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16-1020 Thursday “The Daily Bugle”

16-1020 Thursday “Daily Bugle”

Thursday, 20 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 
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  1. Commerce/BIS: Materials Technical Advisory Committee to Meet on 3 Nov in Wash DC 
  2. Commerce/BIS: Transportation and Related Equipment Technical Advisory Committee to Meet on Nov 16 in Wash DC 
  1. Ex/Im Items Scheduled for Publication in Future Federal Register Editions
  2. Commerce/BIS: (No new postings.) 
  3. State/DDTC: (No new postings.) 
  1. ST&R Trade Report: “$220,000 Penalty for Misleading “Made in USA” Claims”
  1. M.P. Gurdak, S.T. Boyce & C.O. Dorr: “Beyond Rum and Cigars: Further Easing of Sanctions Paves Way for Increased Business Opportunities in Cuba”  
  2. Gary Stanley’s ECR Tip of the Day 
  1. Bartlett’s Unfamiliar Quotations 
  2. Are Your Copies of Regulations Up to Date? Latest Changes: ATF (15 Jan 2016), Customs (26 Aug 2016), DOD/NISPOM (18 May 2016), EAR (17 Oct 2016), FACR/OFAC (17 Oct 2016), FTR (15 May 2015), HTSUS (30 Aug 2016), ITAR (12 Oct 2016) 

EXIMEX/IM ITEMS FROM TODAY’S FEDERAL REGISTER

EXIM_a1

1. Commerce/BIS: Materials Technical Advisory Committee to Meet on 3 Nov in Wash DC

(Source: Federal Register) [Excerpts.]
 
81 FR 72566-72567: Materials Technical Advisory Committee; Notice of Partially Closed Meeting
   The Materials Technical Advisory Committee will meet on November 3, 2016, 10:00 a.m., Herbert C. Hoover Building, Room 3884, 14th Street between Constitution & Pennsylvania Avenues NW., Washington, DC. The Committee advises the Office of the Assistant Secretary for Export Administration with respect to technical questions that affect the level of export controls applicable to materials and related technology. …
   The open session will be accessible via teleconference to 20 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 27, 2016.
   A limited number of seats will be available during the public session of the meeting. Reservations are not accepted. To the extent time permits, members of the public may present oral statements to the Committee. Written statements may be submitted at any time before or after the meeting. However, to facilitate distribution of public presentation materials to Committee members, the materials should be forwarded prior to the meeting to Ms. Springer via email. …
   For more information, call Yvette Springer at (202) 482-2813.
 
   Dated: October 17, 2016.
Yvette Springer, Committee Liaison Officer.

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EXIM_a2

2. Commerce/BIS: Transportation and Related Equipment Technical Advisory Committee to Meet on Nov 16 in Wash DC

(Source: Federal Register) [Excerpts.]
 
81 FR 72566: Transportation and Related Equipment Technical Advisory Committee; Notice of Partially Closed Meeting
   The Transportation and Related Equipment Technical Advisory Committee will meet on November 16, 2016, 9:30 a.m., in the Herbert C. Hoover Building, Room 3884, 14th Street between Constitution & Pennsylvania Avenues NW., Washington, DC. The Committee advises the Office of the Assistant Secretary for Export Administration with respect to technical questions that affect the level of export controls applicable to transportation and related equipment or technology. …
   The open session will be accessible via teleconference to 20 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 November 9, 2016.
   A limited number of seats will be available during the public session of the meeting. Reservations are not accepted. To the extent 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 distribution of public presentation materials to 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 17, 2016.
Yvette Springer, Committee Liaison Officer.

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OGS
OTHER GOVERNMENT SOURCES

OGS_a13. Ex/Im Items Scheduled for Publication in Future Federal Register Editions
(Source: Federal Register)

* Defense Acquisition Regulations System; RULES; Defense Federal Acquisition Regulation Supplements: Network Penetration Reporting and Contracting for Cloud Services [Publication Date: 21 October 2016.]

* U.S. Customs and Border Protection; RULES; Investigation of Claims of Evasion of Antidumping and Countervailing Duties [Publication Date: 21 October 2016.]

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OGS_a24. Commerce/BIS: (No new postings.)

(Source: Commerce/BIS)
* * * * * * * * * * * * * * * * * * * *

OGS_a35. State/DDTC: (No new postings.)

(Source: State/DDTC)
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NWSNEWS

NWS_a16
. ST&R Trade Report: “$220,000 Penalty for Misleading “Made in USA” Claims”

 

The Federal Trade Commission announced Oct. 19 that a specialty chemical company
[
Chemence, Inc.] has agreed to pay $220,000 to resolve charges that it deceived consumers by making “Made in USA” or “Proudly Made in USA” claims for certain glue products. According to an FTC press release, these claims implied that the products were all, or virtually all, made in the U.S. when approximately 55 percent of the costs of the chemical inputs were attributable to imported chemicals that are essential to the glues’ function. The FTC also alleged that the company assisted others in deceiving consumers by distributing its “Made in USA” marketing materials to private-label sellers and third-party websites and storefronts.

 
The FTC states that the stipulated final order prohibits the company from making unqualified “Made in USA” claims for any product unless it can show that the product’s final assembly or processing, and all significant processing, takes place in the U.S. and that all or virtually all ingredients or components of the product are made and sourced in the U.S. The order permits the company to make qualified “Made in USA” claims as long as they include a clear and conspicuous disclosure about the extent to which the product contains foreign parts, ingredients, and/or processing. The company also is prohibited from providing others with the means to make deceptive “Made in USA” claims about its products.

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COMMCOMMENTARY

COMM_a17
. M.P. Gurdak, S.T. Boyce & C.O. Dorr: “Beyond Rum and Cigars: Further Easing of Sanctions Paves Way for Increased Business Opportunities in Cuba”

(Source: Jones Day)
 
* Authors: Michael Gurdak, Esq., mpgurdak@jonesday.com, 202-879-5470; Sean Boyce, Esq., sboyce@jonesday.com, +971-4-709-8416 (Dubai); and Chad O. Dorr, Esq., cdorr@jonesday.com, 202-879-3795. All of Jones Day.
 
On October 17, 2016, the U.S. government further eased the economic sanctions and trade embargo against Cuba to implement the administration’s policy of increasing engagement and commerce to benefit the Cuban people and American businesses. In coordinated revisions that reflect their overlapping jurisdiction over the U.S. embargo of Cuba, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) and the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) released revisions to the Cuban Assets Control Regulations, 31 C.F.R. Part 515 (“CACR”), and the Export Administration Regulations, 15 C.F.R. Parts 730-774 (“EAR”). The revised regulations are effective immediately.
 
While initial headlines have highlighted the relaxation of limitations on the importation of Cuban-origin rum and cigars, other aspects of this latest round of eased sanctions are much more significant for those planning to expand their business opportunities in Cuba.
 
This Commentary summarizes key provisions that will increase flexibility for trade with Cuba. These provisions will most directly benefit the following entities:
 
  – Pharmaceutical manufacturers and distributors;
  – Medical researchers;
  – Infrastructure development firms;
  – Direct-to-consumer retailers, including online retailers;
  – Manufacturers of “agricultural items”;
  – Air and maritime cargo operators; and
  – Civil aviation safety services providers.
 
In addition, all entities exploring future opportunities in Cuba can now lay contractual groundwork for future operations through contracts contingent on OFAC authorization or further relaxation of the sanctions.
 
Although these revisions provide U.S. companies with an increased array of opportunities in Cuba, the long-standing comprehensive U.S. trade embargo on Cuba remains in force. As a result, U.S. citizens and U.S. companies-as well as foreign-incorporated entities owned or controlled by such persons (collectively in CACR parlance, “persons subject to U.S. jurisdiction”)-must remain vigilant in their trade compliance. This could prove more challenging as compliance programs adapt to the expanded scope of authorized activities in and exports to Cuba.
 
Medical Research and Pharmaceuticals
 
The amended CACR-through a new general license at § 515.547-have opened significant opportunities in medical research and pharmaceuticals manufacturing in Cuba and with Cuban partners. First, persons subject to U.S. jurisdiction may now engage in joint medical research projects with Cuban nationals, including both commercial and non-commercial medical research. Second, persons subject to U.S. jurisdiction may also engage in all transactions incident to obtaining approval for Cuban-origin pharmaceuticals from the U.S. Food and Drug Administration (“FDA”). This authorization includes: discovery and development; pre-clinical research; clinical research; regulatory review, approval, licensing, and post-marketing activities; and the importation into the United States of Cuban-origin pharmaceuticals. Third, transactions incident to the marketing, sale, or other distribution of Cuban-origin pharmaceuticals in the United States are also authorized. In addition, accounts may be opened and maintained in Cuban financial institutions for use in conducting these activities.
 
Infrastructure Development
 
Framed as an expansion of the authority to provide humanitarian services in Cuba and to Cuban nationals, the amended CACR now offer substantial opportunities for persons subject to U.S. jurisdiction to provide a broad range of services associated with Cuban infrastructure development and maintenance. Specifically, pursuant to § 515.591, persons subject to U.S. jurisdiction may now provide services related to developing, repairing, maintaining, and enhancing Cuban infrastructure that directly benefit the Cuban people, consistent with the export or reexport licensing policies of the Department of Commerce. For the purposes of this authorization, infrastructure means hospitals, public housing, primary and secondary schools, and, more generally, those systems and assets used to provide the Cuban people with goods and services produced or provided by the public transportation, water management, waste management, non-nuclear electricity generation, and electrical distribution sectors. The authorization includes projects related to the environmental protection of U.S., Cuban, and international air quality, waters, and coastlines.
 
Direct-to-Consumer Exports and Reexports
 
OFAC and BIS have amended their regulations to expand existing authorizations to export and reexport certain items to Cuba. These changes are significant because the revisions provide more opportunities for Cuban citizens to access most American goods.
 
First, in another broad expansion, BIS has amended License Exception Support for the Cuban People (“SCP”) to authorize exports or reexports of any items subject to the EAR that are classified EAR99 or controlled only for antiterrorism purposes, provided that such items are sold directly to eligible individuals for their personal use, or the personal use of their immediate families. (Previously, the license exception applied to certain items for use by the private sector, and the export of items that would meet the needs of the Cuban people, including wholesale or retail distribution for domestic consumption, was subject to a case-by-case licensing policy). While certain Cuban government and Communist Party officials remain ineligible end-users under the expanded License Exception SCP, the revisions also narrow the categories of individuals subject to this exclusion. This new authorization will be particularly important for online retailers and other entities that directly market products to consumers.
 
Second, the amended general license at § 515.533(a) of the CACR removed the reference to 100 percent U.S.-origin items in the general license authorizing certain reexports of U.S.-origin goods from a third country to Cuba. OFAC intended this revision to minimize and clarify the circumstances under which an export or reexport authorized by BIS would require separate licensing by OFAC. Now, all transactions related to the export or reexport of goods authorized by BIS under the EAR are also authorized under the general license except transactions between a U.S.-owned or -controlled firm in a third country and Cuba for the exportation to Cuba of commodities produced in a country other than the United States or Cuba.
 
U.S. Financing of Agricultural Items
 
In amendments to § 515.533(a), OFAC has also taken steps to clarify the extent to which restrictions of payment terms apply to certain agricultural exports and reexports. The CACR have long required transactions involving “agricultural commodities” (as defined in the EAR) and “agricultural items” (related goods that fall outside that definition, such as pesticides and tractors) to be paid for in advance, in cash, or to be financed by a third-country financial institution. Although limitations on financing of “agricultural commodities” remain in place as required by the Trade Sanctions Reform and Export Enhancement Act of 2000, 22 U.S.C. § 7207(a), the revised CACR now clarify that transactions involving the export and reexport of “agricultural items” may be made under payment and financing terms that apply to other authorized exports and reexports. Banking institutions that are persons subject to U.S. jurisdiction are authorized to provide financing for exports and reexports of such “agricultural items,” including issuing, advising, negotiating, paying, or confirming letters of credit, accepting collateral backing such as letters of credit, and processing documentary collections.
 
Air and Maritime Cargo Operations
 
Separate from the easing of export and reexport restrictions, OFAC and BIS have taken steps to ease restrictions on international cargo shipments involving or transiting through Cuba.
 
First, foreign cargo vessels that call on a Cuban port for trade purposes are generally prohibited from entering U.S. ports to load or unload cargo for 180 days following the vessel’s departure from Cuba, subject to certain exceptions. The revised regulations add another exception such that foreign vessels are no longer subject to this restriction if their cargo contains only items from a third country that would be classified as EAR99 or controlled only for antiterrorism reasons (if they were subject to the EAR).
 
Second, the amended EAR also authorize cargo loaded on an aircraft to transit Cuba under License Exception Aircraft, Vessels, and Spacecraft (“AVS”) provided that cargo is not removed from the aircraft for use in Cuba, is not transferred to another aircraft or vessel, and leaves with the same aircraft when it departs. This revision authorizes temporary sojourn of air cargo in the same fashion as that previously authorized for maritime cargo.
 
Civil Aviation Safety-Related Services
 
The amended CACR, pursuant to the revised general license at § 515.572, now also offer expanded opportunities for commercial civil aviation companies and service providers. In an effort to promote safety of civil aviation and the safe operation of commercial aircraft, the revised CACR implement a new general license authorizing the provision of civil aviation safety-related services to Cuba and to Cuban nationals. Export or reexport of repair parts to Cuba, however, must be separately authorized by BIS or provisions of the EAR.
 
Contingent Contracts
 
Perhaps most significantly, companies contemplating expanding business into Cuba in the future will be able to benefit from the general license authorizing the negotiation of and entry into contingent contracts related to otherwise prohibited transactions. Prior to the revisions, the authorization to enter into only executory contracts was limited to the export or reexport of certain goods, provided the contract was contingent on compliance with Department of Commerce regulations. Under the new general license at § 515.534, persons subject to U.S. jurisdiction may enter into and engage in all transactions ordinarily incident to the negotiation and entry into contingent contracts for transactions that are prohibited by the CACR, provided that performance of the contract is made expressly contingent on prior authorization by OFAC and any other federal agency with licensing authority over the transaction (or when such authorization and licensing requirements have been removed).
 
The new ability to enter into contingent contracts will enable companies to lay the contractual foundations for future business-for example, to establish a relationship with a prospective distributor or to lease facilities to establish a physical presence in Cuba-and offers a substantial opportunity for U.S. businesses to plan proactively and prepare to enter the Cuban market.
 
Importation of Cuban-Origin Items
 
Finally, although the summaries above have focused on those provisions that likely will most benefit the expansion of business opportunities in Cuba, those travelling to Cuba to prepare for or engage in authorized activities also now have fewer restriction on importing Cuban-origin goods. OFAC has removed the limitation on the value of such items that may be imported from Cuba-previously $400 (with no more than $100 of tobacco or alcohol products). The limitation that the items be for personal use and imported as accompanied baggage continues to apply, subject to normal import duty and tax exemptions. Also, persons subject to U.S. jurisdiction may now import Cuban-origin items from third countries under the same conditions. Before the revisions, such goods purchased in third countries could be purchased and consumed, but not imported into the United States. Foreign persons travelling to the United States also benefit from the relaxation because they may now import any Cuban-origin items-including alcohol and tobacco products-as accompanied baggage, provided the goods are not in commercial quantities and are not imported for resale.
 
Continued Caution Remains Warranted
 
Significantly, despite these revisions and the several prior rounds of amendments over the past two years, Cuba remains subject to a comprehensive U.S. trade embargo. Although these most recent amendments to the CACR and EAR are likely to be welcome news to those entities eager to expand into Cuba, taking advantage of these new authorizations could pose increased compliance risks or present other business complications. For example:
 
  – The authorization to conduct joint medical research does not authorize travel to conduct such research. Although separate travel authorization is provided elsewhere in the CACR, such travel must not be paid for through a Cuban bank account established in connection with the research activities. The funds in such an account may be used exclusively for the medical research (and related) transactions authorized in the general license.
  – The general license authorizing services related to commercial aircraft safety could authorize certain repair activities for aircraft that develop a safety-of-flight malfunction while in Cuba. However, export of the repair parts to Cuba must be separately authorized by the CACR and EAR.
  – Companies relying on the direct-to-consumer export authorization should have measures in place to ensure that the goods are intended for use by the purchaser or immediate family members. Criteria to evaluate quantities of purchase, frequency of purchase, and the nature of the goods being sold, among other potential factors, would be helpful, if not necessary to maintain compliance with this broadened export authorization.
  – Notwithstanding the expansion of opportunities to engage with Cuba, persons subject to U.S. jurisdiction must be sure to conduct reasonable due diligence on all counterparties, a requirement that may be complicated in the near term, given the long-standing restrictions on trade with Cuba.
  – Finally, while the U.S. government continues to expand its policy of increasing the engagement with and support of the Cuban people, practical realities in the Cuban market and restrictions imposed by the Cuban government may continue to limit the extent to which U.S. parties might benefit from efforts in Cuba.

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COMM_a28. Gary Stanley’s ECR Tip of the Day
(Source: Defense and Export-Import Update; available by subscription from
gstanley@glstrade.com
)
 
* Author: Gary Stanley, Esq., Global Legal Services, PC, (202) 352-3059,
gstanley@glstrade.com
 
Records for items licensed under the ITAR that have transitioned to the Commerce Control List must continue to be maintained for a period of five years following the last transaction, regardless of jurisdiction. 

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ENEDITOR’S NOTES

(Source: Editor)

 

Notable birthdays:

 

* Bela Lugosi (Béla Ferenc Dezső Blaskó; 20 Oct 1882 – 16 Aug 1956, was a Hungarian-American actor, famous for portraying “Count Dracula” in the original 1931 film, and for his roles in many other horror films.
  – “It is women who love horror. Gloat over it. Feed on it. Are nourished by it. Shudder and cling and cry out-and come back for more.”
 
* Stanislaus I (Stanisław I Leszczyński, 20 Oct 1677 – 23 Feb 1766) was King of Poland, Grand Duke of Lithuania, Duke of Lorraine and a count of the Holy Roman Empire.
  – “To believe with certainty we must begin with doubting.”

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EN_a2
10. 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: 26 Aug 2016: 81 FR 58831-58834: Administrative Exemption on Value Increased for Certain Articles  

* 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: 17 Oct 2016: 81 FR 71365-71367: Cuba: Revisions to License Exceptions 

  
*
FOREIGN ASSETS CONTROL REGULATIONS (OFAC FACR)
: 31 CFR, Parts 500-599, Embargoes, Sanctions, Executive Orders
  – Last Amendment: 17 Oct 2016: 81 FR 71372-71378: Cuban Assets Control 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 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. 
 
*
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 (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:
12 Oct 2016: 81 FR 70340-70357: Amendment to the International Traffic in Arms Regulations: Revision of U.S. Munitions List Category XII and associated sections.

  – The only available fully updated copy (latest edition 12 Oct 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, footnotes to amendments that will take effect on 15 November and 31 December, plus a large Index and over 750 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 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.

* 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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