19-1022 Tuesday “Daily Bugle”

19-1022 Tuesday “Daily Bugle”

Tuesday, 22 October 2019

The Daily Bugle is a free daily newsletter from Full Circle Compliance, containing changes to export/import regulations (ATF, DOE/NRC, Customs, NISPOM, EAR, FACR/OFAC, FAR/DFARS, FTR/AES, HTSUS, and ITAR), plus news and events. Subscribe here. Contact us for advertising 

inquiries and rates

(No items of interest noted today.)
  1. Items Scheduled for Publication in Future Federal Register Editions
  2. Commerce/BIS Updates Cuba FAQs 
  3. DHS/CBP Publishes Guidance on Section 301 Tranche 1 Eighth Round of Exclusions
  4. DoD/DSCA Publishes DSCA Policy Memo 19-29: Payment Schedule Calculations and Updates
  5. State: “The US and the UK Host 16th International Strategic Trade Controls and Border Security Conference in Edinburgh”
  6. State/DDTC: (No new postings.)
  7. Treasury/OFAC Extends Expiration Date of Belarus-related General License
  8. UK ECJU Publishes Guidance on Advance Checks for Registered Firearms Dealers Exporting to EU Member States
  1. American Shipper: “OFAC’s ‘50% Rule’ Challenges Compliance”
  2. Business Insider: “Malaysia Could Become Target for Sanctions in US-China Trade War, Mahathir Warns”
  3. MTCR: “Report by the Chair of the Technical Experts Meeting: Update of MTCR Annex”
  1. E. Scheer, M. Marinc & J.H. Wajer: “Netherlands: Starting 1 December 2019 Exporters Can Only be EU-Established Entities”
  1. ECS Presents “ITAR/EAR Boot Camp: Achieving Compliance” on 11-12 Feb in Tampa, FL
  2. FCC Presents “The ABC of FMS”, 28 Nov in Bruchem, the Netherlands
  1. Bartlett’s Unfamiliar Quotations 
  2. New Edition of the BAFTR is Available 
  3. Are Your Copies of Regulations Up to Date? Latest Amendments: DHS/Customs (5 Apr 2019), DOC/EAR (21 Oct 2019), DOC/FTR (24 Apr 2018), DOD/NISPOM (18 May 2016), DOE/AFAEC (23 Feb 2015), DOE/EINEM (20 Nov 2018), DOJ/ATF (14 Mar 2018), DOS/ITAR (30 Aug 2019), DOT/FACR/OFAC (9 Sep 2019), HTSUS (3 Sep 2019)
  4. Weekly Highlights of the Daily Bugle Top Stories 


(No items of interest noted today.)

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OGS_a11. Items Scheduled for Publication in Future Federal Register Editions

(Source: Federal Register)

* President; ADMINISTRATIVE ORDERS; Congo, Democratic Republic of the; Continuation of National Emergency (Notice of October 22, 2019) [Pub. Date: 22 Oct 2019.]

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Commerce/BIS Updates Cuba FAQs

(Source: Commerce/BIS, 21 Oct 2019.)
On October 21, 2019, the Department of Commerce’s Bureau of Industry and Security (BIS) amended the Export Administration Regulations (EAR) to support the President’s policy to hold the Cuban regime accountable for its repression of the Cuban people and its support of the Maduro regime in Venezuela. BIS established a general policy of denial for leases of aircraft to Cuban state-owned airlines; clarifed that aircraft and vessels are not eligible for the License Exception Aircraft and Vessels (AVS) if they are leased to or chartered by a national of Cuba; established a general 10-percent de minimis level for Cuba; and revised License Exception Support for the Cuban People (SCP) to make the Cuban government and communist party ineligible for certain donations, remove an authorization for promotional items that generally benefits the Cuban government, and clarify the scope of telecommunications items that the Cuban government may receive without a license.
The United States maintains a comprehensive embargo on trade with Cuba. The export and reexport to Cuba of items subject to the Export Administration Regulations (EAR) require a BIS license unless authorized by a license exception specified in section 746.2(a)(1) of the EAR or exempted from license requirements in section 746.2(a)(2). The EAR sets forth licensing policy for exports and reexports that generally will be approved, exports and reexports that will be reviewed on a case-by-case basis, and exports and reexports that will generally be denied.
For additional information, please review the BIS rule, Department’s press release and BIS’s updated Frequently Asked Questions. For specific questions regarding exports or reexports to Cuba, please contact the Foreign Policy Division at (202) 482-4252.

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DHS/CBP Publishes Guidance on Section 301 Tranche 1 Eighth Round of Exclusions

(Source: CSMS #40330403, 22 Oct 2019.) [Excerpts.]
On October 2, 2019, the U.S. Trade Representative (USTR) published Federal Register (FR) Notice 84 FR 52567 announcing the decision to grant the eighth round of certain exclusion requests from the 25 percent duty assessed under the Section 301 investigation related to goods from China ($34B Action – Tranche 1).
These product exclusions relate to the imposed additional duties announced in 83 FR 28710 on Chinese goods 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 product exclusions announced in this notice will retroactively apply as of the July 6, 2018 effective date of the $34 billion action (Tranche 1), and will extend for one year after the publication of 84 FR 52567.
The exclusions are available for any product that meets the description as set out in the Annex to Federal Register Notice 84 FR 52567, regardless of whether the importer filed an exclusion request. Further, the scope of each exclusion is governed by the scope of the Harmonized Tariff Schedule of the United States (HTSUS) 10-digit headings and product descriptions in the Annex; not by the product descriptions set out in any particular request for exclusion. For ease of reference, a link to the entire Federal Register Notice, which includes the Annex is embedded in this message.
The functionality for the acceptance of the eighth round of product exclusions for articles from China specific to Tranche 1 of Section 301 duties is available in the Automated Commercial Environment (ACE) as of October 8, 2019.
Instructions for importers, brokers, and filers on submitting entries to CBP containing products granted exclusions by the USTR from the Section 301 measures as set out in 84 FR 52567 are as follows:
– In addition to reporting the regular Chapters 84, 85, 88 and 90 classifications of the HTSUS for the imported merchandise, importers shall report the HTSUS classification 9903.88.19 (Articles the product of China, as provided for in U.S. note 20(x) to this subchapter, each covered by an exclusion granted by the U.S. Trade Representative) for imported merchandise subject to the exclusion.
– Importers shall not submit the corresponding Chapter 99 HTS number for the Section 301 duties when HTS 9903.88.19 is submitted.
– Paragraph “B” of the Annex to 84 FR 52567 corrects a previous exclusion round; U.S. note 20(q) to subchapter III of chapter 99 of the HTSUS (9903.88.14), deleting “Machine tool stands having leveling, stabilizing, attachment or other special features (described in statistical reporting number 8466.30.8000).
– Paragraph “C” of the Annex to 84 FR 52567 corrects a previous exclusion round; U.S. note 20(q) to subchapter III of chapter 99 of the HTSUS (9903.88.14), deleting “Granulating machines not specifically designated for use with specific particulate materials, each valued more than $25,000 (described in statistical reporting number 8479.89.9499).
– Paragraph “D” of the Annex to 84 FR 52567 corrects a previous exclusion round; U.S. note 20(q) to subchapter III of chapter 99 of the HTSUS (9903.88.14), deleting “Vertical or single shaft shredding machines of a kind suitable for use in the recycling industry, weighing over 10,000 kg but not over 15,000 kg each (described in statistical reporting number 8479.89.9499).
– Paragraph “E” of the Annex to 84 FR 52567 corrects a previous exclusion round; U.S. note 20(q) to subchapter III of chapter 99 of the HTSUS (9903.88.14), deleting “CB radio antennas (described in statistical reporting number 8529.10.9100). …


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DoD/DSCA Publishes DSCA Policy Memo 19-29: Payment Schedule Calculations and Updates

(Source: DoD/DSCA, 22 Oct 2019.)
DSCA Policy Memo 19-29 Payment Schedule Calculations and Updates has been posted.
Effective October 30, 2019, IAs are required to prioritize LOAs that contribute most to early collections using the guidelines in SAMM Chapter 9, IA’s will update payment schedules for LOAs requiring Congressional Notification after the primary contract(s) have been awarded. Further, manual USG-developed payment schedules are no longer required during development of the basic LOA for Pre-Counter Signature Review. All payment schedules will be calculated by DSAMS using a payment curve for the basic LOA, unless the IA deems it necessary to develop a manual payment schedule to meet USG requirements. Policy regarding customer requested payment schedules remains unchanged.
This memo updates:
Effective immediately, the program codes listed in the memo are assigned to track funds executed in FY 2020 under the authority provide in Section 333 of Title 10, United States Code. Funds are provided under Division A of the Continuing Appropriations, 2020 and Health Extenders Act of 2019 (P.L. 116-59) and will remain available until November 21, 2019.

This memo adds codes 7G, 7K, and DB to Table C4.T2B. – Security Cooperation (SC) Customer and Regional Codes and FMS Eligibility (DSCA/DFAS Reserved) and Table C15.T2. BPC Programs and Authorities. 


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State: “The US and the UK Host 16th International Strategic Trade Controls and Border Security Conference in Edinburgh”
(Source: State, 21 Oct 2019.)
The United States and the United Kingdom are hosting the 16th International Strategic Trade Controls and Border Security Conference in Edinburgh October 22-24, 2019. This conference brings together more than 200 export control and border security practitioners from 85 partner countries involved in dual-use and conventional arms policy, licensing, and enforcement to promote the development of effective strategic trade management and counter proliferation measures.
The Conference is organized under the auspices of the Export Control and Border Security (EXBS) Program, a technical capacity-building program at the Bureau of International Security and Nonproliferation at the U.S. Department of State. The EXBS Program provides substantive knowledge, skills, and tools to prevent the proliferation of weapons of mass destruction (WMD), missile delivery systems, and advanced conventional weapons by helping to build effective strategic trade control and border security systems in countries that possess, produce, or supply strategic items, and in transshipment states.
With the number of chemical weapons attacks on the rise in recent years, this year’s conference aims to address the proliferation of chemical materials, technology, and equipment that may be used in the development of chemical weapons, missile propellants, nuclear reprocessing, and improvised explosive devices (IEDs). The conference will also highlight the importance of updating controls on unregulated chemical substances that may be deployed as targeted assassination tools. Participants will examine the challenges of targeting, identifying, inspecting, and interdicting illicit chemical shipments, including developing risk profiles for high-risk end-users.
The international community has a clear, compelling, and urgent responsibility to redouble our efforts to counter the proliferation and use of chemical weapons. The United States and the United Kingdom are firmly committed to advancing global stability and international security by encouraging international action to further tighten controls in order to impede illicit cross-border transfers of proliferation-sensitive goods and technologies, and working closely with our international partners to achieve this goal.

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

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OGS_a77. Treasury/OFAC Extends Expiration Date of Belarus-related General License

Treasury/OFAC, 22 Oct 2019.)
The Department of the Treasury’s Office of Foreign Assets Control extended the expiration date of a general license related to nine Belarus-related entities by issuing
General License No. 2G – General License with Respect to Entities Blocked Pursuant to Executive Order 13405.

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UK ECJU Publishes Guidance on Advance Checks for Registered Firearms Dealers Exporting to EU Member States
, 21 Oct 2019.)
In preparation for a no-deal exit from the EU, UK registered firearms dealers (RFDs) who regularly export to other firearms dealers based in the EU may apply in advance for their regular consignees to be checked before goods are exported.

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American Shipper: “OFAC’s ‘50% Rule’ Challenges Compliance”
(Source: American Shipper, 22 Oct 2019.)
The Office of Foreign Assets Control policy, which focuses on financial ownership of sanctioned individuals or entities, bedevils U.S. companies with sophisticated compliance programs.
In 2008, the Treasury Department’s Office of Foreign Assets Control (OFAC) issued “guidance” that precludes U.S. companies and individuals from conducting business with entities that are owned 50% by a sanctioned party.
Specifically, these sanctioned parties have been placed on OFAC’s Specially Designated Nationals and Blocked Persons (SDN) List and the Sectoral Sanctions (SSI) List for alleged activities that harm U.S. national security and foreign policy interests.
In time, OFAC’s so-called “50% rule” has become one of the most onerous sanctions compliance obligations for American and foreign companies involved in cross-border trade. …

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NWS_a210. Business Insider: “Malaysia Could Become Target for Sanctions in US-China Trade War, Mahathir Warns”

(Source: Business Insider, 21 Oct 2019.) [Excerpts.]
Malaysia needs to stay prepared as it could become a victim of escalating tensions between the US and China, Malaysian Prime Minister Mahathir Mohamad has warned.
The 94-year-old said on Monday (Oct 21) morning that Malaysia, an export-reliant economy, could eventually also become a target for sanctions.
“Economically we are linked to both markets, and physically we are also caught in between for geographical reasons. There are even suggestions that we ourselves would be a target for sanctions,” Reuters reported him as saying. …

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MTCR: “Report by the Chair of the Technical Experts Meeting: Update of MTCR Annex”

(Source: Missile Technology Control Regime, 18 Oct 2019.)
The MTCR Technical Experts Meeting conducted a regular revision of the MTCR Equipment, Software, and Technology Annex as part of the 32nd MTCR plenary week in Auckland. This revision has ultimately led to several changes to the description of thrust vector control subsystems and to the accuracy parameters used for missile guidance and navigation systems.
The MTCR Annex cover page identifies all amended sections. The most recent version of the MTCR Annex is now available here, including the version which shows all changes from the previous Annex via tracked changes.

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E. Scheer, M. Marinc & J.H. Wajer: “Netherlands: Starting 1 December 2019 Exporters Can Only be EU-Established Entities”
(Source: Baker McKenzie, 22 Oct 2019.)
* Authors: Erik T.H. Scheer, Esq., erik.scheer@bakermckenzie.com; Mirko L. Marinć, Esq., mirko.marinc@bakermckenzie.com; and Jaap Huenges Wajer, Esq., Jaap.Huengeswajer@bakermckenzie.com; all of Baker & McKenzie Amsterdam N.V..
The Dutch Custom Authorities have published a short communique on October 1, 2019 stating that as of December 1, 2019 only EU-established entities can be mentioned as exporter on the Dutch customs declaration for export. As a result, per December 1, 2019 only EU-established entities can formally act as exporter. This is especially noteworthy in light of Brexit, where UK-established entities will no longer qualify as EU-established and will therefore no longer be able to act as exporter.
(1) Legal Framework
When the Union Customs Code (UCC) was implemented in May 2016, only an entity established in the EU could qualify as exporter for customs purposes if, in addition, this entity held a contract with a consignee in a third country and had the power to determine that the goods were to be brought to a destination outside the EU.
As of July 2018, exporter was further defined under Art. 1(19) UCC-DA as a person that it is established in the EU and:
   (1) has the power to determine that the goods are to be brought outside the customs territory of the Union, or,
   (2) is a party to the contract under which goods are to be taken out of that territory. The conditions of the first possibility have to be assessed based on actual facts and circumstances. With regard to the second possibility mentioned above, business partners are free to designate a person as exporter in their contractual or business arrangements, provided that such a person is established in the EU.
As indicated in the communiqué at hand, Dutch Customs will now enforce the legal framework as put in place upon the implementation of the UCC.
  (3) Impact of change on filing of customs declarations
Since an EU-established entity will have to act as exporter on the customs declaration, an EU-group entity (if available) or an EU-established third party can fulfill that obligation. Under the new “flexibility” provided by the interpretation of the new exporter definition, parties are contractually free to choose any person established in the EU to act as exporter. This person does not necessarily have to be a party in the sales chain.
Note that whoever is contractually assigned as exporter takes over the responsibility for the correctness of the export declaration towards the customs administration. The exporter is also the addressee of the customs administration for reviews or audits of the export declarations.
   (4) Brexit

Please note that companies should also be aware of this change if a UK-established entity is currently acting as exporter from the Netherlands.
If Brexit takes effect, then the UK-established entity can also no longer act as exporter, since said entity would no longer be established in the EU.
(4) Suggestions
In the event that a non-EU established company is still acting as exporter from the Netherlands, we would suggest reviewing whether an EU-group entity could take over the position of exporter or whether an EU-established third party should be contracted in that respect.

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ECS Presents “ITAR/EAR Boot Camp: Achieving Compliance” on 11-12 Feb in Tampa, FL

*What: ECS ITAR/EAR Boot Camp:  Achieving Compliance
*When: February 11-12, 2019
*Where: Tampa, FL
*Sponsor: Export Compliance Solutions & Consulting (ECS)
*ECS Speaker Panel: Suzanne Palmer, Mal Zerden
or by calling 866-238-4018 or email 


back to top 

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TE_a214. FCC Presents “The ABC of FMS”, 28 Nov in Bruchem, the Netherlands

This training course is specifically designed for compliance professionals and those in a similar role working for government agencies or companies (temporarily) obtaining U.S. export-controlled articles and technology procured through government-to-government Foreign Military Sales (FMS), and authorized by the Arms Export Control Act (AECA) (22 U.S.C. 2751, et. seq.).
The course will cover multiple topics relevant for organizations outside the U.S. working with U.S. export-controlled articles and technology procured through FMS, including: the U.S. regulatory framework, with a special focus on the AECA, key concepts and definitions, and practical compliance tips to ensure the proper handling of FMS-acquired articles and technology. Participants will receive a certification upon completion of the training.
* What: The ABC of Foreign Military Sales (FMS)
* When: Thursday, 28 Nov 2019
– Welcome and Registration: 9.00 am – 9.30 am
– Training hours: 9.30 am – 4.00 pm
* Where: Full Circle Compliance, Landgoed Groenhoven, Dorpsstraat 6, Bruchem, the Netherlands
* Information & Registration:
or contact FCC at
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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Yesterday the Bugle contained the unfamiliar quotations of Stanislaus I and Alfred Nobel, who were born October 20
 and 21
st, respectively. Unfortunately, I did not realize that those quotations ran in the Bugle a week ago.  A faithful Bugle reader spotted this error, and of course wasted no time pointing it out to me.  Not wanting to short-change my other 10,000 Bugle subscribers, who all probably wondered last Monday whether anyone born on 14 October said anything worth quoting, I hereby provide what should have run a week ago:
* e. e. cummings (Edward Estlin “E. E.” Cummings; 14 Oct 1894 – 3 Sep 1962; was an American poet, painter, essayist, author, and playwright.  He wrote approximately 2,900 poems, two autobiographical novels, four plays, and several essays. He is often regarded as one of the most important American poets of the 20th century.  Much of his work has idiosyncratic syntax and uses lower case spellings for poetic expression.)
“the most wasted of all days is one without laughter.”
Monday was pun day.

* My math teacher called me average. How mean!
* Confucius say, “man who runs behind car will get exhausted, but man who runs in front of car will get tired.”
* Why don’t aliens visit our planet? Terrible ratings. Only one star.
Now for today’s quotations …
* Doris Lessing (Doris May Lessing, née Taylor; 22 Oct 1919 – 17 Nov 2013; was a British-Zimbabwean (Rhodesian) novelist. Her novels include
The Grass Is Singing
 (1950), the sequence of five novels collectively called
Children of Violence (1952-1969), and five novels collectively known as
Canopus in Argos: Archives
 (1979-1983). Lessing, at age 88, was awarded the 2007 Nobel Prize in Literature, and was the oldest person ever to receive the Nobel Prize in Literature.)
– “The great secret that all old people share is that you really haven’t changed in seventy or eighty years. Your body changes, but you don’t change at all. And that, of course, causes great confusion.”
* Franz Liszt (22 Oct 1811 – 31 Jul 1886; was a Hungarian composer, virtuoso pianist, conductor, music teacher, arranger, and organist of the Romantic era. He was also a writer, a philanthropist, a Hungarian nationalist, and a Franciscan tertiary.)

  – “Beware of missing chances; otherwise it may be altogether too late some day.”

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. A N
ew Edition of the BAFTR is Available

(Source: Editor)

A new edition of Bartlett’s Annotated Foreign Trade Regulations (The “BAFTR”), dated Oct. 22, 2019, is available for download by BAFTR subscribers.  The new edition updates numerous footnotes including cites to websites, adds many new Index entries, and adds the new office name and address for sending VSDs to Census in a footnote to FTR § 30.74.  

The BAFTR contains the original wording of the U.S. Foreign Trade Regulations, 15 CFR Part 30 (2019), plus 248 footnotes listing the errors in the FTR, histories of FTR amendments, copies of all FTR Letters and Notices, a Glossary, and a robust Index listed alphabetically and by section numbers.  Subscribers will receive a revised edition of the FTR within a day after any amendment to the FTR.  Subscribe 
HERE to receive a subscription to the BAFTR for $100 per year.  Subscribers to 
Bartlett’s Annotated ITAR (The “BITAR”) are eligible for a $25 discount on a subscription to the BAFTR.

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

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


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 October 2019: FR 56117-56121: Restricting Additional Exports and Reexports to Cuba


: 15 CFR Part 30.  Implemented by Dep’t of Commerce, U.S. Census Bureau.
  – Last Amendment: 24 Apr 2018: 
83 FR 17749-17751
: Foreign Trade Regulations (FTR): Clarification on the Collection and Confidentiality of Kimberley Process Certificates
  – HTS codes that are not valid for AES are available

  – The latest edition (22 Oct 2019) of Bartlett’s Annotated FTR (“BAFTR”), by James E. Bartlett III, is available for downloading in Word format. The BAFTR is a 154-page Word document containing all FTR amendments, FTR Letters and Notices, a large Index, and approximately 250 footnotes containing case annotations, practice tips, Census/AES guidance, and explanations of the numerous errors contained in the official text. Subscribers receive revised copies in Microsoft Word every time the FTR is amended. The BAFTR is available by annual subscription from the Full Circle Compliance 
.  BITAR subscribers are entitled to a 25% discount on subscriptions to the BAFTR. Government employees (including military) and employees of universities are eligible for a 50% discount on both publications at 


: DoD 5220.22-M. Implemented by Dep’t of Defense.
  – Last Amendment: 18 May 2016: 

Change 2
: Implement an insider threat program; reporting requirements for Cleared Defense Contractors; alignment with Federal standards for classified information systems; incorporated and cancelled Supp. 1 to the NISPOM (Summary 

: 10 CFR Part 810; Implemented by Dep’t of Energy, National Nuclear Security Administration, under the Atomic Energy Act of 1954.
  – Last Amendment: 23 Feb 2015:

80 FR 9359
, comprehensive updating of regulations, updates the activities and technologies subject to specific authorization and DOE reporting requirements. This rule also identifies destinations with respect to which most assistance would be generally authorized and destinations that would require a specific authorization by the Secretary of Energy.

; 10 CFR Part 110; Implemented by Dep’t of Energy, U.S. Nuclear Regulatory Commission, under the Atomic Energy Act of 1954.
  – Last Amendment: 20 Nov 2018, 10 CFR 110.6, Re-transfers.
DOJ ATF ARMS IMPORT REGULATIONS: 27 CFR Part 447-Importation of Arms, Ammunition, and Implements of War.  Implemented by Dep’t of Justice, Bureau of Alcohol, Tobacco, Firearms & Explosives.
  – Last Amendment: 14 Mar 2019:
84 FR 9239-9240
: Bump-Stock-Type Devices

: 22 C.F.R. Ch. I, Subch. M, Pts. 120-130. Implemented by Dep’t of State, Directorate of Defense Trade Controls.

  – Last Amendment: 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

, 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.

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Review last week’s top Ex/Im stories in “Weekly Highlights of Daily Bugle Top Stories” posted here.
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* The Ex/Im Daily Update is a publication of FCC Advisory B.V., compiled by: Editor, James E. Bartlett III; and Assistant 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 of this newsletter cannot be relied upon as legal or expert advice.  Consult your own legal counsel or compliance specialists before taking actions based upon news items or opinions from this or other unofficial sources.  If any U.S. federal tax issue is discussed in this communication, it was not intended or written by the author or sender for tax or legal advice, and cannot be used for the purpose of avoiding penalties under the Internal Revenue Code or promoting, marketing, or recommending to another party any transaction or tax-related matter.

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