20-1211 Friday “Daily Bugle”

20-1211 Friday “Daily Bugle”

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Friday, 11 December 2020

  1. State Department: “ITAR Extension of Temporary Suspensions, Modifications and Exceptions”
  2. State Department: “Notice of Department of State Sanctions Actions Blocking Property and Suspending Entry of Certain Persons Contributing to the Situation in Syria”
  1. Items Scheduled for Future Federal Register Edition
  2. Commerce/BIS: (No new postings)
  3. State/DDTC: (No new postings)
  4. EU Imposes Restrictive Measures Against Persons Acting in Violation Of The Arms Embargo Of Congo
  5. UK DIT: “UK Strikes Singapore and Vietnam Trade Deals, Start of New Era of Trade with Asia”
  1. EUS: “UK to Prohibit Installation of Huawei 5G Equipment from September 2021”
  2. Reuters: “EU to Discuss Arms Exports to Turkey with NATO and U.S., Merkel Says”
  1. Helmsman: “US and EU Sanctions – What is the Difference?”
  2. Osborne Clarke: “What to Look for in a UK-EU Free Trade Agreement”
  3. Thompson Hine: “U.S. and Ecuador Update Trade and Investment Council Agreement”
  1. ECTI Presents 15 Dec; The Export Control Year in Review Webinar (just $99/seat!)
  2. Friday List of Approaching Events: 187 Events Posted This Week, Including 6 New Events
  1. New BITAR Update Available
  2. Bartlett’s Unfamiliar Quotations 
  3. Are Your Copies of Regulations Up to Date? Find the Latest Amendments Here. 
  4. Weekly Highlights of the Daily Bugle Top Stories 
  5. Submit Your Job Opening and View All Job Openings 
  6. Submit Your Event and View All Approaching Events 

Are You Keeping Up to Date with the Latest Regulations?

  Bartlett’s Annotated ITAR and Bartlett’s Annotated FTR are Word documents to download to your laptop to keep you updated on the latest amendments. They contain over 800 footnotes of section history, key cases, practice tips & tricks, and extensive Tables of Contents.  Subscribers receive updated editions every time the regulations are amended (usually within 24 hours), so you will always have the current versions of the regulations.  Subscribe to the BITAR and BAFTR here to guarantee you have an up-to-date annotated versions of these essential regulations.  


(Source: Federal Register, 11 Dec 2020) [Excerpts]
85 FR 79836: Rule
* AGENCY: Department of State.
* ACTION: Extension of temporary suspensions, modifications, and exceptions.
* SUMMARY: The Department of State is issuing this document to inform the public of a second extension to certain temporary suspensions, modifications, and exceptions to certain provisions of the International Traffic in Arms Regulations (ITAR) to provide for continued telework operations during the current SARS-COV2 public health emergency. This extension will terminate on June 30, 2021 unless otherwise extended in writing by the Directorate of Defense Trade Controls (DDTC). This action is taken in order to ensure continuity of operations among members of the regulated community.
* DATES: This document is issued December 11, 2020.
* FOR FURTHER INFORMATION CONTACT: Ms. Engda Wubneh, Office of Defense Trade Controls Policy, U.S. Department of State, telephone (202) 663-1809, or email ddtccustomerservice@state.gov. ATTN: June 2021 Extension of Suspension, Modification, and Exception.

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

(Source: Federal Register and Federal Register, 11 Dec 2020) [Excerpts]
85 FR 80214-80215: Notice
* SUMMARY: The Secretary of State has imposed sanctions on four individuals, Blocking Property and Suspending Entry of Certain Persons Contributing to the Situation in Syria.
– The Secretary of State’s determination and selection of certain sanctions to be imposed upon the four individuals identified in the SUPPLEMENTARY INFORMATION section were effective on August 20, 2020.
– The Secretary of State’s determination and selection of certain sanctions to be imposed upon the three individuals identified in the SUPPLEMENTARY INFORMATION section were effective on September 30, 2020.
Taylor Ruggles, Director, Office of Economic Sanctions Policy and Implementation, Bureau of Economic and Business Affairs, Department of State, Washington, DC 20520, tel.: (202) 647 7677, email: RugglesTV@state.gov.

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


* Treasury/OFAC: NOTICES; Blocking or Unblocking of Persons and Properties [Pub.Date: 14 Dec 2020] (PDF) (PDF) (PDF)

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

OGS_a24. Commerce/BIS: (No new postings)

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OGS_a35. State/DDTC: “International Traffic in Arms RegulationsNotification of Temporary Suspensions, Modifications, and Exceptions to Regulations due to SARS-COV2″
  On December 11, 2020, DDTC published in the Federal Register a document announcing certain temporary modifications, suspensions, and exceptions to the ITAR to facilitate continued telework operations during the current SARS-COV2 public health emergency. Originally published at paragraphs 3 and 4 of Federal Register document 85 FR 25287, dated May 1, 2020, with a termination date of July 31, 2020, the Deputy Assistant Secretary of State for Defense Trade Controls ordered their extension until December 31, 2020 in Federal Register document 85 FR 45513, dated July 29, 2020. These temporary modifications, suspensions, and exceptions are being further extended until June 30, 2021 as indicated in this Federal Register notice 85 FR 79836.  These actions are taken pursuant to ITAR §§ 126.2 and 126.3 and are in the interest of the U.S. Government and the security and foreign policy of the United States and will help to ensure continuity of operations among members of the regulated community. 

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

OGS_a46. EU Imposes Restrictive Measures Against Persons Acting in Violation Of The Arms Embargo Of Congo
Having regard to the Treaty on the Functioning of the European Union,
Having regard to Council Regulation (EC) No 1183/2005 of 18 July 2005 imposing certain specific restrictive measures directed against persons acting in violation of the arms embargo with regard to the Democratic Republic of Congo (1), and in particular Article 9 thereof,
Having regard to the proposal from the High Representative of the Union for Foreign Affairs and Security Policy,
  (1) On 18 July 2005, the Council adopted Regulation (EC) No 1183/2005.
  (2) Further to a review of the autonomous restrictive measures laid down in Article 2b of Regulation (EC) No 1183/2005, the statements of reasons relating to certain persons listed in Annex Ia to Regulation (EC) No 1183/2005 should be amended and one person should be removed from the list in that Annex.
  (3) Regulation (EC) No 1183/2005 should therefore be amended accordingly,
Article 1: Annex Ia to Regulation (EC) No 1183/2005 is replaced by the text appearing in the Annex to this Regulation.
Article 2: This Regulation shall enter into force on the day following that of its publication in the Official Journal of the European Union.
This Regulation shall be binding in its entirety and directly applicable in all Member States.
Done at Brussels, 10 December 2020.

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OGS_a57. UK DIT: “UK Strikes Singapore and Vietnam Trade Deals, Start of New Era of Trade with Asia”
  • New continuity trade deals with Singapore and Vietnam will deepen relationships in the Indo-Pacific region and deliver vital certainty for UK business.
  • Singapore deal paves the way for a cutting-edge relationship in digital as part of the government’s plan to make the UK a global hub for tech and services trade post-Brexit.
  • Agreements bring the UK a step closer to joining the Trans-Pacific Partnership (CPTPP), a high-standards agreement of 11 Pacific nations.
Read the full article here.

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


  The Government has published a “road-map” to removing high-risk vendors from the telecoms network for operators.
  In July the UK decided to remove Huawei equipment from the UK’s telecoms infrastructure following US sanctions on Huawei. The UK Digital Secretary Oliver Dowden has now said that the Telecoms Security Bill will provide that operators must stop installing Huawei equipment in 5G networks from 30 September 2021. The press release says a failure to comply could result in fines of up to 10% of an operator’s turnover, or £100,000 per day for continuing contravention. Ofcom will monitor telecoms operators’ security, and enforce compliance. Codes of practice setting out operators’ obligations will be published after the Bill has received Royal Assent.

(Source: Reuters, 11 Dec 2020) [Excerpts]

  EU leaders plan to discuss arm exports to Turkey with NATO allies and Washington, German Chancellor Angela Merkel said on Friday, after Greece pushed for an arms embargo on Ankara.
  Merkel spoke after a summit where the bloc’s 27 leaders agreed to prepare limited sanctions on Turkish individuals over an energy exploration dispute with Greece and Cyprus but postponed any harsher steps until March.
“We also spoke about how questions about arms exports must be discussed within NATO. We said that we want to coordinate with the new U.S. administration about Turkey,” Merkel told a news conference.
   The European Union and NATO are planning to hold a summit with U.S. President-elect Joe Biden after he takes office in January. Many EU states are also members of the NATO alliance.
  Merkel’s comments underlined a hardening stance on Turkey among EU governments, many of whom have in the past resisted punitive measures on Ankara, a NATO ally, candidate for EU membership and host to Syrians fleeing civil war who would otherwise seek refuge in Europe.
  But member states have also grown increasingly critical of Turkey’s involvement in Libya and its purchase of a Russian weapons system, among other flashpoints. The United States is already poised to impose sanctions on Turkey over those purchases, Reuters reported this month.
   Tensions have also flared over Turkey’s decision to send oil-and-gas drilling ships to waters off southern Cyprus where Greek Cypriot authorities have already awarded hydrocarbon exploration rights to Italian and French companies. … 
  The EU exported only 45 million euros ($54.53 million) worth of arms and ammunition to Turkey in 2018, including missiles, according to EU statistics office Eurostat, but sales of aircraft amounted to several billion euros.
   The United States, Italy and Spain were the top exporters of arms to Turkey from 2015-2019, according the Sweden-based Stockholm International Peace Research Institute (SIPRI), a leading conflict and armaments think tank.
EU governments agreed in October 2019 to limit arms sales to Turkey but stopped short of a bloc-wide ban. The bloc currently bans arms sales to several states including Russia, Belarus, Syria and Venezuela.
   EU governments including Finland, France, Germany, Italy, the Netherlands, Spain and Sweden said last year they were halting or restricting arms export licence approvals for Turkey.


(Source: Manifold Times, Nov 2020)

* Author: Maureen Poh, 65-6950-8667, Helmsman Law LLP 

  I am frequently asked about the differences between US and EU sanctions.  For instance, when negotiating sanctions clauses in a contract; or, where the spectre of a breach of sanctions is raised during the performance of a contract.  Commonly asked questions include: if a certain entity is under US sanctions, does it mean that it is similarly caught by EU sanctions?  I am not a US company or citizen, do I have to comply with US sanctions laws?  How will I be penalised for breaching sanctions?  In essence, tell me what I should do in order to comply with sanctions laws.
 Unfortunately for businesses (and fortunately for lawyers!), the US-EU sanctions landscape is a minefield, with overlapping and sometimes contradictory sanctions regulations.  The sanctions policies and enforcement of sanctions vary widely between the US and EU.  To illustrate the differences, I discuss below three aspects of sanctions: scope, extra-territorial reach and enforcement.
Scope of Sanctions
  For starters, let us look at the scope of sanctions: the list of sanctioned entities differs between the US and the EU.  The US has a far longer list of sanctioned countries, entities and individuals than the EU.  US sanctions may also be implemented relatively quickly, sometimes overnight, by way of Executive Order.  This leads to a situation where a company in a global supply chain may be in breach of one sanctions regime, while at the same time being allowed by another regime to deal with that same entity.  Another example is in respect of sectoral sanctions.  For example, US sanctions against Russia extend to Russia’s oil and gas industries; EU sanctions do not cover most Russian gas projects.
Reach of Sanctions
  Another big difference is the reach of sanctions rules: do sanctions laws apply extra-territorially, i.e., do US sanctions laws apply only to US companies and citizens?   US primary sanctions generally restrict or prohibit US companies (including their non-US branches) as well as US citizens, and non-US entities owned or controlled by US persons, from doing business with sanctioned countries, companies or individuals.  This applies regardless of where they are located.  In some instances, US secondary sanctions are more complex, applying to any company or individual in the world that wants to do business in the US, with US companies or individuals, or even non-US persons in possession of or dealing with US-origin goods.  A transaction that involves a US nexus, for instance, the use of the US dollar, might be sufficient for US sanctions to bite.
  Contrast this with EU sanctions – EU sanctions generally apply only within the jurisdiction of the EU, i.e., within EU territory; to EU nationals, whether or not they are within the EU; and, to companies incorporated under the laws of an EU Member State whether or not they are within the EU (including branches of EU companies in third countries).  Companies incorporated outside the EU and non-EU nationals are generally not required to comply with EU sanctions, except in respect of business done in whole or in part within the EU.  To add to the complexity of EU sanctions, individual EU Member States may also impose their own domestic sanctions in addition to any imposed by the EU.
  Perhaps the most obvious gulf between US and EU sanctions is demonstrated in how the EU tries to block the extra-territorial effect of US sanctions.  In 1996, the EU introduced the “Blocking Regulation” (EC Regulation 2271/96).  It obliges EU residents and companies to refrain from complying with extra-territorial laws that are set out in the Blocking Regulation.  The effect of this is that it allows EU entities to engage in activities with companies and individuals that are lawful in the EU but which might be sanctioned by the US.  In other words, it makes compliance with US sanctions a violation of EU laws.  Little surprise that this only adds to the already confusing situation!
Enforcement of Sanctions
  I round off my discussion by touching on another area of difference, which is how breaches of sanctions are enforced.  The US sanctions policy is administered and enforced centrally, by the US Treasury’s Office of Foreign Assets Control (OFAC).  In the EU, each Member State administers and enforces EU sanctions.  This means that they have their own approach to enforcement: some Member States impose criminal penalties, while others only impose civil or administrative penalties.  In addition, in some EU Member States, companies and individuals have an obligation to report to the authorities if they believe there has been a breach of EU financial sanctions; it is a criminal offence in certain instances if they fail to do so.  This obligation does not exist in other Member States.
What should you do?
  So, back to the question: what should businesses do in order to comply with sanctions laws?
  The answer is to check and double-check, otherwise it will be checkmate to you mate!
  While the reality is that no one will be able to ensure compliance with 100% of oftentimes vague, complex and conflicting sanctions laws 100% of the time, you still have to try your best to keep on top of the different global sanctions regimes.
  Due diligence is key – companies should check, and monitor, their customers, suppliers and all counterparties, including the end user of the product or service, together with their financiers’ requirements, as financial institutions usually have pretty stringent sanctions compliance regulations.  Due diligence should be carried out not only before the deal but also constant monitoring during the performance or lifetime of the contract.
  You should pay attention not only to trading with counterparties who are sanctioned entities, but also companies who are alleged or found to breach sanctions laws, for instance, by trading with a sanctioned third party.  You might in turn be potentially exposed to penalties. It all depends on the type of sanctions – UN mandatory sanctions or unilateral sanctions by individual countries – that the company has breached while taking into consideration the place of incorporation of that company, your jurisdiction of incorporation and where your business is carried out.
  Faced with a situation like that, is imperative that you quickly seek legal advice from multiple jurisdictions.  As a rule of thumb, consider the following:
  • the jurisdiction where the breaching company is charged with or convicted of breaching sanctions laws;
  • place of incorporation of that company, if different from the former;
  • the jurisdiction where your business is incorporated. Where it involves a parent company and foreign subsidiary, the countries of incorporation of both parent and subsidiary;
  • the countries where your directors are from; and/or
  • the place where the relevant trade or service is, or is supposed, to be performed.
  Appropriate due diligence processes, together with legal advice from relevant jurisdictions are your essential tools to navigate the ever-shifting international sanctions environment.

  If the UK and EU agree on the text of a free trade agreement (FTA), here are some of the areas which will be relevant to business. 
  This note is written from the perspective of a UK business trading into one or more EU Member States, but most of the note will also be relevant to trade from the EU to the UK, as many FTA provisions are reciprocal.
  Given that the FTA is expected to run to around 800 pages plus annexes, what follows is by necessity a very high level overview.

Temporary Entry and Stay for Business Purposes

  Here, we’re talking about travel and movement for business purposes, not general immigration rules (which have to be considered separately).
  • For short-term business visitors, there is likely to be a visa-free limit of 90 days in every 180 days, but the crucial issue will be what activities are permitted during any visit, and to what extent there is an EU-wide regime and to what extent there will be individual national regimes or derogations across the Member States.
  • What does the FTA say about:
    • intra-company transfers between the UK and EU, for example for senior personnel, specialists and graduate trainees;
    • the movement of contractual service suppliers i.e. employees of a UK business into a Member State to support a service contract between their employer and a local client;
    • the duration for which UK self-employed professionals and investors can work in a Member State and for what purpose; and
    • UK business visitors travelling for investment purposes?
  That is, to what extent does the FTA build on Mode 4 of the WTO GATS Modes of Supply.


Services and Investment

  Here, we’re talking about business selling services into, or making investments in, the EU.
  What does the FTA do to reduce or eliminate barriers around Market Access, such as economic needs tests (where a market entrant has to show that there is an economic need for their service), requirements on corporate form (such as non-recognition of English LLPs or of the limited liability of UK-incorporated companies), or caps on the amount of equity that can be held by a UK investor?
  Does the FTA address National Treatment by prohibiting discriminatory treatment between UK and EU service suppliers?
  Are local presence requirements – such as the need for a UK supplier to establish a physical presence in a relevant Member State, or to have a local management or board presence, or to have a local partner – reduced or eliminated?
  Does the FTA reduce restrictive conditions on UK service providers, such as requirements for content to have a specified amount produced locally?
In all of the above, what specific national exceptions (sectoral, industry-specific or geographic) to these liberalising provisions have Member States managed to include?

Mutual Recognition of Professional Qualifications

  Here, we’re talking about the recognition by Member States of UK qualifications, to enable the holder to practise in that Member State. To take two examples, management accountants and architects.
  Does the FTA set out a framework or pathway for the recognition of all professional qualifications by Member States? Is that framework limited to general conditions and guidelines which can then be applied to profession-specific agreements – or does the FTA allow for full mutual recognition of qualifications (unlikely!).
  What is the extent of the coverage of the MRPQ provisions? And does the FTA allow the UK to conclude bilateral agreements on mutual recognition with individual Member States (which the UK would like, so that it is not stuck only with EU-wide general framework provisions)?


  Here, we’re talking about FTA provisions to ease the flow of goods each way between the UK and the EU.
  An FTA will almost certainly remove tariffs and quotas (quantitative restrictions) for goods moving between UK and EU. But what does it say about Rules of Origin? These are the rules which stipulate what percentage of a product moving between the UK and the EU has to ‘originate’ in the UK to qualify for zero tariffs and quotas. For example, if 60% of the product actually originates from the US and only 40% from the UK, it is unlikely to qualify.
On Rules of Origin, does the FTA allow for bilateral cumulation (any EU content in a ‘UK’ product is treated as of UK origin for the percentage calculation) or for diagonal cumulation (any content from a third country with which both the UK and EU have a free trade agreement, such as Japan, is treated as of UK origin)? Are there sector-specific provisions, for example disregarding batteries in electric vehicles manufactured in the UK from the percentage calculation, as the UK has no battery making capacity?
  What is the extent of provisions in the FTA addressing Technical Barriers to Trade in manufactured goods, such as detailed technical regulation, standardisation requirements, accreditation stipulations, and marking and labelling?
  Are UK conformity assessment bodies permitted to test products against EU requirements, and so reduce or avoid the need for UK manufacturers to appoint an EU-based conformity assessment body?
  What measures does the FTA contain on Customs and Trade Facilitation, streamlining customs arrangements through processes such as the advance clearance of documentation and paperwork simplification and transparency. Does the FTA have specific provisions to ease roll-on, roll-off trade, given the importance of the Short Straits crossing between northern EU Member States and the UK?
  How much does the FTA ease sanitary and phyto-sanitary regulations, and in particular does it contain (or aim towards) an equivalence mechanism to reduce border checks and simplify certifications regimes for animal movement and trade in animal and plant products (such as food!).

Other areas: digital trade, energy, road transport, aviation

  Here, we’re talking about a wide range of important sectoral areas and issues (some of these, such as aviation, may be dealt with separate agreements).
For digital trade (excluding data adequacy), will there be commitments on market access to minimise barriers to the supply of digital services between the UK and the EU?
  Will the Energy chapter contain a link between any future UK Emissions Trading Scheme and the EU ETS, including mutual recognition of allowances?
To what extent will road transport operators be permitted to provide services to, from and through each territory, including cabotage rights for UK operators? Will there be non-discrimination measures to allow full recognition of the UK regulatory regime?
  For aviation, to what extent will UK and EU airlines have the right to operate between points in the UK and points in the EU without restrictions on frequency or capacity? What restrictions will there be on ownership or control?

Level playing field

  Here, we’re talking about the EU’s ‘red line’ that the UK, given its geographical proximity, should not be able to lessen standards across environmental, labour and social, tax and climate regulationand so provide UK businesses with potential competitive advantage over EU businesses.
  Will the UK (and the EU!) agree not to regress from existing standards? Will there be a ‘ratchet’ that means a party cannot regress from its own future higher standards? Could there be a ratchet which requires the other party to match (and not regress from) the future higher standards of the other party (no)?
  On state aid, will the UK agree to establish an independent domestic regulator to monitor state aid decisions, and if so, what powers would that regulator have? Or could there be a bilateral dispute settlement mechanism (arbitration) to resolve state aid disputes between the EU and UK?

Overarching provisions

  What provisions will there be for retaliation if a party breaches the FTA? The EU would like a single overarching mechanism which permits cross-retaliation, allowing the EU to remove concessions in areas unrelated to the area of breach. The UK wants separate mechanisms for different parts of the relationship, with no cross-retaliation.
  Will an FTA contain future review procedures, by which provisions in areas which have been difficult in these negotiations are reviewed in, say, five years’ time? That is a possible way of the current impasse.
  Finally, will there be any sectoral or area-specific implementation periods? This could be a way of managing some of the difficulties thrown up by the Northern Ireland Protocol for goods movements between NI and Great Britain.
We await the text. And developments on data adequacy and financial services equivalence, which are unilateral decisions of the EU taken outside the scope of an FTA.

(Source: SmarTrade, 8 Dec 2020)


  On December 8, 2020, the United States and Ecuador signed a new Protocol on Trade Rules and Transparency that updates the U.S.-Ecuador Trade and Investment Council Agreement (TIC Agreement).  The Protocol adds four new annexes on (i) Customs Administration and Trade Facilitation, (ii) Good Regulatory Practices, (iii) Anticorruption and (iv) Small and Medium-Sized Enterprises.  In a brief press release, U.S. Trade Representative Robert Lighthizer stated, “Today’s Protocol builds on the existing TIC Agreement to establish high standards for efficient customs procedures, transparency in regulatory development, anti-corruption policies, and cooperation and information sharing to benefit small and medium-sized enterprises.  This Protocol is an important step in establishing closer economic ties between our countries.”
  On customs administration and trade facilitation, the Protocol includes, for example, provisions on advance rulings, penalties and automation, which go well beyond the baseline of the WTO Trade Facilitation Agreement. On good regulatory practices, the Protocol includes, for example, provisions for the online publication of draft regulations, regulatory impact analyses and transparency, and the assessment of the effectiveness of regulations. On anti-corruption, the Protocol expands both countries’ frameworks to include provisions addressing money laundering, effective sanctions, the accountability of public officials, and additional protections for whistleblowers. Regarding small and medium sized enterprises (SMEs), the Protocol recognizes the importance of small businesses, including micro-sized businesses, to the economies of both countries, and includes provisions promoting cooperation to increase trade and investment opportunities for SMEs.  A Fact Sheet on the four annexes is available here.
  The Protocol will go into effect once each party has notified the other that it has completed the internal procedures required for the entry into force.


* What: The Export Control Year in Review 
* When: 15 Dec; 1:00 p.m. (EST)
* Where: Webinar
* Sponsor: Export Compliance Training Institute (ECTI)
* ECTI Speaker: Scott Gearity
* Register: here or contact Ashleigh Foor, 1-540-433-3977, ashleigh@learnexportcompliance.com
 * * * * * * * * * * * * * * * * * * * *

(Sources: Event sponsors)  

Submit your event in the Submission section at the end of this newsletter.  
[Editor’s note:  This Daily Bugle Event List has grown so large that we have run out of space to display it, so we are displaying here only the new events in the Daily Bugle, while maintaining a LINK HERE to the full list.]

Published every Friday or last publication day of the week. Send events to events@fullcirclecompliance.eu, composed in the below format:
# * Date: (Location;) “Event Title”; <Weblink>” Event Sponsor;


* 15 Dec: “Proposed Continuing Education for Customs Brokers“; Braumiller Law Group
* 15 Dec: “NEW Rules of Origin: Made in … where? Workshop“; Chamber International
* 17 Dec: “HS Code Classification & the UK Global Tariff Workshop“; Chamber International
* 12 Jan 2021: “Export Documentation & Import Procedures Course“; Chamber International
* 12-13 Mar 2021: “Webinar on Pharmaceutical Sciences“; Inovine Conferences

Back to top

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EN_a115. New BITAR Update Available

(Source: Editor)

  A new edition of Bartlett’s Annotated ITAR (The BITAR) is available for download by subscribers.  The 11 Dec 2020 edition adds footnotes at § 120.39 and § 126.18(d)(1) resulting from the notice in 85 Fed. Reg. 79836 (Dec. 11, 2020), “Notification of Temporary Suspension, Modification, or Exception to Regulations,” and adds the FR notice to Appendix B.  To download the 11 Dec 2020 edition of the BITAR in Word, please login to your account on  our website.     
  Bartlett’s Annotated ITAR™ (the “BITAR”) contains the full text of the International Traffic in Arms Regulations, 22 C.F.R. §§ 120-130, with features added by the author, including a Table of Contents, nearly 1,000 footnotes, section histories, appendixes containing government guidance, user aides, and a huge 34-page Index. The text is the same as published in the latest official version, 22 C.F.R. §§ 120-130, with all amendments published in the Federal Register, but the official version contains no footnotes, appendixes, or index.  If you are not yet a BITAR subscriber, go HERE  to subscribe.
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EN_a116. Bartlett’s Unfamiliar Quotations

(Source: Editor)

* Hector Berlioz  (Louis-Hector Berlioz; 11 Dec 1803 – 8 Mar 1869; was a French Romantic composer and conductor. His output includes orchestral works such as the Symphonie Fantastique and choral pieces including the Requiem and L’Enfance du Christ, and his three operas, Benvenuto Cellini, Les Troyens and Béatrice et Bénédict.)
 – “Every composer knows the anguish and despair occasioned by forgetting ideas which one had no time to write down.”
* Gustave Flaubert (12 Dec 1821 – 8 May 1880) was a French novelist. Highly influential, he has been considered the leading exponent of literary realism in his country. He is known especially for his debut novel, Madame Bovary, his Correspondence, and his scrupulous devotion to his style and aesthetics.)
  – “Nothing is more humiliating than to see idiots succeed in enterprises we have failed in.”
  – “Success is a consequence and must not be a goal.” 
Friday funnies

* How does a happy sheep say “Merry Christmas”?  “Fleece Navidad!”
* What does a grumpy sheep say at Christmas? “Baaaa humbug!” 

* Jane: “You know there were actually nine reindeer, right?”  Bob: “I thought there were only eight.  What was the ninth reindeer’s name?”  Jane: “Olive, the other reindeer.” 


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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 are listed below.
Latest Update 


5 Apr 2019: 84 FR 13499:

Civil Monetary Penalty Adjustments for Inflation. 

18 Nov 2020: 
85 FR 73411:  Revisions to Export Enforcement Provisions. 

24 Apr 2018: 83 FR 17749: Foreign Trade Regulations (FTR): Kimberley Process Certificates.  The latest edition of the BAFTR is 
9 Nov 2020.

: DoD 5220.22-M. Implemented by Dep’t of Defense. 

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.    23 Feb 2015: 80 FR 9359: comprehensive updating of regulations, updates the activities and technologies subject to specific authorization and DOE reporting requirements. 

15 Nov 2017, 82 FR 52823: miscellaneous corrections include correcting references, an address and a misspelling.

DOJ ATF ARMS IMPORT REGULATIONS: 27 CFR Part 447-Importation of Arms, Ammunition, and Implements of War. 
14 Mar 2019: 84 FR 9239: Bump-Stock-Type Devices.


11 Dec 2020: 85 FR 79836: Extension of temporary suspensions, modifications and exceptions. The latest edition of the BITAR is 11 Dec 2020. 

DOT FOREIGN ASSETS CONTROL REGULATIONS (OFAC FACR): 31 CFR, Parts 500-599, Embargoes, Sanctions, Executive Orders
Amendment of Cuban Assets Control Regulations.

1 Jan 2019: 19 USC 1202 Annex.
  – HTS codes for AES are available here.
  – HTS codes that are not valid for AES are available here.

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Are you looking for a new job in trade compliance? Click here to see the current job openings.

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Are you looking for an upcoming event?   Click here to see upcoming events.

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