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17-0314 Tuesday “The Daily Bugle”

17-0314 Tuesday “The Daily Bugle”

Tuesday, 14 March 2017

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. DHS/CBP Posts Notice of Final Determination Concerning Certain Data Storage Products 
  1. Ex/Im Items Scheduled for Publication in Future Federal Register Editions
  2. Commerce/BIS: (No new postings.) 
  3. DHS/CBP Updates Ocean CAMIR Port Code for Yangshan, China 
  4. DHS/CBP Newsroom: CBP Officers in Tacoma Seize Shipments In Violation of Trade Laws
  5. State/DDTC: (No new postings.) 
  6. EU Amends and Implements Restrictive Measures Concerning Iraq and Ukraine
  7. EUP2P Posts Summaries of Activities in Various Countries 
  1. ST&R Trade Report: “CBP Identifies Country of Origin of Certain Data Storage Products” 
  1. The Export Compliance Journal: “How to Avoid Becoming the Next Face of an Export Compliance Violation” 
  2. R. Roe: “License Exception ‘ENC’ Reporting Requirements” 
  3. Gary Stanley’s ECR Tip of the Day 
  4. R.C. Burns: “Ohio Company ‘Earns’ ITAR ‘Certification'” 
  1. ECTI Presents Export Compliance Essentials for Defense Contractors and Subcontractors Webinar – 12 Apr 
  1. Bartlett’s Unfamiliar Quotations 
  2. Are Your Copies of Regulations Up to Date? Latest Changes: ATF (15 Jan 2016), Customs (27 Jan 2017), DOD/NISPOM (18 May 2016), EAR (24 Feb 2017), FACR/OFAC (10 Feb 2017), FTR (15 May 2015), HTSUS (7 Mar 2017), ITAR (11 Jan 2017) 

EXIMEX/IM ITEMS FROM TODAY’S FEDERAL REGISTER

EXIM_11
. DHS/CBP Posts Notice of Final Determination Concerning Certain Data Storage Products

(Source:
Federal Register
) [Excerpts.]
 
82 FR 13644-13648: Notice of Issuance of Final Determination Concerning Certain Data Storage Products
 
* AGENCY: U.S. Customs and Border Protection, Department of Homeland Security.
* ACTION: Notice of final determination.
* SUMMARY: This document provides notice that U.S. Customs and Border Protection (“CBP”) has issued a final determination concerning the country of origin of three data storage products. Based upon the facts presented, CBP has concluded that the country of origin of two data storage products is Mexico and the country of origin of the third data storage is Malaysia for purposes of U.S. Government procurement.
* DATES: The final determination was issued on March 8, 2017. A copy of the final determination is attached. Any party-at-interest, as defined in 19 CFR 177.22(d), may seek judicial review of this final determination within April 13, 2017.
* FOR FURTHER INFORMATION CONTACT: Grace A. Kim, Tariff Classification and Marking Branch, Regulations and Rulings, Office of Trade, (202) 325-7941.
* SUPPLEMENTARY INFORMATION: Notice is hereby given that on March 8, 2017, pursuant to subpart B of part 177, U.S. Customs and Border Protection Regulations (19 CFR 177(B)), CBP issued a final determination concerning the country of origin of certain data storage products, which may be offered to the U.S. Government under an undesignated government procurement contract. This final determination, HQ H269185, was issued under procedures set forth at 19 CFR 177(B), which implements Title III of the Trade Agreements Act of 1979, as amended (19 U.S.C. 2511-18). In the final determination, CBP concluded that for two of the three products, the processing in Mexico results in a substantial transformation. However, for the third product, the processing in Mexico does not result in a substantial transformation. Therefore, the country of origin of two data storage products is Mexico and the country of origin of the third data storage is Malaysia for purposes of U.S. Government procurement.
Section 177.29, CBP Regulations (19 CFR 177.29), provides that a notice of final determination shall be published in the Federal Register within 60 days of the date the final determination is issued. Section 177.30, CBP Regulations (19 CFR 177.30), provides that any party-at-interest, as defined in 19 CFR 177.22(d), may seek judicial review of a final determination within 30 days of publication of such determination in the Federal Register.
 
  Dated: March 8, 2017.
Alice A. Kipel, Executive Director, Regulations and Rulings, Office of Trade.
 
[Editor’s Note: to read “HQ H269185” click here or on the source link below item title.]

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OGS
OTHER GOVERNMENT SOURCES

OGS_a12. Ex/Im Items Scheduled for Publication in Future Federal Register Editions

(Source: Federal Register)
[No items of interest noted today.]

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OGS_a23. Commerce/BIS: (No new postings.)

(Source: Commerce/BIS

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OGS_a34.

DHS/CBP Updates Ocean CAMIR Port Code for Yangshan, China 

(Source:
CSMS# 17-000140, 13 Mar 2017.]
 
New ACE Programming
 
Appendix F of the Ocean
Customs Automated Manifest Interface Requirements (CAMIR) has been updated to reflect “57037 Yangshan” as a valid Schedule K location code. Effective immediately, filers are able to use this location code on applicable ocean bills. 

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OGS_4
5. DHS/CBP Newsroom: CBP Officers in Tacoma Seize Shipments In Violation of Trade Laws

(Source:
DHS CBP Newsroom)
 
U.S. Customs and Border Protection import specialists and officers at the Port of Tacoma seized three shipments of goods from China in February that were in violation of various laws or regulations.
 
“CBP remains focused on enforcing the importation of counterfeit products and products that violate other regulations while facilitating the lawful importation of merchandise,” said Mark Wilkerson, director of the Area Port of Seattle. “Stopping the flow of illicit goods is a priority trade issue for CBP. The importation of counterfeit merchandise can damage the U.S. economy and threaten the health and safety of the American people.”
 
One of the seizures included a shipment of nearly 120 pieces of furniture with a retail value of nearly $720,000 that was in violation of trademark laws. During inspection of the shipment, a CBP import specialist conferred with representatives from the trademark holders and determined the furniture infringed upon trademarks and was subject to seizure.
 
Another seizure included a shipment of 950 microphones and cables with a value of more than $25,000. While examining the cargo, a CBP officer discovered that the packaging the items were in said, “Made & Manufactured in the U.S.A.,” whereas the he cartons the items were shipped in had “Made in China” on the outside of them. Additionally, the invoice and packing list had the country of origin declared as China. The items were seized under 19 USC 1595A(c) for violation of 15 USC 1124 and 15 USC 1125, which is the law regarding false designation of origin.
 
Finally, CBP officers seized a shipment of 950 automotive headlamps with a value of nearly $80,000. The headlamps were found to be in violation of standards set by the National Highway Traffic Safety Administration.
 
CBP is responsible for enforcing nearly 500 U.S. trade laws and regulations on behalf of 47 federal agencies, facilitating legitimate trade, collecting revenue, and protecting the U.S. economy and its consumers from harmful imports and unfair trade practices.
 
With the growth of foreign trade, unscrupulous companies have profited billions of dollars from the sale of counterfeit and pirated goods. To combat the illicit trade of merchandise violating laws relating to Intellectual Property Rights (IPR), trademark and copyright holders may register with CBP through an online system. Such registration assists CBP officers and import specialists in identifying merchandise that violate U.S. law.
 
CBP’s IPR enforcement strategy is multi-layered and includes seizing illegal merchandise at our borders, pushing the border “outward” through audits of suspect importers, cooperating with our international trading partners, and collaborating with industry and governmental agencies to enhance these efforts.
 
For more information on CBP’s Intellectual Property Rights priority trade issue visit:
CBP Trade and IPR.

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OGS_a6

7EU Amends and Implements Restrictive Measures Concerning Iraq and Ukraine  

 
Regulations
  – Council Implementing
Regulation (EU) 2017/437 of 13 March 2017 implementing Regulation (EU) No 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine.
  – Commission Implementing
Regulation (EU) 2017/441 of 13 March 2017 amending Council Regulation (EC) No 1210/2003 concerning certain specific restrictions on economic and financial relations with Iraq.
 
Decisions
  –
Council Decision (CFSP) 2017/445 of 13 March 2017 amending Decision 2014/145/CFSP concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine.
[Editor’s note: on 13 March 2017, the Council of the European Union announced prolongation of the restrictive measures over actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine for a further six months, until 15 September 2017. The measures consist of asset freezes and travel bans.  See item #5 in the Daily Bugle of Monday, 13 March 2017.]  

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OGS_a7

8. EUP2P Posts Summaries of Activities in Various Countries

(Source:
EUP2P)
 
The EU Partner-to-Partner (“EUP2P”) Consortium has posted various summaries of its activities. To read the summary of a specific activity, click on a link attached to an activity in the list below.
 

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COMMNEWS

NWS_19. ST&R Trade Report: “CBP Identifies Country of Origin of Certain Data Storage Products”

 
U.S. Customs and Border Protection has issued a final determination concerning the country of origin of certain data storage products of subheading 8471.70 that may be offered to the U.S. government under an undesignated government procurement contract. Any party-at-interest may seek judicial review of this determination by April 13. CBP issues country of origin advisory rulings and final determinations as to whether an article is or would be a product of a designated country or instrumentality for the purposes of granting waivers of certain “Buy American” restrictions in U.S. law or practice for products offered for sale to the U.S. government.
 
CBP determined that certain processing operations carried out in Mexico result in a substantial transformation for two of the three products under consideration. However, for the third product under consideration the processing in Mexico does not result in a substantial transformation and that product is therefore deemed to originate in Malaysia for purposes of U.S. government procurement. However, the country of origin for all three products for marking purposes will be Mexico under the NAFTA marking rules.
 
[Editor’s note: See related FedReg notice in Item #1 above.] 

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COMMCOMMENTARY

COMM_a110The Export Compliance Journal: “How to Avoid Becoming the Next Face of an Export Compliance Violation”

 
Consent Agreements from the U.S. Department of State’s Directorate of Defense Trade Controls may not be popular light reading, but they’re worth a look if you’re a key player in your company’s export compliance infrastructure.
Ongoing Consent Agreements to companies in the aerospace, defense, and manufacturing industries, remind us that the penalties for violations can be severe regardless of how or why the infractions occurred. But don’t despair-simple preemptive measures can help you stay compliant and avoid the common issues that appear throughout many of these Agreements.
 
Five Things to Consider to Improve Your Export Compliance Processes:
 
(1) Export Compliance and Cutting Corners Are a Risky Combination
 
In the Consent Agreement of a leading defense contractor inadequate compliance resources are observed, indicating poor compliance prioritization within the organization. The cost of developing an Export Management and Compliance Program, implementing dependable compliance solutions and training your staff to use them is minuscule compared to the consequences of not doing so. If the Department of State (DOS) audited you today, what would they say about your company’s compliance culture?
 
(2) You May Not Know Your Products as Well as You Think You Do 
 
For two prominent manufacturers of high technology products, “failure to properly determine export control jurisdiction” over their commodities resulted in unauthorized exports and re-exports of items controlled by International Traffic in Arms Regulations (ITAR) such as electronics and associated technical data. Despite recent changes to the United States Munitions List (USML), it is still your responsibility to know whether or not your goods or technology are subject to ITAR, and to classify them correctly. Reliable solutions that simplify the classification process and help verify your commodity jurisdiction determinations are essential to avoiding costly errors and oversights. Enlisting staff with detailed knowledge about a product’s intended purpose is also vital to achieving correct classifications.  
One company took this advice to the extreme – inviting their engineers to a pizza party, locking them in, and ordering them to classify products! We hope they were fed well.
 
(3) Sticky Notes and Spreadsheets Just Won’t Do
 
“Failure to maintain records involving ITAR-controlled transactions”-including license records-contributed to the problems of two aerospace equipment providers. Comprehensive audit records of all screening activities and an automated classification workflow that ensures your product information is accurate and defensible are necessary (a) to achieve the precision that compliance demands and (b) to easily prove your due diligence.
 
(4) Those Who Ignore History Are Doomed to Repeat it 
 
One expanding aerospace company learned that when you acquire new subsidiaries the onus is on you to investigate the past. Among other proactive steps, batch screening of all the employees and customers in your database can give you a quick but necessary glimpse into what you are inheriting in an acquisition or merger. Even if export violations precede your procurement of a subsidiary, it’s up to you to ensure the illegal procedures don’t unwittingly continue under new management. Some companies have had multiple repeat violations, a situation that is completely avoidable.
 
(5) “I Didn’t Know” Won’t Get You Off the Hook
 
Compliance violations are often due to decentralized compliance programs. In one company’s case, “inadequate corporate oversight” of divisions and subdivisions resulted in unlawful transactions that head office simply didn’t catch. Systems enabling corporate-wide communication are essential. For another organization, “lack of awareness of the ITAR” was a contributing factor to their violations, demonstrating ignorance of the law is not a valid defense. The wealth of compliance information online can be daunting to wade through, but the best compliance solutions help companies navigate the complexities of export regulations and ensure all obligations are met to the highest standard.
 
Avoiding the mistakes of the companies above requires a firm commitment-not only to achieving a high level of compliance but also to staying compliant. And while this requires an investment of your company’s time and resources, it’s undeniably worthwhile.

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COMM_a211. R. Roe: “License Exception ‘ENC’ Reporting Requirements”

(Source:
American Shipper) [Excerpts.]
 
* Author: Renee Roe, Director, BPE Global,
renee@bpeglobal.com.
 
Encryption reporting is an area that could be going unnoticed in some trade compliance departments, and management must be aware that encryption reporting is required for certain encryption exports, explained Renee Roe, director at BPE Global.
 
As we’ve discussed here previously, recordkeeping is often overlooked in the midst of the operational chaos that dominates most of our day-to-day lives despite its importance when conducting audits. And the first step to tackling recordkeeping is understanding what regulatory agency requirements apply to your company.
 
Another area that could potentially be going unnoticed in your trade compliance department is that of encryption reporting.
 
As with recordkeeping, encryption reporting requires you to know what U.S. regulatory agencies’ reporting rules are applicable to your organization, such as those of the Bureau of Industry and Security and the National Security Agency. … 

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COMM_a312.

Gary Stanley’s ECR Tip of the Day

 
* Author: Gary Stanley, Esq., Global Legal Services, PC, (202) 352-3059,
gstanley@glstrade.com
 
A foreign person is obligated to know whether an item is subject to the ITAR or, if subject to the EAR, how it is classified before reexporting or transferring the item in order to ensure compliance with the ITAR’s and the EAR’s licensing and other obligations. The U.S. exporter is responsible for determining the jurisdictional and classification status of the items it is exporting. However, if reliable jurisdictional and classification information has not already been provided by another party, such as the original equipment manufacturer, then the foreign person may and, indeed, must make these determinations itself to avoid violating the ITAR or the EAR if it later reexports or retransfers the article or item.
 
As a matter of due diligence, however, the foreign person should seek jurisdictional and classification information from the manufacturer of the items or the owner of the technology in question and resolve any potential differences in interpretation. If after reviewing the ITAR’s U.S. Munitions List (USML) and all relevant facts, doubt exists regarding whether the item is enumerated or otherwise described on the USML, the foreign person should request from DDTC a commodity jurisdiction determination pursuant to 22 C.F.R. §120.4. If the item is clearly not enumerated or otherwise described on the USML and, after reviewing the EAR and all relevant facts, there is doubt regarding whether or where the item is enumerated or otherwise described on the EAR’s Commerce Control List, then the foreign person should request from the Department of Commerce’s Bureau of Industry and Security a commodity classification determination pursuant to 15 C.F.R. §748.3.

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COMM_a413.

R.C. Burns: “Ohio Company “Earns” ITAR ‘Certification'”

(Source:
Export Law Blog. Reprinted by permission.)
 
* Author: R. Clifton Burns, Esq., Bryan Cave LLP, Wash DC,
Clif.Burns@bryancave.com, 202-508-6067
 
It seems like it has been quite a while since I’ve seen a press release from a company boasting that it had “earned” or “achieved” ITAR “certification.” But
MJM Industries obliges with this 
self-congratulatory press release.
 
“Fairport Harbor, Ohio – MJM Industries, a contract manufacturer of custom over-molded cable and wire harness assemblies, has earned certification for International Traffic in Arms Regulations (ITAR) compliance. This designation will add to their growing portfolio of certificates and compliances such as ISO, WEEE, RoHs, REACH, UL, CSA, FM, MIL, and UL Canadian that verify MJM Industries’ commitment to producing high quality and reliable products.”
 
As I’ve said before many times and will say again, all that an ITAR registration can “verify” is that someone at MJM figured out how to fill out and file a form and that MJM had at one time at least $2,250 in its checking account.
 
But wait! There’s more!
 
“Having the ITAR certification is the key to customer satisfaction.”
 
Indeed it is. That and, oh, I don’t know, maybe a free flashlight (shipping and handling extra) with every order?

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TEEX/IM TRAINING EVENTS & CONFERENCES

TE_a1
14. ECTI Presents Export Compliance Essentials for Defense Contractors and Subcontractors Webinar – 12 Apr

(Source: Danielle McClellan, danielle@learnexportcompliance.com)

* What: Export Compliance Essentials for Defense Contractors and Subcontractors
* When: 12 April 2017; 1:00 p.m. (EDT)
* Where: Webinar
* Sponsor: Export Compliance Training Institute (ECTI)
* ECTI Speaker: Mary Edquist
* Register: Here or Danielle McClellan, 540-433-3977, danielle@learnexportcompliance.com.

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ENEDITOR’S NOTES

(Source: Editor)

*
Paul Ehrlich (14 Mar 1854 – 20 Aug 1915, was a German physician and scientist. His 1968 book,
The Population Bomb, warned of the mass starvation of humans in the 1970s and 1980s due to overpopulation, as well as other major societal upheavals, and advocated immediate action to limit population growth.)

  – “By the year 2000 the United Kingdom will be simply a small group of impoverished islands, inhabited by some 70 million hungry people.”

 

*
Albert Einstein (14 Mar 1879 – 18 Apr 1955, was a German-born theoretical physicist. He developed the theory of relativity, and is best known in popular culture for his mass-energy equivalence formula 
E
 
=
 
mc
2, dubbed “the world’s most famous equation.”  In 1921 he received the Nobel Prize in Physics.)

  – “We cannot solve our problems with the same thinking we used when we created them.”

  – “Whoever is careless with the truth in small matters cannot be trusted with important matters.”  

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EN_a216
. 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: 27 Jan 2017: 82 FR 8589-8590: Delay of Effective Date for Importations of Certain Vehicles and Engines Subject to Federal Antipollution Emission Standards; and 82 FR 8590: Delay of Effective Date for Toxic Substance Control Act Chemical Substance Import Certification Process Revisions 

* 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: 24 Feb 2017: 82 FR 11505-11506: Temporary General License: Extension of Validity

  
*
FOREIGN ASSETS CONTROL REGULATIONS (OFAC FACR)
: 31 CFR, Parts 500-599, Embargoes, Sanctions, Executive Orders
  – Last Amendment: 10 Feb 2017: 82 FR 10434-10440: Inflation Adjustment of Civil Monetary Penalties.  
 
*
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.
 
*
HARMONIZED TARIFF SCHEDULE OF THE UNITED STATES (HTS, HTSA or HTSUSA)
, 1 Jan 2017: 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: 7 Mar 2017: Harmonized System Update 1702, containing 1,754 ABI records and 360 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: 11 Jan 2017: 82 FR 3168-3170: 2017 Civil Monetary Penalties Inflationary Adjustment
 – The only available fully updated copy (latest edition 8 Mar 2017) 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, 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 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 8,000 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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