19-1025 Friday “Daily Bugle”

19-1025 Friday “Daily Bugle”

Friday, 25 October 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 Noted Today.
  1. Items Scheduled for Publication in Future Federal Register Editions
  2. State/DDTC: (No new postings.)
  3. Commerce/BIS: (No new postings.)
  4. DHS/CBP Announces Scheduled ACE Maintenance
  5. DOJ/Treasury Issues Amended Venezuela-Related General License 5A and Frequently Asked Questions
  1. ST&R Trade Report: “Dates and Deadlines: Tariffs and Exclusions, Trade Barriers, Classification, Import Information”
  2. Ohio DOJ: “Columbus Man Sentenced to Prison for Illegally Exporting Goods to Iran”
  3. US Treasury Lifts Restrictions from Operator of Tankers for Yamal LNG Project
  4. Avianca Holdings Acknowledges Possibility of US Sanctions Over Cuba Operations
  1. J.E. Bartlett: “Census Bureau Changes Name of Office that Reviews VSDs for FTR Violations”
  2. R. Poelzl: “The Connection Between Trade Compliance and Logistics”
  3. Forbes: “Paul Scharre On Weapons, Autonomy, and Warfare”
  1. ECTI Presents U.S. Export Control (ITAR/EAR/OFAC) Seminar Series in Washington, DC: November 11-14, 2019
  2. FCC Presents “U.S. Export Controls: ITAR From a Non-U.S. Perspective,” 26 Nov in Bruchem, the Netherlands
  3. List of Approaching Events: 100 Events Posted This Week, Including 11 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 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 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 


 No items of interest noted today.
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. Items Scheduled
for Publication in Future Federal Register Editions
* * * * * * * * * * * * * * * * * * * *

State/DDTC: (No new postings.)

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. Commerce/BIS: (No new postings.)


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(Source: CSMS, 25 Oct. 2019)

CSMS # – ACE PROD AND CERT EXTENDED Scheduled Maintenance this weekend, Sat. Oct 26, 2019@ 2100 ET to 0400 ET Sun. Oct 27 
* The ACE PRODUCTION Maintenance scheduled for this Saturday evening, October 26, 2019, will start one hour early from 2100 ET to 0400 ET Sunday, October 27, 2019 for CBP ACE Infrastructure maintenance. 
* The ACE CERTIFICATION environment will also undergo this infrastructure maintenance during this 2100 ET to 0400 ET window.

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NWS_a16. ST&R Trade Report: “Dates and Deadlines: Tariffs and Exclusions, Trade Barriers, Classification, Import Information”

(Source: ST&R Trade Report, 25 Oct. 2019) [Excerpts.]
* Oct. 29 – SPESA Executive Conference (ST&R’s Nicole Bivens Collinson speaking on mitigating exposure to
China tariffs
* Oct. 31 – deadline for comments to USTR on
foreign trade barriers 
* Oct. 31 – opening day to request exclusions from
Section 301 tariff on China List 4A goods …

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Ohio Department of Justice, 25 Oct. 2019)
Defendant used Dublin shell company to export oil industry parts

COLUMBUS, Ohio – A Central Ohio man was sentenced in U.S. District Court today for exporting gas and oil pipeline parts to Iran for more than a decade in deliberate violation of a U.S. embargo and trade sanctions.
Behrooz Behroozian, 64, of Columbus, was sentenced to 20 months in prison.
Benjamin C. Glassman, United States Attorney for the Southern District of Ohio; Joseph M. Deters, Acting Special Agent in Charge, Federal Bureau of Investigation (FBI), Cincinnati Division; and Douglas R. Hassebrock, Acting Assistant Secretary for Export Enforcement, Bureau of Industry and Security, U.S. Department of Commerce, announced the sentence handed down today by Senior U.S. District Judge James L. Graham.
Behroozian was born in Iran in 1955 and entered the United States in 1976. He became a naturalized U.S. citizen in 1987. 
According to the sentencing memorandum filed in this case, Behroozian used an intermediary company, Sumar Industrial Equipment, to attempt to cover-up that he was illegally supplying industrial equipment to Iran in violation of the Emergency Economic Powers Act (IEEPA).
Behroozian exported manifolds, valves and connectors used for industrial pipelines in the gas and oil refinement industry to Iran via Sumar and profited $35,000 to $40,000 per year. This violated embargo and trade sanctions, which have been imposed upon Iran by the United States since May 1995.
In November 2006, Behroozian became the owner and operator of a computer parts supplier in Dublin, Ohio called Comtech International. Comtech had no storefront and made no domestic sales. It seldom exported computer parts. Instead, Comtech primarily exported industrial equipment to Sumar in the United Arab Emirates for further exportation to Iran. 
 . . .

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NWS_a38. US Treasury Lifts Restrictions from Operator of Tankers for Yamal LNG Project

, Russian News Agency, 22 Oct. 2019)

LNG Shipping L.L.C. – a joint venture between Teekay LNG and China LNG Shipping – notified Yamal LNG that the US Treasury had lifted the company’s restrictions on LNG transportation for the project, Russian independent gas producer Novatek, the owner of the Yamal LNG project, reported on Tuesday.

“The Yamal LNG Project has received a notification from LNG Shipping LLC (TC LNG), the owner and operator of Arc7 ice-class LNG tankers, that it is no longer a Blocked Person in accordance with the rules for managing foreign control assets of the United States Department of the Treasury (OFAC),” the report said.

TC LNG owns Arc7 ice-class LNG tankers. At the moment, they continue to transport LNG as usual, Novatek added.

In late September, the US Office of Foreign Assets Control (OFAC) announced sanctions against six Chinese companies, including tanker operators Cosco Shipping Tanker (Dalian) Co. Ltd. and Cosco Shipping Tanker (Dalian) Seaman & Ship Management Co. for breaching the ban on carriage of Iranian oil.

As a result, 12 LNG carriers were virtually put out of operation…

Yamal LNG project (50.1% owned by Novatek, 20% – France’s Total, 20% – China’s CNPC, 9.9% – Silk Road Fund) is being implemented on the resource base of the Yuzhno-Tambeiskoye field in Russia’s Arctic region.

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(Source: Blue Swan Daily, 24 Oct. 2019)

Avianca Holdings announced (23-Oct-2019) the holding “recently became aware” that it is presently subject to US jurisdiction for purposes of certain US sanctions laws and regulations administered by the Office of Foreign Assets Control of the US Department of the Treasury (OFAC). The jurisdiction is linked to Synergy Aerospace’s transfer of approximately 78% of Avianca Holdings’ common shares on 09-Nov-2018 from a Panama based company to a Delaware limited liability company wholly-owned by Synergy (BRW). Synergy formed BRW and effected the share transfer unilaterally in connection with BRW obtaining a loan from United Airlines. 

Avianca Holdings became considered a person subject to US jurisdiction by OFAC. 

Avianca Holdings engaged outside counsel to conduct a review aimed at identifying any potential violations of US sanctions regulations. As a result of this review, Avianca Holdings identified that the regularly scheduled commercial passenger operations between cities in Central and South America and Havana, Cuba
and related Cuba operations that it has historically conducted may have constituted inadvertent violations of the US-Cuban Assets Control Regulations during the period following the share transfer. 

During the period beginning on the date of the share Transfer and ending on 30-Sep-2019, such operations to and from Havana comprised an “immaterial amount” of Avianca Holdings’ gross revenue. Avianca Holdings state it is committed to fully cooperating with OFAC “but it is too early to predict what action OFAC may take in this regard (including sanctions and fines) and what effect such action could have on the Company’s reputation, business, financial position or results of operations.”

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(Source: Author) [A similar article was published in the Bugle on 23 October, but contained a typo, so it is revised today. Thanks to Jackson Olesky, Esq., Torres Law PLLC, for noticing the error.]
The Foreign Trade Regulations (“FTR”), 15 CFR Part 30, regulate the filing of the Electronic Export Information (EEI) reports and contain instructions on writing and submitting voluntary disclosures of suspected FTR violations.  FTR 30.75(c)(5), states:  “Where to make voluntary self-disclosures. With the exception of voluntary disclosures of manifest violations under paragraph (c) of this section, the information constituting a Voluntary Self-Disclosure or any other correspondence pertaining to a Voluntary Self-Disclosure may be submitted to: Chief, International Trade Management Division, U.S. Census Bureau, 4600 Silver Hill Road, Washington, DC 20233. Additional instructions are found at www.census.gov/trade.” 
The address in FTR 30.75(c)(5) and several Census websites discussing VSDs contain the above out-of-date information. But the name of the cognizant office has changed to the Economic Management Division.  See the Census Voluntary Self-Disclosure Guidelines website, stating that VSDs should be delivered by carrier delivery to Chief, Economic Management Division, 4600 Silver Hill Road, Room 6K-064, Suitland, MD, 20746 (or to Washington, DC 20233, if sent by U.S. mail).
If you need assistance investigating and disclosing foreign trade violations, please contact Jim Bartlett at Full Circle Trade Law, PLLC, 1-202-802-0646, JEBartlett@FullCircleTradeLaw.com.

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Logistics Viewpoints, 24 Oct. 2019)
* Author: Reinhard Poelzl, Senior Solutions Consultant for E2Open in the European Region.
Historically, governments have focused on the exporter of record when looking for sanction or embargo violations, including of the movement of sensitive dual-use products and technologies across borders. However, all parties to an export transaction, including freight forwarders and carriers, are subject to the same rules, and as such must be aware of what is required of them in the transaction. The scope of their due diligence must include destination controls, export licenses and restricted party screening. For freight forwarders, it is particularly challenging to comply with export license regulations since shipping companies tend not to gather the detailed information about the cargo they’re moving and partners involved in the transaction.

But this obstacle hasn’t slowed down the enforcement of any rulings.  In addition to the potential for reputational damage, penalties for non-compliance can include substantial fines-millions of dollars in some instances- and criminal charges, including prison time.

Recently, logistics companies that have failed to comply with the regulations that govern exports have experienced more and significant penalties. For example, in 2018 US officials brought forward a landmark case of an export compliance violation resulting in a fine against one of the world’s leading freight forwarders. US agencies fined FedEx $500,000 for inadequate commodity screening that resulted from flawed software. The goods, which included aviation parts and electron microscope manufacturing items, are classified under a series of Export Control Classification Numbers (ECCNs) for anti-terrorism purposes. The delivery of such goods requires a license from the relevant authorities, which FedEx had not obtained.

This case is just the tip of the iceberg — other logistics companies that have been fined recently as well include:
  • American Export Lines received a fine of $518,000 for transporting auto parts to Iran and Afghanistan
  • Pilot Air Freight distributed restricted goods to a denied Pakistani customer and received a subsequent fine of $175,000 (this was a case in which the screening software had major flaws)
These latest examples clearly demonstrate how important a robust and dedicated solution for export management is for freight forwarders, NVOCC and similar operators in the transportation space.

Don’t risk your company reputation, margins and import/export privileges; leverage technology and content solutions to stay out of hot water.

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Forbes, 24 Oct. 2019 [Excerpt.]

* Author: Paul Scharre is a Senior Fellow and Director of the Technology and National Security Program at the Center for a New American Security. He is the award-winning author of
Army of None: Autonomous Weapons and the Future of War, which won the 2019 Colby Award and was named one of Bill Gates’ top five books of 2018.

Aswin Pranam [Forbes Reporter]: To start, what classifies as an autonomous weapon?

Paul Scharre: An autonomous weapon, quite simply, makes its own decisions of whom to engage in the battlefield. The core challenge is in figuring out which of those decisions matter. For example, modern-day missiles and torpedoes maneuver on their own to course-correct and adjust positioning. Do these decisions matter on a grand scale? Not so much. But munitions that can make kill decisions on their own, without human supervision, matter a great deal.

Pranam: Why should the average citizen care about autonomous weapons?

Scharre: Everyone will have to live in the future we’re building, and we should all have a personal stake in what that future looks like. The question of AI being used in warfare isn’t a question of when, but rather a question of how. What are the rules? What is the degree of human control? Who sets those rules? There is a real possibility that militaries transition to a world in which human control over war is significantly reduced, and that could be quite dangerous. So, I think engaging in broad conversation internationally and bringing together nations, human rights groups, and subject matter experts (lawyers, ethicists, technologists) to have a productive dialogue is necessary to chart the right course.

Pranam: People concerned about the destructive power of AI weapons want to halt development completely. Is this a realistic solution?

Scharre: We can’t stop the underlying technology from being developed because AI and automation are dual-use. The same sensors and algorithms that prevent a self-driving car from hitting pedestrians may also enable an autonomous weapon in war. The basic tools to build a simple autonomous weapon exist today and can be found freely online. If a person is a reasonably competent engineer and has a bit of free time, they could build a crude autonomous drone that could inflict harm for under a thousand dollars. The open question is still what militaries choose to build with regards to their weapons arsenal. If you look at chemical and biological weapons as a parallel, certain rogue states develop and use them, but the majority of civilized countries have generally agreed not to move forward with development. Historically, attempts to control technology has been a mixed bag, with some successes and many failures.

Pranam: In the United States, the International Traffic in Arms Regulations (ITAR) compliance framework controls and restricts the export of munitions and military technologies. Do you believe AI should fall under the export restricted category?

Scharre: This is an area with a lot of active policy debate in both Washington DC and the broader tech community. Personally, I don’t see it as being realistic in most cases. However, there’s room for non-ITAR export controls that restrict the sale of AI technologies to countries engaged in human rights abuses. We shouldn’t have American enterprises or universities enabling foreign entities that will repurpose the technology to suppress their citizens.

By and large, as far as the access to research is concerned, the AI world is very open. Papers are published online and breakthroughs are freely shared, so it is difficult to imagine components of AI technology being controlled under tight restrictions. If anything, I could see sensitive data sets being ITAR controlled, along with potentially specialized chips or hardware used exclusively for military applications, if they were developed. . . .

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* What: United States Export Control (ITAR/EAR/OFAC) Seminar Series in Washington, DC
* When: ITAR Seminar: November 11-12, 2019; EAR/OFAC Seminar: November 13-14, 2019
* Where: Embassy Suites Alexandria Old Town
* Sponsor: Export Compliance Training Institute (ECTI)
* ECTI Speaker Panel: Scott Gearity, Greg Creeser, Melissa Proctor, Marc Binder and Timothy O’Toole
* Register
here, or Jessica Lemon, 540-433-3977.

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This intermediate-level training course is specifically designed for compliance professionals and those in a similar role who aim to stay up-to-date with the latest International Traffic in Arms Regulations (ITAR) requirements that apply to non-U.S. transactions.
The course will cover multiple topics relevant for organizations outside the U.S. that are subject to the International Traffic in Arms Regulations, including but not limited to: the U.S. regulatory framework, key ITAR concepts and definitions, tips regarding classification and licensing, essential steps to ensure an ITAR compliant shipment, how to handle a (potential) non-compliance issue, recent enforcement trends, and the latest regulatory amendments, including the latest U.S. Export Control Reform developments. Participants will receive a certification upon completion of the training.
* What: U.S. Export Controls: The International Traffic in Arms Regulations (ITAR) from a non-U.S. Perspective
* When: Tuesday, 26 Nov 2019
– Welcome and Registration: 9.00 am – 9.30 am
– Training hours: 9.30 am – 4.30 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 Export Administration Regulations (EAR) from a non-U.S. Perspective” (27 Nov 2019), and/or “The ABC of Foreign Military Sales” (29 Nov 2019). Please, see the event page for our combo deals.

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(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 

* Date: Location; “Event Title”; <Weblink>”; EVENT SPONSOR
# = New or updated listing  

Continuously Available Training
* E-Seminars:US Export Controls” / “Defense Trade Controls“; Export Compliance Training Institute; danielle@learnexportcompliance.com 

* Webinar: ”
Company-Wide US Export Controls Awareness Program“; Export Compliance Training Institute;

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

* Webinar Series: “Complying with US Export Controls“; Commerce/BIS

* E-Seminars: “Webinars On-Demand Library“; Sandler, Travis & Rosenberg, P.A.
* Online: “International Trade Webinars“; Global Training Center

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

Online: “On-Demand Webinars“; “General Training“; Center for Development of Security Excellence; Defense Security Service (DSS)
* Online: “ACE Reports Training and User Guide“; DHS/CBP

* Online: ”
Increase Your International Sales – Webinar Archive“; U.S. Commercial Service

* Web Form: “Compliance Snapshot Assessment“; Commonwealth Trading Partners (CTP)
* Online: “
Customs Broker Exam Prep Course
“; The Exam Center
Seminars and Conferences


Oct 28-29: Washington D.C.; “
2019 Fall Advanced Conference
“; SIA

* Oct 28-31; Phoenix, AZ; “
ITAR Controls / EAR & OFAC Export Controls Seminar Series

* Oct 29: Montreal, Canada; “
Trade Compliance & Policy” C.H. Robinson

* Oct 29: 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: San Francisco, CA; “Incoterms 2020 Rules Seminar“; International Chamber of Commerce

* Oct 31: Toronto, Canada; “Trade Compliance & Policy” C.H. Robinson  
* Nov 1:  Plainville, MA; “Essentials of Harmonized Tariff Classification and Free Trade Agreement Compliance“; Massachusetts Export Cente   

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

* Nov 5: London, UK; Making Better Licence Applications (MBLA); UK DIT

* Nov 5-6: Huntsville, AL; “Complying with U.S. Export Controls“; NAITA 

* Nov 7: Huntsville, AL; “Complying with U.S. Export Controls: DDTC & ITAR“; NAITA

* Nov 7; Amsterdam, the Netherlands; “Annual International Trade & Compliance Conference“; Baker McKenzie

* Nov 8:  North Reading, MA; “Best Practices for EAR99 Exporters“; Massachusetts Export Center

* Nov 12: Leeds, UK: “Incoterms 2020“; Chamber International

* 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

* 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 15:  Westborough, MA; “Deemed Export Compliance & Technology Control Plan Development“; Massachusetts Export Center

* Nov 18: London, UK; “2nd Annual Navigating Russia Sanctions Complexities“; C5

* Nov 19: Leeds, UK; “Customs Declaration Service Seminar“; Chamber International
* Nov 19: Leeds, UK; “Export Documentation & Import Procedures“; Deloitte

* Nov 19-20: London, UK; “London Forum on Economic Sanctions“; C5

* Nov 19-21: Tysons Corner, VA; “Export Controls Specialist – Certification“; Amber Road

* Nov 20-21: Washington D.C.; “Customs Compliance Industry Exchange“; ACI

Nov 20: Bristol, UK; “
Introduction to Export Procedures – Export Training
“; BusinessWest
Nov 21: Bristol, UK; “
A Foundation Course in Importing
“; BusinessWest

* Nov 26: Birmingham, UK; “
Export Control Symposium

Nov 26: Bruchem, The Netherlands; “
The International Traffic in Arms   
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: Leeds, UK; “Understanding Exporting“; Chamber International

* 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: Dallas, TX; “Trade Compliance Officer Training“; Globaleyes; andrewmell@getglobaleyes.com

Dec 4-5: Washington, DC; “
36th International Conference on the Foreign Corrupt Practices Act
“; American Conference Institute

* Dec 9-12; Miami, FL; “
ITAR Controls / EAR & OFAC Export Controls Seminar Series

* Dec 10-11: New York, NY; ” 
10th Annual New York Forum on Economic Sanctions“; American Conference Institute

 Dec 12-13; Washington D.C.; “
Coping with U.S. Export Controls and Sanctions 2019
“; Practicing Law Institute
Dec 12-13: Frankfurt, Germany; ”
The Top 20 Digital Twin Implementation Ideas from Europe’s Top Companies;” Digital Twins

* Dec 13:  Boston, MA; “Export Expo“; Massachusetts Export Center


* Jan 14: Leeds, UK; “
Export Documentation
“; Chamber International 
* 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 5-6: St. Antonio, TX; “Complying with U.S. Export Controls“; Commerce/BIS

* Feb 11: “Incoterms 2020“; Chamber International

* 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

* Mar 17-18: Orlando, FL; “Complying with U.S. Export Controls“; Commerce/BIS
* Mar 19: Orlando, FL; “How to Build an Export Compliance Program“; Commerce/BIS

* Mar 24: “Understanding Exporting & Incoterms“; Chamber International

* Apr 7-8: Washington D.C.; “6th National Conference on CFIUS & Team Telecom; ACI

* Apr 15-16: Harrisburg, PA; “Complying with U.S. Export Controls“; Commerce/BIS
* Apr 28-29: Orange County, CA; “Complying with U.S. Export Controls“; Commerce/BIS

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

* May 19-20: Charleston, SC; “Complying with U.S. Export Controls“; Commerce/BIS

* 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



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

* Oct 31: “Conflicts Between EU and US Export Rules Webinar“; ECTI; 540-433-3977

* Oct 31: “Warehousing and China Tariffs: Why Pay Them?“; Freight Waves

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

* Nov 19:  Webinar; “
Using ACE Reports to Manage and Audit AES Filings
“; Massachusetts Export Center

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

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


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

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

* Mar 10: Webinar: “Cultural Sensitivity Program” NCBFAA

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

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


* Max Stirner
(Johann Kaspar Schmidt; 25 Oct 1806 – 26 Jun 1856; was a German philosopher. He is often seen as one of the forerunners of nihilism, existentialism, psychoanalytic theory, postmodernism, and individualist anarchism.  Stirner’s main work is Der Einzige und sein Eigentum, the English title The Ego and Its Own.)

  – “The state calls its own violence ‘law’, but that of the individual ‘crime’.”
* Nisandeh Neta
(born 1969; Dutch marketing expert, serial entrepreneur, business mentor, and philanthropist. Neta is the founder of Open Circles Academy, the creator of the Business Bootcamp and 24 other business and personal development training programs, best-selling author of Elements of Success; and The Enlightened Millionaire; and co-founder of the Open Circles Foundation, a not-for-profit organization dedicated to transforming the education system in the world.)
 – “Efficiency is doing things right. Effectiveness is doing the right things. Success is doing the right things right, right now.”
Friday funnies:

* I called an old engineering classmate and asked what he was doing.  He replied, “I’m working on the aqua-thermal treatment of ceramics, aluminum, and steel under a constrained environment.”  I was impressed!  However, upon further inquiry, I learned that he was washing dishes with hot water under his wife’s supervision.

* Here’s a million dollar idea: a smoke alarm that shuts off when you yell “I’m just cooking!”

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EN_a217. Are Your Copies of Regulations Up to Date?

(Source: Editor)

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

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

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: 9 October 2019: 84 FR 54002-54009: Addition of Certain Entities to the Entity List and Revision of Entries on the Entity List


: 15 CFR Part 30.  Implemented by Dep’t of Commerce, U.S. Census Bureau.
  – Last Amendment: 24 Apr 2018: 
83 FR 17749-17751
: Foreign Trade Regulations (FTR): Clarification on the Collection and Confidentiality of Kimberley Process Certificates
  – HTS codes that are not valid for AES are available
  – The latest edition (4 Jul 2019) of Bartlett’s Annotated FTR (“BAFTR”), by James E. Bartlett III, is available for downloading in Word format. The BAFTR is a 152-page Word document containing all FTR amendments, FTR Letters and Notices, a large Index, and approximately 250 footnotes containing case annotations, practice tips, Census/AES guidance, and explanations of the numerous errors contained in the official text. Subscribers receive revised copies in Microsoft Word every time the FTR is amended. The BAFTR is available by annual subscription from the Full Circle Compliance 
.  BITAR subscribers are entitled to a 25% discount on subscriptions to the BAFTR. Government employees (including military) and employees of universities are eligible for a 50% discount on both publications at 

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

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

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

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

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

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

  – Last Amendment: 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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. Weekly Highlights of the Daily Bugle Top Stories
(Source: Editor)

Review last week’s top Ex/Im stories in “Weekly Highlights of Daily Bugle Top Stories” posted here.

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* The Ex/Im Daily Update is a publication of FCC Advisory B.V., compiled by: Editor, James E. Bartlett III; and Assistant 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.

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