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16-1007 Friday “The Daily Bugle”

16-1007 Friday “Daily Bugle”

Friday, 7 October 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 here for free subscription. Contact us for advertising inquiries and rates. [Editor’s Note: The Daily Bugle will not be published on Monday, 10 October 2016, a U.S. national holiday.] 

  1. Commerce/BIS: Emerging Technology and Research Advisory Committee to Meet on 27 Oct in Wash DC 
  1. Ex/Im Items Scheduled for Publication in Future Federal Register Editions 
  2. Commerce/BIS: (No new postings.) 
  3. DoD/DSS Posts Reminder on Identifying Government Customer on Investigations for Personnel Clearances 
  4. Justice: “Brooklyn Resident and Two Russian Nationals Arrested in Connection with Scheme to Illegally Export Controlled Technology to Russia” 
  5. State/DDTC: (No new postings.) 
  1. ST&R Trade Report: “Dates and Deadlines: MTB, Export Controls, International Payments, Duty Savings”
  1. Friday List of Approaching Events 
  1. Bartlett’s Unfamiliar Quotations 
  2. Are Your Copies of Regulations Up to Date? Latest Changes: ATF (15 Jan 2016), Customs (30 Sep 2016), DOD/NISPOM (18 May 2016), EAR (7 Sep 2016), FACR/OFAC (18 May 2016), FTR (15 May 2015), HTSUS (30 Aug 2016), ITAR (29 Sep 2016)

EXIMEX/IM ITEMS FROM TODAY’S FEDERAL REGISTER

EXIM_a1

1. Commerce/BIS: Emerging Technology and Research Advisory Committee to Meet on 27 Oct in Wash DC

(Source: Federal Register) [Excerpts.]
 
81 FR 69782: Emerging Technology and Research Advisory Committee; Notice of Open Meeting
   The Emerging Technology and Research Advisory Committee (ETRAC) will meet on October 27, 2016, 8:30 a.m., Room 3884, at the Herbert C. Hoover Building, 14th Street between Pennsylvania and Constitution Avenues NW., Washington, DC. The Committee advises the Office of the Assistant Secretary for Export Administration on emerging technology and research activities, including those related to deemed exports.
   The open sessions will be accessible via teleconference to 25 participants on a first come, first serve basis. To join the conference, submit inquiries to Ms. Yvette Springer at Yvette.Springer@bis.doc.gov no later than, October 20, 2016.
   A limited number of seats will be available for the public session. Reservations are not accepted. To the extent that time permits, members of the public may present oral statements to the Committee. The public may submit written statements at any time before or after the meeting. However, to facilitate the distribution of public presentation materials to the Committee members, the Committee suggests that presenters forward the public presentation materials prior to the meeting to Ms. Springer via email.
   For more information, call Yvette Springer at (202) 482-2813.
 
   Dated: October 4, 2016.
Yvette Springer, Committee Liaison Officer.

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OGSOTHER GOVERNMENT SOURCES

OGS_a12. Ex/Im Items Scheduled for Publication in Future Federal Register Editions
(Source: Federal Register)

* Defense Acquisition Regulations System; PROPOSED RULES; Defense Federal Acquisition Regulation Supplements: Procurement of Commercial Items; DFARS Case 2016-D006; Extension of Comment Period [Publication Date: 11 October 2016.]

* Treasury; Foreign Assets Control Office; NOTICES; Blocking or Unblocking of Persons and Properties [Publication Date: 11 October 2016.]

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The Defense Security Service (DSS) requests assistance in assuring that all of your requests for personnel security investigations (PSIs) in the Joint Personnel Adjudication System (JPAS) identify the government customer in the contract number field when requesting PCLs. Accurate data entry of the source of the investigative requirement for a clearance is essential to effectively manage and validate industry’s PSI submissions with the government customers. We have provided guidance here for your ease of reference and implementation.
* * * * * * * * * * * * * * * * * * * * 

OGS_a45. Justice: “Brooklyn Resident and Two Russian Nationals Arrested in Connection with Scheme to Illegally Export Controlled Technology to Russia”

(Source: Justice) [Excerpts.]
 
Earlier today, Alexey Barysheff of Brooklyn, New York, a naturalized citizen of the United States, was arrested on federal charges of illegally exporting controlled technology from the United States to end-users in Russia. Simultaneously, two Russian nationals, Dmitrii Aleksandrovich Karpenko and Alexey Krutilin, were arrested in Denver, Colorado, on charges of conspiring with Barysheff and others in the scheme. Federal agents also executed search warrants at two Brooklyn locations that were allegedly used as front companies in Barysheff’s illegal scheme.
 
Barysheff is scheduled to make his initial appearance today at 2:00 p.m EDT at the United States Courthouse, 225 Cadman Plaza East, Brooklyn, New York, before Chief United States Magistrate Judge Roanne L. Mann. Karpenko and Krutilin are scheduled to make their initial appearances today at 2:00 p.m. MDT at the United States Courthouse in Denver, Colorado, where the government will seek their removal in custody to the Eastern District of New York. …
 
The complaints allege that Barysheff, Karpenko, Krutilin, and others were involved in a conspiracy to obtain cutting-edge microelectronics from manufacturers and suppliers located within the United States and to export those high-tech products to Russia, while evading the government licensing system set up to control such exports. The Department of Commerce, pursuant to authority granted by the President of the United States, has placed restrictions on the export and re-export of items that it has determined could make a significant contribution to the military potential and weapons proliferation of other nations and that could be detrimental to the foreign policy and national security of the United States. The microelectronics shipped to Russia included, among other products, digital-to-analog converters and integrated circuits, which are frequently used in a wide range of military systems, including radar and surveillance systems, missile guidance systems and satellites. These electronic devices required a license from the Department of Commerce to be exported to Russia and have been restricted for anti-terrorism and national security reasons.
 
As further detailed in the complaints, in 2015 Barysheff registered the Brooklyn, New York-based companies BKLN Spectra, Inc. (Spectra) and UIP Techno Corp. (UIP Techno). Since that time, the defendants and others have used those entities as U.S.-based front companies to purchase, attempt to purchase, and illegally export controlled technology. To induce U.S.-based manufacturers and suppliers to sell them high-tech, export-controlled microelectronics and to evade applicable controls, the defendants and their co-conspirators purported to be employees and representatives of Spectra and UIP Techno and provided false end-user information in connection with the purchase of the items, concealed the fact that they were exporters and falsely classified the goods they exported on records submitted to the Department of Commerce. To conceal the true destination of the controlled microelectronics from the U.S. suppliers, the defendants and their co-conspirators shipped the items first to Finland and subsequently to Russia. …
 
If convicted of the charges, the defendants face up to 25 years in prison and a $1 million fine.
 
A criminal complaint is merely an allegation, and the defendant is presumed innocent unless and until proven guilty beyond a reasonable doubt in a court of law. The maximum statutory sentence is prescribed by Congress and is provided here for informational purposes. If convicted of any offense, the sentencing of the defendant will be determined by the court based on the advisory Sentencing Guidelines and other statutory factors. …

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OGS_a56. State/DDTC: (No new postings.)

(Source: State/DDTC)

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NWSNEWS

NWS_a17
. ST&R Trade Report: “Dates and Deadlines: MTB, Export Controls, International Payments, Duty Savings”

 
Following are highlights of regulatory effective dates and deadlines and federal agency meetings coming up in the next week:
 
  – Oct 11: deadline for comments on USDA proposal to allow imports of orchids in growing media from Korea
  – Oct 11: deadline for comments to BIS on licensing of agricultural shipments to Cuba
  – Oct 11: deadline for comments to BIS on foreign policy-based export controls
  – Oct 13: deadline for comments to ITC on proposed modifications to Morocco FTA rules of origin

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TrainingEX/IM TRAINING EVENTS & CONFERENCES

TE_a28
. Friday List of Approaching Events

(Sources: Event sponsors.) 
 
Published every Friday or last publication day of the week. Send events to
apbosch@fullcirclecompliance.eu
, composed in the below format:

* DATE: PLACE; “TITLE;” SPONSOR; WEBLINK; CONTACT (email and phone number)
 
Continuously Available Training:
* Executive Masters: “
International Trade Compliance
;” University of Liverpool;
exed@liverpool.ac.uk
;
+44 (0) 20 768 24614
* E-Seminars: “
US Export Controls” / “Defense Trade Controls
;” Export Compliance Training Institute;
danielle@learnexportcompliance.com 
* On-Line: “
Simplified Network Application Process Redesign (SNAP-R)
;” Commerce/BIS; 202-482-2227
* E-Seminars: “
Webinars On-Demand Library
;” Sandler, Travis & Rosenberg, P.A.
 
Training by Date:

* Oct 9-11: Grapevine TX: “DFW Fall Conference;” ICPA

* Oct 10: Webinar; “Exports 101;” Foreign Trade Association

* Oct 11: Webinar; “NISP Administration & Policy Analysis (NAPA) Industry Insider Threat Workshop;” Dept. of Defense/Defense Security Service

* Oct 12: Laredo TX; “
AES Compliance Seminar
;” Dept. of Commerce/Census;
shawn@m-palm.com

* Oct 12: Farmington Hills MI; “Harmonized Tariff Schedule – Classifications;”
Sandler, Travis & Rosenberg, P.A.; bwhite@sttas.com

* Oct 12-13: Miramar FL; “7th Maritime/Logistics Seminar;” ABS-Consulting; albert@abs-consulting.net; 954-218-5285.

* Oct 12-13: New Orleans; “
Critical Compliance: Jurisdiction/Classification, Auditing & Recordkeeping
;” Export Compliance Solutions (ECS);
spalmer@exportcompliancesolutions.com
; 866-238-4018

* Oct 12: Webinar; “
International Payment Options – the Basics;”
Sandler, Travis & Rosenberg, P.A.;
webinarorganizers@strtrade.com

* Oct 13: Farmington Hills MI; “NAFTA Qualification, Compliance and Recordkeeping (Non-Automotive);”
Sandler, Travis & Rosenberg, P.A.; imeyer@sttas.com

* Oct 13-14: London; “
WorldECR Export Controls and Sanctions Forum 2016
;” WorldECR;
Mark.Cusick@WorldECR.com 

* Oct 13: Webinar; “Creative Uses of Standby Letters of Credit and Other Security Tools for Exporters” Massachusetts Export Center

* Oct 17-20: Huntsville AL; “

EAR/ITAR/OFAC Compliance
;” ECTI;
jessica@learnexportcompliance.com
; 540-433-3977

* Oct 18-19: New Orleans; “
ITAR/EAR Critical Compliance Jurisdiction/Classification Auditing/Recordkeeping
” Export Compliance Solutions;
spalmer@exportcompliancesolutions.com
; 866-238-4018

* Oct 18-19: San Francisco; “9th West Coast FCPA Enforcement & Compliance Conference;” American Conference Institute

* Oct 18-19: Washington, DC; “International Technology Transfers, Cloud Computing, and Deemed Exports;” American Conference Institute; americanconference.com/techtransfers OR 1-888-224-2480

* Oct 19: London; “Control List Classification – Dual Use;” UK/BIS Export Control Organisation; denise.carter@bis.gsi.gov.uk 

* Oct 19-20: Oslo Norway; “US Defense Contracting and DFARS Compliance;” C5

* Oct 20: London; “Making Better License Applications;”
UK/BIS Export Control Organisation;
denise.carter@bis.gsi.gov.uk 

* Oct 20: Lowell MA; “Essentials of Harmonized Tariff Classification and Free Trade Agreement Compliance” Massachusetts Export Center

* Oct 20: Webinar; “Conflicts Between EU and US Export Rules;” ECTI; danielle@learnexportcompliance.com; 540-433-3977

* Oct 24-25: Arlington VA; “2016 Fall Conference;” Society for International Affairs; admin@siaed.org 

* Oct 25: Troy MI; “Incoterms;” East Michigan District Export Council
* Oct 25: Webinar; “NISP Administration & Policy Analysis (NAPA) Industry Insider Threat Workshop;” Dept. of Defense/Defense Security Service

* Oct 31-Nov 2: Wash DC; “
Commerce/BIS Update 2016 Conference on Export Controls
;” U.S. Dept. of Commerce/Bureau of Industry and Security;
UpdateConference@bis.doc.gov
; 202-482-6031

* Oct 31-Nov 3: Wash DC; “US Export Controls Seminar;” ECTI; jessica@learnexportcompliance.com; 540-433-3977

* Nov 1: Webinar; “NISP Administration & Policy Analysis (NAPA) Industry Insider Threat Workshop;” Dept. of Defense/Defense Security Service

* Nov 2: Chicago; “AES Compliance Seminar;” Dept. of Commerce/ Census & M-Palm; shawn@m-palm.com 

* Nov 3-4: Amsterdam; International Trade & Compliance Conference; Baker McKenzie; claudia.wehmeijer@bakermckenzie.com; + 31 20 551 7481

* Nov 6-7: Singapore; “
Singapore Conference
;” International Compliance Professionals Association;
wizard@icpainc.org 

* Nov 8: London; “Control List Classification – Military;”
UK/BIS Export Control Organisation;
denise.carter@bis.gsi.gov.uk 

* Nov 8: Webinar; “NISP Administration & Policy Analysis (NAPA) Industry Insider Threat Workshop;” Dept. of Defense/Defense Security Service
* Nov 9: Cerritos CA; “CTPAT Internal Auditor Training Program;” Foreign Trade Association

* Nov 9: London; “Making Better License Applications;”
UK/BIS Export Control Organisation;
denise.carter@bis.gsi.gov.uk 


* Nov 9: Sturbridge MA; “Export School Fast Track Certificate Program” Massachusetts Export Center

* Nov 10-11: Shanghai; “
ICPA China Conference
;” International Compliance Professionals Association;
wizard@icpainc.org 

* Nov 13-15: Miami FL; “
Conference of the Americas
;” Florida Customs Brokers & Freight Forwarders; 
info@fcbfconference.com
; 305-499-9490

* Nov 14: Long Beach CA; “44th Annual Golf Tournament;” Foreign Trade Association

* Nov 14-16: London; “Expert Industry and Regulatory Advice for Solutions to Export Controls’ Global Compliance Risks;” Informa Maritime

* Nov 14-17: Phoenix AZ; “
EAR/ITAR/OFAC Compliance
;” ECTI;
jessica@learnexportcompliance.com
; 540-433-3977

* Nov 15-16: Santa Clara CA; A Year-End Review of Import/Export Developments; Baker McKenzie; Brendan.Gilmartin@bakermckenzie.com; 415-591-3246

* Nov 15: Westborough MA; “Essentials of Export Logistics & Regulatory Compliance” Massachusetts Export Center

* Nov 15: Webinar; “NISP Administration & Policy Analysis (NAPA) Industry Insider Threat Workshop;” Dept. of Defense/Defense Security Service

* Nov 16: Manchester UK; “Intermediate Seminar;”
UK/BIS Export Control Organisation;
denise.carter@bis.gsi.gov.uk 

* Nov 16: Webinar; “
Classification: Advanced Classification, Part 1;”
Sandler, Travis & Rosenberg, P.A.;
webinarorganizers@strtrade.com

* Nov 17: Manchester UK; “Beginners Workshop;”
UK/BIS Export Control Organisation;
denise.carter@bis.gsi.gov.uk 

* Nov 17: Manchester UK; “Making Better License Applications;”
UK/BIS Export Control Organisation;
denise.carter@bis.gsi.gov.uk 
* Nov 17: Manchester UK; “Control List Classification Combined Dual Use and Military;”
UK/BIS Export Control Organisation;
denise.carter@bis.gsi.gov.uk 

* Nov 24: London; “
Cyber Export Controls 2016
;”
UK/BIS Export Control Organisation;
denise.carter@bis.gsi.gov.uk 

* Nov 30: London; “Control List Classification – Dual Use;”

UK/BIS Export Control Organisation;
denise.carter@bis.gsi.gov.uk

* Nov 29-Dec 2: Washington, D.C.; “
33rd International Conference on the Foreign Corrupt Practices Act
“; American Conference Institute

* Dec 1-2: Arlington VA; “
2016 East Coast Trade Symposium
;” Dept. of Homeland Security/U.S. Customs and Border Protection

* Dec 1: London; “Making Better License Applications;”
UK/BIS Export Control Organisation;
denise.carter@bis.gsi.gov.uk 

* Dec 2: Wash DC; “
SIA Holiday Party
;” Society for International Affairs

* Dec 5-8: Miami FL; “
EAR/ITAR/OFAC Compliance Seminar Series
;” ECTI;
jessica@learnexportcompliance.com
; 540-433-3977

* Dec 7: Boston; “
AES Compliance Seminar
;”
Dept. of Commerce/Census
& M-Palm;
shawn@m-palm.com  

* Dec 7: London; “Intermediate Seminar;”
UK/BIS Export Control Organisation;
denise.carter@bis.gsi.gov.uk 
* Dec 8: London; “Beginners Workshop;”
UK/BIS Export Control Organisation;
denise.carter@bis.gsi.gov.uk 
* Dec 8: London; “Making Better License Applications;”
UK/BIS Export Control Organisation;
denise.carter@bis.gsi.gov.uk 
* Dec 9: Boston MA; “Export Expo” Massachusetts Export Center

* Dec 14: Wash DC; “In-House Industry Seminar;” Dept. of State/DDTC; DDTCInHouseSeminars@state.gov

* Dec 14: Webinar; “
Classification: Advanced Classification, Part 2;”
Sandler, Travis & Rosenberg, P.A.;
webinarorganizers@strtrade.com

* Dec 16: Webinar; “Navigating the Intersection of HR and Trade Compliance” Massachusetts Export Center

* Jan 23-26: San Diego, CA; “
EAR/ITAR/OFAC Compliance Seminar Series
;” ECTI;
jessica@learnexportcompliance.com
; 540-433-3977

* Mar 13-15: Newport Beach CA; “2017 Winter Back to Basics Conference;” Society for International Affairs

* Mar 20-23: Singapore; “
United States Export Control (EAR/OFAC/ITAR) (for Asia-Pacific and other non-US Companies)
;” ECTI;
jessica@learnexportcompliance.com
; 540-433-3977

* Jun 12-15: San Francisco; “
United States Export Control (EAR/OFAC/ITAR) Seminar
;” ECTI;
jessica@learnexportcompliance.com
; 540-433-3977

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ENEDITOR’S NOTES

EN_a19. Bartlett’s Unfamiliar Quotations

(Source: Editor)
 
Notable birthdays:
 
* Niels Bohr (Niels Henrik David Bohr, 7 Oct 1885 – 18 Nov 1962, was a Danish physicist who made foundational contributions to understanding atomic structure and quantum theory, for which he received the Nobel Prize in Physics in 1922. Bohr was also a philosopher and a promoter of scientific research.)
  – “An expert is a man who has made all the mistakes which can be made, in a narrow field.”
 
Friday funnies:
  

The Harvard “Ig Nobels” awards ceremony for quirky scientific achievement has recognized Andreas Sprenger, of the University of Luebeck in Germany, who found that if you have an itch on one arm, you can relieve it by looking in a mirror and scratching the opposite arm. Sprenger discovered that if you have a skin condition with an intolerable itch, you can scratch the other arm to relieve it without scratching the affected arm raw.

  — Laura Lyons, Fremont, CA

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EN_a210. 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.
 
*
ATF ARMS IMPORT REGULATIONS
: 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
 
*
CUSTOMS REGULATIONS
: 19 CFR, Ch. 1, Pts. 0-199
  – Last Amendment:
30 Sep 2016: 81 FR 67140-67144: Notice of Arrival for Importations of Pesticides and Pesticidal Devices

* DOD NATIONAL INDUSTRIAL SECURITY PROGRAM OPERATING MANUAL (NISPOM): DoD 5220.22-M
  – 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.)

* EXPORT ADMINISTRATION REGULATIONS (EAR): 15 CFR Subtit. B, Ch. VII, Pts. 730-774 
  – Last Amendment: 20 Sep 2016: 81 FR 64693-64698: Revisions to the Entity List; and 81 FR 64655-64692: Wassenaar Arrangement 2015 Plenary Agreements Implementation, Removal of Foreign National Review Requirements, and Information Security Updates   

  
*
FOREIGN ASSETS CONTROL REGULATIONS (OFAC FACR)
: 31 CFR, Parts 500-599, Embargoes, Sanctions, Executive Orders
  – Last Amendment: 18 May 2016: 81 FR 31169-31171: Burmese Sanctions Regulations  
 
*
FOREIGN TRADE REGULATIONS (FTR)
: 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
here.
  – The latest edition (9 Mar 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. 
 
*
HARMONIZED TARIFF SCHEDULE OF THE UNITED STATES (HTS, HTSA or HTSUSA)
, 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: 30 Aug 2016; Harmonized System Update (HSU) 1612, containing 4,692 ABI records and 935 harmonized tariff records. 
  – HTS codes for AES are available
here
.
  – HTS codes that are not valid for AES are available
here.
 
*
INTERNATIONAL TRAFFIC IN ARMS REGULATIONS (ITAR)
: 22 C.F.R. Ch. I, Subch. M, Pts. 120-130
  – Latest Amendment: 29 Sep 2016: 81 FR 66804-66807: RIN 1400-AD95; Amendment to the International Traffic in Arms Regulations: Tunisia, Eritrea, Somalia, the Democratic Republic of the Congo, Liberia, Cote d’Ivoire, Sri Lanka, Vietnam, and Other Changes
  – The only available fully updated copy (latest edition 29 Sep 2016) of the ITAR with all amendments 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.  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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EPEDITORIAL POLICY

* 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 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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