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19-0814 Wednesday “Daily Bugle”

19-0814 Wednesday “Daily Bugle”

Wednesday, 14 August 2019

TOP
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. Commerce/BIS Adds 17 Entities, Modifies 23, and Removes 2 Entities on the Entity List 
  2. DoD, GSA, NASA Amend FAR and Prohibits Contracting for Certain Telecommunications and Video Surveillance Services or Equipment 
  1. Items Scheduled for Publication in Future Federal Register Editions 
  2. Commerce/BIS: (No new postings.) 
  3. DoD/DSCA Releases NISP eMASS Industry Operation Guide Version 1.0
  4. State/DDTC: (No new postings.)
  5. UK ECJU Publishes New Notice on New Control on Exporting Submersible Vessels and Related Equipment to Russia
  6. UK ECJU Updates Guidance on Consolidated List of Strategic Military and Dual-Use Items that Require Export Authorisation
  1. Expeditors News: “USTR Announces Next Steps on Proposed 10 Percent Tariff on Imports from China”
  2. Nikkei: “US Adds China’s Biggest Nuclear Company to ‘Entity List'”
  1. G.R. Talati: “What IP Professionals Need to Know About Export Controls”
  2. D.M. Edelman, L.K. Rothberg & Matt Savare
    :
    Quantum Cryptography, Quantum Computing, Robotics, A.I. May Be Subject to New U.S. Export Policy” 

  1. ECTI Presents United States Export Control (ITAR/EAR/OFAC) Seminar Series in Austin, TX 
  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 (14 Aug 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 2019), DOT/FACR/OFAC (7 Aug 2019), HTSUS (22 July 2019) 
  3. Weekly Highlights of the Daily Bugle Top Stories 

EXIMITEMS FROM TODAY’S FEDERAL REGISTER

EXIM_a11.
Commerce/BIS Adds 17 Entities, Modifies 23, and Removes 2 Entities from the Entity List
(Source: Federal Register, 14 August 2019.) [Excerpts.]
 
84 FR 40237-40247: Addition of Certain Entities to the Entity List, Revision of Entries on the Entity List, and Removal of Entities from the Entity List
 
* AGENCY: Bureau of Industry and Security, Commerce.
* ACTION: Final rule.
* SUMMARY: In this rule, the Bureau of Industry and Security (BIS) amends the Export Administration Regulations (EAR) by adding seventeen entities, under a total of nineteen entries, to the Entity List. These seventeen entities have been determined by the U.S. Government to be acting contrary to the national security or foreign policy interests of the United States. These entities will be listed on the Entity List under the destinations of Armenia, Belgium, Canada, the People’s Republic of China (China), Georgia, Hong Kong, Malaysia, the Netherlands, Russia, the United Arab Emirates (U.A.E.), and the United Kingdom (U.K.). This rule also modifies a total of twenty-three entries on the Entity List under the destinations of China, Hong Kong, and Russia. Finally, this rule removes a total of three entities under the destinations of China and the U.A.E. The removals are made in connection with requests for removal that BIS received pursuant to the EAR and a review of information provided in those requests.
* DATES: This rule is effective August 14, 2019.
* FOR FURTHER INFORMATION CONTACT: Chair, End-User Review Committee, Office of the Assistant Secretary, Export Administration, Bureau of Industry and Security, Department of Commerce, Phone: (202) 482-5991, Email: ERC@bis.doc.gov. … 

 
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EXIM_a22.
DoD, GSA, and NASA Amend FAR and Prohibits Contracting for Certain Telecommunications and Video Surveillance Services or Equipment
(Source: Federal Register, 13 Aug 2019.) [Excerpts.]
 
84 FR: 40216-40223: Federal Acquisition Regulation: Prohibition on Contracting for Certain Telecommunications and Video Surveillance Services or Equipment
* AGENCY: Department of Defense (DoD), General Services Administration (GSA), and National Aeronautics and Space Administration (NASA).
* ACTION: Interim rule.
* SUMMARY: DoD, GSA, and NASA are issuing an interim rule amending the Federal Acquisition Regulation (FAR) to implement section 889(a)(1)(A) of the John S. McCain National Defense Authorization Act (NDAA) for Fiscal Year (FY) 2019 (Pub. L. 115-232).
* DATES: Effective Date: August 13, 2019.
 
Applicability: Contracting officers shall include the provision at FAR 52.204-24, Representation Regarding Certain Telecommunications and Video Surveillance Services or Equipment and clause at FAR 52.204-25, Prohibition on Contracting for Certain Telecommunications and Video Surveillance Services or Equipment as prescribed–
 
In solicitations issued on or after August 13, 2019, and resultant contracts; and In solicitations issued before August 13, 2019, provided award of the resulting contract(s) occurs on or after August 13, 2019. Contracting officers shall modify, in accordance with FAR 1.108(d), existing indefinite delivery contracts to include the FAR clause for future orders, prior to placing any future orders.
 
If modifying an existing contract or task or delivery order to extend the period of performance, including exercising an option, contracting officers shall include the clause in accordance with 1.108(d). The contracting officer shall include the provision at 52.204-24, Representation Regarding Certain Telecommunications and Video Surveillance Services or Equipment, in all solicitations for an order, or notices of intent to place an order, including those issued before August 13, 2019, where performance will occur on or after that date, under an existing indefinite delivery contract.
 
Comment date: Interested parties should submit written comments to the Regulatory Secretariat Division at one of the addresses shown below on or before October 15, 2019 to be considered in the formation of the final rule. …
 
SUPPLEMENTARY INFORMATION:
 
I. Background
 
This interim rule revises the FAR to implement section 889(a)(1)(A) of the NDAA for FY 2019 (Pub. L. 115-232). Section 889(a)(1)(A) prohibits agencies from procuring or obtaining, or extending or renewing a contract to procure or obtain, any equipment, system, or service that uses covered telecommunications equipment or services as a substantial or essential component of any system, or as a critical technology as part of any system, on or after August 13, 2019.
 
“Covered telecommunications equipment or services,” as defined in the statute, means —
  Telecommunications equipment produced by Huawei Technologies Company or ZTE Corporation (or any subsidiary or affiliate of such entities);
  For the purpose of public safety, security of Government facilities, physical security surveillance of critical infrastructure, and other national security purposes, video surveillance and telecommunications equipment produced by Hytera Communications Corporation, Hangzhou Hikvision Digital Technology Company, or Dahua Technology Company (or any subsidiary or affiliate of such entities);
  Telecommunications or video surveillance services provided by such entities or using such equipment; or
  Telecommunications or video surveillance equipment or services produced or provided by an entity that the Secretary of Defense, in consultation with the Director of National Intelligence or the Director of the Federal Bureau of Investigation, reasonably believes to be an entity owned or controlled by, or otherwise connected to, the government of a covered foreign country. …

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OGSOTHER GOVERNMENT SOURCES

OGS_a13. Items Scheduled for Publication in Future Federal Register Editions
(Source: Federal Register, 14 August 2019.)

 

* President; ADMINISTRATIVE ORDERS; Export Control Regulations; Continuation of National Emergency (Notice of August 14, 2019) [Pub. Date: 15 August 2019.]
 
* State; NOTICES; Sanctions Actions Pursuant to Executive Order [Pub. Date: 15 August 2019.]

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OGS_a24
.
Commerce/BIS (No new postings.)

(Source: Commerce/BIS)

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OGS_a35.
DoD/DSCA Releases NISP eMASS Industry Operation Guide Version 1.0
(Source: DoD/DSCA, 14 August 2019.)
 
The NISP Authorization Office (NAO) released the NISP Enterprise Mission Assurance Support Service (eMASS) Industry Operation Guide Version 1.0. The operation guide is designed to assist Industry users navigate eMASS. The operation guide is posted on the NISP eMASS Information and Resource Center (https://www.dss.mil/ma/ctp/io/nao/rmf/) under “Resources”. If you have questions or concerns, please contact the NAO eMASS Mailbox at dcsa.quantico.dcsa.mbx.emass@mail.mil.

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OGS_a46. 
State/DDTC: (No new postings.)
(Source: State/DDTC)

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OGS_a57.
UK ECJU Publishes New Notice on New Control on Exporting Submersible Vessels and Related Equipment to Russia
(Source: UK ECJU, 14 August 2019.)
 
A new national control covering the export of submersible vessels and related equipment, software and technology to Russia comes into force on 14 August 2019. A link to the list of items subject to the new control can be found below.
 
This additional control is a consequence of Russia developing certain capabilities – including the ability to track, access and disrupt undersea communication cables. These activities represent a risk to our national security and the new control is intended to mitigate this risk.
 
The control only applies to exports to Russia. Export licence applications for items subject to the new control will be assessed on a case-by-case basis against the consolidated EU and national arms export licensing criteria.
 
The new control has been implemented by an amendment to the Export Control Order 2008. The Export Control (Amendment) (No. 2) Order 2019 (SI 2019/1159) introduces a new control entry, PL9012, into Schedule 3 of the Export Control Order 2008.
 
 

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OGS_a68.
UK ECJU Updates Guidance on Consolidated List of Strategic Military and Dual-Use Items that Require Export Authorisation
(Source:
UK ECJU
), 14 August 2019.)
 
The UK Export Control Joint Unit (ECJU) within the Department of International Trade (TID) has published the following update on its website:
 
The consolidated list of ‘controlled’ military and dual-use items that require an export licence issued by the export control joint unit:
 

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NWSNEWS

NWS_a19
.
Expeditors News: “USTR Announces Next Steps on Proposed 10 Percent Tariff on Imports from China”
(Source: Expeditors News), 13 August 2019.)
 
On August 13, 2019, the U.S. Trade Representative (USTR) issued a press release announcing the next steps on the proposed additional 10% tariffs on imports from China on approximately $300 billion in trade value. This list was originally published on May 17, 2019.
 
According to the press release, certain products have been removed from the initial list “based on health, safety, national security and other factors”.
 
The press release contains links to two lists:
 
– List 4A (Effective September 1, 2019), and
– List 4B (Effective December 15, 2019).
 
The two lists are based on HTS subheadings to the 8-digit level, and many general product categories appear on both lists; for example: watches under 9101.11.40 will be subject to the additional tariff beginning September 1, and watches under 9101.91.40 will be subject to the additional tariff beginning December 15.
 
The USTR plans to include an exclusion process for products subject to the additional tariff. The USTR will publish a Federal Register Notice once more details become available.
 
The USTR press release may be found here, which includes links to the two lists of tariffs.

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NWS_a210.
Nikkei: “US Adds China’s Biggest Nuclear Company to ‘Entity List'”
(Source: Nikkei Asian Review, 14 August 2019.) [Excerpts.]
 
The U.S. will add China General Nuclear Power Group, the country’s biggest state-owned nuclear company, to its “entity list,” the Department of Commerce said Tuesday.
 
With the change, American companies will be barred from selling products to China General Nuclear Power. The Commerce Department says the company diverts U.S. technology to military use.
 
The U.S. government in October 2018 announced restrictions on the export of civil nuclear technology to China. The latest decision will cut off CGN’s access to U.S. technology.
 
Beijing has named nuclear technology a priority under its “Made in China 2025” initiative that aims to transform the country into a high-tech powerhouse. Washington is responding to the initiative by tightening restrictions on Chinese tech companies through embargoes and other measures. …

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COMMCOMMENTARY

COM_a111
.
G.R. Talati: “What IP Professionals Need to Know About Export Controls”
(Source: Kilpatrick Townsend & Stockton, Aug 2019.)[Excerpts.]
 
* Author: Gunjan R. Talati, Esq., gtalati@kilpatricktownsend.com, 1-404-815-6503; Kilpatrick Townsend & Stockton LLP.
 
Kilpatrick Townsend partner Gunjan Talati recently presented to clients on the topic of “What IP Professionals Need to Know About Export Controls” at the annual Kilpatrick Townsend Intellectual Property Seminar (KTIPS). KTIPS is an intensive, two-day patent strategy and protection seminar for firm clients.
 
Key takeaways from the presentation include:
 
(1) IP professionals have to consider export controls risks before sending technical data and information abroad.
 
(2) Depending on the technology involved and intended destination, the International Traffic in Arms Regulations or the Export Administration Regulations may impose a license requirement for the “export.”
 
(3) In 2018 Congress passed the Export Control Reform Act which directs the Government to issue controls on emerging and foundational technologies.
 
(4) It is more important than ever to assess whether a foreign investment in a U.S. business implicates the Committee on Foreign Investment in the United States (CFIUS) issues.
 
(5) While CFIUS has traditionally been a voluntary process, updates to the law last year now make CFIUS filings mandatory for certain transactions.

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(Source: The Qubit Report, 13 August 2019.)[Excerpts.]
 

* Authors: Doreen M. Edelman, Esq.,
dedelman@lowenstein.com, 1-202-753-3808; 1-202-753-3816; Louis K. Rothberg, Esq.,
lrothberg@lowenstein.com, 1-202-753-3816; and Matt Savare, Esq.,
msavare@lowenstein.com, 1-646-414-6911.


Much of the source article details U.S. export control policies targeting A.I. It is interesting to note, quantum computing and quantum cryptography are also called out. Are the U.S. export policies a catch-22 for quantum computing and related technologies?  
 
What Artificial Intelligence Companies Must Know to Comply with New Export Policies.  Selected notes:
 
Shortly after the pilot program went into effect, the DOC’s Bureau of Industry and Security (BIS) issued a proposed rule to add 14 technology categories to list of emerging technologies, which could also be subject to the mandatory CFIUS declarations and would also impose new export license requirements by amending or adding additional Export Control Classification Numbers (ECCN) which are an alphanumeric designation (e.g., 1A984 or 4A001) used in the Commerce Control List (CCL) to identify items for export control purposes.
 
Companies or individuals that wish to export items, technology or software on the CCL may be required to obtain an export license depending on the item being exported as informed by the correct ECCN properly determined and the country to which the item is being exported. Among these 14 additional technology categories were robotics, quantum computing, and artificial intelligence (AI).
 
It’s important to note that even if your organization is not seemingly related to one of the 27 specific industries, under other recent US Commerce Department action, your company may still be subject to the mandatory export license requirements. The DOC recently added discrete microwave transistors, continuity of operation software, post-quantum cryptography, underwater transducers, and air-launch platforms to the list of emerging technologies and designated these items with ECCNs than can trigger DOC export license requirements, outside the CFIUS purview.
 
The current policies assume that differentiating between commercial and military AI applications is easy, when in reality is there is plenty of overlap between the spaces. For example, iPhone users can unlock their phones with facial recognition technology. That same technology could be used to target weapons. As the regulations continue to roll out for identifying and imposing export controls on new ECCNs to AI and other emerging technologies essential to US national security, it will be important for lawmakers to consider how the AI export controls will be implemented so as not to hinder innovation.

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TEEX/IM TRAINING EVENTS & CONFERENCES

TE_a113. ECTI Presents United States Export Control (ITAR/EAR/OFAC) Seminar Series in Austin, TX

(Source: Jill Kincaid;
jill@learnexportcompliance.com
)
 
* What: United States Export Control (ITAR/EAR/OFAC) Seminar Series in Austin, TX
* When: ITAR Seminar: September 16-17, 2019; EAR/OFAC Seminar: Sept 18-19, 2019
* Where: Austin, TX: Hilton Garden Inn Austin Downtown
* Sponsor: Export Compliance Training Institute (ECTI)
* ECTI Speaker Panel: Scott Gearity and Melissa Proctor
* Register
here
, or email
Jessica Lemon
, 540-433-3977.

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TE_a214. 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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ENEDITOR’S NOTES

 

* Letitia Elizabeth Landon (14 Aug 1802 – 15 Oct 1838; was an English poet and novelist, better known by her initials L.E.L.) 
  – “All sweeping assertions are erroneous.”
  – “An apt quotation is like a lamp which flings its light over the whole sentence.”
 
* John Galsworthy
(14 Aug 1867 – 31 Jan 1933; was an English novelist and playwright. Notable works include The Forsyte Saga and its sequels, A Modern Comedy and End of the Chapter. He won the Nobel Prize in Literature in 1932.)
 – “There is one rule for politicians all over the world: Don’t say in Power what you say in opposition; if you do, you only have to carry out what the others have found impossible.”

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EN_a316
. 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
 


DOC EXPORT ADMINISTRATION REGULATIONS (EAR)
: 15 CFR Subtit. B, Ch. VII, Pts. 730-774. Implemented by Dep’t of Commerce, Bureau of Industry & Security.


 
* 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 July 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 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: 4 July 2019) of the ITAR with all amendments is contained in Bartlett’s Annotated ITAR (“BITAR”), by James E. Bartlett III. The BITAR is a 371-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 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: 7 August 2019: 84 FR 38545August 2019 Amendments to Iranian Financial Sanctions Regulations and Iranian Human Rights Abuses Sanctions Regulations [amendment of 31 CFR Parts 561 and 562
.] 

  

* 
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: 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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EN_a0317
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  
here

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EPEDITORIAL POLICY

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

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

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


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