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19-0816 Friday “Daily Bugle”

19-0816 Friday “Daily Bugle”

Friday, 16 August 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.

[No items of interest today.]
  1. Items Scheduled for Publication in Future Federal Register Editions 
  2. Commerce/BIS: (No new postings.) 
  3. DHS/CBP Announces 23 October Customs Broker Examination
  4. State/DDTC: (No new postings.)
  5. Treasury/OFAC Announces $345,315 Settlement with Trade Credit Insurer for Violation of Foreign Narcotics Kingpin Sanctions Regulations
  1. CNN: “US May Have Supplied Tear Gas Used Against Hong Kong Protesters”
  2. NK News: “Singapore Company Charged with Shipping Alcohol to North Korea”
  3. Reuters: “China Says U.S. Block on Nuclear Firms a ‘Misuse’ Of Export Controls”
  1. D. W. Layton & T. C. Lee: ” USTR Announces Additional Tariffs on $300 Billion of Chinese Imports and Excludes Products Subject to Prior Section 301 Tariffs”
  2. M. Volkov: “OFAC Implements Broad Sanctions Against Venezuela”
  1. ECS Presents “2nd Annual ECS ITAR/EAR Symposium and Managing ITAR/EAR Complexities” on 17-19 Sep in Annapolis, MD
  2. FCC Presents “The ABC of FMS”, 28 Nov in Bruchem, the Netherlands
  3. List of Approaching Events: 145 Events Posted This Week, Including 2 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 (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 2019), DOS/ITAR (19 Apr 2019), DOT/FACR/OFAC (6 Aug 2019), HTSUS (22 Jul 2019) 
  3. Weekly Highlights of the Daily Bugle Top Stories 

EXIMITEMS FROM TODAY’S FEDERAL REGISTER

 
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OGSOTHER GOVERNMENT SOURCES

OGS_a01
. Items Scheduled
for Publication in Future Federal Register Editions

(Source: Federal Register, 16 August 2019.)
 
[No items of interest noted today.] 


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OGS_a12
. Commerce/BIS: (No new postings.)

(Source: Commerce/BIS)

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OGS_a23.
DHS/CBP Announces 23 October Customs Broker Examination
(Source: DHS/CBP, 16 Aug 2019.) [Excerpts.]
 
REGISTRATION NOTICE OF EXAMINATION FOR OCTOBER 23, 2019
 
Administrative Information
 
This notice announces that U.S. Customs and Border Protection (CBP) will conduct an electronic version of the Customs Broker License Examination on Wednesday, October 23, 2019. CBP allows individual to register for the exam through an online automated CBP broker examination registration system (replacing Form 3124E, “Application for Customs Broker License Exam”), and mandates the registrant pay a $390 required examination fee at that time. …

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OGS_a45.
Treasury/OFAC Announces $345,315 Settlement with Trade Credit Insurer for Violation of Foreign Narcotics Kingpin Sanctions Regulations
(Source: Treasury/OFAC, 16 Aug 2019.)
 
Atradius Trade Credit Insurance, Inc. (“ATCI”) of Hunt Valley, Maryland, a trade credit insurer licensed to operate in the state of Maryland, is a subsidiary of Atradius N.V. ATCI has agreed to remit $345,315 to settle its potential civil liability for two apparent violations of the Foreign Narcotics Kingpin Sanctions Regulations, 31 C.F.R. Part 598. The Office of Foreign Assets Control (OFAC) has determined that ATCI did not make a voluntary self-disclosure of the Apparent Violations, and that these Apparent Violations constitute a non-egregious case.
 
For more information, please visit the following web notice.  For more information on this specific action, please visit our Recent Actions page.

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COMNEWS

NWS_a16.
CNN: “US May Have Supplied Tear Gas Used Against Hong Kong Protesters”

(Source: CNN, 16 Aug 2019.) [Excerpts.]
 
Hong Kong’s police have routinely used tear gas in their attempts to dispel pro-democracy protests that have roiled Hong Kong for weeks — and it turns out the tear-inducing, throat-choking crowd control devices may have been made in the USA.
 
In recent years, the US government has authorized millions of dollars’ worth of military and defense equipment exports to the government of Hong Kong, equipment that includes “toxicological agents” such as “tear gases and riot control agents.”
 
But as protesters continue to roil Hong Kong with their demands for greater freedoms and China begins to mass troops at the border, lawmakers on both sides of the aisle are raising concerns about the role the US could be playing in abetting any violent suppression.
 
Republicans and Democrats in Congress have issued statements calling for the US to block those exports in the future – and some are planning to introduce legislation to stop more sales. …

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

NWS_a27.
NK News: “Singapore Company Charged with Shipping Alcohol to North Korea”
(Source: NK News, 15 Aug 2019.) [Excerpts.]
 
A Singapore-based company sanctioned last year by the U.S. Treasury was on Thursday charged with facilitating shipments of alcohol worth SGD600,000 ($432,384) to North Korea.
 
SinSMS Pte. Ltd. – an affiliate of the China-based Dalian Sun Moon Star International Logistics Trading Co. – stands accused of shipping wine and spirits to the DPRK between October 2016 and January 2017.
 
Channel News Asia reports that the company shipped alcohol to North Korea via the city of Dalian four times, with the value of the shipments ranging from $96,317 and $144,908 in value.
 
The company has reportedly been handed four charges of violating Singapore’s United Nations (Sanctions – Democratic People’s Republic of Korea) Regulations 2010. …

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NWS_a38.
Reuters: “China Says U.S. Block on Nuclear Firms a ‘Misuse’ of Export Controls”

(Source:
Reuters, 16 Aug 2019.)
 
A U.S. decision to stop China General Nuclear Power Corp (CGN) and its subsidiaries from dealing with U.S. companies was a misuse of export control measures and would harm both U.S. and Chinese firms, China’s foreign ministry said.
 
Washington this week said CGN was involved in activities contrary to the national security and foreign policy interests of the United States and would be added to an “Entity List” of firms banned from doing business with U.S. enterprises.
 
“China resolutely opposes the U.S. side harming the interests of China and the world through unilateralist and protectionist policies,” Foreign Ministry spokeswoman Hua Chunying said in a statement issued late on Thursday.
 
CGN is one of China’s major state-owned reactor builders. The other firms added to the list on Wednesday include the Suzhou Nuclear Power Research Institute Co. Ltd, a CGN subsidiary that got the go-ahead to build a nuclear reactor project in Guangdong province earlier this year. …

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COMCOMMENTARY

COM_a19.
D. W. Layton & T. C. Lee: “USTR Announces Additional Tariffs on $300 Billion of Chinese Imports and Excludes Products Subject to Prior Section 301 Tariffs” 

(Source: Mayer Brown, 16 August 2019.)
 
* Authors: Duane W. Layton, Esq., dlayton@mayerbrown.com, +1 202 263 3811; and Timothy C. Lee, Esq., tlee@mayerbrown.com, +1 202 263 3055, both of Mayer Brown.
 
Announcement of Additional 10 Percent Tariff
 
On August 13, 2019, the United States Trade Representative (“USTR”) announced an additional 10 percent ad valorem duty on approximately $300 billion of Chinese imports. [FN/1] This announcement follows USTR’s notice on May 17, 2019, to begin the process to subject virtually all remaining imports from China to tariffs pursuant to Section 301 of the Trade Act of 1974 (the so-called “Tranche IV”). [FN/2]
 
The new tariff will go into effect in two stages. The first stage is effective September 1, 2019, and will apply to a broad range of products, including a wide range of food items, certain electronics, steel and iron pipes, and certain clothing items. The complete list of products subject to the 10 percent tariff effective September 1 is available here (“List 4A”). The second stage is effective December 15, 2019, and will apply to consumer items such as cellphones, laptops, textile materials, certain toys and video game consoles. The complete list of products subject to the 10 percent tariff effective December 15 is available here (“List 4B”). Moreover, certain products will be removed from the list due to health, safety, national security and other factors and will not be subject to the Tranche IV tariff. Specifically, products exempt from the Tranche IV list fall under 25 tariff headings, which include items ranging from frozen fish and minerals to ocean shipping containers and child safety seats.
 
Exemption Process Forthcoming
 
According to its announcement, USTR intends to conduct an exclusion process for the products on List 4A and List 4B, which is consistent with its prior imposition of tariffs on Chinese imports pursuant to the Section 301 investigation on China. In this regard, USTR recently approved exemptions for certain Chinese imports subject to the 25 percent ad valorem duty on approximately $200 billion of Chinese imports (the so-called “Tranche III”). For example, on August 7, 2019, USTR published a notice of product exclusions for 10 products, which will apply as of the effective date of the Tranche III action (September 24, 2018) and will be in effect until August 7, 2020. [FN/3] To date, USTR has published eight notices approving exemptions for thousands of products under 403 tariff headings. [FN/4]
 
Takeaways
 
Companies impacted by the Tranche IV tariffs should monitor developments related to the forthcoming product exclusion process in order to either (a) avail themselves of opportunities to avoid additional duties on their products, or (b) file comments objecting to certain exclusion requests. Moreover, parties considering changes to their supply chain should continue to consider the impact that such changes may have with respect to their compliance with US customs laws.
 
[FN/1] United States Trade Representative, USTR Announces Next Steps on Proposed 10 Percent Tariffs on Imports from China, available at https://ustr.gov/about-us/policy-offices/press-office/press-releases/2019/august/ustr-announces-next-steps-proposed.
 
[FN/2] 19 U.S.C. §§ 2411-2420. For additional details on USTR’s May 17, 2019, action, please see Mayer Brown Legal Update, US Prepares to Hit All Chinese Imports with Tariffs, as China Retaliates and Launches a Product Exclusion Process, available at https://www.mayerbrown.com/en/perspectives-events/publications/2019/05/us-prepares-to-hit-all-chinese-imports-with-tariffs-as-china-retaliates-and-launches-a-product-exclusion-process#_edn1.
 
[FN/3] United States Trade Representative, Notice of Product Exclusions: China’s Acts, Policies, and Practices Related to Technology Transfer, Intellectual Property, and Innovation, available at https://www.federalregister.gov/documents/2019/08/07/2019-16886/notice-of-product-exclusions-chinas-acts-policies-and-practices-related-to-technology-transfer.
 
[FN/4] Details on these product exclusions can be found in the Federal Register, available athttps://www.federalregister.gov/agencies/trade-representative-office-of-united-states.

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COM_a210. 
M. Volkov: “OFAC Implements Broad Sanctions Against Venezuela”
(Source: Volkov Law Group Blog, 15 Aug 2019. Reprinted by permission.)
 
* Author: Michael Volkov, Esq., Volkov Law Group, mvolkov@volkovlaw.com, 240-505-1992.
 
In a major announcement and escalation of the sanctions regime targeting President Maduro and Venezuela, on August 5, 2019, the Trump Administration issued a new Executive Order 13884 (Here) to block all property of the Venezuela Government. The aggressive action was implemented to target the Maduro regime. At the same time, OFAC issued 12 amended general licenses (Here) and 13 new general licenses (Here), and related guidance and FAQs (Here and Here).
 
EO 13884 targets the Venezuelan government and any entities owned 50 percent or more or otherwise controlled by the Venezuelan government. The new sanctions, while not a full territorial embargo, broadly prohibit virtually all United States Persons from dealings and transactions with the Venezuelan government, including all Venezuelan state-owned enterprises. Private-to-private commercial transactions that do not involve the Venezuelan government or any related entities are permitted. United States Persons includes US companies, their branches, US banks, citizens and green-card holders, as well as any person when they are physically located in the United States. Any funds, property, contracts or other property interests that come into the possession or control of US Persons have to be blocked and reported to OFAC.
 
The Venezuela government is broadly defined to include any political subdivision, agency or instrumentality thereof, including the Central Bank of Venezuela (CBV) and Petroleos de Venezuela (PdVSA). The reach of this prohibition extends to any entity owned 50 percent or more by a prohibited government entity or otherwise controlled by the prohibited government entity.
 
EO 13884 also authorize broad secondary sanctions to sanction any other person who (i) “materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, any person” who is blocked under EO 13884, or (ii) to be owned or controlled by, or have acted on behalf of any person who is blocked under EO 13884.
 
At the same time, OFAC amended a number of existing general licenses and issued numerous general licenses authorizing a number of activities.
 
The amended licenses include the following (This is a non-exhaustive list):
 
General License 7C (Here) – Transactions with PDV Holding, CITGO Holding and Nynas: The amended license authorizes continued dealings with these entities, subject to certain limitations.
 
General License 8C (Here) – Transactions with PdVSA: The amended license authorizes all transactions and activities ordinarily incident and necessary to operations in Venezuela involving PdVSA in relation to the following entities: Chevron Corporation; Halliburton; Schlumberger Limited; Baker Hughes; and Weatherford International.
 
General License 10A (Here) – US Persons in Venezuela: The amended license authorizes transactions involving refined petroleum products for personal, commercial, or humanitarian uses. It does not allow the commercial resale, transfer, exportation, or re-exporation of those products. But it also clarifies that payments of taxes, fees, and import duties to, and purchase or receipt of permits, licenses, or public utility services from the Venezuela government are authorized.
 
General License 3F (Here) – Dealings in Debt and Securities: This license was amended to authorize transactions related to, provide financing for, and otherwise deal in bonds that (i) are specified in the Annex to General License 3F provided that any divestments or transfer of, or facilitation of divestment or transfer of, any holdings in those bonds are to a non-US person; or (ii) were issued prior to the effective date of EO 13808.
 
OFAC also issued a number of new general licenses (This is a non-exhaustive list):
 
General License 28 (Here) – Wind Down of Transactions with the Venezuelan Government: This general license authorizes all transactions and activities ordinarily incident and necessary to the wind down of operations, contracts, or other agreements involving the Venezuelan government that were in effect prior to August 5, 2019. All wind down activities must be completed by September 4, 2019.
 
General License 30 (Here) – Port and Airport Operations: this general license authorizes all transactions and activities that are ordinarily incident and necessary to operations or use of ports and airports in Venezuela.
 
General License 20A (Here) – Humanitarian Assistance and Sales of Agricultural and Medical Commodities: This general license, along with related General Licenses 4C, 22, 23, 24, 26 and 29, are designed to ensure the continued delivery of humanitarian goods and services to the Venezuelan people.

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TEEX/IM TRAINING EVENTS & CONFERENCES

TE_1
11
.
ECS Presents “2nd Annual ECS ITAR/EAR Symposium and Managing ITAR/EAR Complexities” on 17-19 Sep in Annapolis, MD
(Source: ECS)
 
* What:  The 2nd Annual ECS ITAR/EAR Symposium and Managing ITAR/EAR Complexities, Annapolis, MD
* When:  September 17-19, 2019
* Where:  Chart House
* Sponsor:  Export Compliance Solutions & Consulting (ECS)
* ECS Speaker Panel: Commerce/BIS; Debi Davis, Esterline; Scott Jackson, Curtiss Wright; Matt Doyle, Lockheed Martin; Matthew McGrath, McGrath Law Group and ECS staff. 
* Register here or by calling 866-238-4018 or email spalmer@exportcompliancesolutions.com

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TE_2
12
. 
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

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TE_List13. 
List of Approaching Events: 145 Events Posted This Week, Including 2 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: “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

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

* Aug 23: Shanghai, China; “China – US Trade War and China Customs Update“; Sandler, Travis and Rosenberg

* 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 5: London, UK; “Sanctions Compliance in Maritime Trade Financing“; Dow Jones

* 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
“; 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 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”; 
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 25-26: San Francisco, CA; “West Coast Conference on FCPA Enforcement and Compliance“; American Conference Institute

* Sep 26: Amsterdam, The Netherlands; “Global Trade Management: Turning trade challenges into opportunities” Amber Road

*
 
Sep 26: Bristol, UK; “
Understanding The Paperwork
“; BusinessWest

* Sep 27: London, UK; “Managing Sanctions & Anti-Corruption in Shipping Seminar“; The Nautical Institute

* Sep 30 – Oct 3; Amsterdam, NL; “
ITAR Controls / EAR/OFAC Commercial and Military Controls
“; ECTI
; 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
“; ECTI

* 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 20-22: Grapevine, TX; “ICPA Fall Conference 2019“; ICPA

* 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: San Francisco, CA; “San Francisco Economic Sanctions Boot Camp“; American Conference Institute

* 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 12; Washington, DC; “2019 OFAC Fall Symposium“, Treasury/OFAC

* 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
“; ECTI

* 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

* Nov 27: Rotterdam, the Netherlands; “Incoterms 2020“; Fenex

* 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 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

* Apr 29-30: Washington DC; “Economic Sanctions Enforcement and Compliance“; American Conference Institute
* May 20-21: Berlin, Germany; “Berlin Forum on Global Economic Sanctions“; C5

* May 27-28: Hong Kong, China; “Hong Kong Summit on Economic Sanctions Enforcement and Compliance“;
American Conference Institute

* Jun 9-10: Shanghai, China; “China Forum for Legal and Compliance Officers“; American Conference Institute
* Jul 21-22: Washington DC; “FCPA High Risks Markets“; American Conference Institute

 
Webinars 


 


* Aug 21: Webinar: “Classification for Automotive Industry“; Global Training Center
* Aug 22:
 
Webinar:
Emerging” Technology Export Controls: Global Update 2019“;
 
ECTI; 540-433-3977

* Aug 22: Webinar: “ITAR 126.4 Exemption Expansion & Benefits to Exporters“; National Defense Industrial Association

* Sep 18: Webinar: “CBP Organization and Operations 
“; Sandler, Travis & Rosenberg


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

* 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_a214
. Bartlett’s Unfamiliar Quotations

(Source: Editor)

 

* T. E. Lawrence
(Thomas Edward Lawrence; 16 Aug 1888 – 19 May 1935; was a British archaeologist, army officer, diplomat, and writer. He was renowned for his liaison role during the Sinai and Palestine Campaign and the Arab Revolt against the Ottoman Empire during the First World War. The breadth and variety of his activities and associations, and his ability to describe them vividly in writing, earned him international fame as “Lawrence of Arabia,” a title used for the 1962 film based on his wartime activities.)
– “The people of England have been led in Mesopotamia into a trap from which it will be hard to escape with dignity and honor.”
 
* Francis Darwin
(Sir Francis “Frank” Darwin; 16 Aug 1848 – 19 Sep 1925; was a British botanist. He was a son of the naturalist and scientist Charles Darwin.)
– “In science, the credit goes to the man who convinces the world, not to whom the idea first occurs.”
 
Friday funnies (more State jokes):
* New Mexico: Traveling outside Taos, a man comes upon a Native American lying in the middle of the road with his ear pressed against the blacktop. “What are you doing?” asks the man. The tribesman replies, “Woman, late 30s, three kids, one barking dog in late model, four-door station wagon, traveling at 65 mph.” “Amazing! You can tell all of that just by listening to the ground?” “No,” says the Native American. “They ran over me five minutes ago.”
* New York: I moved to New York City for my health. I’m paranoid, and it was the only place where my fears were justified.
* North Carolina: On his first trip to Boston, the North Carolinian guy met a girl at a bar and asked her, “Say, do y’all go to Harvard?” The girl responded, “Yale.” “OK! Shouted the guy. DO Y’ALL GO TO HARVARD?!”

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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.
 

*
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.

*
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: 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 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: 6 August 2019: 84 FR 38545 – August 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.

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

EN_a416
. 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.

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

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