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18-0129 Monday “Daily Bugle”

18-0129 Monday “Daily Bugle”

Monday, 29 January 2018

TOP
The Daily Bugle is a free daily newsletter from Full Circle Compliance, containing changes to export/import regulations (ATF, DOE/NRC, Customs, NISPOM, EAR, FACR/OFAC, FTR/AES, HTSUS, and ITAR), plus news and events.  Subscribe 
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  1. Justice Adjusts Civil Monetary Penalties for Inflation  
  2. State Accepts Membership Applications for DTAG 
  1. Items Scheduled for Publication in Future Federal Register Editions
  2. Commerce/BIS Issues TDO Against Gulnihal Yegane and Others of Istanbul, Turkey, for Alleged Export Violations
  3. State/DDTC: (No new postings.)
  4. UK DIT/ECO Publishes Guidance on Completing MOD Form 680 Applications
  1. The Australian: “Bid to Future-Proof Hi-Tech Defense Discoveries”
  2. Fox Business: “U.S. Companies Brace for Wider Scrutiny of Chinese Deals”
  3. News.com.au: “Australia Set to Become a Major Manufacturer and Exporter of Military Hardware”
  1. O. Torres: “Foreign Companies Must be Mindful of the Extraterritorial Reach in the Newest U.S. Sanctions Law Developments”
  2. O. Coulon: “EU Commission Issues Notice to Stakeholders on Impact of Brexit”
  3. T. Murphy: “More Private Party-Initiated Trade Enforcement Actions”
  4. Gary Stanley’s ECR Tip of the Day
  1. Monday List of Ex/Im Job Openings: 147 Jobs Posted, Including 14 New Jobs
  1. ECTI Presents “Fundamental Research Exclusion: Your Guide to Properly Applying It – Part Two” Webinar, 8 Mar
  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 (26 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

EXIM_a1

1. 
Justice Adjusts Civil Monetary Penalties for Inflation

(Source:
Federal Register, 29 Jan 2018.) [Excerpts.]
 
83 FR 3944-3948: Civil Monetary Penalties Inflation Adjustment
 
* AGENCY: Department of Justice.
* ACTION: Final rule.
* SUMMARY: The Department of Justice is adjusting for inflation the civil monetary penalties assessed or enforced by components of the Department, in accordance with the provisions of the Bipartisan Budget Act of 2015 (“BAA”), for penalties assessed after January 29, 2018, with respect to violations occurring after November 2, 2015.
* DATES:
This rule is effective January 29, 2018. …
* SUPPLEMENTARY INFORMATION: … In accordance with the provisions of the BBA, on June 30, 2016 (81 FR 42491), the Department of Justice published an interim rule to adjust for inflation the civil monetary penalties assessed or enforced by components of the Department after August 1, 2016, with respect to violations occurring after November 2, 2015, the date of enactment of the BBA. Readers may refer to the Supplementary Information (also known as the preamble) of the Department’s 2016 interim rule for additional background information regarding the statutory authority for adjustments of civil monetary penalty amounts to take account of inflation and the Department’s past implementation of inflation adjustments.
  The BBA also provides for agencies to adjust their civil penalties on January 15 of each year to account for inflation during the preceding year, rounded to the nearest dollar. Accordingly, on February 3, 2017 (82 FR 9131), the Department published a final rule to adjust for inflation the civil monetary penalties assessed or enforced by components of the Department after that date, with respect to violations occurring after November 2, 2015.
 
Inflation Adjustments Made by This Rule
 
  As required, the Department is publishing this final rule to adjust the civil penalties that were most recently adjusted as of February 3, 2017. Under the statutory formula, the adjustments made by this rule are based on the Bureau of Labor Statistics’ Consumer Price Index for October 2017. The OMB Memorandum for the Heads of Executive Departments and Agencies M-18-03 (Dec. 15, 2017), available
here (last visited Jan. 1, 2018), instructs that the applicable inflation factor for this adjustment is 1.02041. Accordingly, this rule adjusts the civil penalty amounts in 28 CFR 85.5 by applying this inflation factor mechanically to each of the civil penalty amounts listed (rounded to the nearest dollar). …
  This rule adjusts for inflation civil monetary penalties within the jurisdiction of the Department of Justice for purposes of the Inflation Adjustment Act, as amended. Other agencies are responsible for the inflation adjustments of certain other civil monetary penalties that the Department’s litigating components bring suit to collect. The reader should consult the regulations of those other agencies for inflation adjustments to those penalties.
 
Effective Date of Adjusted Civil Penalty Amounts
 
  Under this rule, the adjusted civil penalty amounts are applicable only to civil penalties assessed after January 29, 2018, with respect to violations occurring after November 2, 2015, the date of enactment of the BBA.
  The penalty amounts set forth in the existing table in 28 CFR 85.5 are applicable to civil penalties assessed after August 1, 2016, and on or before the effective date of this rule, with respect to violations occurring after November 2, 2015. Civil penalties for violations occurring on or before November 2, 2015, and assessments made on or before August 1, 2016, will continue to be subject to the civil monetary penalty amounts set forth in the Department’s regulations in 28 CFR parts 20, 22, 36, 68, 71, 76, and 85 as such regulations were in effect prior to August 1, 2016 (or as set forth by statute if the amount had not yet been adjusted by regulation prior to August 1, 2016). …
 

[Editor’s Note: Excerpt from overview of Justice civil monetary penalty adjustments. Source:
83 FR 3944-3948: Civil Monetary Penalties Inflation Adjustment.] 

 
  Dated: January 19, 2018.
Jefferson B. Sessions III, Attorney General.

* * * * * * * * * * * * * * * * * * * *

EXIM_a2

2. 
State Accepts Membership Applications for DTAG

(Source:
Federal Register, 29 Jan 2018.)
 
83 FR 4114-4115: Defense Trade Advisory Group; Notice of Membership
 
* AGENCY: Department of State.
* ACTION: Notice.
 
The U.S. Department of State’s Bureau of Political-Military Affairs’ Defense Trade Advisory Group (DTAG) is accepting membership applications. The Bureau of Political-Military Affairs is interested in applications from subject matter experts from the United States defense industry, relevant trade and labor associations, academic, and foundation personnel.
  The DTAG was established as an advisory committee under the authority of 22 U.S.C. Sections 2651a and 2656 and the Federal Advisory Committee Act, 5 U.S.C. App. (“FACA”). The purpose of the DTAG is to provide the Bureau of Political-Military Affairs with a formal channel for regular consultation and coordination with U.S. private sector defense exporters and defense trade organizations on issues involving U.S. laws, policies, and regulations for munitions exports. The DTAG advises the Bureau on its support for and regulation of defense trade to help ensure that impediments to legitimate exports are reduced while the foreign policy and national security interests of the United States continue to be protected and advanced in accordance with the Arms Export Control Act (AECA), as amended. Major topics addressed by the DTAG include (a) policy issues on commercial defense trade and technology transfer; (b) regulatory and licensing procedures applicable to defense articles, services, and technical data; (c) technical issues involving the U.S. Munitions List (USML); and (d) questions relating to actions designed to carry out the AECA and International Traffic in Arms Regulations (ITAR).
  Members are appointed by the Assistant Secretary of State for Political-Military Affairs on the basis of individual substantive and technical expertise and qualifications, and must be representatives of United States defense industry, relevant trade and labor associations, academic, and foundation personnel. In accordance with the DTAG Charter, all DTAG members must be U.S. citizens, and DTAG members will represent the views of their organizations. All DTAG members shall be aware of the Department of State’s mandate that arms transfers must further U.S. national security and foreign policy interests.
  DTAG members also shall be versed in the complexity of commercial defense trade and industrial competitiveness, and all members must be able to advise the Bureau on these matters. While members are expected to use their expertise and provide candid advice, national security and foreign policy interests of the United States, as well as the interests of the entities they represent, shall be the bases for all policy and technical recommendations.
  DTAG members’ responsibilities include:
 
  – Service for a consecutive two-year term which may be renewed or terminated at the discretion of the Assistant Secretary of State for Political-Military Affairs (membership shall automatically terminate for members who fail to attend two consecutive DTAG plenary meetings).
  – Making recommendations in accordance with the DTAG Charter and the FACA.
  – Making policy and technical recommendations within the scope of the U.S. commercial export control regime as mandated in the AECA, the ITAR, and appropriate directives.
 
  Please note that DTAG members may not be reimbursed for travel, per diem, and other expenses incurred in connection with their duties as DTAG members. How to apply: Applications in response to this notice must contain the following information: (1) Name of applicant; (2) affirmation of U.S. citizenship; (3) organizational affiliation and title, as appropriate; (4) mailing address; (5) work telephone number; (6) email address; (7) resume; and (8) summary of qualifications for DTAG membership.
  This information may be provided via two methods:
  
  – Emailed to the following address:
DTAG@State.Gov. In the subject field, please write, “DTAG Membership Application.”
  – Send in hardcopy to the following address: Mr. Glenn E.
Smith, PM/DDTC, SA-1, 12th Floor, Directorate of Defense Trade
Controls, Bureau of Political Military Affairs, U.S. Department of
State, Washington, DC 20522-0112.
  All applications must be postmarked by
March 2, 2018.
 
Anthony Dearth, Alternate Designated Federal Officer, Defense Trade Advisory Group, 
Department of State.
 

[Editor’s Note: the
next DTAG meeting is scheduled for 1 February 2018 in Washington DC. DTAG’s current membership list (released by DDTC on 17 Sep 2018) is available
here. More information on DTAG is available
here.] 

* * * * * * * * * * * * * * * * * * * *

OGSOTHER GOVERNMENT SOURCES

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

* U.S.-China Economic and Security Review Commission; NOTICES; Hearing [Publication Date: 30 Jan 2018.]
* * * * * * * * * * * * * * * * * * * *

OGS_a24.

Commerce/BIS Issues TDO Against Gulnihal Yegane and Others of Istanbul, Turkey, for Alleged Export Violations     


(Source:
Commerce/BIS, 26 Jan 2018.)   
 
* Respondent: Gulnihal Yegane, Trigron Lojistik Kargo Limited Sirketi, Ufuk Avia Lojistik Limited Sirketi and RA Havacilik Lojistik Ve Tasimacilik Ticaret Limited Sirketi of Istanbul, Turkey.
* Charges: Gulnihal Yegan, who owns or controls or is otherwise affiliated with Tigron Lojistik Kargo and the other companies at issue, was placed on BIS’s Entity List (Suppl. 4 to EAR Part 744) on 12 Dec 2013 (see 78 FR 75,464) for engaging in activities contrary to the national security or foreign policy interest of the U.S., and particularly because of her involvement in the development and operation of a procurement scheme that directly supported the operation of Iranian airline Mahan Airways (see 78 FR 75,463). Evidence presented relates to transactions that occurred between at least Sep 2016 through at least Dec 2017.   
* Order: Temporary denial, for a period of 180 days, of export privileges (“Temporary Denial Order” or “TDO”).
* Date of Order: 26 Jan 2018.

* * * * * * * * * * * * * * * * * * * *

* * * * * * * * * * * * * * * * * * * * 

OGS_a4
6.

UK DIT/ECO Publishes Guidance on Completing MOD Form 680 Applications

(Source:
UK DIT/ECO
, 29 Jan 2018.)
 
The Export Control Organization (ECO) of the UK Department of International Trade (DIT) has released Notice to Exporters 2018/02: guidance on completing MOD form 680 applications.
 

The guidance is available here.

* * * * * * * * * * * * * * * * * * * * 

NWSNEWS

NWS_a1
7. The Australian: “Bid to Future-Proof Hi-Tech Defense Discoveries”

(Source:
The Australian, 29 Jan 2018.) [Excerpts.]
 
A parliamentary review of laws stopping sensitive defense equipment from getting into the wrong hands will examine “dual-use” technologies research projects linked to China’s military at Australian universities.
 
The audit, due in April, follows the Turnbull government’s establishment of a $3.8 billion loan scheme designed to boost defense exports. Government ministers have insisted there are enough controls in place to stop military technology developed in Australia being used against the country by possible enemies.
 
Security and China-focused aca­demics last year called for greater scrutiny of research collaboration projects between Australian universities, Chinese tech­nology companies and Chinese state-owned enterprises. …
 
Defense Minister Marise Payne’s office told 
The Australian that the review of the Defense Trade Controls Act would commence in April. She said last month that “some of the issues that have been raised recently will be considered in the context” of the review. … 

* * * * * * * * * * * * * * * * * * * * 

NWS_a28. Fox Business: “U.S. Companies Brace for Wider Scrutiny of Chinese Deals”

(Source:
Fox Business, 29 Jan 2018.) [Excerpts.]
 
Lawmakers are moving to crack down on the flow of U.S. technology to foreign investors, creating potential problems for a number of American companies that have bet big on partnering with China.
 
The Senate and House, with the backing of the White House, are working on bipartisan legislation to broaden the authority of the Committee on Foreign Investment in the U.S., a multi-agency body that has oversight of deals that could lead to the transfer of sensitive technology to rival countries. The current CFIUS statute doesn’t single out any country, but in recent years, the committee has often been focused on deals involving China.
 

Currently, CFIUS can recommend the president block foreign entities from buying majority stakes in U.S. companies; the new bill would let the committee make similar recommendations for deals involving minority investments and joint ventures, along with transactions that it determines involve “emerging technologies.” … 

* * * * * * * * * * * * * * * * * * * * 

NWS_a39. News.com.au: “Australia Set to Become a Major Manufacturer and Exporter of Military Hardware”

(Source:
News.com.au, 29 Jan 2018.) [Excerpts.]
 
Australia is set to provide key military hardware to a global defense market which is growing rapidly as uncertainty spreads. …
 
The Turnbull government is spending $200 billion over 10 years on defense industries, but the domestic market is not big enough to sustain the manufacturing through peaks and troughs. …
 
Companies can’t send off military hardware to just anyone.  
There are controls to ensure the buyers don’t offend Australia’s foreign policy, strategic and humanitarian priorities. For example, no matter how much money the Taliban might offer, it won’t be getting any Australian equipment.
 
Sales are overseen by the Defense Export Controls which has final say on the destinations of items designed for, or adaptable to, military use – or those which are just plain lethal.
 
The DEC also keeps watch on exports of “items and technologies that may be used or adapted for use in a military program or contribute to the development and production of chemical, biological or nuclear weapon systems”. … 

* * * * * * * * * * * * * * * * * * * * 

COMMCOMMENTARY

COMM_a01
10. O. Torres: “Foreign Companies Must be Mindful of the Extraterritorial Reach in the Newest U.S. Sanctions Law Developments”

(Source: Torres Law PLLC, 29 Jan 2018.)
 
* Authors: Olga Torres, Esq., Torres Law PLLC.  Contact information: +1 214-593-7120, info@torrestradelaw.com.
 
Insights Foreign Companies Must be Mindful of the Extraterritorial Reach in the Newest U.S. Sanctions Law Developments by: Olga Torres, Managing Member
 
Pursuant to Section 231(a) of the Countering America’s Adversaries Through Sanctions Act (“CAATSA” or “the Act”), [FN/1]  beginning January 29, 2018, President Trump is required to impose five or more of the Act’s laundry list of sanctions, found in Section 235, on persons that the President has determined to have knowingly engaged in a “significant transaction” with a person that is part of, or operating for or on behalf of, the defense or intelligence sectors of the Russian government. This article reviews the extraterritorial impact of the Act on non-U.S. persons, and provides some guidance regarding how to best prepare for these new developments.

The continuing development of these sanctions is particularly important for non-U.S. companies because CAATSA and subsequent enforcement measures make it progressively more difficult for foreign companies to conduct business in the three targeted countries, particularly Russia. As briefly discussed below, in many respects, the Act’s establishment of secondary sanctions will impact non-U.S. persons more than U.S. persons who are already for the most part restricted from conducting business in these regions.
 
With respect to Iran, CAATSA codifies existing sanctions against the Islamic Revolutionary Guard Corps (“IRGC”) and the Quds Force (“IRGC-QF”) by granting the President authority to add additional persons to the Specially Designated Nationals (“SDN”) list and forcing the President to impose sanctions on any “person who knowingly violates the arms embargo against Iran.” With respect to North Korea, CAATSA expands the list of activities and persons for which sanctions can be applied, including activities related to precious metals and aviation, as well as companies that provide insurance services for North Korean vessels or deal with North Korean financial institutions. The Iran and North Korean sanctions will not impact American companies much since American businesses are for the most part already restricted from doing business in these countries. However, the Trump administration will likely aggressively enforce these new extraterritorial measures as seen, for example, in OFAC’s recent designation of Chinese individuals and entities for facilitating transactions on behalf of North Korea even when these transactions did not involve U.S. persons or otherwise appeared to be subject to U.S. jurisdiction. Thus, companies in China, Russia, and other countries that still trade or conduct transactions with Iran or North Korea should closely monitor these new developments.
 
Finally, with respect to Russia, CAATSA codifies existing sectoral sanctions, including those related to the railway, mining, and financial sectors, as well as projects in which Russian persons subject to Directive 4 under Executive Order 13662 have a thirty-three percent interest, such as deep water, Artic offshore, and shale projects that produce oil. The Act’s Russian sanctions will impact non-U.S. companies who provide support to Russian energy export pipeline projects or who engage in significant transactions with persons in the Russian defense and intelligence sectors. The applicable part of CAATSA states that “the President shall impose five or more of the sanctions described in Section 235 of the Act with respect to a person that knowingly, on or after [August 2, 2017], engages in a significant transaction with a person that is part of, or operates for or on behalf of, the defense or intelligence sectors of the Government of the Russian Federation.” On October 27, 2017, the Department of State (“the Department”) published a list pursuant to Section 231(d) of the Act (“Section 231(d) List”), which lists individuals and entities that are involved in Russian defense and intelligence sectors. Notably, inclusion in this list does not mean that these companies will be listed as Specially Designated Nationals (“SDN”), which would require the freezing of assets. Also, because the listed individuals are not SDNs, the government will not be applying OFAC’s “50% rule” requiring companies to check the ownership of subsidiaries and affiliates of Section 231(d) listed persons.
 
To prepare for enforcement of sanctions under the Act, Companies conducting business in Russia should consult the Department’s public guidance concerning Section 231(d) (“the Guidance”). First, the Department will sanction any person who knowingly engages in business with any of the persons listed on the Section 231(d) List. Additionally, the Guidance states that the Department will determine whether a transaction is “significant” by considering the totality of the circumstances surrounding the transaction and weighing various factors. Relevant factors include the significance of the transaction to national security and foreign policy interests, and whether it has a significant adverse effect on those interests; the nature and magnitude of the transactions; and the relation and significance of the transaction to the defense or intelligence sector of the Russian government. These factors comprise a “flexible standard” that includes weighing the scope, magnitude, and size of the transaction, as well as the types of items transferred and national security and foreign policy interests at stake. Transactions that are solely for a civilian end user or civilian use (and do not involve intelligence entities listed in the Section 231(d)) will not be subject to sanctions.
 
****
 
Both U.S. and particularly non-U.S. companies must pay close attention to the implementation of CAATSA and any sanctions that follow for persons that violate it. The Russian-related sanctions of Section 231 in particular have broad extraterritorial reach. Even after the publication of the Guidance, how and to whom these sanctions will be applied is unclear. There is no clear definition of a “significant transaction,” and the Department has provided few practical examples of the type of conduct that would trigger sanctions under the Act.
 
In preparation of the January 29, 2018 implementation of Section 231, companies, both in the U.S. and abroad, should review their contracts and supply chains to determine whether they conduct any business with persons listed on the Section 231(d) List. If the transactions are considered significant, you must cease such transactions or face potential Section 235 sanctions. As the January 29, 2018 date approaches, we will continue monitoring any new developments regarding the planned enforcement of CAATSA, as well as what this will mean for persons doing business with Section 231(d)-listed persons. In the event that you have transactions with a 231(d)-listed individual or entity and wish to determine if these transactions are significant, please feel free to contact us.
 
——-
  [FN/1] On August 2, 2017, President Trump signed the Countering America’s Adversaries Through Sanctions Act, which codifies existing U.S. sanctions against Iran, North Korea, and Russia.

* * * * * * * * * * * * * * * * * * * * 

COMM_a2
11. O. Coulon: “EU Commission Issues Notice to Stakeholders on Impact of Brexit”

(Source:
World Trade Controls Blog, 26 Jan 2018.)
 
* Author: Olivier Coulon, Esq.,
Olivier.Coulon@loyensloeff.com; Loyens & Loeff, Brussels.  
 
On 25 January 2018, the EU Commission issued a
notice regarding the impact of Brexit on future movements of controlled goods.
 
In its notice, the EU Commission recalls that, unless an agreement would provide for another date, the United Kingdom shall be treated as a third country as from 30 March 2019. The impact is expected to be significant, not only for the EU, but also and in particular for private parties, which are reminded here of the legal repercussions of the future Brexit.
 
Unless otherwise provided in a transitional agreement, different types of goods will be subject to import/export licenses as from 30 March 2019. Amongst these goods are waste, certain hazardous chemicals, specimens of endangered species, rough diamonds, as well as dual-use and military goods.
 
While the notice is addressed to stakeholders engaged in shipments of goods subject to import or export licenses, it is also of particular interest to entities engaged in transfers of controlled technologies.
 
Private stakeholders dealing with the United Kingdom and controlled goods and technologies should plan ahead of 30 March 2019 so as to already mitigate the future impact of Brexit. Increased compliance costs, triggered by heavier administrative procedures, are to be expected, together with potential uncertainties and slowdowns to be incurred in the beginning of 2019.

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COMM_a3
12. T. Murphy: “More Private Party-Initiated Trade Enforcement Actions”

(Source: Author, 29 Jan 2018.)
 
* Author: Ted Murphy, Esq., Baker McKenzie, 
ted.murphy@bakermckenzie.com.
 
We wanted to bring to your attention two recent qui tam case settlements involving the underpayment of customs duties.  They are as follows:
 
  – Further to our message below where Z Gallerie agreed to settle with the U.S. Department of Justice (“DOJ”) for $15 million, the DOJ recently announced that Bassett Mirror Co. (“Bassett”) agreed to pay $10.5 million to settle allegations that it violated the False Claims Act (“FCA”) by underpaying antidumping duties.  Total settlements in this case have now reached $25.5 million.  The underlying complaint, initiated by a competitor, alleged that between January 2009 and February 2014, several companies deliberately misclassified wooden bedroom furniture as non-bedroom furniture on its official import documents to avoid paying antidumping duties.  A copy of the most recent DOJ press release is available
here.
  – DOJ announced that a textile importer, American Dawn, and three company executives, agreed to pay more than $2.3 million to settle allegations that they violated the FCA by intentionally misclassifying goods in order to pay lower duty rates.  The underlying complaint, initiated by a former employee, alleged that for more than a decade American Dawn intentionally misclassified certain textile articles, including bath towels and shop towels, as polishing cloths in order to pay a lower duty rate.  The press release is available
here.
 
These cases and settlements are interesting for a few reasons.
 
First, both cases were initiated by whistleblowers under the FCA.  In Bassett/Z Gallerie, a competitor initiated the court action and, in American Dawn, it was a former employee.  The whistleblowers in these cases with receive a sizeable portion of the settlements.  This incentive will continue to feed the trend of there being an increasing number of private-party initiated trade enforcement actions.
 
Second, DOJ appears to be settling these cases for less than is available to it under applicable laws.  Under the FCA, maximum liability includes the unpaid duties, three times the unpaid duties, $11,000 for each false claim (i.e., each import entry), plus attorneys’ fees.  In addition, under the Tariff Act of 1930, maximum penalties include the full value of the imported merchandise (because the government alleged intentional evasion of duties, rather than negligence or gross negligence).  Considering that the PRC-wide rate for wooden bedroom furniture is ~216%, the importers could have been liable for many millions more than the government ultimately agreed to settle for.  It is unclear why the government would agree to what could be considered “generous” settlements, particularly since they appear to be “global” in nature (they resolve not just the FCA liability, but the liability imposed under the Tariff Act of 1930, as well), but it is unlikely that such generous terms would be afforded by CBP in an stand-alone administrative proceeding.
 
Finally, in both press releases, government agencies restated their commitment to protecting the economy by investigating alleged evasions of customs duties.  For example, in the American Dawn settlement announcement, the director of the CBP field office in Atlanta stated, “[t]his settlement agreement is another example of CBP’s day to day collaborative efforts between U.S. Customs and Border Protection Officers at ports of entry, Import Specialists with the Centers of Excellence and Expertise, and Immigration & Customs Enforcement Homeland Security Investigations to protect the American public and the U.S. economy.”
 

In light of this, all importers should make sure that they effective internal controls in place over customs matters that include a mechanism for employees to raise legitimate compliance-related concerns.  In our experience, companies can generally protect themselves from enforcement actions (FCA or otherwise) by having reasonable internal controls.

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COMM_a4
13. Gary Stanley’s ECR Tip of the Day

(Source: Defense and Export-Import Update, 25 Jan 2017. Available by subscription from 
gstanley@glstrade.com.)
 
* Author: Gary Stanley, Esq., Global Legal Services, PC, (202) 352-3059,  
gstanley@glstrade.com.
 
DFARS clause 252.204-7012 was structured to ensure that unclassified DoD information residing on a contractor’s internal information system is safeguarded from cyber incidents, and that any consequences associated with the loss of this information are assessed and minimized via the cyber incident reporting and damage assessment processes. In addition, by providing a single DoD-wide approach to safeguarding covered contractor information systems, the clause prevents the proliferation of cyber security clauses and contract language by the various entities across DoD. DFARS clause 252.204-7012 is required in all solicitations and contracts, including solicitations and contracts using Federal Acquisition Regulation (FAR) part 12 procedures for the acquisition of commercial items. The clause is not required for solicitations and contracts solely for the acquisition of COTS items. The clause is not required to be applied retroactively, but that does not preclude a contracting officer from modifying an existing contract to add the clause. When the acquisition of commercial items involves CDI, such as in some cases when commercial items, services, or offerings are tailored to meet a particular customer’s requirement, DFARS clause 252.204-7012 will apply to commercial items involving CDI. The requirements in DFARS clause 252.204-7012 must be implemented when CDI is processed, stored, or transits through an information system that is owned, or operated by or for, the contractor, or when performance of the contract involves operationally critical support. The contracting officer shall indicate in the solicitation/contract when performance of the contract will involve, or is expected to involve, CDI or operationally critical support. All CDI provided to the contractor by the Government will be marked or otherwise identified in the contract, task order, or delivery order.

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MSEX/IM MOVERS & SHAKERS

MS_a214. Monday List of Ex/Im Job Openings; 147 Jobs Posted This Week, Including 14 New Jobs

(Source: Editor)  
 

Published every Monday or first business day of the week. Please, send job openings in the following format to 
jobs@fullcirclecompliance.eu.

 
* COMPANY; LOCATION; POSITION TITLE (WEBLINK); CONTACT INFORMATION; REQUISITION ID
 

#
” New or amended listing this week (
14 New Jobs
)

* Aerojet Rocketdyne; Huntsville, AL, or Camden, AR; 
Senior International Trade and Compliance Analyst
; Requisition ID: 12620

*
AJC Logistics; Atlanta, GA; NVOCC Export Specialist;

* 
AJC Logistics; Atlanta, GA; NVOCC Export Specialist;

* Alcon Laboratories, Inc.; Fort Worth, TX;
Manager, Customs Compliance; Requisition ID: 227402BR

* Allports Forwarding Inc.; Portland, OR;
Import Entry Specialist

*
ASM; Phoenix, AZ; Senior Manager Global Trade Compliance; Requisition ID: 7421

* BAE Systems; Los Angeles, CA; 
Program Manager, International and Offset; Requisition ID: 33778BR

* Baylor University; Waco, TX;
Manager/Director of Export Compliance; Vacancy ID S030428

* Bell Helicopter; Fort Worth, Texas;
Trade Compliance Specialist III;

* Boecore; Colorado Springs; 
Export Compliance/Contracts Support
; Julie Perkins, 719-465-5341; Requisition ID: 8289



Boeing; Multiple Locations;
Trade Control Specialist
; Requisition ID: 
1700011280

*
 
Boeing; Queensland, Australia
Trade Control Specialist
; Requisition ID: 
1700027720

*
 
Boeing; St Louis, MO; 
Trade Control Specialist
; Requisition ID: 1700011280 

* Boeing; Crawley, United Kingdom;
Trade Compliance Project Manager – 12 months FTC; Requisition ID: 
1800000286

* BMW North America; Woodcliff Lake, NJ;
Senior Analyst, Trade Compliance; Requisition ID: 170004RD
# Buehler; Lake Bluff, IL;
Manager, Compliance and Logistics; Requisition ID: 2018-004

Carl Zeiss, Inc.; Thornwood, NY;
Trade Compliance Specialist
; Internal Number: 13309

* Crane ChemPharma & Energy; Long Beach, CA;
Import Export Compliance Specialist;

* CSRA; San Diego, CA;
Mid-Level FMS Case Analyst; Requisition ID: RQ 3035

* CSRA; San Diego, CA;
Mid-level Case Analyst for MIDS FMS Program; Requisition ID: RQ6975
 

*
 CSRA; San Diego, CA; 
Senior Case Analyst for MIDS FMS Program
; RQ6763 

* CSRA; San Diego, CA;
Senior FMS Case Analyst; Requisition ID: 3004

* CSRA; San Diego, CA; 
Senior FMS Financial Analyst; Requisition ID: 
RQ3010

*
 DynCorp International; Tampa, FL; Foreign Disclosure Officer; Requisition ID: PR1701977

* Eaton; Syracuse, NY;
Global Logistics Manager; Requisition ID: 036620

* Eaton; Shanghai Shi, China;
Global Ethics and Compliance Director, APAC; Requisition ID: 039260

* Elbit Systems of America; Merrimack, NH or Fort Worth, TX; 
Trade Specialist I (Export); Requisition ID 5869
* Elbit Systems of America; Merrimack, NH or Fort Worth, TX;  
Trade Specialist I (Import); Requisition ID 5869

Elbit Systems of America; Fort Worth, TX; 
Trade Specialist II
; Requisition ID 5862

* EoTech Technologies; Ann Arbor, MI;
Trade Compliance Manager; Requisition ID: 092335

* Expeditors; Portland, OR;
US Export Compliance Consultant;

* Expeditors; Sunnyvale, CA;
Customs Compliance Supervisor;

* Expeditors; Atlanta, GA; 
Customs Brokerage Agent


* Expeditors; Aalsmeerderbrug
, NH – Netherlands; 
Import en Export Control Medewerker

* Expeditors; Krefeld, Germany; 
Sachbearbeiter Import/ Export;
* Expeditors; Bedfont, United Kingdom;
Customs Brokerage Clerk;
* Expeditors; Birmingham, UK;
Customs Brokerage Agent;

* Expeditors; Düsseldorf, Germany;
Sachbearbeiter Luftfracht Import;


* Export Solutions Inc.; Melbourne FL; 
Trade Compliance Specialist;
info@exportsolutionsinc.com

* EY; Belgium; 
Senior Consultant, Global Trade; Requisition ID: BEL000PT

* FD Associates; Tysons Corner, VA; 
Senior Export Compliance Associate;
 Send 
resume to and salary requirements to 
jobs@fdassociates.net 

* FLIR; Billerica, MA;
Global Trade Compliance Analyst,Traffic;
*
 FLIR; Wilsonville, OR; 
Global Trade Compliance Analyst,Traffic
;

*
 FLIR; Elkridge, MD; 
Global Trade Compliance Analyst,Traffic
;

*
FLIR; Arlington, VA;
Senior Analyst, Licensing
* FLIR; Billerica, MA;
Senior Analyst, Licensing
;

# Garmin; Olathe, Kansas; International Trade Compliance Specialist; Requisition ID: 1800006
*
 
General Atomics; San Diego, CA; Sr. Director of Import/Export Compliance; Job ID: 13892BR

* General Atomics; San Diego, CA;
Import/Export Compliance Manager / Licensing; Requisition ID: 15444BR
* General Atomics; San Diego, CA;
Import/Export Compliance Manager / Operations; Requisition ID: 15371BR
* General Atomics; San Diego, CA;
Internship, Import/Export, Summer 2018; Requisition ID: 15729BR
*
 General Atomics; San Diego, CA; 
Internship, Import/Export, Summer 2018
; Requisition ID: 15731BR 

* General Dynamics Ordinance and Tactical Systems; Lincoln, NE;
Contracts Administrator; Requisition ID: j29241586


General Dynamics Land Systems; Sterling Heights, MI; Licensing Officer
; Requisition IDSHC-LC-17-20056

* Georgia-Pacific; Atlanta, GA; 
Sr. Analyst, International Trade
; Requisition ID: 052010
 

*
Geokinetics; Houston, TX;
Global Trade Compliance & Logistics Manager
;

* Henderson Group Unlimited; Inc; Washington, DC; 
Process Improvement Mgr

* Henderson Group Unlimited; Inc; Washington, DC; 
Defense Control Analyst

* Henderson Group Unlimited, Inc; Washington, DC; 
Compliance Analyst;

* Honda of America Manufacturing; Marysvile, OH;
Import Specialist

* Infineon Technologies; El Segundo, CA;
Senior Export Compliance Specialist; Requisition ID: 23173

* Infineon Technologies; Milpitas, CA;
Senior Export Compliance Specialist; Requisition ID: 21326

* Infineon Technologies; Shanghai, China;
Senior Import and Export Specialist; Requisition ID: 22067

* Infineon Technologies; Munich, Germany;
Experte Export Control (w/m); Requisition ID: 22825

* InteliTrac Global Solutions; Herndon, VA; 
ITAR Compliance Official / Deputy Facility Security Officer;

* InteliTrac Global Solutions; Herndon, VA;
ITAR Compliance Official;

* Johnson and Johnson; Skillman, NJ;
Export Trade Compliance Lead;

*
JTEKT North America Corporation; Greenville, South Carolina; Senior Import Export Specialist;

* Koch Industries; Tulsa, OK; 
Global Trade Compliance & Logistics Director; Requisition ID: 052013
* Livingston International; El Segundo, CA;
HTS Classification;

* Lockheed Martin; Sunnyvale, CA;
Licensing Analyst (Early Career); Requisition ID: 415037BR_1

*
 Lockheed Martin; Littleton, CO; 
Licensing Analyst (Early Career)
; Requisition ID: 415037BR

* Lockheed Martin; Littleton, CO;
International Licensing Analyst; Requisition ID: 412863BR

* Lockheed Martin; Manassas, VA;
International Licensing Analyst; Requisition ID: 399617BR
* Lockheed Martin; Stratford, CT;
International Trade Compliance Technology Specialist; Requisition ID: 415922BR
* Lockheed Martin; Ft Worth, TX;
International Trade Compliance Analyst; Requisition ID: 416747BR

* Lockheed Martin; Ft Worth, TX; 
Senior Regulatory Compliance Analyst; Requisition ID: 
406664BR

*
LORD Corporation; Cary, NC; Global Trade Compliance Specialist; Requisition ID: REQ-17-528

* Lutron; Coopersburg, PA;
Trade Manager-Export; Requisition ID: 2926
* L-3 LINK Division; Tulsa, OK; 
Contracts Administrator 1; Requisition ID: 091686
* L-3 LINK Division; Arlington, TX;
Trade Compliance Practitioner / Empowered Official; Requisition ID: 089915
* L-3 ALST; Orlando, FL;
Contracts Manager / Empowered Official; Requisition ID: 093069
* L-3 Warrior Sensor Systems; Middle East;
International Business Development Manager – Middle East Region; Requisition ID: 093343
#
Maersk/DAMCO; Agent de transit IMPORT – EXPORT; Job Ref.: DC-164022
* Medtronic; Heerlen, The Netherlands;
Trade Compliance Analyst; Requisition ID: 16000DYY
* Medtronic; Wash DC;
Global Trade Lawyer;
stacy.m.johnson@medtronic.com; Requisition ID: 170002ON

* Moog Inc.; Blacksburg, VA; 
Trade Compliance Specialist
; Requisition ID: 174447

* Nortek Security & Control; Carlsbad, CA;
Global Logistics & Trade Compliance Analyst; Requisition ID: GLOBA01150

* Northrop Grumman; Herndon, VA;
Manager, International Trade Compliance 2; Requisition ID: 17022805
*
Northrop Grumman; Huntsville, AL;
International Trade Compliance 3
; Requisition ID: 17026172
* Northrop Grumman; Rolling Meadows, IL; 
International Trade Compliance Analyst 3; Requisition ID: 
17015695

* OneWeb; Arlington, VA;
Export Compliance Specialist;

# Oracle; United States;
Senior Customs Compliance Specialist; Job ID: 170018FJ

# Oracle; United States;
Customs Compliance Specialist; Job ID: 17001CBG

# Oracle; Bejing, China;
Senior Customs Compliance Specialist – APAC; Job ID: 17001CBI

# Oracle; Singapore;
Trade Compliance Specialist; Job ID: 17001ESC

* Orbital ATK; Promontory, UT;
Import/Export Specialist; Requisition ID: 
JAY20181101-43069

* Pratt & Whitney; East Hartford, CT;
International Trade Compliance (ITC) Specialist; Requisition ID:
 49375BR

* Pratt & Whitney; West Palm Beach, FL;
International Trade Compliance (ITC) Specialist; Requisition ID: 
55088BR

* Pratt & Whitney; East Hartford, CT;
International Trade Compliance Technology Manager; Requisition ID: 
51863BR

* Pratt & Whitney; East Hartford, CT;
Manager, International Trade Compliance Military Engines
Requisition ID: 57613BR

* Raytheon SAS; McKinney, TX;
Senior Regulatory Compliance Analyst; Requisition ID: 
107180BR
* Raytheon IIS; Orlando, FL;
 
Global Trade Licensing Analyst II; Requisition ID: 104036BR
* Raytheon IIS; Dulles, VA;
Global Trade Licensing Analyst II
Requisition ID: 104036BR

* Rolls-Royce; Indianapolis, IN;
 
Export Control Specialist; Req ID:
 

JR6025484 

*
RUAG Space USA; Huntsville AL; 
Global Trade Control Manager
; Requisition ID: 1748547

* SABIC; Houston TX; 
Senior Analyst, Trade Compliance
;
Danielle.Cannata@sabic.com
; Requisition ID: 8411BR

* SAFRAN Group; United Kingdom;
Trade Compliance Specialist;

# Sierra Nevada Corporation; Centennial, CO; International Trade Compliance Analyst I – Customs and Imports; Requisition ID: R0004365
# The Spaceship Company; Mojave, CA; Export Compliance Officer;
# Spirent; San Jose, CA;
Global Trade Compliance Specialist; Requisition ID: 4088

* Team Worldwide; Houston, Texas; 
Import Export Specialist;

* Teledyne Imaging; Waterloo, Ontario, Canada;
Director of International Trade Compliance; Requisition ID: TC0617

* Teledyne Imaging; Chestnut Ridge, NY; 
Director of International Trade Compliance; Requisition ID: 2017-5558
*
 Teledyne Imaging; Billerica, MA; Director of International Trade Compliance; Requisition ID: 2017-5558 

* Teledyne Imaging; Tarrytown, NY; 
Director of International Trade Compliance; Requisition ID: 2017-5558
* Teledyne Imaging; Kiln, MS; 
Director of International Trade Compliance; Requisition ID: 2017-5558
*
 Teledyne Imaging; Fredricton, NB; 
Director of International Trade Compliance
; Requisition ID: 2017-5558 

* Textron; Hunt Valley, MD;
2018 Intern – Export Import Analyst;

* Textron; Hunt Valley, MD;
Manager – Export Compliance;

* Textron; Hunt Valley, MD;
Senior Manager – Export Compliance;

*
Thermo Fisher Scientific; Waltham, MA;
Director, Global Trade Compliance
;

* TLR; Portland, OR; 
Export Documentation Specialist; Requisition ID: 1042

* TLR; San Fransisco, CA;
Import CSR; Requisition ID: 1040

* TLR; Houston, TX; 
Import Supervisor; Requisition ID: 1041

*
Tradewin; Portland, OR;
U.S. Export Compliance Consultant

* Trek; Waterloo, WI; Global Trade & Logistics Specialist;
* Ultra Electronics; Loudwater, United Kingdom;
International Trade Manager;

* United Technologies Corporation, UTC Aerospace Systems; Chula Vista, CA; 
ITC Specialist
; Requisition ID: 51240BR

* United Technologies Corporation, UTC Aerospace Systems; Chula Vista, CA; 
Supply Chain International Trade and Compliance Focal
; Requisition ID: 53794BR

* United Technologies Corporation; Chula Vista, CA;
Senior Associate, ITC Digital Solutions; Requisition ID: 58783BR

* United Technologies Corporation; East Hartford, CT;
International Trade Compliance Technology Manager; Requisition ID: 51863BR
* United Technologies Corporation; East Hartford, CT;
Manager, International Trade Compliance – Military Engines; Requisition ID: 57613BR
* United Technologies Corporation; East Hartford, CT; Manager, ITC Operations; Requisition ID: 56385BR


* United Technologies Corporation; East Hartford, CT;
ITC and ACE Program Manager, ASC; Requisition ID: 58388B
R

* 
University of Colorado, LASP; Boulder CO; 
Export Compliance Administrator

hrads@lasp.colorado.edu
; Requisition ID: 12298
* Vigilant; Negotiable Location, USA;
Global Trade Compliance Analyst;

# Virgin Galactic; Mojave, CA; Export Compliance Officer; Requisition ID: 2018-3440
# Virgin Galactic; Las Cruces, NM; Export Compliance Officer; Requisition ID: 2018-3558

Virgin Galactic; Las Cruces, NM; Director of Trade Compliance; Requisition ID: 2018-3349
Virgin Galactic; Washington, D.C.; Director of Trade Compliance; Requisition ID: 2018-3349
*
Volvo; Charleston, SC; OBL- Operations & Ocean Export Specialist;

* Xilinx; San Jose, CA;
Global Trade Compliance Manager; Requisition ID: 154441

*
 Xilinx; San Jose, CA; Global Trade Compliance Program Manager; Requisition ID: 154442 

*
Xylem, Inc.; Any Location, United States;
Manager, Global Ethics & Compliance

* * * * * * * * * * * * * * * * * * * *

TEEX/IM TRAINING EVENTS & CONFERENCES

 
* What: Fundamental Research Exclusion: your Guide to Properly Applying It – Part Two
* When: March 8, 2018; 1:00 p.m. (EST)
* Where: Webinar
* Sponsor: Export Compliance Training Institute (ECTI)
* ECTI Speaker: Jennifer Saak
* Register: Here or Danielle Hatch, 540-433-3977, danielle@learnexportcompliance.com.

* * * * * * * * * * * * * * * * * * * * 

ENEDITOR’S NOTES


  – “People don’t notice whether it’s winter or summer when they’re happy.” 
  – “Let us learn to appreciate there will be times when the trees will be bare, and look forward to the time when we may pick the fruit.
 

W.C. Fields (William Claude Dukenfield; 29 Jan 1880 – 25 Dec 1946, was an American comedian, actor, juggler and writer.  Fields’ comic persona
 was a misanthropic and hard-drinking egotist, who remained a sympathetic character despite his snarling contempt for dogs and children.
  – “If at first you don’t succeed, try, try again. Then quit. There’s no point in being a damn fool about it.”
 
Monday is pun day:

* I dropped out of communism class because of lousy Marx.
* Velcro – what a rip off!

* * * * * * * * * * * * * * * * * * * *

EN_a317
. 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 Amendment: 26 Jan 2018: 83 FR 3577-3583: Addition of Certain Entities; Removal of Certain Entities; and Revisions of Entries on the Entity List

  
*
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.

* * * * * * * * * * * * * * * * * * * *

EN_a0318
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

* * * * * * * * * * * * * * * * * * * *

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, DOE/NRC, 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.

* TO UNSUBSCRIBE: Use the Safe Unsubscribe link below.

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