17-0626 Monday “The Daily Bugle”

17-0626 Monday “Daily Bugle”

Monday, 26 June 2017

The 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. DoD/DSS Posts Reminder Concerning FOCI Conference Registration
  4. State/DDTC: (No new postings.)
  5. EU Amends Restrictive Measures Against Iran
  1. Defense News: “Corker Vows to Block US Arms Sales to GCC”
  1. M. Volkov: “Top Mistakes Chief Compliance Officers Make (And How to Avoid Them)”
  1. Monday List of Ex/Im Job Openings: 95 Jobs Posted 
  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 (22 Jun 2017), FACR/OFAC (16 Jun 2017), FTR (19 Apr 2017), HTSUS (7 Mar 2017), ITAR (11 Jan 2017) 
  3. Weekly Highlights of the Daily Bugle Top Stories 



[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

[No items of interest noted today.]
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Registration for this year’s combined one-day Foreign Ownership, Control or Influence (FOCI) Conference, which will also be video-streamed to DSS field offices, closes June 28, 2017. Electronic invitations for the 2017 FOCI Conference were sent out June 2, 2017. If you are either a Facility Security Officer or an Outside Director/Proxy Holder for a FOCI company and you haven’t received an invitation, please check your spam filters or call your local Industrial Security Representative for more information.

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5. EU Amends Restrictive Measures Against Iran

  – Council Implementing Regulation (EU) 2017/1124 of 23 June 2017 implementing Regulation (EU) No 267/2012 concerning restrictive measures against Iran.
  – Council Implementing Decision (CFSP) 2017/1127 of 23 June 2017 implementing Decision 2010/413/CFSP concerning restrictive measures against Iran.

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. Defense News: “Corker Vows to Block US Arms Sales to GCC”

Powerful Senate Foreign Relations Committee Chairman Bob Corker announced he is blocking U.S. arms sales to Gulf Cooperation Council member states to pressure a resolution to the escalating row over Qatar.
The move threatens to close off a major market for the U.S. defense industry and throw off U.S. President Donald Trump’s marquee accomplishment during his Riyadh trip of a $110 billion U.S.-Saudi arms deal. The deal spurred concern in Israel about protecting its military edge and criticism at home as supportive of the kingdom’s air campaign in Yemen, a mushrooming humanitarian crisis.
In a letter Monday to Secretary of State Rex Tillerson, Corker said until there is a path for resolving the ongoing dispute, he will block all such sales. Major arms sales are subject to preliminary approval by the chairman and ranking member of the Senate Foreign Relations Committee and the House Foreign Affairs Committee before the statutory 30-day congressional review process.

Corker’s move also comes amid a dramatic shakeup of Saudi leadership. Saudi King Salman bin Abdul-Aziz Al Saud Salman made his 31-year-old son and defense minister next in line to the throne on Wednesday, removing the country’s counterterrorism czar and a figure well-known to Washington from the line of succession.
Corker, R-Tenn., said he “could not have been more pleased with” Trump’s recent meeting with the heads of the Gulf Cooperation Council and their commitments to fostering deeper regional ties against the Islamic State group and Iran, calling them “welcome steps forward.” But Corker contrasted the message with the deepening diplomatic crisis. 
  “Unfortunately, the GCC did not take advantage of the summit and instead chose to devolve into conflict,” Corker’s letter reads. “All countries in the region need to do more to combat terrorism, but recent disputes among the GCC countries only serve to hurt efforts to fight ISIS and counter Iran.
  “For these reasons, before we provide any further clearances during the informal review period on sales of lethal military equipment to the GCC states, we need a better understanding of the path to resolve the current dispute and reunify the GCC.


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7. M. Volkov: “Top Mistakes Chief Compliance Officers Make (And How to Avoid Them)”

* Author: Michael Volkov, Esq., Volkov Law Group, mvolkov@volkovlaw.com, 240-505-1992.
We all make mistakes, and Chief Compliance Officers (CCOs) are no exception. While CCOs are a creative and dedicated bunch, they are often susceptible to these five common mistakes. Probably unsurprisingly, the cure for these ills is more due diligence and more relationship building.
Chief Compliance Officers are fallible – I know that is not a controversial statement. To err is human, and CCOs are members of the human species.
With the enormous expectations placed on CCOs’ shoulders, they are bound to make some mistakes. I have seen CCOs who have run into difficulties, and occasionally they have contributed to the problem through their own behaviors.

I thought I would identify some of the common mistakes I have seen. It is hard to generalize, but I have observed some common themes.
So, here is my list:
#1: Buying CEO Happy Talk
The compliance profession regularly runs into a credibility problem. When joining a company or when seeking major changes in the company’s compliance program, the CEO and other managers often make promises or characterize their commitment to compliance, and many CCOs believe it without pressure-testing the claims and promises.
CCOs should be more skeptical when a CEO’s or senior manager’s assertions sound too good to be true. Many CCOs have been “burned” by these promises; they joined the company and then found out the CEO’s representations were indeed false. In the face of these difficulties, CCOs have no other choice but to speak with their feet and leave. Whenever you see such a short stint on a CCO’s CV, you know the CCO faced some serious problems.
CCOs have to bring more skepticism to the table. CEOs and senior managers have become adept at mouthing the words of compliance and making it sound like they are committed. CCOs listen to their claptrap without questioning or demanding more proof before joining the company. I know it can be difficult in the context of a job search to raise these kinds of issues, but CCOs have to apply their due diligence skills.
#2: Ignoring Corporate Culture
Most CCOs love their compliance controls. They like the “certainty” of a policy, demand performance in accordance with the procedures and then wait to measure compliance with some hard and fast numbers that show how “effective” the compliance program is operating. Of course, compliance controls are important, and rules need to be followed. Everyone understands this basic requirement.
CCOs, however, have to embrace and promote the company’s culture. CCOs often ignore this area or devote little time to developing innovative ways to promote and measure a company’s culture. Granted, it is much more amorphous, but the returns can be significant to the overall business performance. We all know that an ethical culture adds to the company’s bottom line, and CCOs have to be willing to educate the board, the CEO and senior management on this important issue. After getting buy-in, CCOs have to design and implement strategies to promote corporate culture, measure it and address culture issues.
#3: Reinforcing Stovepipes
CCOs have a lot of work and often feel overwhelmed because of a lack of resources and technology. At the same time, CCOs tend to spend time with their staff, working on compliance issues but failing to devote adequate attention to building relationships with natural allies: human resources, legal, internal audit, information technology and security.

Like politicians, CCOs have to schmooze and gain support from natural allies. They have to create win-win solutions, not just a list of demands to make the relationship beneficial to both parties. It means getting out in the company, “walking the halls” and using interpersonal skills to advance the program.
#4: Becoming the Sheriff
If a CCO walks into a room and company officials say (or joke), “uh oh, here’s the sheriff,” that is not a good sign. A CCO who embraces the enforcement aspect of his/her job is doomed to fail – no one will communicate, and no one will trust the CCO to help them solve problems. CCOs have to avoid this trap. A CCO has a lot of power over company employees and discipline. But a CCO has to work hard to become a problem solver, not a “Doctor No.” Company employees have to feel comfortable to communicate issues to the CCO, knowing that the CCO will solve problems to make sure business managers and employees can do their jobs while ensuring compliance with the law and the company’s code of conduct.
#5: Avoidance and Failure to Prioritize
CCOs face an overwhelming number of tasks and projects. It is hard to prioritize what needs to be done. Under these circumstances, some CCOs will avoid the tough issues that may require serious discussions with senior management and the board, and instead stick to issues over which they have greater control (meaning they can implement a specific initiative without relying on too many folks outside the compliance department). There is a natural inclination for a CCO to accomplish tasks under his or her control without taking the major effort to build internal support and convince senior leaders to make some changes. These initiatives can be frustrating and may result in little change, but CCOs have to stick to priorities, follow the map from its risk assessment and seek to solve the larger problems. Priorities are important, and care has to be taken when allocating time, attention and resources to specific projects.

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MS_a18. Monday List of Ex/Im Job Openings: 95 Jobs Posted

(Source: Editor)  
Published every Monday or first business day of the week. Please send openings in the following format to jobs@fullcirclecompliance.eu.
#” New listing this week:
* Abcam; Cambridge, United Kingdom;
Trade Compliance Coordinator; Requisition ID: CAM-012-996
* Acteon Group Ltd.; Norwich, Suffolk, or London, UK;
Head of Compliance; or email
Mike Pay
* Advanced Micro Devices (AMD); Austin TX; 
Import/Export Compliance Manager
; Requisition ID: 24061

Akin Gump Strauss Hauer & Feld LLP; Washington DC; 
International Trade and Customs Specialist
; Requisition ID: 147

* Amazon; Mexico City, Mexico; Mexico Trade Compliance Program Manager; Requisition ID: 520481

* Amazon; Mexico City, Mexico;
Senior Manager, Mexico Trade Compliance
; Requisition ID: 520460

* Amazon; Seattle WA; NA Compliance Analyst; Requisition ID: 256357

* Amazon; Seattle WA;
U.S. Export Compliance PM
; Requisition ID: 475927

* Amazon; Tokyo, Japan;
Trade Compliance Specialist
; Requisition ID: 481891

* Ansell; Iselin NJ;
Senior Specialist NA Trade Compliance; Requisition ID: IRC6513
* Applied Materials; Alzenau, Germany;
Europe Trade Manager
; Requisition ID: (M3)-1701376

* Arthrex; Naples FL;
Senior Compliance Officer;

* ASML; Veldhoven, the Netherlands;
Senior Manager Trade & Customs;
Requisition ID: RC05619
* Babcock; Portsmouth, United Kingdom; 
Divisional Trade & Compliance Manager

* Bemis Company; Neenah WI;
Director – Global Trade Compliance
; Requisition ID: REQ_13735
* Berry Plastics Corporation; Evansville IN;
International Trade Compliance Administrator
; Requisition ID: 4054

* Boeing; Sydney, Australia, and other locations;
Global Trade Control Manager; Requisition ID: 1700006067

* Boeing; Amsterdam, The Netherlands, and Brussels, Belgium;

Trade Control Specialist
; Requisition ID: 1700006121

* Brunswick Corporation; Lake Forest IL;
Trade Compliance Auditor
; Becky Longrie, 847-735-4755,
; Requisition ID: 22999

* Cobham Advanced Electronic Solutions; Exeter, NH, Plainview, NY, Eatontown, NJ, or Lansdale, PA;
Export Compliance Manager
; Charles Trokey

* CSRA Inc.; Falls Church VA;
Global Trade & Compliance Principal
; Alan Strober 571-375-4890; Requisition ID: 17002RN
Cubic Corporation; San Diego, CA; 
Senior Export Compliance Analyst

Requisition ID: 5982

* Danaher; Wash DC (Other locations possible);
Global Trade Compliance Manager; Requisition ID: DAN000510

* DB Schenker (2 positions); Atlanta GA, and Long Beach CA;
Area Customs Director
; Requisition ID: 17P009

# DRS Technologies; Dayton, OH; Senior Trade Compliance Manager
* Eaton; Titchfield, United Kingdom;
Global Trade Manager (Trade Compliance); Requisition ID: 020681

* Erickson Inc.; Portland OR;
Trade Compliance Manager
Joanna Rafiner-Jarboe
; Requisition 2017-2267

* Esterline CMC Electronics; Montreal, Quebec, Canada;
Senior Manager Trade Compliance; Requisition ID: 9971BR

* Expeditors; Sunnyvale CA;
Customs Compliance Specialist
* Export Solutions Inc.; Melbourne FL; Trade Compliance Specialist;

* FlightSafety International; Oklahoma; Trade Compliance Advisor; Requisition ID 16480

FLIR; Billerica MA; 
Sr. Defense Trade Licensing & Compliance Analyst
; Requisition ID: 8008

* Fluke; Everett WA; 
Trade Compliance Manager
; Requisition ID: FLU005544

* General Atomics Aeronautical Systems, Inc.; San Diego CA; 

International Trade Compliance Analyst (ITC) / Export Import Specialist / Global Trade Administrator
; Requisition ID: 12252BR

General Dynamics Land Systems; Sterling Heights, MI; Site Lead/Compliance OfficerRequisition ID: 

General Dynamics Land Systems; Sterling Heights, MI; Compliance Officer


* George Washington University; Washington DC;
Research Compliance Officer, Export Control
; Requisition ID: PI97906765

* Givaudan; Bogor, Indonesia;
Compliance Manager
; Requisition ID: 68063
* Harris Corporation; Clifton NJ; 
Trade Compliance Analyst
; Requisition ID: ES20172404-18675

 Huntington Ingalls Industries, Newport News Shipbuilding Division; Newport News, VA; International Trade Compliance Analyst 3; Requisition ID:  18350BR

* KPMG; Antwerp, Brussels;
Manager Global Trade & Customs – SAP GTS
; 122756BR

* Lam Research Corporation; Fremont CA;
Foreign Trade Intern 1

* Lam Research Corporation; Shanghai, China;
Foreign Trade Analyst 

* Lutron; Coopersburg PA;
Trade Manager-Export
; Requisition ID: 2926
Livingston International; Western Region (TX, CA, OR, WA preferred)

Trade Ad

Livingston International; Western Region (TX, CA, OR, WA preferred);
Research Consultant

* L-3 Technologies; Arlington VA;
Sr. Mgr. Corporate Customs Compliance
; Requisition ID: 087862

* L-3 Technologies, Platform Integration Division; Waco TX;
Import/Export Compliance Administrator 3
; Requisition ID 

* Lockheed Martin; Orlando FL;
International Trade Compliance Sr Staff / ITAR / EAR / Export Control Officer
; Requisition ID: 387435BR

* ManTech International; Herndon VA; 
Director of Corporate Export Control
; Requisition ID: 90965BR

* Mars – Wrigley; Chicago IL; 
Global Trade Compliance Analyst (Corporate Export)
; Requisition ID: 69452

* Maxim Integrated; Dallas TX;
Manager, Global Trade
; 3304BR

* Medtronic; Heerlen, The Netherlands;
Trade Compliance Analyst
; Requsition ID: 16000DYY

* Medtronic; Wash DC; Global Trade Lawyer;  
; Requisition ID: 170002ON

* Meggitt PLC; Maidenhead, UK;
Trade Compliance Officer 

* North Dakota State University; Fargo ND;
Director for Research Integrity Compliance; Requisition ID: 1700372

* Northrop Grumman; Falls Church VA; 
International Trade Compliance Analyst 3/4
; Patricia Vives, 
; Requisition ID: 17011893

* Northrop Grumman Corporation; Herndon VA;
International Trade Compliance Analyst 2
; Requisition ID: 17010105

* Northrop Grumman Corporation; Herndon VA;
International Trade Compliance Analyst 3/4; Requisition ID: 17001180

* Northrop Grumman Corporation; Linthicum MD;
International Trade Compliance Analyst 1
; 17003433
* Northrop Grumman Corporation; Linthicum MD;
International Trade Compliance Analyst 3
; 17005262

* Northrop Grumman Sperry Marine; New Malden, UK;
Trade Compliance Coordinator

* Panduit; Tinley Park IL;
Global Trade Compliance Agent
; Requisition ID: PAND-03297

* Plexus Corporation; Neenah Wi;
Manager – Export Compliance
; Requisition ID: 14645BR
* Plexus Corporation; Neenah Wi;
Manager – Import Compliance
; Requisition ID: 14593BR
* Premier Farnell Organisation; Leeds, UK;
Trade Compliance Specialist – Europe
; Requisition ID: 4301
* Raytheon; (El Segundo CA, McKinney TX, Dallas TX, Marlborough MA, or Washington D.C.);
Senior Manager of Global Trade Management
; Requisition ID: 98724BR

* Roanoke Insurance Group; Schaumburg IL; 
Carnet Service Representative
; Requisition ID: 1019

* Saab Defense and Security USA LLC; Syracuse NY;
Senior Import/Export Analyst
; Requisition ID: USA_00413

# Science and Engineering Services, LLC; Huntsville AL;
Export Compliance Specialist
bob.davis@ses-i.com; Requisition ID: 157

* SIRE: Noord-Brabant province, the Netherlands;
Trade Compliance Expert; Requisition ID: 33934

* Talbots; Hingham MA;
Sr Mgr Global Trade & Customs Compliance
; Requisition ID: 1077
* Talbots; Lakeville MA;
Dir., Global Logistics & Customs Com
; Requisition ID: 1085

* Tesla Motors; Fremont CA;
Global Supply Manager – Logistics
; Requisition ID: 38153

* Thales Defense and Security, Inc.; Clarksburg MD; Senior Manager Trade Compliance
; William.Denning@thalesdsi.com; Requisition ID: 2592

* ThermoFisher Scientific; Breda, the Netherlands;
Import/Export Specialist – EMEA CMD Commercial Offices
; Requisition ID: 44930BR

* UBC; Monheim, Germany;
Manager Customs and Trade Compliance 
* Ultra Electronics; Greater London, United Kingdom;
International Trade and Export Compliance Specialist

* United Technologies Corporation, UTC Aerospace Systems; Brea CA;
Sr. Anlst, Intl Trade Compl
; Requisition ID: 46798BR

* United Technologies Corporation, UTC Aerospace Systems; Burnsville MN;

ITC Tech Manager- SIS
; Requisition ID:38565BR

* United Technologies Corporation, UTC Aerospace Systems; Chula Vista CT;
International Trade Compliance Analyst
; Requisition ID: 46876BR

United Technologies Corporation, UTC Aerospace Systems; Rockford IL;
Specialist, International Trade Compliance- Operations and Licensing
; Requisition ID: 50118BR

* United Technologies Corporation, UTC Aerospace Systems; Troy OH;
Sr. Manager, Intl Trade Compliance
; Requisition ID: 44065BR 

* VAG; Mannheim, Germany;
Trade Compliance Manager (m/w)
; Contact: Mr. Florian Uhl, +49 621 749 – 1870

* Varex Imaging Corp; Salt Lake City UT; 
Senior Customs Compliance Analyst; Requisition ID: 11402BR

Vertiv (formerly Emerson Network Power); Columbus, OH,  
International Trade Management (ITM) Senior Specialist
; Req #1700001087

* Vigilant; Unknown location in the U.S.;
BioTech/Pharmaceutical Global Trade Analyst

* Xilinx, Inc.; San Jose, CA, US;
Global Trade Compliance Program Manager; Requisition ID: 153811

* XPO Logistics; Greenwich CT;
Global Trade Compliance Analyst

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* George Orwell (Eric Arthur Blair, 25 Jun 1903 – 21 Jan 1950, better known by his pen name George Orwell, was an English novelist, essayist, journalist, and critic. He is best known for the allegorical novella Animal Farm and the dystopian novel Nineteen Eighty-Four.) 
  – “People sleep peaceably in their beds at night only because rough men stand ready to do violence on their behalf.”
  – “If liberty means anything at all, it means the right to tell people what they do not want to hear.”
* Lord Kelvin (William Thomson, 1st Baron Kelvin, 26 Jun 1824 – 17 Dec 1907, was a Scotish-Irish mathematical physicist and engineer who did important work in the mathematical analysis of electricity and formulation of the laws of thermodynamics. Absolute temperatures are stated in units of kelvin in his honour. While the existence of a lower limit to temperature (absolute zero) was known prior to his work, Lord Kelvin is widely known for determining its correct value as approximately −273.15 degree Celsius or −459.67 degree Fahrenheit.)
  – “In science there is only physics; all the rest is stamp collecting.”
  – “Heavier-than-air flying machines are impossible.”
Monday is pun day:
Q. Why did the chicken go to church?
A. Because he wanted to be a bird of pray. 
  — Jennings Mergenthal, Chicago, IL

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. 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: 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.

  – 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: 22 Jun 2017: 82 FR 28405-28410: Russian Sanctions: Addition of Certain Entities to the Entity List

: 31 CFR, Parts 500-599, Embargoes, Sanctions, Executive Orders
  – Last Amendment: 16 Jun 2017: 82 FR 27613-27614: Removal of Burmese Sanctions Regulations 
: 15 CFR Part 30
  – Last Amendment: 19 Apr 2017: 82 FR 18383-18393: Foreign Trade Regulations: Clarification on Filing Requirements 
  – HTS codes that are not valid for AES are available
  – The latest edition (19 Apr 2017) 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.
, 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
  – HTS codes that are not valid for AES are available
  – Latest Amendment: 11 Jan 2017: 82 FR 3168-3170: 2017 Civil Monetary Penalties Inflationary Adjustment
  – The only available fully updated copy (latest edition 10 Jun 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 800 footnotes containing amendment histories, 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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Review last week’s top Ex/Im stories in “Weekly Highlights of the Daily Bugle Top Stories” published

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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 8,000 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 of this newsletter 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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