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18-0125 Thursday “Daily Bugle”

18-0125 Thursday “Daily Bugle”

Thursday, 25 January 2018

TOP
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. President Signs Memoranda Concerning Critical Technology Item Shortfalls Affecting National Defense 
  1. Items Scheduled for Publication in Future Federal Register Editions
  2. Commerce/BIS: (No new postings.)
  3. DHS/ICE: “North Texas Man Sentenced to Nearly 4 Years in Federal Prison for Conspiring to Illegally Export Radiation-Hardened Integrated Circuits to Russia and China”
  4. State/DDTC: (No new postings.)
  5. Committee on Foreign Investment Releases Statement of Assistant Secretary of Commerce for Export Administration Concerning FIRRMA
  1. Defense News: “German Arms Sales Hit Roadblock as Turkey Continues Syria Campaign”
  2. WorldECR News Alert of 25 Jan
  1. C.T. Cherniak: “Compliance Incentive: Canada to Appoint a Canadian Ombudsman for Responsible Enterprise”
  2. Financier Worldwide Magazine: “Sanctions Compliance & Enforcement”
  3. H.C. Boehning, J.S. Carey & M. E Gertzman: “Economic Sanctions and Anti-Money Laundering Developments: 2017 Year in Review”
  4. Gary Stanley’s ECR Tip of the Day
  1. Full Circle Compliance and the Netherlands Defense Academy Will Present “Winter School at the Castle”, 5-9 Feb 2018 in Breda, the Netherlands
  2. ECS Will Present “ITAR/EAR Boot Camp” in Orlando on 13-14 Feb
  1. Bartlett’s Unfamiliar Quotations 
  2. Are Your Copies of Regulations Up to Date? Latest Amendments: ATF (15 Jan 2016), Customs (8 Dec 2017), DOD/NISPOM (18 May 2016), EAR (8 Jan 2018), FACR/OFAC (28 Dec 2017), FTR (20 Sep 2017), HTSUS (1 Jan 2018), ITAR (19 Jan 2018) 
  3. Weekly Highlights of the Daily Bugle Top Stories 

EXIMITEMS FROM TODAY’S FEDERAL REGISTER

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1. 
President Signs Memoranda Concerning Critical Technology Item Shortfalls Affecting National Defense

(Source: Federal Register, 25 Jan 2018.) [Excerpts of 2 separate FR notices.]
 
[FR Notice 1] 83 FR 3533: Presidential Determination Pursuant to Section 4533(a)(5) of the Defense Production Act of 1950
 
Memorandum for the Secretary of Defense
 
By the authority vested in me as President by the Constitution and the laws of the United States, including section 4533(a)(5) of the Defense Production Act of 1950 (the “Act”)(50 U.S.C. 4533(a)(5)), I hereby determine, pursuant to section 4533(a)(5) of the Act, that critical technology item shortfalls affecting domestic production of trusted advanced photomasks are critical to national defense.
 
Without Presidential action under this Act, the United States defense industrial base cannot reasonably be expected to adequately provide those capabilities or critical technology items in a timely manner. Further, purchases, purchase commitments, or other action pursuant to section 4533 of the Act are the most cost effective, expedient, and practical alternative method for meeting the need for those capabilities or critical technology items. …
 
  (Presidential Sig.)
THE WHITE HOUSE,
Washington, January 23, 2018
 
[FR Notice 2] 
83 FR 3535
: Presidential Determination Pursuant to Section 4533(a)(5) of the Defense Production Act of 1950
 
Memorandum for the Secretary of Defense
 
By the authority vested in me as President by the Constitution and the laws of the United States, including section 4533(a)(5) of the Defense Production Act of 1950 (the “Act”)(50 U.S.C. 4533(a)(5)), I hereby determine, pursuant to section 4533(a)(5) of the Act, that critical technology item shortfalls affecting thin-wall castings for military applications are critical to national defense.
 
Without Presidential action under this Act, the United States defense industrial base cannot reasonably be expected to adequately provide those capabilities or critical technology items in a timely manner. Further, purchases, purchase commitments, or other action pursuant to section 4533 of the Act are the most cost-effective, expedient, and practical alternative method for meeting the need for those capabilities or critical technology items. … 
 
  (Presidential Sig.)
THE WHITE HOUSE,
Washington, January 23, 2018

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OGSOTHER GOVERNMENT SOURCES

OGS_a12. Items Scheduled for Publication in Future Federal Register Editions
(Source: Federal Register

 
* Commerce/BIS;
  – RULES; Entity List: Additions, Deletions, and Revisions; and
  – NOTICES; Agency Information Collection Activities; Proposals, Submissions, and Approvals: Miscellaneous Short Supply Activities [Publication Dates: 26 Jan 2018.]

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OGS_a34.

DHS/ICE: “North Texas Man Sentenced to Nearly 4 Years in Federal Prison for Conspiring to Illegally Export Radiation-Hardened Integrated Circuits to Russia and China”

(Source:
DHS/ICE, 25 Jan 2018.) [Excerpts.]
 
A North Texas man was sentenced Wednesday to 46 months in federal prison for conspiring to smuggle and illegally export from the U.S. radiation-hardened integrated circuits (RHICs) for use in the space programs of China and Russia. …
 
According to the plea agreement, between about June 2015 and March 2016, Peter Zuccarelli, 62, of Plano, Texas, and his co-conspirators agreed to illegally export RHICs to China and Russia in violation of the International Emergency Economic Powers Act (IEEPA). RHICs have military and space applications, and their export is strictly controlled. 

In furtherance of the conspiracy, Zuccarelli’s co-conspirator received purchase orders from customers seeking to purchase RHICs for use in China’s and Russia’s space programs. Zuccarelli received these orders from his co-conspirator, as well as payment of about $1.5 million to purchase the RHICs for the Chinese and Russian customers. Zuccarelli placed orders with U.S. suppliers, and used the money received from his co-conspirator to pay the U.S. suppliers. In communications with the U.S. suppliers, Zuccarelli certified that his company, American Coating Technologies, was the end user of the RHICs, knowing that this was false. Zuccarelli received the RHICs he ordered from U.S. suppliers, removed them from their original packaging, repackaged them, falsely declared them as “touch screen parts,” and shipped them out of the U.S. without the required licenses. He also attempted to export what he believed to be RHICs. In an attempt to hide the conspiracy from the U.S. government, he created false paperwork and made false statements.  . . . 
 
Zuccarelli was also sentenced to three years supervised release and a $50,000 fine. … 

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6.

Committee on Foreign Investment Releases Statement of Assistant Secretary of Commerce for Export Administration Concerning FIRRMA

 
The U.S. Senate Committee on Banking, Housing and Urban Affairs has released a statement of Assistant Secretary of Commerce for Export Administration, Richard E. Ashooh, concerning the Foreign Investment Risk Review Modernization Act (FIRRMA) (S. 2098).
 
The statement is available here

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NWSNEWS

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7. Defense News: “German Arms Sales Hit Roadblock as Turkey Continues Syria Campaign”

(Source: Defense News, 25 Jan 2018.)
 
Germany’s foreign minister says major decisions on arms sales are being put on hold as deliberations on forming a new government are underway, amid growing concerns about Turkish action in northern Syria.
 
The government has come under fire for selling military equipment to NATO ally Turkey, after it became known Turkey was using German-built Leopard tanks in its drive against Kurdish fighters in northern Syria.
 
Turkey had been pushing for upgrades to those tanks to protect against mines, but Foreign Minister Sigmar Gabriel said Thursday any decisions on “critical projects” will have to wait until his Social Democrats come to a coalition agreement with Chancellor Angela Merkel’s Union bloc.
 
Talks are expected to begin Friday between the two sides, and Gabriel said the issue of arms exports would be discussed.

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NWS_a28. WorldECR News Alert of 25 Jan

(Source: WorldECR, 25 Jan 2018.)
 
  (1) OFAC publishes FAQ on Venezuela’s proposed digital currency
  (2) New OFAC designations in response to North Korea ‘ongoing development of WMD’
  (3) Germany under pressure to halt arms exports to Turkey
  (4) UK updates consolidated control list of strategic military and dual-use items
  (5) Update brings list into line with EU changes made at the end of 2017.
 
[Editor’s Note: Click on the source link below the item title
 to subscribe to WorldECR, the journal of export controls and sanctions.]

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COMMCOMMENTARY

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9. 
C.T. Cherniak: “Compliance Incentive: Canada to Appoint a Canadian Ombudsman for Responsible Enterprise”
(Source: Canada-U.S. Blog, 17 Jan 2018.)
 
* Author: Cyndee Todgham Cherniak, Esq, LexSage PC, cyndee@lexsage.com, 416-307-4168.
 
On January 17, 2018, the Government of Canada furthered its “progressive trade agenda” and responded to calls from human rights groups by announcing that it is going to watch the activities of Canadian businesses operating in overseas markets more seriously.  The Government of Canada will create an Office of the Canadian Ombudsman for Responsible Enterprise (CORE).  This will be a different type of Ombudsman.  The person appointed to this office will be charged with investigating Canadian companies operating in foreign markets rather than investigating the activities of Canadian government officials.  The Canadian Ombudsman for Responsible Enterprise will receive complaints about Canadian companies from Canadians, competitors, foreign governments, foreign citizens, not-for-profit organizations, activists and others. These complaints will be investigated.  This may be the first Corporate Responsibility Ombudsman anywhere in the world.
 
The initial scope of the Corporate Responsibility Ombudsman will be on the mining, oil and gas, and garment sectors. However, there is an expectation that the scope will expand within a year of the Corporate Responsibility Ombudsman taking office to other business sectors. This means that other business sectors should also get ready.
 
This new Corporate Responsibility Ombudsman will incentivize Canadian companies to implement compliance programs to ensure that they are complying with Canadian laws and the laws of foreign jurisdictions. In addition, the new Corporate Responsibility Ombudsman will incentivize compliance with human rights laws and Canadian values on human rights and corporate responsibility. Further, the new Ombudsman will incentivize Canadian companies operating overseas to implement policies to limit risk exposure for potential complaints to the Corporate Responsibility Ombudsman.  This would cover not only the strict wording of laws, but complying with the object and spirit of laws and value propositions and taking a wider interpretation of the laws than a court might.
 
The Corporate Responsibility Ombudsman will be empowered to independently investigate, report, recommend remedy and monitor its implementation. The Ombudsman will be given the powers to recommend a “punishment” for “bad behavior”.  If a Canadian company has broken export controls, economic sanctions, anti-bribery or other laws, the Corporate Responsibility Ombudsman file should be handed to the Royal Canadian Mounted Police for prosecution so that a court can decide if an offence has been committed.  If the “bad behavior” of the Canadian company falls short of the existing legal standards, the Corporate Responsibility Ombudsman will have the power to impose trade sanctions, such as recommending the withdrawal of consular services or cutting access to Export Development Canada trade financing or insurance products and services.  The Corporate Responsibility Ombudsman may also make non-binding recommendations concerning payment of compensation, which cannot be ordered by Canadian courts under Canada’s export controls, economic sanctions, anti-bribery and other international laws.


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10. Financier Worldwide Magazine: “Sanctions Compliance & Enforcement”

(Source: Financier Worldwide Magazine, February 2018 Issue.) [Excerpts.]
 
The sanctions compliance and enforcement landscape has been impacted in recent months by a number of significant developments, including the Trump administration’s rollback of Obama-era policies, more aggressive OFAC enforcement  actions and an uptick in coordination between government agencies pursuing sanctions violations. With global enforcement activities in 2018 likely to be as vigorous as the year before, companies are under pressure to address the complex nature of the sanctions environment and ensure their compliance obligations are fulfilled. The stakes, as ever, remain high.
 
Financier Worldwide
: In broad terms, what do you consider to be the key developments and trends to have arisen in sanctions compliance and enforcement over the past 12 months or so? …
 
[Editor’s Note: The above is an excerpt from a Financier Worldwide Magazine interview with representatives from BPE Global, Bryan Cave LLP, and Dechert LLP, Gibson, Dunn & Crutcher LLP, Mastercard, and Textron Inc. Due to copyright restrictions, we are not authorized to include the entire item. Click on the source link below the item title to read the entire interview.] 

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11H.C. Boehning, J.S. Carey & M. E Gertzman: “Economic Sanctions and Anti-Money Laundering Developments: 2017 Year in Review”

(Source: Paul Weiss, 23 Jan 2018.) [Executive Summary.]
 
* Authors: H. Christopher Boehning, Esq., cboehning@paulweiss.com; Jessica S. Carey, Esq., jcarey@paulweiss.com; and Michael E. Gertzman, Esq., mgertzman@paulweiss.com. All of Paul Weiss, New York City.
 
Executive Summary
 
Economic sanctions and anti-money laundering (“AML”) remain at the forefront of U.S. regulatory priorities. Indeed, in 2017, federal and state agencies imposed over $2.5 billion in penalties for sanctions/AML violations. And, despite its generally deregulatory agenda, the Trump administration has taken a rigorous approach in this area, particularly with respect to sanctions.  At the state level, the New York Department of Financial Services (“DFS”) continues to take aggressive action on both the regulatory and enforcement fronts.  This memorandum surveys major developments and trends in 2017 and provides an outlook for the year ahead.  We also provide some practical advice for U.S. and non-U.S. companies seeking to strengthen compliance and mitigate risk in this challenging environment.
 
Last year witnessed a number of dramatic changes to the economic sanctions landscape. President Trump has continued the recent trend of using economic sanctions as a powerful national security and foreign policy tool, and Treasury Secretary Mnuchin estimates that he spends “probably over 50 percent” of his time on national security and sanctions issues. [FN/1] In addition, the U.S. Congress asserted its authority on sanctions by passing the Countering America’s Adversaries Through Sanctions Act (“CAATSA”), which President Trump signed into law on August 2, 2017. [FN/2]  The administration’s and Congress’s actions have reshaped President Obama’s sanctions policies, significantly expanded the threat of secondary sanctions, and created new uncertainty and risks for U.S. and non-U.S. companies across industries.
 
The Trump administration has taken an aggressive stance towards North Korea, broadly threatening the imposition of secondary sanctions against non-U.S. persons conducting business involving North Korea. With respect to Iran, President Trump refused to certify that the suspension of sanctions under the Iran deal was in the U.S.’s national interest, and has threatened to reinstitute the sanctions relief granted pursuant to the deal. And, while the president this month extended waivers allowing the nuclear deal to remain intact, he threatened that this was for the “last time.”  The Trump administration also imposed a new and novel sanctions program in response to events in Venezuela, implemented new Global Magnitsky Act sanctions targeting human rights abuses and government corruption, and re-imposed certain Cuba-related restrictions that had been relaxed under the Obama administration.  Finally, 2017 saw the revocation of the longstanding U.S. trade embargo against Sudan.  On the enforcement side, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) has continued to push the boundaries of its jurisdiction and intensified its focus on non-financial entities, as demonstrated by its largest ever settlement with Chinese Zhongxing Telecommunications Equipment Corporation (“ZTE”).
 
Enforcement of the Bank Secrecy Act/anti-money laundering (“BSA/AML”) laws-and their state analogues-remains a high priority for federal prosecutors and regulatory agencies, as well as the DFS. Prosecutors and regulators remain willing to impose substantial penalties, as when the Department of Justice (“DOJ”) and Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) reached a $586 million resolution with Western Union, and DFS issued major consent orders against non-U.S. banks. FinCEN also used its USA PATRIOT Act Section 311 authority to designate Bank of Dandong an institution of “primary money laundering concern” based on its alleged processing of North Korean transactions, thus cutting the institution off from the U.S. financial system.  The Securities and Exchange Commission (“SEC”) also took several enforcement actions against broker/dealers that demonstrate its continued focus on AML enforcement.
 
On the policy side, last year FinCEN issued significant guidance, and DFS’s groundbreaking Part 504 regulation on sanctions/AML requirements went into effect. Congress has also focused on AML issues with the introduction of multiple bills designed to modernize and enhance the Bank Secrecy Act. [FN/3] Finally, last year’s revelations of the Paradise Papers and the new revelations related to the “Russian Laundromat” money laundering scheme-like the release of the Panama Papers the year before-suggest that non-governmental actors, including investigative journalists and hackers, will continue to be an important force in spurring regulatory inquiries and prompting in-house reviews. …
 
——-
  [FN/1] Angela Greiling Keane, Pro Policy Summit: Live Updates and highlights, Politico (Sept. 14, 2017), available here.
  [FN/2] See our prior Paul, Weiss memorandum, President Trump Signs Sanctions Legislation Targeting Russia, North Korea and Iran, Creating New Compliance Risks for U.S. and Non-U.S. Companies (Aug. 3, 2017), available here.
  [FN/3] See, e.g., H.R. 4373, 115th Cong. (1st Sess. 2017), available here; S. 1241, 115th Cong. (1st Sess. 2017), available here.

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12. Gary Stanley’s ECR Tip of the Day

(Source: Defense and Export-Import Update, 23 Jan 2018; available by subscription from
gstanley@glstrade.com
.)
 
* Author: Gary Stanley, Esq., Global Legal Services, PC, (202) 352-3059,
gstanley@glstrade.com
.
 
EAR Part 772 defines the term “commodity” as any article, material, or supply except technology and software.

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TEEX/IM TRAINING EVENTS & CONFERENCES

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Full Circle Compliance and the Netherlands Defense Academy Will Present “Winter School at the Castle”, 5-9 Feb 2018 in Breda, the Netherlands

 
The Netherlands Defense Academy and Full Circle Compliance present a winter seminar, “Compliance and Integrity in International Military Trade,” 5-9 February 2018, in the charming town of Breda, the Netherlands, an hour’s drive south of Amsterdam. Many hotels and restaurants are within walking distance of the Defense Academy, which is the Dutch equivalent of the U.S. military academies. The course is designed for NATO+ military officers, government employees, and employees of NATO+ defense contractors. Participants will receive certificates of completion from the Academy.

*
Registration & Information: please, complete the seminar registration form and send a copy to events@fullcirclecompliance.eu. More information is available 
at the Full Circle Compliance website or via events@fullcirclecompliance.eu

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(Source: Suzanne Palmer, 
spalmer@exportcompliancesolutions.com.)

* What: ITAR/EAR Boot Camp, Orlando, FL
* When: 13-14 February 2018
* Sponsor: Export Compliance Solutions (ECS)
* ECS Speaker Panel:  Suzanne Palmer, Mal Zerden
* Register Here or by calling 866-238-4018 or email

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ENEDITOR’S NOTES


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EN_a316
. 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.  The latest amendments 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: 8 Dec 2017: 82 FR 57821-57825: Civil Monetary Penalty Adjustments for Inflation
 
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 Amendments: 8 Jan 2018: 83 FR 709-711: Revisions, Clarifications, and Technical Corrections to the Export Administration Regulations; Correction; and 83 FR 706-709: Civil Monetary Penalty Adjustments for Inflation

  
*
FOREIGN ASSETS CONTROL REGULATIONS (OFAC FACR)
: 31 CFR, Parts 500-599, Embargoes, Sanctions, Executive Orders
  – Last Amendment: 28 Dec 2017: 
82 FR 61450-61451: Iraq Stabilization and Insurgency 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 (1 Jan 2018) 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 2018: 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: 1 Jan 2018: Updated HTS for 2018

  – 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: 19 Jan 2018: 83 FR 2738: Department of State 2018 Civil Monetary Penalties Inflationary Adjustment; Correction
  – The only available fully updated copy (latest edition: 19 Jan 2018) 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_a0317
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, provided attribution is given to “The Export/Import Daily Bugle of (date)”. 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.

* SUBSCRIPTIONS: Subscriptions are free.  Subscribe by completing the request form on the Full Circle Compliance website.

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