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19-0920 Friday “Daily Bugle”

19-0920 Friday “Daily Bugle”

Friday, 20 September 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. President Continues National Emergency with Respect to Persons Who Commit, Threaten to Commit, or Support Terrorism
  2. USTR Adds Product Exclusions, Amends Exclusion Process, and Makes Technical Amendments Concerning Duties on Goods of China
  3. USTR Grants Product Exclusions Concerning Duties on Goods of China
  4. USTR Grants Product Exclusions Concerning Duties on Goods of China
  1. Items Scheduled for Publication in Future Federal Register Editions 
  2. Commerce/BIS: (No new postings.)
  3. State/DDTC: (No new postings.)
  4. Treasury/OFAC Sanctions Iran’s Central Bank and National Development Fund
  1. Business Insider: “A FedEx Pilot Was Held in Chinese Custody for a Week in the Latest Dustup Amid Trump’s Trade War”
  2. Reuters: “France, Germany Closing in on Arms Exports Pact”
  1. I. Chase, E. Dall & T. Keatinge: “Designing Sanctions After Brexit: Recommendations on the Future of UK Sanctions Policy”
  2. I. Zhang, L.S. Test & K.B. Contini: “State Department Issues Draft Guidance for the Export of Items with Surveillance Capacities”
  3. P. Fair & G. Farrant: “Australian Government Announces Foreign Influence Taskforce for Universities”
  1. ECTI Presents U.S. Export Control (ITAR/EAR/OFAC) Seminar Series in Miami, FL: December 9-12, 2019
  2. FCC Presents “The ABC of FMS”, 28 Nov in Bruchem, the Netherlands
  3. List of Approaching Events: 122 Events Posted This Week, Including 7 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 (21 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 (30 Aug 2019), DOT/FACR/OFAC (9 Sep 2019), HTSUS (3 Sep 2019) 
  3. Weekly Highlights of the Daily Bugle Top Stories 

EXIMITEMS FROM TODAY’S FEDERAL REGISTER

EXIM_a01
.
President Continues National Emergency with Respect to Persons Who Commit, Threaten to Commit, or Support Terrorism

(Source: Federal Register, 20 Sep 2019.)
 
84 FR 49633: Continuation of the National Emergency with Respect to Persons Who Commit, Threaten to Commit, or Support Terrorism
 
Notice of September 19, 2019
 
Continuation of the National Emergency with Respect to Persons Who Commit, Threaten to Commit, or Support Terrorism
 
On September 23, 2001, by Executive Order 13224, the President declared a national emergency with respect to persons who commit, threaten to commit, or support terrorism, pursuant to the International Emergency Economic Powers Act (50 U.S.C. 1701-1706) to deal with the unusual and extraordinary threat to the national security, foreign policy, and economy of the United States constituted by the grave acts of terrorism and threats of terrorism committed by foreign terrorists, including the terrorist attacks on September 11, 2001, in New York and Pennsylvania and against the Pentagon, and the continuing and immediate threat of further attacks against United States nationals or the United States.
 
The actions of persons who commit, threaten to commit, or support terrorism continue to pose an unusual and extraordinary threat to the national security, foreign policy, and economy of the United States. For this reason, the national emergency declared in Executive Order 13224 of September 23, 2001, and the measures adopted on that date to deal with that emergency, must continue in effect beyond September 23, 2019. Therefore, in accordance with section 202(d) of the National Emergencies Act (50 U.S.C. 1622(d)), I am continuing for 1 year the national emergency with respect to persons who commit, threaten to commit, or support terrorism declared in Executive Order 13224.

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

EXIM_a12
.
USTR Adds Product Exclusions, Amends Exclusion Process, and Makes Technical Amendments Concerning Duties on Goods of China

(Source: Federal Register, 20 Sep 2019.) [Excerpts.]
 
84 FR 49591-49600: Notice of Product Exclusions, Amendment to the Exclusion Process, and Technical Amendments: China’s Acts, Policies, and Practices Related to Technology Transfer, Intellectual Property, and Innovation
 
* AGENCY: Office of the United States Trade Representative.
* ACTION: Notice of product exclusions and technical amendments.
* SUMMARY: In September of 2018, the U.S. Trade Representative imposed additional duties on goods of China with an annual trade value of approximately $200 billion as part of the action in the Section 301 investigation of China’s acts, policies, and practices related to technology transfer, intellectual property, and innovation. The U.S. Trade Representative initiated a product exclusion process in June 2019, and interested persons have submitted requests for the exclusion of specific products. This notice amends the exclusion process by establishing August 7, 2020 as a uniform expiration date for all exclusions granted under the $200 billion action. This notice also announces the U.S. Trade Representative’s determination to grant certain exclusion requests, as specified in Annex A. As specified in Annex B, this notice also makes technical amendments to the $200 billion action and to the $300 billion action announced in August 2019.
* DATES: The product exclusions announced in this notice will apply as of the September 24, 2018, effective date of the $200 billion action, to August 7, 2020. The technical amendments in Annex B to the $200 billion and $300 billion actions are effective as of the respective effective date of those actions. U.S. Customs and Border Protection will issue instructions on entry guidance and implementation.
* FOR FURTHER INFORMATION CONTACT:…
SUPPLEMENTARY INFORMATION: …
 
B. Amendment to the Exclusion Process
 
The June 24 notice announced that the exclusions granted for the $200 billion trade action would be effective starting from September 24, 2018, and extend for one year after the publication of the exclusion determination in the Federal Register. This policy, however, would have resulted in disparities in the effective periods between exclusions granted early in the exclusion process and those granted later. Accordingly, the Trade Representative is amending the exclusion process so as to adopt a uniform expiration date for exclusions granted for the $200 billion trade action, subject to special circumstances. In particular, all exclusions from the $200 billion action will be effective from September 24, 2018, to August 7, 2020.
 
C. Determination To Grant Certain Exclusions
 
Based on the evaluation of the factors set out in the June 24 notice, which are summarized above, pursuant to sections 301(b), 301(c), and 307(a) of the Trade Act of 1974, as amended, and in
accordance with the advice of the interagency Section 301 Committee, the U.S. Trade Representative has determined to grant the product exclusions set out in Annex A. The U.S. Trade Representative’s determination also takes into account advice from advisory committees and any public comments on the pertinent exclusion requests.
   As set out in Annex A, the exclusions are reflected in 38 specially prepared product descriptions, which cover 46 separate exclusion requests.
   In accordance with the June 24 notice, the exclusions are available for any product that meets the description in Annex A, regardless of whether the importer filed an exclusion request. Further, the scope of each exclusion is governed by the scope of the product descriptions in Annex A, and not by the product descriptions set out in any particular request for exclusion.
   Paragraph A, subparagraphs (3)-(5) are conforming amendments to the HTSUS reflecting the modification made by Annex A.
   As stated in Section B above, the exclusions will apply from September 24, 2018, to August 7, 2020. U.S. Customs and Border Protection will issue instructions on entry guidance and implementation.
   The U.S. Trade Representative will continue to issue determinations on pending requests on a periodic basis.
 
D. Technical Amendments to $200 Billion and $300 Billion Actions
 
Annex B make technical amendments to the $200 billion and $300 billion trade actions. These amendments provide that the additional duties do not apply to entries under certain subheadings if the applied rate of duty for an entry is derived from another subheading, and if the entry for this reason already is subject to the additional duties. …

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EXIM_a23
.
USTR Grants Product Exclusions Concerning Duties on Goods of China

(Source: Federal Register, 20 Sep 2019.) [Excerpts.]
 
84 FR 49564-49590: Notice of Product Exclusions: China’s Acts, Policies, and Practices Related to Technology Transfer, Intellectual Property, and Innovation
 
* AGENCY: Office of the United States Trade Representative.
* ACTION: Notice of product exclusions.
* SUMMARY: Effective July 6, 2018, the U.S. Trade Representative imposed additional duties on goods of China with an annual trade value of approximately $34 billion as part of the action in the Section 301 investigation of China’s acts, policies, and practices related to technology transfer, intellectual property, and innovation. The U.S. Trade Representative’sdetermination included a decision to establish a product exclusion process. The U.S. Trade Representative initiated the exclusion process in July 2018, and stakeholders have submitted requests for the exclusion of specific products. In December 2018, March 2019, April 2019, May 2019, June 2019, and July 2019 the U.S. Trade Representative granted exclusion requests. This notice announces the U.S. Trade Representative’s determination to grant additional exclusion requests, as specified in the Annex to this notice. The U.S. Trade Representative will continue to issue decisions on pending requests on a periodic basis.
* DATES: The product exclusions announced in this notice will apply as of the July 6, 2018 effective date of the $34 billion action, and will extend for one year after the publication of this notice. U.S. Customs and Border Protection will issue instructions on entry guidance and implementation.
* FOR FURTHER INFORMATION CONTACT: …
* SUPPLEMENTARY INFORMATION: …
 
B. Determination to Grant Certain Exclusions
 
Based on the evaluation of the factors set out in the July 11 notice, which are summarized above, pursuant to sections 301(b), 301(c), and 307(a) of the Trade Act of 1974, as amended, and in accordance with the advice of the interagency Section 301 Committee, the U.S. Trade Representative has determined to grant the product exclusions set out in the Annex to this notice. The U.S. Trade Representative’s determination also takes into account advice from advisory committees and any public comments on the pertinent exclusion requests.
   As set out in the Annex, the exclusions are reflected in 310 specially prepared product descriptions, which cover 724 separate exclusion requests.
   In accordance with the July 11 notice, the exclusions are available for any product that meets the description in the Annex, regardless of whether the importer filed an exclusion request. Further, the scope of each exclusion is governed by the scope of the product descriptions in the Annex, and not by the product descriptions set out in any particular request for exclusion.
   Paragraph A, subparagraphs (3)-(5) are conforming amendments to the HTSUS reflecting the modification made by the Annex to this notice.
   Paragraph B of the Annex corrects a typographical error in U.S. note 20(n)(105) to subchapter III of chapter 99 of the HTSUS, as set out in the Annex to the notice published at 84 FR 32821 (July 9, 2019).
   As stated in the July 11 notice, the exclusions will apply as of the July 6, 2018 effective date of the $34 billion action, and extend for one year after the publication of this notice. U.S. Customs and Border Protection will issue instructions on entry guidance and implementation.
   The U.S. Trade Representative will continue to issue determinations in pending requests on a periodic basis. …

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EXIM_a34
.
USTR Grants Product Exclusions Concerning Duties on Goods of China

(Source: Federal Register, 20 Sep 2019.) [Excerpts.]
 
84 FR 49600-49610: Notice of Product Exclusions: China’s Acts, Policies, and Practices Related to Technology Transfer, Intellectual Property, and Innovation
 
* AGENCY: Office of the United States Trade Representative.
* ACTION: Notice of product exclusions.
* SUMMARY: Effective August 23, 2018, the U.S. Trade Representative imposed additional duties on goods of China with an annual trade value of approximately $16 billion as part of the action in the Section 301 investigation of China’s acts, policies, and practices related to technology transfer, intellectual property, and innovation. The U.S. Trade Representative’s determination included a decision to establish a product exclusion process. The U.S. Trade Representative initiated the exclusion process in September 2018, and stakeholders have submitted requests for the exclusion of specific products. In July 2019, the U.S. Trade Representative granted exclusion requests. This notice announces the U.S. Trade Representative’s determination to grant certain exclusion requests, as specified in the Annex to this notice. The U.S. Trade Representative will continue to issue decisions on pending requests on a periodic basis.
* DATES: The product exclusions announced in this notice will apply as of the August 23, 2018 effective date of the $16 billion action, and will extend for one year after the publication of this notice. U.S. Customs and Border Protection will issue instructions on entry guidance and implementation.
* FOR FURTHER INFORMATION CONTACT: …
* SUPPLEMENTARY INFORMATION: …
 
B. Determination To Grant Certain Exclusions
 
Based on the evaluation of the factors set out in the September 18 notice, which are summarized above, pursuant to sections 301(b), 301(c), and 307(a) of the Trade Act of 1974, as amended, and in accordance with the advice of the interagency Section 301 Committee, the U.S. Trade Representative has determined to grant the product exclusions set out in the Annex to this notice. The U.S. Trade Representative’s determination also takes into account advice from advisory committees and any public comments on the pertinent exclusion requests.
   As set out in the Annex, the exclusions are reflected in 89 specially prepared product descriptions, which cover 400 separate exclusion requests.
   In accordance with the September 18 notice, the exclusions are available for any product that meets the description in the Annex, regardless of whether the importer filed an exclusion request. Further, the scope of each exclusion is governed by the scope of the product descriptions in the Annex, and not by the product descriptions set out in any particular request for exclusion.
   Paragraph A, subparagraphs (3)-(5) are conforming amendments to the HTSUS reflecting the modification made by the Annex.
   As stated in the September 18 notice, the exclusions will apply as of the August 23, 2018 effective date of the $16 billion action, and extend for one year after the publication of this notice. U.S. Customs and Border Protection will issue instructions on entry guidance and implementation.
   The U.S. Trade Representative will continue to issue determinations on pending requests on a periodic basis. …

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OGSOTHER GOVERNMENT SOURCES

OGS_a05
. Items Scheduled
for Publication in Future Federal Register Editions

(Source: Federal Register, 20 September 2019.)


back to top
 

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OGS_a16
. Commerce/BIS: (No new postings.)

(Source:
Commerce/BIS)

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OGS_a38.
Treasury/OFAC Sanctions Iran’s Central Bank and National Development Fund
(Source: Treasury/OFAC, 20 Sep 2019.) [Excerpts.]
 
Today, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) took action against the Central Bank of Iran (CBI), the National Development Fund of Iran (NDF), and Etemad Tejarate Pars Co. under its counterterrorism authority, Executive Order (E.O.) 13224. Iran’s Central Bank has provided billions of dollars to the Islamic Revolutionary Guards Corps (IRGC), its Qods Force (IRGC-QF) and its terrorist proxy, Hizballah. Iran’s NDF, which is Iran’s sovereign wealth fund and whose board of trustees include Iran’s president, oil minister, and the governor of the Central Bank, has been a major source of foreign currency and funding for the IRGC-QF and Iran’s Ministry of Defense and Armed Forces Logistics (MODAFL). Etemad Tejarate Pars, also designated today, is an Iran-based company that is used to conceal financial transfers for MODAFL’s military purchases, including funds originating from the NDF. …

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COMNEWS

NWS_a19.
Business Insider: “A FedEx Pilot Was Held in Chinese Custody for a Week in the Latest Dustup Amid Trump’s Trade War”

(Source: Business Insider, 19 Sep 2019.) [Excerpts,]
 
FedEx has been caught in the middle of the US-China trade debacle.
 
Trade tensions are partially to blame for FedEx slashing its 2020 outlook by 18%, and the package giant even sued the Trump administration this summer over trade rules.
 
And now, the impact of Trump’s trade war is getting personal. According to a new report from The Wall Street Journal, the Chinese government held a FedEx pilot in custody for a week. A FedEx representative told Business Insider that the pilot was later released.
 
Todd A. Hohn, the FedEx pilot, reportedly was detained while waiting for a commercial flight home from the Guangzhou airport. Hohn’s checked bag had “nonmetallic pellets used in low-power replica air guns.”
 
Because of that, people close to the situation said the Chinese government is now launching a criminal investigation for Hohn’s alleged transportation of ammunition. …

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NWS_a210.
Reuters: “France, Germany Closing in on Arms Exports Pact”

(Source: Reuters, 19 Sep 2019.) [Excerpts.]
 
France and Germany said on Thursday they were close to an agreement on how to remove obstacles to exporting weapons manufactured in joint programs, after French firms called for easing German export restrictions.
 
German curbs on arms exports to non-European Union or non-NATO countries have been a thorn in bilateral co-operation for years. Germany’s SPD party, part of the ruling coalition, is particularly concerned about the trade.
 
French firms, such as Nexter and Arquus, previously known as Renault Trucks Defense, say the restrictions have hindered deals and have urged the authorities to allow the export of equipment with German parts without requiring Berlin’s green light.
 
Germany’s ruling coalition agreed in 2018 to ban arms sales to countries involved in conflicts unless a waiver is granted. Germany extended by six months an embargo on sales to parties in the Yemen conflict, seen as a proxy war between Saudi Arabia and Iran. …

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COMCOMMENTARY

COM_a111.
I. Chase, E. Dall & T. Keatinge: “Designing Sanctions After Brexit: Recommendations on the Future of UK Sanctions Policy”

(Source:
RUSI, 19 Sep 2019.)
 
* Authors: Isabella Chase, Research Analyst; Emil Dall, Research Fellow, emild@rusi.org; and Tom Keatinge, Director, tomk@rusi.org; all of Royal United Services Institute for Defence Studies (RUSI).
 
This Occasional Paper offers recommendations adapted from initial discussions by the RUSI Task Force on the Future of UK Sanctions Policy regarding what UK sanctions could look like after Brexit.
 
Brexit presents many challenges and opportunities for the UK government. One challenge the government quickly identified as being an urgent priority was the UK’s ability to continue to implement sanctions, a foreign policy tool currently designed and agreed to within the EU. This potential gap has been addressed in the form of the Sanctions and Anti-Money Laundering Act (SAMLA) 2018. In addition, civil servants have devoted significant resources to rolling over existing EU sanctions into UK law by creating the necessary statutory instruments and replicating the vast majority of EU sanctions designations under this new legal regime. Together, these measures will ensure that under any Brexit scenario – whether it be with a deal and a resulting implementation period, or without a deal – the UK can continue to implement and enforce sanctions without interruption.
 
While the technical and legal work has been completed, an open question remains: what will the UK’s post-Brexit sanctions policy be? For the past 40 years, financial and economic sanctions implemented by the UK have been designed either at the UN (which will continue to be the case) or in Brussels via the consensus of all EU member states, a process in which the UK is widely viewed as being highly influential by both other member states and outsiders, such as US policymakers. Once no longer subject to the EU’s consensus decision-making process, it might be argued that the UK will have the freedom to design and implement a creative and more independent sanctions policy. Or, the UK might feel the need to remain aligned with the EU and/or the US to ensure that it follows the actions of these much bigger economic players.
 
Answering the question as to what the UK’s post-Brexit sanctions strategy should be is therefore urgent and – thus far – unaddressed. As the House of Commons Foreign Affairs Committee (FAC) noted in a June 2019 report (the FAC Report): ‘Little high-level thought appears to have been given to UK priorities for post-Brexit sanctions’.
 
With the technical work required to prepare the UK’s sanctions regimes for Brexit now complete, and to respond to the challenge posed by the FAC, RUSI has formed ‘The RUSI Task Force on the Future of UK Sanctions Policy’, composed of former officials, academic and policy experts and senior private sector executives, to inform RUSI’s work which seeks to provide recommendations on what UK sanctions policy could look like after Brexit. Over the coming months, the Task Force intends to consider a range of questions over several meetings in London, informed by research trips to other EU member states, to provide input to a debate that will shape UK sanctions policy for decades to come. The first meeting of the Task Force explored the possible scope of an independent post-Brexit sanctions policy, focusing on how the UK will design and implement unilateral sanctions in practice.
 
The Task Force will hold two further workshops to consider how the UK’s future sanctions regime will exist alongside those of other countries and multilateral bodies and how the government will overcome practical barriers to effective implementation of its new regime. As such, questions on potential coordination with European or US allies on sanctions, and the benefits or challenges this presents for UK sanctions, are not discussed in this paper, as later meetings will be devoted to this specific purpose.
 
This paper and its recommendations are adapted from discussions from the first London-based workshop.
 
The workshop discussion questions were as follows:
 
– What role should sanctions play in UK foreign policy after Brexit?
– How should the UK exercise the range of sanction use-cases offered to it under SAMLA?
– How should the British government work with the private sector to prepare them for independent UK sanctions?
 
Before elaborating on these recommendations, a note on terminology. This project focuses on economic and financial sanctions – that is to say: targeted assets freezes; restrictions on financial markets and services; and direction to cease certain types of business. Put simply, these are measures that reduce the ability of the sanctioned entity to conduct business and earn revenue. It is to economic and financial sanctions that most contemporary references to ‘sanctions’ by politicians or the media relate. Other forms of sanction such as travel bans or trade embargoes also exist but are outside the scope of this paper, but the recommendations contained in the paper may also apply equally to those measures.
 
As a result of the discussions framed by these questions, three primary recommendations emerged. The recommendations were developed by RUSI, and are not necessarily the consensus view of Task Force members, nor have individual Task Force members been involved in the drafting of this report.

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COM_a212.
I. Zhang, L.S. Test & K.B. Contini: “State Department Issues Draft Guidance for the Export of Items with Surveillance Capacities”
(Source: Baker McKenzie, 20 Sep 2019.)
 
Authors: Iris Zhang, Esq.; Lise S. Test, Esq., lise.test@bakermckenzie.com; and Kerry B. Contini, Esq., kerry.contini@bakermckenzie.com; all of Baker McKenzie.
 
On September 4, 2019, the US Department of State published draft Guidance for the Export of Hardware, Software and Technology with Surveillance Capabilities and/or parts/know-how (the “Guidance”) to provide insight to exporters of items with surveillance capacities on human rights concerns to consider prior to export of such items. The State Department is soliciting feedback on the Guidance until October 4, 2019 for its consideration for the final version of the Guidance to be published at a later date (yet to be specified).
 
According to the Department of State, the Guidance is not intended to be comprehensive or mandatory and is not meant to address any requirements under export control laws. Rather, it seeks to assist exporters of items with surveillance capacities with implementation of the UN Guiding Principles on Business and Human Rights as well as the OECD guidelines for Multinational Enterprises to prevent and eliminate the misuse of such items in violations or abuses of human rights, with a particular concern for the right to privacy.
 
The Guidance encourages exporters of “items with intended or unintended surveillance capacities” to integrate human rights due diligence into their export control compliance programs and provides suggestions for how to do so as well as detailed due diligence considerations, examples of red flags, and other practice-ready advice on how to conduct effective human rights due diligence.
 
The term “items with intended or unintended surveillance capacities” is defined broadly in the Guidance to include “hardware, software, technology, technical assistance, services, and/or parts/know-how that is marketed for or can be used for the monitoring, interception, collection, preservation and/or retention of information that has been communicated, relayed or generated over communications networks to a recipient or group of recipients.” 

Examples of items with surveillance capabilities, include, e.g., spyware; crypto-analysis products; penetration-testing tools; information technology products with deep packet inspection functions; specialized computer vision chips; non-cooperative location tracking (i.e., products that can be used for ongoing tracking of individuals’ locations without their knowledge and consent); cell site simulators (Stingrays); automatic license plate readers; body-worn cameras; drones and unmanned aerial vehicles; facial recognition software; thermal imaging systems; rapid DNA testing; automated biometric systems; social media analytics software; gait analysis software; network protocols surveillance systems; and devices that record audio and video and can remotely transmit or can be remotely accessed.

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

COM_a213.
P. Fair & G. Farrant: “Australian Government Announces Foreign Influence Taskforce for Universities”

(Source:
Baker McKenzie, 19 Sep 2019.) [Excerpts.]
 
* Authors: Patrick Fair, Esq., patrick.fair@bakermckenzie.com; and Georgie Farrant, Esq., georgie.farrant@bakermckenzie.com; both of Baker McKenzie.
 
On 28 August 2019, Australia’s Minister for Education Dan Tehan MP, announced the establishment of the Taskforce to Protect Universities from Foreign Interference (Taskforce). The Taskforce will target four key strategic areas include: cybersecurity, research and intellectual property, foreign collaboration, culture and communication.
 
The Taskforce
 
On 28 August 2019, Australia’s Minister for Education Dan Tehan MP, announced the establishment of the Taskforce to Protect Universities from Foreign Interference (Taskforce).
 
The Taskforce will target four key strategic areas:
  – Cybersecurity – Bolstering safeguards with respect to unauthorised access, manipulation, disruption or damage. Better managing and protecting Australian networks, and increasing capacity to respond to cyber security incidents;
  – Research and intellectual property – Increasing ability to deter and detect deception, undue influence, unauthorised disclosure or disruption to research, IP and the Australian research community. At the same time balance the interest in protecting academic freedom;
  – Foreign collaboration – Increasing transparency in collaboration with foreign entities, undertaking such activities with full knowledge and consent, and in a way that avoids harm to Australia’s interests; and
  – Culture and communication – Educating, increasing awareness, improving research and cyber resiliency. Encouraging positive security culture through government and community engagement.
 
The Taskforce will include representatives from Australian universities, the Department of Education and national security organisations. The Taskforce is set to develop best-practice guidelines for dealing with foreign interference. The Government’s stated aim is to build an approach that balances national security interests relating to foreign interference, with giving universities autonomy and the freedom to expand knowledge and pursue collaboration.

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TEEX/IM TRAINING EVENTS & CONFERENCES

TE_114
.
ECTI Presents U.S. Export Control (ITAR, EAR, OFAC
)
 
Seminar Series in Miami, FL: December 9-12, 2019
(Source:
Jill Kincaid)
 
* What: United States Export Control (ITAR/EAR/OFAC) Seminar Series in Miami, FL
* When: ITAR Seminar: December 9-10, 2019; EAR/OFAC Seminar: December 11-12, 2019
* Where: Doubletree Ocean Point Resort and Spa by Hilton
* Sponsor: Export Compliance Training Institute (ECTI)
* ECTI Speaker Panel: Scott Gearity, Greg Creeser, Melissa Proctor, and Marc Binder
* Register
here, or Jessica Lemon, 540-433-3977.

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

TE_215
. 
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_List16. 
List of Approaching Events: 122 Events Posted This Week, Including 7 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

 

* 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: Oxford, UK; “Intermediate Seminar: Strategic Export Controls“; UK DIT

*
 
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 26: Oxford, UK; “Intermediate Seminar: Licenses Workshop“; UK DIT

* Sep 26: Tallahassee, FL; “Export University 101: Introduction to Exporting“; EXIM

* 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 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; Strongsville, OH; “Trade Compliance & Policy Seminar 2019“; C.H. Robinson

* Oct 15-16: Washington DC; “The WorldECR Export Controls & Sanctions Forum 2019“; WorldECR

* Oct 16-17; Miramar, FL; “12th Maritime Logistics Training Course“; albert@abs-consulting.net or 954-218-5285; ABS Consulting & Florida Shipowners Group

* Oct 17: Grayslake, IL: “How to Write an Export Management Compliance Program (EMCP)“; Lake County Chamber of Commerce

* 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 5; Baltimore, MD; “
Automated Commercial Environment (ACE) Export Compliance Seminar
“; U.S. Census Bureau

* 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: Manchester, UK; “Intermediate Seminar: Strategic Export Controls“; UK DIT

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

* Nov 14: Manchester, UK; “Foundation Workshop: Strategic Export Controls“; UK DIT
* Nov 14: Manchester, UK; “Licenses Workshop: Strategic Export Controls“; UK DIT

* 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 3: London, UK; “Intermediate Seminar: Strategic Export Controls“; UK DIT


* Dec 4: London, UK; “Foundation Workshop: Strategic Export Controls“; UK DIT
* Dec 4: London, UK; “Licenses Workshop: Strategic Export Controls“; UK DIT

*
 
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
#
* Mar 2-5: Washington; “ITAR Controls (Mar 2-3) / EAR & OFAC Export Controls (Mar 4-5)“; ECTI; 540-433-3977
#
* Mar 30-Apr 2: Orlando, FL; “ITAR Controls (Mar 30-31) / EAR & OFAC Export Controls (Apr 1-2)“; ECTI; 540-433-3977

* 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

* Jun 17: London, UK; “Trade & Customs Compliance Group“; TechUK

* Jul 21-22: Washington DC; “FCPA High Risks Markets“; American Conference Institute

 
Webinars 


 


* 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 8: Webinar: “Advanced Letters of Credit“; NCBFAA 

#
* Oct 23: Webinar: “Understanding the ITAR and EAR Order of Review“; ECTI; 540-433-3977

* Oct 29: Webinar: “Key updates on export controls and sanctions“; Baker McKenzie

* Nov 12: Webinar: “Duty Drawback and Refunds“; NCBFAA

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

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

 

2020
 
* Jan 14: Webinar: “Commodity Jurisdiction“; NCBFAA

Feb 18: Webinar: “Drop Shipments & Routed Transactions“; NCBFAA

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

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

ENEDITOR’S NOTES

EN_a117
. Bartlett’s Unfamiliar Quotations

(Source: Editor)

 
* Bill Root 
(William A, Root; born 20 Sep 1923 (age 96 today), known as “Mr. COCOM” in 1964-1969, and often referred to as the “Godfather of export controls,” began working for the State Department in 1950, and was Director of the Export Controls Office from 1976 to 1983. He was a member of the Regulations and Procedures Technical Advisory Committee (RPTAC) and its predecessor from the 1983 until 2010, and is still an active participant in RPTAC meetings and a prolific contributor to DDTC and BIS. Bill was an original co-author of the textbook,
United States Export Controls
(now co-authored by Roz Thomsen, Jim Bartlett, and John Pisa-Relli).

The general belief that EAR99 means No License Required except for embargoed destinations (Crimea and Country Groups E:1 and E:2) is incorrect. There are 28 instances in which technically specified license requirements in the EAR, but not on the CCL, differ from the above.  Many of these are License Required to other than Crimea, E1, or E2. The existing text of EAR99 in each of the 10 CCL Categories is: “Items subject to the EAR that are not elsewhere specified in this CCL Category or in any other category in the CCL are designated by the number EAR99.” This exclusion of the 28 EAR License Required status not in the CCL from EAR99 leaves their status in limbo, thereby supporting the incorrect belief that EAR99 generally means NLR.”   

 
Friday funnies:
* Why do the French eat snails? They don’t like fast food.
* Why do the French drink so much wine? Because in France the water is l’eau.
* Why do the French eat only one egg for breakfast? Because in France one egg is an oeuf.

back to top
 

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

EN_a318. Are Your Copies of Regulations Up to Date?
(Source: Editor)

The official versions of the following regulations are published annually in the U.S. Code of Federal Regulations (C.F.R.), but are updated as amended in the Federal Register.  The latest amendments to applicable regulations are listed below.
 

*
DHS CUSTOMS REGULATIONS
: 19 CFR, Ch. 1, Pts. 0-199.  Implemented by Dep’t of Homeland Security, U.S. Customs & Border Protection.
  – Last Amendment: 5 Apr 2019:
 
5 Apr 2019: 84 FR 13499-13513: Civil Monetary Penalty Adjustments for Inflation
 


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


Last Amendment: 21 August 2019: 84 FR 43493-43501: Addition of Certain Entities to the Entity List and Revision of Entries on the Entity List and 84 FR 43487-43493: Temporary General License: Extension of Validity, Clarifications to Authorized Transactions, and Changes to Certification Statement Requirements

 

*
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: 30 Aug 2019: 84 FR 45652-45654, Adjustment of Controls for Lower Performing Radar and Continued Temporary Modification of Category XI of the United States Munitions List.  


  – The only available fully updated copy (latest edition: 30 August 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: 9 Sep 2019: 84 FR 47121-47123: Cuban Assets Control Regulations

 


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: 4 Sep 2019: Harmonized System Update (HSU) 1915   
  – HTS codes for AES are available here.
  – HTS codes that are not valid for AES are available here.

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

EN_a419
. 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 Editor, Alexander Witt. The Ex/Im Daily Update is emailed every business day to approximately 7,500 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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