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17-1116 Thursday “Daily Bugle”

17-1116 Thursday “Daily Bugle”

Thursday, 16 November 2017

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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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  1. Justice/ATF Seeks Comments on Form ATF F 6NIA (5330.3D), Application and Permit for Temporary Importation of Firearms and Ammunition by Nonimmigrant Aliens
  2. Justice/ATF Seeks Comments on Form 3310.12, Report of Multiple Sale or Other Disposition of Certain Rifles
  1. Ex/Im Items Scheduled for Publication in Future Federal Register Editions
  2. Commerce/BIS: (No new postings.)
  3. State/DDTC: (No new postings.)
  4. Australia DEC Releases Update on Contact Details
  1. Expeditors News: “Thai Customs to Strictly Enforce ‘Marks and Numbers’ Rule”
  1. Great Lakes Customs Law: “Penalties for Violations of the EAR”
  2. M. Volkov: “Business Ethics, Values and Personal Ethics (Part I of IV)”
  3. R. Denton: “EU Introduces Legislation Imposing Targeted Sanctions Against Venezuela”
  4. 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 (28 Sep 2017), DOD/NISPOM (18 May 2016), EAR (9 Nov 2017), FACR/OFAC (13 Nov 2017), FTR (20 Sep 2017), HTSUS (20 Oct 2017), ITAR (30 Aug 2017) 
  3. Weekly Highlights of the Daily Bugle Top Stories 

EXIMEX/IM ITEMS FROM TODAY’S FEDERAL REGISTER

EXIM_a1

1. Justice/ATF Seeks Comments on Form
ATF F 6NIA (5330.3D), Application and Permit for Temporary Importation of Firearms and Ammunition by Nonimmigrant Aliens

(Source: Federal Register) [Excerpts.]
 
82 FR 53524-53525: Agency Information Collection Activities; Proposed eCollection eComments Requested; Application and Permit for Temporary Importation of Firearms and Ammunition by Nonimmigrant Aliens–ATF F 6NIA (5330.3D)
* AGENCY: Bureau of Alcohol, Tobacco, Firearms and Explosives, Department of Justice
* ACTION: 30-Day notice. …
* DATES: Comments are encouraged and will be accepted for an additional 30 days until December 18, 2017.
* FOR FURTHER INFORMATION CONTACT: If you have additional comments, particularly with respect to the estimated public burden or associated response time, have suggestions, need a copy of the proposed information collection instrument with instructions, or desire any other additional information, please contact Desiree M. Dickinson, ATF Firearms and Explosives Imports Branch either by mail at 244 Needy Road, Martinsburg, WV 25405, by or telephone (304) 616-4550, or by email at desiree.dickinson@atf.gov. Written comments and/or suggestions can also be directed to the Office of Management and Budget, Office of Information and Regulatory Affairs, Attention Department of Justice Desk Officer, Washington, DC 20503 or sent to OIRA_submissions@omb.eop.gov.
* SUPPLEMENTARY INFORMATION: …
  – The Title of the Form/Collection: Application and Permit for Temporary Importation of Firearms and Ammunition By Nonimmigrant Aliens. …
  – Form number: ATF F 6NIA (5330.3D).
  – Component: Bureau of Alcohol, Tobacco, Firearms and Explosives, U.S. Department of Justice. …
  – Abstract: The form allows nonimmigrant aliens to temporarily import firearms and ammunition into the United States for hunting or other sporting purposes. …
  If additional information is required contact: Melody Braswell, Department Clearance Officer, United States Department of Justice, Justice Management Division, Policy and Planning Staff, Two Constitution Square, 145 N Street NE., 3E.405A, Washington, DC 20530.
 
  Dated: November 13, 2017.
Melody Braswell, Department Clearance Officer for PRA, U.S. Department of Justice.

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EXIM_a2

2. Justice/ATF Seeks Comments on Form 3310.12, Report of Multiple Sale or Other Disposition of Certain Rifles

(Source: Federal Register) [Excerpts.]
 
82 FR 53523-53524: Agency Information Collection Activities; Proposed eCollection eComments Requested; Report of Multiple Sale or Other Disposition of Certain Rifles–ATF Form 3310.12
* AGENCY: Bureau of Alcohol, Tobacco, Firearms and Explosives, Department of Justice.
* ACTION: 30-Day notice. …
* DATES: Comments are encouraged and will be accepted for an additional 30 days until December 18, 2017.
* FOR FURTHER INFORMATION CONTACT: If you have additional comments, particularly with respect to the estimated public burden or associated response time, have suggestions, need a copy of the proposed information collection instrument with instructions, or desire any other additional information, please contact Ed Stely, Branch Chief, Tracing Operations and Records Management Branch, National Tracing Center Division, either by mail at 244 Needy Road, Martinsburg, WV 25405, by telephone at 800-788-7133, or by email at Edward.Stely@atf.gov. Written comments and/or suggestions can also be directed to the Office of Management and Budget, Office of Information and Regulatory Affairs, Attention Department of Justice Desk Officer, Washington, DC 20503 or sent to OIRA_submissions@omb.eop.gov.
* SUPPLEMENTARY INFORMATION: …
  – The Title of the Form/Collection: Report of Multiple Sale or Other Disposition of Certain Rifles. …
  – Form number: ATF Form 3310.12.
  – Component: Bureau of Alcohol, Tobacco, Firearms and Explosives, U.S. Department of Justice. …
  – Abstract: The purpose of this information collection is to continue a requirement that Federal firearms licensees report multiple sales or other dispositions whenever the licensee sells or otherwise disposes of two or more rifles to the same person at one time or within any five consecutive business days with the following characteristics: (a) Semi-automatic; (b) a caliber greater than .22; and (c) the ability to accept a detachable magazine. This requirement will apply to Federal Firearms Licensees (FFLs) who are dealers and/or pawnbrokers in Arizona, California, New Mexico and Texas. …
  If additional information is required contact: Melody Braswell, Department Clearance Officer, United States Department of Justice, Justice Management Division, Policy and Planning Staff, Two Constitution Square, 145 N Street NE., 3E.405A, Washington, DC 20530.
 
  Dated: November 13, 2017.
Melody Braswell, Department Clearance Officer for PRA, U.S. Department of Justice.

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OGSOTHER GOVERNMENT SOURCES

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

* Treasury; Foreign Assets Control Office; NOTICES; Blocking or Unblocking of Persons and Properties [Publication Date: 17 November 2017.]
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OGS_a46
. Australia DEC Releases Update on Contact Details

(Source:
Australia DEC, not dated.)
 
The current email addresses for Australia Defense Export Controls (DEC) have been in operation since August 2016. They are as follows:
 
  (1) Queries, DEC reports, and amendment requests should be sent to ExportControls@defence.gov.au
  (2) Applications should be sent to ExportControls.Applications@defence.gov.au
 
Defence Export Controls will be closing the following obsolete mailboxes on 27 November 2017:
 
 
This will be a complete closure, and emails will not be forwarded from the obsolete mailboxes. All correspondence to DEC, including permit reports should be supplied to the operational email addresses.

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NWSNEWS

NWS_a1
7. Expeditors News: “Thai Customs to Strictly Enforce ‘Marks and Numbers’ Rule”

(Source: Expeditors News, 16 Nov 2017.)
 
Thai Customs has announced that effective November 13, 2017, it will strictly enforce the “marks and numbers” provisions of Custom Act B.E. 2560 (2017), Section 59. This rule requires all commercial and transportation documentation, and all packages containing goods to bear “marks and numbers, and such marks and numbers shall be shown on all documents related to such goods.” Penalties for non-compliance may be levied to a maximum amount of THB 50,000 (approximately USD 1,500.00) and will be charged to importers or exporters in Thailand for any violation.  
 
Exporters who ship to Thailand should ensure that their cargo is appropriately marked, and that the documentation (shipper’s instructions, packing lists, invoices, etc.) contains marks and numbers matching what is applied to the physical cargo so that the information may be transferred to the transportation documents.
 
The regulation in Thai can be found here.

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COMMCOMMENTARY

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8. Great Lakes Customs Law: “Penalties for Violations of the EAR”
(Source:
Great Lakes Customs Law
, 16 Nov 2017.)
 
Who is an exporter?
 
If you ship and transport anything out of the country you are considered to be an exporter, even if you do not think of it that way. The shipment can be a commercial shipment, like export of manufactured products to another country; or, it can be personal shipment like shipping (or taking with you on a flight iPhone/Android mobile phones and laptops for your family in another country.
 
CBP Penalty for Export Violations
 
CBP will issue a penalty for export violations; typically, the notice of penalty states that there was a violation of the Export Administration Regulations (EAR), which are in Title 15 Part 30 of the Code of Federal Regulations. These violations can include:
 
  – Late filing of file electronic export information/shippers declaration in the AES [Automated Export System];
  – Failure to file electronic export information in the AES;
  – Failure to file correct and/or necessary export information in the AES (USPPI [U.S. Principal Party in Interest], Consignee, End User, Commodity Description, Port of Export);
  – Failure of the exporting carrier to provide certain documents or information to CBP;
  – Failure to cite license code or number;
  – Failure to obtain Power of Attorney for AES transmission;
  – Failure to identify transaction as a routed transaction;
  – Failure to correct information as changes become known to the filer;
  – Failure to provide carrier with proof of filing or exemption legend; and
  – Failure to retain records for 5 years.
 
Carriers themselves have different obligations under the Export Administration Regulations, and carrier violations can include failure to notify the USPPI with changes to date or port of export, failure to file manifest information, and failure to file proof of filing citation or exemption legends, to name a few.
 
What are my responsibilities as an exporter?
 
Electronic export information is filed in the AES – Automated Export System, which is now part of the ACE (Automated Commercial Environment). Export reporting is required for all exports valued at $2,500 or more, or if a license is required for export (for example, this can happen with dual use military goods, certain encryption hardware/software, or even innocent seeming items like things such as iPhones to prohibited/embargoed countries like North Korea). Some exceptions do exist. The Commerce Control List is a starting point for making these determinations.
 
The consequences for not making the required filing vary depending on the nature of the violation. For instance, shipping 10 iPhones to Canada is far different than shipping weapons grade plutonium to Sudan.
 
Penalty Amount for Export Violations
 
The most typical penalty amount for AES export violations is $10,000. The party receiving the notice of penalty has 60 days from the date of the penalty to file a petition for mitigation of the penalty with CBP’s Fines, Penalties and Forfeitures’ officer who issued the penalty. CBP can consider certain mitigating factors in deciding whether to reduce the penalty, such as:
 
  – First offense;
  – First time filer (inexperience);
  – An isolated incident (not part of broader violations, negligence or accidental);
  – Voluntary self-disclosure was made by violator pursuant to 15 CFR 30.74;
  – Exceptional cooperation by the filer;
  – Demonstration of systematic export compliance; and
  – Assistance in investigation of another person.
 
CBP can also consider certain aggravating factors in deciding whether to reduce the penalty, such as:
 
  – Second through Fourth and subsequent offenses (aggravating);
  – Intentional violations (deliberate incorrect values, product descriptions, commodity codes, etc);
  – High number of violations in last 3 years;
  – Evidence of criminal conviction for a related violation;
  – Exhibition of disregard for responsibilities under the export laws and regulations; and
  – Party is regular exporting, but does not have a compliance system in place.

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COMM_a2
9. M. Volkov: “Business Ethics, Values and Personal Ethics (Part I of IV)”
(Source: Volkov Law Group Blog, 13 Nov 2017. Reprinted by permission.)
 
* Author: Michael Volkov, Esq., Volkov Law Group, mvolkov@volkovlaw.com, 240-505-1992.

[Editor’s Note: The following parts of this item will be included in the days to come.]
 
This week I am examining in a four-part series the issue of business ethics in an attempt to provide practical approaches to business ethics to help build and promote a company’s culture.
 
As more attention is paid to the importance of an ethical culture, I wanted to first offer some general observations. The field of business ethics is thick with definitions, moral arguments and theoretical discussions, most of which are interesting from an academic perspective. Nor would I ever offer my own ethical principles or moral values as a guidepost for businesses to build an ethical culture. Instead, my approach is to find common ground within a company that aligns company constituencies or stakeholders in order to embed a set of principles and values.
 
No two companies share the same culture or the same set of company values and principles. Each company is distinct like the products and services the company may provide and the community in which they operate.
 
First, we start with the obvious assumption – companies need to implement an ethics and compliance program. I have insisted on placing the term “ethics” in front of “compliance” to underscore the point that a company’s ethical culture transcends a company’s legal compliance. If we are to apply rules of statutory construction (I know, which do not apply), the fact is that ethics is more than and separate from legal compliance.
 
Second, the term “ethics” in the business context applies to business operations involving the purchase and sale of goods and services in the marketplace. In reality, business is hard to separate from many other aspects of our lives so business ethics has a broad application and impact on society, and necessarily reflects our personal values.
 
Given the vast presence and impact of business ethics, there are numerous important questions that business ethics should address, including the responsibilities of business owners, managers and employees, and external engagement with customers, suppliers, the public, government and communities. It is easy to get lost or twisted up in these esoteric but very important issues.
 
From my perspective, business ethics is defined as the company’s values and principles guiding its internal operations and relationships with external parties, such as customers, suppliers, government, communities and the public. These ethical principles infuse every aspect of the company’s internal and external operations, and include questions beyond compliance with the law.
 
We always hear about doing the “right” thing as an ethical principle that requires more than what the law requires – thereby implicating every person’s own moral definition of what is right and what is wrong. Such a definition is too limited in my view.
 
I look to other principles such as trust and integrity. The term “trust” is predicated on a relationship between employer and employee, and between leaders and followers. Similarly, the term “integrity” suggests more than doing the “right thing” – it encompasses acting towards one another with honesty and truthfulness.
 
A third principle, fairness, should be considered as a separate and important value. It is something we all demand in life from friends, family and colleagues. Employees look for fairness in their interactions at a company. When fairness is present, the company can build on this foundation to raise ethical performance and conduct.
 
Each company should define its set of ethical or values to guide its behavior. This is an important process that has to resonate with all relevant stakeholders, including board members, senior management, managers, employees, and shareholders. A company cannot adopt these principles without proper regard for the personal values of its actors – from the employee to the chairperson of the board.
 
A company’s ethical principles, however, are not up for a democratic vote by its employees, but the principles have to reflect the corporate mission and inspire trust and integrity from all of its actors – these are not inconsistent ideas because individual employees have joined the company for a reason, sometimes in part because of the greater corporate mission, the company’ reputation, and the trust and integrity factor that the employee perceives.
 
When corporate ethical principles are “aligned,” the crafting of a company’s ethical principles has been successful. The company’s ethical values are properly aligned among leadership, management and employees. The principles reflect a common understanding and buy-in from each of these constituencies. This alignment has to be reinforced by corporate performance, conduct of its leaders, communications and should be subject to measurement and monitoring.
 
The company’s ethical principles and moral values should be written and communicated in the company’s code of business ethics and conduct. This important document governs business operations and sets forth principles that set standards for accountability.
 
The company’s defined values govern every aspect of its operations. The code should address the importance of corporate profitability, social responsibility, principles governing day-to-day conduct, as well as the interests of stakeholders such as governments, employees, shareholders, suppliers, communities and customers.

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COMM_a3
10. R. Denton: “EU Introduces Legislation Imposing Targeted Sanctions Against Venezuela”

(Source: Global Compliance News, 16 Nov 2017.)
 
* Author: Ross Denton, Esq., ross.denton@bakermckenzie.com, Baker McKenzie, London.
 
The EU imposed sanctions on Venezuela in response to the continuing crisis in Venezuela and the perceived deterioration of democracy, the rule of law and human rights.
 
Following on from a meeting of the EU Foreign Affairs Council (“FAC”) on November 13, at which the FAC unanimously agreed to impose restrictive measures on Venezuela, the EU has today published Council Decision 2017/2074 and Council Regulation (EU) 2017/2063 (together, the “Legislation”). The Legislation prescribes targeted sanctions against Venezuela, including an arms embargo, with immediate effect.
 
The Legislation has been formulated in response to the continuing crisis in Venezuela and the perceived deterioration of democracy, the rule of law and human rights. In particular, the EU has expressed concern over the opaque and irregular election by which the Constituent Assembly was elected, and reported violations of human rights and fundamental freedoms. The EU therefore views the Legislation as a justified tool to help foster a credible and peaceful negotiated solution.
 
The Legislation has two primary aspects:
 
  (1) Extensive export restrictions against the Venezuelan regime. These consist of a tripartite embargo on the following:
    – Arms and related material of all types as well as the financing of military activities and provision of related services such as technical assistance;
    – Equipment which might be used for internal repression as well as financial assistance relating to such equipment and provision of related services such as technical assistance;
    – Equipment, technology or software intended primarily for use in telecommunications monitoring or interception by the Venezuelan regime, as well as financial or technical assistance to install, operate or update such equipment, technology or software.
 
  (2) A legal framework for designated party controls, comprising travel bans and asset freezes, to be applied to persons who are responsible for (i) serious human rights violations; (ii) the repression of civil society and democratic opposition in Venezuela; or (ii) actions, policies or activities that otherwise undermine democracy or the rule of law.
 
At the time of publication, no designations of individuals or entities have been imposed by the EU. The Legislation states that a list of designated parties will be established and amended by the EU Council acting by unanimity upon a proposal by a Member State or the EU High Representative for Foreign Affairs and Security Policy.
 
The Legislation will remain in force until 14 November 2018, and will be kept under review. The EU reserves the right to renew or amend the Legislation as appropriate if the EU Council deems that its objectives have not been met.

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COMM_a4
11. Gary Stanley’s ECR Tip of the Day
(Source: Defense and Export-Import Update, 15 Nov 2017; available by subscription from
gstanley@glstrade.com
)
 
* Author: Gary Stanley, Esq., Global Legal Services, PC, (202) 352-3059,
gstanley@glstrade.com
.
 
EAR § 762.7(b) provides that persons located outside of the United States that are required to keep records by any provision of the EAR or by any license, order, or authorization issued thereunder shall produce all records or reproductions of records required to be kept, and make them available for inspection and copying upon request by an authorized agent, official, or employee of the Bureau of Industry and Security, the U.S. Customs Service, or a Foreign Service post, or by any other accredited representative of the U.S. Government, without any charge or expense to such agent, official or employee.

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ENEDITOR’S NOTES

 

* George S. Kaufman (George Simon Kaufman; 16 Nov 1889 – 2 Jun 1961; was an American playwright, theatre director and producer, humorist, and drama critic.)
  – “The kind of doctor I want is one who when he’s not examining me is home studying medicine.”

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EN_a313
. 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: 28 Sep 2017: 82 FR 45366-45408: Changes to the In-Bond Process [Effective Date: 27 Nov 2017.]
 
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 cancelled Supp. 1 to the NISPOM (Summary 
here
.)


EXPORT ADMINISTRATION REGULATIONS (EAR)
: 15 CFR Subtit. B, Ch. VII, Pts. 730-774

  – Last Amendment: 9 Nov 2017: 82 FR 51983-51986: Amendments to Implement United States Policy Toward Cuba

  
*
FOREIGN ASSETS CONTROL REGULATIONS (OFAC FACR)
: 31 CFR, Parts 500-599, Embargoes, Sanctions, Executive Orders
  – Last Amendment: 13 Nov 2017: 82 FR 52209-52210: Removal of Côte d’Ivoire Sanctions Regulations

 
*
FOREIGN TRADE REGULATIONS (FTR)
: 15 CFR Part 30
  – Last Amendment:
20 Sep 2017:
 
82 FR 43842-43844
: Foreign Trade Regulations (FTR): Clarification on Filing Requirements; Correction
 
  – HTS codes that are not valid for AES are available
here.
  – The latest edition (20 Sep 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, Census/AES guidance, and to many errors contained in the official text. 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: 20 Oct 2017: Harmonized System Update 1707, containing 27,291 ABI records and 5,164 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.
  – Last Amendment: 30 Aug 2017: 82 FR 41172-41173: Temporary Modification of Category XI of the United States Munitions List
  – The only available fully updated copy (latest edition: 1 Nov 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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EN_a0314. 
Weekly Highlights of the Daily Bugle Top Stories

(Source: Editor) 

Review last week’s top Ex/Im stories in “Weekly Highlights of the Daily Bugle Top Stories” published 
here

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EPEDITORIAL POLICY

* The Ex/Im Daily Update is a publication of FCC Advisory B.V., compiled by: Editor, James E. Bartlett III; Assistant Editors, Alexander P. Bosch and Vincent J.A. Goossen; and Events & Jobs Editor, John Bartlett. The Ex/Im Daily Update is 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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