nov 19-20: London, UK; “London Forum on Economic Sanctions“; C5

* 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

* 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

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

* Jan 22-23: New York, NY; “AML & OFAC for the Insurance Industry“; American Conference Institute  

* Jan 23: Orlando, FL; “Customs/Import Boot Camp“; Partnering for Compliance

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

* Mar 10-12:  Orlando, FL; “‘Partnering for Compliance’ Export/Import Control Training and Education Program“; Partnering for Compliance

* Apr 22-23: Washington D.C.; “Economic Sanctions Enforcement and Compliance“;
American Conference Institute
* May 27-28: Hong Kong, China; “Hong Kong Summit on Economic Sanctions Enforcement and Compliance“;
American Conference Institute


* Sep 24: Webinar: “Top 10 Mistakes Importers Make (and How to Avoid Them)“; Sandler, Travis and Rosenberg Trade Law

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


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

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. Bartlett’s Unfamiliar Quotations

(Source: Editor)


George Bernard Shaw (26 Jul 1856 –  2 Nov 1950; was an Irish playwright, critic, polemicist, and political activist. His influence on Western theatre, culture and politics extended from the 1880s to his death and beyond. He wrote more than sixty plays, including major works such as 
Man and Superman, Pygmalion, and 
Saint Joan. With a range incorporating both contemporary satire and historical allegory, Shaw became the leading dramatist of his generation, and in 1925 was awarded the Nobel Prize in Literature.)
  – “Marriage is an alliance entered into by a man who can’t sleep with the window shut, and a woman who can’t sleep with the window open.”
Carl Jung (Carl Gustav Jung; 26 Jul 1875 – 6 Jun 1961; was a Swiss psychiatrist and psychoanalyst who founded analytical psychology.)
– “A human being would certainly not grow to be seventy or eighty years old if this longevity had no meaning for the species. The afternoon of human life must also have a significance of its own and cannot be merely a pitiful appendage to life’s morning.”

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EN_a315. 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.

: 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

: 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


: 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
  – 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 
.  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 

: 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 

: 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.

; 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

: 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 
. 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: 23 July 2019: 84 FR 35307 – July 2019 Amendments to Global Terrorism Sanctions Regulations; Transnational Criminal Organizations Sanctions Regulations; and Hizballah Financial Sanctions Regulations [amendment of 31 CFR Parts 566, 590, and 594.] 

, 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: 22 July 2019: Harmonized System Update (HSU) 1913  
  – 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 Daily Bugle Top Stories” posted here.

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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, Alex Witt and Sven Goor. The Ex/Im Daily Update is emailed every business day to approximately 7,000 readers of changes to defense and high-tech trade laws and regulations. We check the following sources daily: Federal Register, Congressional Record, Commerce/AES, Commerce/BIS, DHS/CBP, DOE/NRC, DOJ/ATF, DoD/DSS, DoD/DTSA, FAR/DFARS, State/DDTC, Treasury/OFAC, White House, and similar websites of Australia, Canada, U.K., and other countries and international organizations.  Due to space limitations, we do not post Arms Sales notifications, Denied Party listings, or Customs AD/CVD items.

* RIGHTS & RESTRICTIONS: This email contains no proprietary, classified, or export-controlled information. All items are obtained from public sources or are published with permission of private contributors, and may be freely circulated without further permission, provided attribution is given to “The Export/Import Daily Bugle of (date)”. Any further use of contributors’ material, however, must comply with applicable copyright laws.  If you would to submit material for inclusion in the The Export/Import Daily Update (“Daily Bugle”), please find instructions here.

* CAVEAT: The contents cannot be relied upon as legal or expert advice.  Consult your own legal counsel or compliance specialists before taking actions based upon news items or opinions from this or other unofficial sources.  If any U.S. federal tax issue is discussed in this communication, it was not intended or written by the author or sender for tax or legal advice, and cannot be used for the purpose of avoiding penalties under the Internal Revenue Code or promoting, marketing, or recommending to another party any transaction or tax-related matter.

* SUBSCRIPTIONS: Subscriptions are free.  Subscribe by completing the request form on the Full Circle Compliance website.

* BACK ISSUES: An archive of Daily Bugle publications from 2005 to present is available HERE.

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