16-0818 Thursday “The Daily Bugle”

16-0818 Thursday “Daily Bugle”

Thursday, 18 August 2016

TOPThe Daily Bugle is a free daily newsletter from Full Circle Compliance, containing changes to export/import regulations (ATF, Customs, NISPOM, EAR, FACR/OFAC, FTR/AES, HTSUS, and ITAR), plus news and events. Subscribe 
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[No items of interest noted today.]

  1. Ex/Im Items Scheduled for Publication in Future Federal Register Editions
  2. Commerce/BIS: (No new postings.) 
  3. State/DDTC: (No new postings.) 
  4. Australia DECO Updates End-Use Statements and Certificate Forms 
  1. ST&R Trade Report: “CBP Proposes to Harmonize Vehicle Documentation Requirements, Allow Electronic Filing” 
  2. ST&R Trade Report: “Destination Control Statements Harmonized for ITAR and EAR Exports” 
  1. A. Braumiller: “BIS Issues Final Rules on Charging and Penalty Determinations in Settlement of Administrative Enforcement Cases” 
  2. G.R. Tuttle III: “Changes to CBP’s Entry Reconciliation Program” 
  3. R. Thomsen, A. Paytas & M.M. Shomali: “ZTE Sanctions Update – 18 Aug 2016” 
  4. Gary Stanley’s ECR Tip of the Day 
  5. R.C. Burns: “This Post About Kim Kardashian Will Leave You Utterly Speechless” 
  1. ECTI Presents United States Export Control (EAR/OFAC/ITAR) Seminar Series in Huntsville AL, 17-20 Oct 
  1. Bartlett’s Unfamiliar Quotations 
  2. Are Your Copies of Regulations Up to Date? Latest Changes: ATF (15 Jan 2016), Customs (22 Mar 2016), DOD/NISPOM (18 May 2016), EAR (17 Aug 2016), FACR/OFAC (18 May 2016), FTR (15 May 2015), HTSUS (1 Jul 2016), ITAR (17 Aug 2016) 



[No items of interest noted today.]

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OGS_a11. Ex/Im Items Scheduled for Publication in Future Federal Register Editions
(Source: Federal Register)

* Commerce; Industry and Security Bureau; RULES; Temporary General Licenses: Extension of Validity [Publication Date: 19 August 2016.]

* Commerce; Industry and Security Bureau; Notices; Denials of Export Privileges: Walter Anders and Terand, Inc. [Publication Date: 19 August 2016.]

* Treasury; Foreign Assets Control Office; NOTICES; Blocking or Unblocking of Persons and Properties [Publication Date: 19 August 2016.]

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OGS_a22. Commerce/BIS: (No new postings.)

(Source: Commerce/BIS)
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OGS_a33. State/DDTC: (No new postings.)

(Source: State/DDTC)
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OGS_a44. Australia DECO Updates End-Use Statements and Certificate Forms

(Source: Australia DECO)
The Australia Defence Export Control Office has updated its end-use statements and end-use certificates forms.   The updated supporting documentation can be found here.
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U.S. Customs and Border Protection is proposing to amend its regulations to harmonize the documentation requirements applicable to different classes of vehicles and engines that are subject to the Clean Air Act’s emission standards. This rule also proposes to permit the required Environmental Protection Agency emission compliance forms to be filed with CBP electronically. Comments on this proposed rule are due no later than Sept. 19.
The CAA prohibits the importation of new motor vehicles and motor vehicle engines unless they are covered by an EPA certificate of conformity. The EPA requires the submission of certain documents for purposes of compliance with the CAA: Declaration Form 3520-1 for passenger vehicles, highway motorcycles and their corresponding engines, and Declaration Form 3520-21 for heavy-duty highway engines and non-road engines (gas, diesel, marine, stationary), including those already installed in vehicles or equipment.
CBP regulations currently require importers of goods covered by form 3520-1 to file the requisite information at the time of entry but provide an exemption for imports that are covered by an EPA certificate of conformity and labeled accordingly. Importers of goods covered by form 3520-21 are only required to prepare the form and keep it on file for at least five years from the date of entry, but there is no exemption for goods covered by an EPA certificate of conformity.
CBP is now proposing to conform these entry filing requirements so that importers of stationary, non-road or heavy-duty highway engines (including those incorporated into vehicles or equipment) would have to file form 3520-21 at the time of entry unless they hold a valid EPA certificate of conformity and the engines are labeled to show compliance with applicable emission requirements.
This rule would also allow the electronic filing of forms 3520-1 and 3520-21 in the Automated Commercial Environment, although they could also still be filed on paper with a paper entry filing at the time of entry.
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The Bureau of Industry and Security and the State Department have issued final rules that, effective Nov. 16, will harmonize the destination control statements required under the Export Administration Regulations and the International Traffic in Arms Regulations. Both rules reflect the agreement of BIS and State with public commenters that the proposed rules did not go far enough and additional harmonization was needed. The rules also incorporate certain clarifications and refinements to clarify and alleviate perceived concerns, in particular for exporters of non-600 series and non-9×515 items under the EAR.
Destination Control Statements. The EAR require exporters to include a DCS on certain export control documents that accompany a shipment for most exports. The ITAR include the same type of requirement but specific to the ITAR context and with slightly different text. In both cases the purpose of the DCS is to alert parties outside the United States that receive the item that the item is subject to the EAR/ITAR, that the item was exported in accordance with the EAR/ITAR and that diversion contrary to U.S. law is prohibited.
Because the transfer of formerly ITAR-controlled defense article parts and components to the EAR under the Export Control Reform Initiative has increased the incidence of exporters shipping articles subject to both the ITAR and the EAR in the same shipment, there has been confusion among exporters as to which DCS to include on such mixed shipments or whether to include both. BIS states that adopting a new harmonized DCS will simplify export clearance requirements for exporters because they will not have to decide which DCS to include, especially for mixed shipments containing both ITAR and EAR items. Harmonization is also “one important step” to prepare both regulators and the regulated public for the eventual creation of a single export control list and single licensing agency.
The harmonized DCS will adopt language equally applicable under the ITAR and the EAR. The first sentence specifies that “these items are controlled by the U.S. government and authorized for export only to the country of ultimate destination for use by the ultimate consignee or end-user(s) herein identified.” The term “authorized” includes exports, reexports and transfers (in country) designated as “no license required.” The phrase “country of ultimate destination” means the country specified on the commercial invoice where the ultimate consignee or end user will receive the items as an export.
The second sentence focuses on alerting the persons receiving the items that the items may not be resold or transferred or otherwise be disposed of to any other country or any person other than the authorized ultimate consignee or end-user(s), either in their original form or after being incorporated into other items, without first obtaining approval from the U.S. government or as otherwise authorized by U.S. law and regulations. BIS states that the application of this second sentence is different under the ITAR and the EAR due to the different types of authorizations and other approvals in the respective regulations as well as other differences, such as the de minimis requirements in the EAR.
Under these rules the DCS will only be required with the commercial invoice and will no longer have to be included on the air waybill, bill of lading or other export control documents. In addition, the DCS is only required for items exported in tangible form. However, when a commercial invoice does exist for intangible exports, BIS recommends as a good compliance practice to include a DCS or other export control-related information that may be relevant.
Other Changes. Other changes these rules make to existing regulations include the following.
  – removing from the EAR a provision that requires a special DCS for items controlled under ECCNs for crime control columns 1 and 3 reasons or regional stability column 2 reasons when those items are destined to India
  – adding clarifying language to various provisions of the ITAR pertaining to the use of license requirement exemptions and the export of items subject to the EAR when the EAR items are shipped with items subject to the ITAR (including guidance on the use of licensing exemptions as well as clarification that items subject to the EAR are not defense articles even when exported under a license or other approval (to include exemptions) issued by State)
  – clarifying that items subject to the EAR may be exported pursuant to an ITAR exemption if exported with defense articles
  – clarifying how parties may obtain authorization from State to export or retransfer items subject to the EAR
  – removing from the ITAR the requirement to provide seven paper copies for various export license requests, which has not been necessary for many years due to the use of electronic license submissions
  – removing the pilot filing requirement in the ITAR because it does not take into account the practices of modern airport operations and is no longer necessary
  – adding to the ITAR a provision for requests to interpret ITAR requirements (State notes that it is undertaking a review of the advisory opinion process, which will be addressed in a future rule)
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COMM_a17. A. Braumiller: “BIS Issues Final Rules on Charging and Penalty Determinations in Settlement of Administrative Enforcement Cases”

* Author: Adrianne Braumiller, Esq., Braumiller Law Group, PPLC, Adrienne@BraumillerLaw.com.
On June 22nd, the U.S. Commerce Department Bureau of Industry and Security (BIS) promulgated its final version of the revision of enforcement guidelines (effective July 22, 2016).  BIS proposed its initial revisions in December 2015. Concerns regarding the proposed revisions included the proposed base penalty amounts, mitigation factors, related violations, warning letters, and the treatment of Voluntary Self Disclosures (VSD).  BIS received comments from 11 submitters and resolved most of the concerns in the final version.
The good news is that VSDs continue to be a key tool in an exporter’s arsenal to significantly mitigate its risk for export penalties.
Initially, commenters were concerned that the proposed revision fixed the base penalty amount for egregious cases resulting from a VSD to one-half the statutory maximum. The BIS Office of Export Enforcement (OEE) agreed that the “formula stated in the proposed rule may have been too rigid” and revised the proposed rule to “a range of up to one-half the statutory maximum.” Commenters likewise objected to the initial proposed revision for egregious cases not resulting from a VSD. The OEE again agreed to revise the final rule to a range just near the statutory maximum, rather than the initial rule, which set the applicable statutory maximum as the base penalty.
The final rule also revises the sections on Mitigating Factors. Based on comments received, the OEE revised Mitigating Factor G to include the question:
Has the Respondent previously made substantial voluntary efforts to provide information (such as providing tips that led to enforcement actions against other parties) to federal law enforcement authorities in support of the enforcement of U.S. export control regulations?
This particular mitigating factor while fairly unsettling memorializes a long standing strategy of pointing the finger at other potential parties to help the disclosing party shift some or most of the blame.
OEE also revised Mitigating Factor H to include a practical question: “Would the export have qualified for a license exception?”  If so, the thinking is that there is less harm from the underlying violation.
Another concern from commenters was BIS’s treatment of cases involving multiple violations. The proposed revisions deleted language that distinguishes whether multiple violations “stem from the same underlying error or omission”, thus violations that would currently be viewed as “related” would have been considered “unrelated”. BIS agreed to the concerns and revised the final rules to state: “OEE will consider whether the violations stemmed from the same underlying error or omission, and whether they resulted in distinguished or separate harm.”
An additional concern regarded the proposed changes to the issuance of warning letters. The proposed revisions would have allowed for the issuance of a warning letter if “OEE determines that a violation may have occurred.” Commenters felt that this could have resulted in the issuance of a letter where no violation had occurred. This caused concern because the proposed revisions also allowed for up to a 25% reduction in penalties for a first violation. Receipt of a warning letter would have precluded a violation from being considered a “first violation”. In the final rule, the OEE clarified that it “would not issue a warning letter based on its conclusion that a violation did not occur” and revised the first offense mitigation “to be determined without regard to the prior issuance of warning letters.”
Finally, the proposed rules would have imposed a 75% limitation on mitigation of non-egregious cases based on a VSD submission, and a VSD submission would only affect the civil penalty base amount. This caused anxiety as currently the submission of VSDs for non-egregious cases often results in the complete avoidance of civil penalties. Commenters voiced their worry that this would significantly reduce “the incentive for voluntary disclosure.” BIS agreed and revised the final rule to clarify that it intends to continue its practice of a “very low percentage of VSDs” resulting in civil monetary penalties. BIS further clarified that the rule would formalize standing OEE practice of assigning 50% mitigation for “the submission and completion of VSDs that meet the requirement of § 764.5” and that the “proposed rule would remove the discretion to assign anything less,” thus further incentivizing VSD submission. The final rule retains the 75% limitation on mitigation for egregious cases based on a VSD.
BIS considered commenters concerns seriously and incorporated many of the suggested revisions into the final rules. However, in a few instances, BIS concluded that the comments did not merit revision of the proposed rule. Importantly, a high degree of cooperation is still required for BIS to consider cooperation a mitigating factor. Companies are encouraged to review the final version of the Guidance on Charging and Penalty Determinations in Settlement of Administrative Enforcement Cases.

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COMM_a28. G.R. Tuttle III: “Changes to CBP’s Entry Reconciliation Program”

* Author: George R. Tuttle III, Esq., Law Offices of George R. Tuttle, george.tuttle.iii@tuttlelaw.com, 415-986-8780.

Come October 1, 2016, CBP’s entry reconciliation program is scheduled to transition to the Automated Commercial Environment (ACE) from the Automated Commercial System (ACS), and with it, there will be an important change to the program.
CBP will no longer be applying blanket flags to entry summaries. Under the current process, when an importer applies for participation in the reconciliation program, you must indicate on the application whether you would like to blanket flag or use the entry-by-entry method. When an importer blanket flags, all entry summaries that are transmitted to CBP are automatically flagged for whichever issue(s) the importer indicated at the time of application. According to CBP’s Office of Trade, Trade Processing Branch, beginning October 1, 2016, CBP will no longer automatically apply those flags to entry summaries. Rather, the importer will have to arrange blanket flagging with their broker. Additionally, if the importer is using multiple brokers, the importer will have to contact each one to ensure that they are blanket flagging.
CBP’s reconciliation program is the primary means by which importers may file post entry summary changes in areas such as valuation, 9802, and Free Trade Agreement claims. Under the program, an importer/broker places a “flag” on the entry summary at the time it is filed and makes payment of estimated duties, taxes, and fees. The importer then has up to 21 months to file a reconciled entry summary (12 months for certain FTA claims). Blanket flagging covered all entries for a given importer, and under ACS, was performed by CBP at the request of the importer. Once the type 09 reconciliation entry is transitioned to ACE, importers will have to implement blanket flagging directly with their respective fliers/brokers.
For additional information on the ACS to ACE reconciliation transition, interested parties should listen to CBP’s upcoming Reconciliation Business Webinar, scheduled for 12:30 p.m. EDT, on Friday, August 19th. If you have not already registered, please go here.
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COMM_a59. R. Thomsen, A. Paytas & M.M. Shomali: “ZTE Sanctions Update – 18 Aug 2016”

(Source: Thomsen & Burke, LLP, Export Controls and Economic Sanctions Update)

* Authors: Roszel Thomsen, Esq., Roz@t-b.com; Antoinette Paytas, Esq., Toni@t-b.com; and Maher M. Shomali, Esq., maher@t-b.com. All of Thomsen & Burke, LLP.
Pre-Publication Notice
The Department of Commerce’s Bureau of Industry and Security (BIS) plans to publish a final rule tomorrow that will extend the temporary general license authorizing exports to ZTE Corp and ZTE Kangxun for an additional two months. A copy of the pre-publication notice can be found at the Federal Register’s pre-publication page.

The net effect is that, until November 28, 2016, the export license requirements and policies that had been in place prior to March 8, 2016 (when BIS added the four ZTE companies to the Entity List) temporarily will be reinstated (but only with respect to ZTE Corporation and ZTE Kangxun, and not with respect to ZTE Parsian or Beijing 8 Star International).

Companies exporting to ZTE Corp, ZTE Kangxun and other ZTE subsidiaries may wish to consider obtaining written acknowledgements from their customers confirming that the items exported will not be re-exported or transferred in-country to ZTE Parsian or Beijing 8 Star International without separate authorization from BIS.
Companies exporting to ZTE entities may also wish to consider preparing applications for export licenses during the next sixty days. Currently, the discussions between ZTE and the U.S. Government appear to be moving in a favorable direction. However, in light of the ongoing criminal and civil investigations into ZTE’s activities, there is a substantial risk of further administrative action, including possible re-imposition of the suspended sanctions and, perhaps, additional sanctions. We think it is more likely than not that there will be some form of penalty assessed against ZTE, when it reaches a global settlement with the U.S. Government.

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COMM_a310. Gary Stanley’s ECR Tip of the Day
(Source: Defense and Export-Import Update; available by subscription from
* Author: Gary Stanley, Esq., Global Legal Services, PC, (202) 352-3059,
To ensure compliance with the EAR, one must determine whether or where an item subject to the EAR is controlled on the EAR’s Commerce Control List (CCL) before exporting or reexporting it. Such determinations are among the first steps in determining whether a license is required from BIS to export or reexport the item. With few exceptions, military items that were formerly subject to the ITAR will be within the scope of one of the CCL’s corresponding “600 series” ECCNs. For example, military aircraft parts and components that were once within the scope of USML VIII(h) but that are no longer within the scope of that category or any other USML category are generally now within the scope of ECCN 9A610.x. With few exceptions, satellite-related items no longer subject to the ITAR will be within the scope of the 9×515 or 9×004 ECCNs. One may make classification determinations or decide to submit a license application to BIS without needing to submit a classification request to BIS first. If there is doubt about where or whether the item falls within the scope of one of the EAR’s ECCNs, one may seek a formal classification determination (CCATS) from BIS under established procedures.
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COMM_a411. R.C. Burns: “This Post About Kim Kardashian Will Leave You Utterly Speechless”

Export Law Blog
. Reprinted by permission.)
* Author: R. Clifton Burns, Esq., Bryan Cave LLP, Wash DC, 202-624-3949,
According to this article, the Securities and Exchange Commission is sending out inquiries to certain publicly traded technology companies to ask them whether they are involved in any illegal exports to Syria. Among the subjects of concern by the SEC is a company named Glu Mobile, the perpetrator of a mobile phone game called, and I’m not kidding here, “Kim Kardashian: Hollywood.” This game allows you to “create your own star and customize your look with hundreds of style options … [and] join Kim Kardashian on a red carpet adventure.” Apparently, civilization as we know it will crumble into dust if people in Syria can play this game on their phones. (Frankly, we’d probably be better off if this game could ONLY be played in Syria, but that’s another issue.)
Glu pointed out to the geniuses at the SEC, who apparently can’t figure out how mobile phones work, that mobile games are sold through the iTunes, Amazon and Android stores and that these stores don’t permit sales to Syria. One can only imagine that the folks at the SEC must have been under the impression that mobile games were distributed on floppy disks sent through the mails.

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TE_a112. ECTI Presents United States Export Control (EAR/OFAC/ITAR) Seminar Series in Huntsville AL, 17-20 Oct
(Source: Jill Kincaid;
* What: United States Export Control (EAR/OFAC/ITAR) Seminar Series in Huntsville, AL
* When: EAR/OFAC Seminar: Oct 17-18, 2016; ITAR Seminar:  Oct 19-20, 2016
* Where: Huntsville, AL, Westin Huntsville Hotel; 6800 Governors West, NW
* Sponsor: Export Compliance Training Institute (ECTI)
* ECTI Speaker Panel:  Scott Gearity & John Black
* Register: Here, or Jessica Lemon, 540-433-3977, jessica@learnexportcompliance.com.
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(Source: Editor)

“Goodwill is the only asset that competition cannot undersell or destroy.”

  – Marshall Field (1834-1906, was an American entrepreneur and the founder of Marshall Field and Company, the Chicago-based department stores.)


“We need a type of patriotism that recognizes the virtues of those who are opposed to us.”

  – Francis John McConnell (1871-1953, was an American social reformer and a bishop in the Methodist Episcopal Church.)
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EN_a214. 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.  Changes to applicable regulations are listed below.
: 27 CFR Part 447-Importation of Arms, Ammunition, and Implements of War
  – Last Amendment: 15 Jan 2016: 81 FR 2657-2723: Machineguns, Destructive Devices and Certain Other Firearms; Background Checks for Responsible Persons of a Trust or Legal Entity With Respect To Making or Transferring a Firearm  
: 19 CFR, Ch. 1, Pts. 0-199
  – Last Amendment: 22 Mar 2015: 81 FR 15159: Customs and Border Protection’s Bond Program; Correction 

  – 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 canceled Supp. 1 to the NISPOM  (Summary here.)

  – Last Amendment: 17 Aug 2016: 81 FR 54721-54732: Revisions to the Export Administration Regulations (EAR): Harmonization of the Destination Control Statements 

: 31 CFR, Parts 500-599, Embargoes, Sanctions, Executive Orders
  – Last Amendment: 18 May 2016: 81 FR 31169-31171: Burmese Sanctions Regulations 
: 15 CFR Part 30
  – Last Amendment: 15 May 2015; 80 FR 27853-27854: Foreign Trade Regulations (FTR): Reinstatement of Exemptions Related to Temporary Exports, Carnets, and Shipments Under a Temporary Import Bond 
  – HTS codes that are not valid for AES are available
  – The latest edition (9 May 2016) of Bartlett’s Annotated FTR (“BAFTR”), by James E. Bartlett III, is available for downloading in Word format. The BAFTR contains all FTR amendments, FTR Letters and Notices, a large Index, and footnotes containing case annotations, practice tips, and Census/AES guidance.  Subscribers receive revised copies every time the FTR is amended.  The BAFTR is available by annual subscription from the Full Circle Compliance website.  BITAR subscribers are entitled to a 25% discount on subscriptions to the BAFTR, please contact us to receive your discount code. 
, 1 Jul 2016: 19 USC 1202 Annex.  (“HTS” and “HTSA” are often seen as abbreviations for the Harmonized Tariff Schedule of the United States Annotated, shortened versions of “HTSUSA”.)
  – Last Amendment: 12 Aug 2016; Harmonized System Update 1611, containing 2,707 ABI records and 743 harmonized tariff records.
  – HTS codes for AES are available
  – HTS codes that are not valid for AES are available

22 C.F.R. Ch. I, Subch. M, Pts. 120-130 (Caution — The ITAR as posted on GPO’s eCFR website and linked on the DDTC often takes several weeks to update the latest amendments.)

  – Latest Amendment: 17 Aug 2016:
81 FR 54732-54737: Amendment to the International Traffic in Arms Regulations: Procedures for Obtaining State Department Authorization To Export Items Subject to the Export Administration Regulations; Revision to the Destination Control Statement; and Other Changes 
  – The only available fully updated copy (latest edition 17 Aug 2016) of the ITAR is contained in Bartlett’s Annotated ITAR (“BITAR”), by James E. Bartlett III.  The BITAR contains all ITAR amendments to date, plus a large Index, and over 700 footnotes containing 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.  (If you are a subscriber, but have not received your 17 August revised BITAR, please send an email to JEBartlett@JEBartlett.com.)  The BITAR is THE essential tool of the ITAR professional.  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.

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* The Ex/Im Daily Update is a publication of FCC Advisory B.V., edited by James E. Bartlett III and Alexander Bosch, and emailed every business day to approximately 7,500 subscribers to inform 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, DOJ/ATF, DoD/DSS, DoD/DTSA, 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.

* INTERNET ACCESS AND BACK ISSUES: The National Defense Industrial Association (“NDIA”) posts the Daily Update on line, and maintains back issues since August, 2009 here.

* 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. Any further use of contributors’ material, however, must comply with applicable copyright laws.

* 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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