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18-0222 Thursday “Daily Bugle”

18-0222 Thursday “Daily Bugle”

Thursday, 22 February 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, FAR/DFARS, FTR/AES, HTSUS, and ITAR), plus news and events.  Subscribe 
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  1. DHS/CBP Amends Customs Regulations by Revising List of User Fee Airports 
  1. Items Scheduled for Publication in Future Federal Register Editions
  2. Commerce/BIS: “Mitsui Plastics, Inc. of White Plans, NY, to Pay $28,600 for Antiboycott Violations”
  3. State/DDTC: (No new postings.)
  4. Australia Updates Consolidated List
  5. Hong Kong TID Releases New Overview of Officers Authorized to Sign on Strategic Commodities Licenses and Delivery Verification Certificates
  1. Expeditors News: “House Passes Bill to Extend GSP”
  2. Forbes: “UK Drags Feet on Control of Surveillance Exports To Repressive Regimes”
  3. Reuters: “China Probes Report of Possible North Korea Sanctions Breach at Sea”
  4. Space News: “National Space Council Backs Incremental Space Regulatory Reform”
  5. WorldECR News Alert of 22 Feb
  1. M. Volkov: “The Obvious Partnership – Compliance and Cybersecurity”
  2. Gary Stanley’s ECR Tip of the Day
  3. R.C. Burns: “Oxycodone, Testosterone, Night Vision, and eBay Do Not Mix”
  1. ECS Announces “ITAR/EAR Boot Camp” on 12-13 Sep in Annapolis, MD
  1. Bartlett’s Unfamiliar Quotations 
  2. Are Your Copies of Regulations Up to Date? Latest Amendments: ATF (15 Jan 2016), Customs (22 Feb 2018), DOD/NISPOM (18 May 2016), EAR (16 Feb 2018), FACR/OFAC (28 Dec 2017), FTR (20 Sep 2017), HTSUS (8 Feb 2018), ITAR (14 Feb 2018) 
  3. Weekly Highlights of the Daily Bugle Top Stories 

EXIMITEMS FROM TODAY’S FEDERAL REGISTER

EXIM_a1

1. 
DHS/CBP Amends Customs Regulations by Revising List of User Fee Airports

(Source:
Federal Register, 22 Feb 2018.) [Excerpts.]
 
83 FR 7608-7610: Technical Amendment to List of User Fee Airports: Name Changes of Several Airports and the Addition of Five Airports
 
* AGENCY: U.S. Customs and Border Protection; DHS.
* ACTION: Final rule; technical amendment.
*  SUMMARY: This document amends U.S. Customs and Border Protection (CBP) regulations by revising the list of user fee airports to reflect the name changes of several airports and the designation of user fee status for five additional airports: South Texas International Airport at Edinburg in Edinburg, Texas; Florida Keys Marathon Airport in Marathon, Florida; Appleton International Airport in Appleton, Wisconsin; South Bend International Airport in South Bend, Indiana; and Conroe-North Houston Regional Airport in Conroe, Texas. User fee airports are those airports which, while not qualifying for designation as international or landing rights airports, have been approved by the Commissioner of CBP to receive, for a fee, the services of CBP officers for the processing of aircraft entering the United States, and the passengers and cargo of those aircraft.
* DATES: Effective Date: February 22, 2018. …
* SUPPLEMENTARY INFORMATION:
 
Recent Changes Requiring Updates to the List of User Fee Airports
 
This document updates the list of user fee airports in 19 CFR 122.15(b) by adding the following five airports: South Texas International Airport at Edinburg in Edinburg, Texas; Florida Keys Marathon Airport in Marathon, Florida; Appleton International Airport in Appleton, Wisconsin; South Bend International Airport in South Bend, Indiana; and Conroe-North Houston Regional Airport in Conroe, Texas. During the last several years, the Commissioner of CBP signed MOAs designating each of these five airports as a user fee airport. [FN]
 
Additionally, this document updates the list of user fee airports to reflect name changes of airports that were previously designated as user fee airports. The name changes are shown in the following chart. The left column contains the former name of each airport as it is currently listed in 19 CFR 122.15(b). The right column contains the updated name of each airport.

 
   Dated: February 15, 2018.
Kevin K. McAleenan, Acting Commissioner, U.S. Customs and Border Protection.
——— 
  [FN] The Commissioner of CBP signed an MOA designating Conroe-North Houston Regional Airport on June 14, 2016, an MOA designating South Bend International Airport on July 5, 2016, an MOA designating South Texas International Airport at Edinburg on September 18, 2014, an MOA designating Florida Keys Marathon Airport on April 3, 2015, and an MOA designating Appleton International Airport on October 23, 2015.

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OGSOTHER GOVERNMENT SOURCES

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

* President; PROCLAMATIONS; Cuba, Regulation of Anchorage and Movement of Vessels; Modification and Continuation of National Emergency [Publication Date: 23 Feb 2018.]

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OGS_a23.

Commerce/BIS: “Mitsui Plastics, Inc. of White Plans, NY, to Pay $28,600 for Antiboycott Violations”

(Source:
Commerce/BIS, 22 Feb 2018.)
             
* Respondent: Mitsui Plastics, Inc. of White Plans, NY
* Case No: 14-07
* Charges:
  – Two violations of 15 CFR. §760.2(d) –
Furnishing Information about Business Relationships with Boycotted Countries or Blacklisted Persons
  – Seven violations of 15 CFR. §760.5 –
Failing to Report the Receipt of a Request to Engage in a Restrictive Trade Practice or Foreign Boycott Against a Country Friendly to the United States
* Fine or Civil Settlement: a civil penalty of $28,600 is assessed against Mitsui and shall be paid to the U.S. Department of Commerce within 30 days from the date of entry of this Order.
* Debarred or Suspended from Export Transactions: Not if penalty is paid as agreed.

* Date of Order: 9 Feb 2018.
 

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OGS_a4
5.

Australia Updates Consolidated List

(Source:
Australia DFAT, 21 Feb 2018.) [Excerpts.]
 
The Consolidated List is a list of all persons and entities who are subject to targeted financial sanctions or travel bans under Australian sanctions laws. The list is updated regularly.
 
Full details of all listed persons and entities can be found
here.  

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OGS_a5
6.

Hong Kong TID Releases New Overview of Officers Authorized to Sign on Strategic Commodities Licenses and Delivery Verification Certificates

(Source:
Hong Kong TID, 21 Feb 2018.)
 
The Trade and Industry Department (TID) of Hong Kong has released a new overview of Officers Authorized to Sign on Strategic Commodities Licenses and Delivery Verification Certificates under Import and Export Ordinance, Cap 60 Import and Export (Strategic Commodities) Regulations.
 
The overview is available
here

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NWSNEWS

NWS_a1
7.
Expeditors News: “House Passes Bill to Extend GSP”

(Source:
Expeditors News, 21 Feb 2018.)
 
On February 13, 2018, the U.S. House of Representatives passed H.R. 4979 to extend the Generalized System of Preferences (GSP).
 
The bill passed by a margin of 400 votes to 2, and will now move on to the Senate.  
The bill can be found
here
.

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NWS_a28. Forbes: “UK Drags Feet on Control of Surveillance Exports To Repressive Regimes”

(Source:
Forbes, 21 Feb 2018.) [Excerpts.]       
 
The British government has been accused once again of allowing the export of surveillance tools to repressive regimes – just as the EU moves to tighten up such sales.
 
Eleven EU countries have now reportedly backed a European Commission proposal, released last month, to introduce export controls on surveillance technologies.
 
A leaked
document obtained by
Euractiv shows that Croatia, the Czech Republic, France, Italy, Poland, Portugal, Romania, Slovakia, Slovenia and Spain are supporting the initiative, originally proposed by Germany.
 
The proposal concerns so-called ‘dual-use’ products that can be used for both civilian and military purposes, and was introduced after European companies – especially British-based ones – were discovered to have happily sold surveillance software to repressive governments during the Arab Spring protests seven years ago.
 
Last summer, a BBC investigation revealed that British defense firm BAE Systems was using a Danish subsidiary to sell its Evident surveillance system to Saudi Arabia, the UAE, Qatar, Oman, Morocco and Algeria. …
 
The proposals to increase export controls are controversial, as they cover all sorts of dual-use technologies, from robotics to AI, and some member states think they could be unnecessarily bad for business. …
 
[Authored by Forbes contributor Emma Woollacott.]

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NWS_a39. Reuters: “China Probes Report of Possible North Korea Sanctions Breach at Sea”

(Source:
Reuters, 22 Feb 2018.) [Excerpts.]
 
China said on Thursday it is investigating a Japanese report that a Chinese ship may have carried out a ship-to-ship transfer with a North Korean vessel in breach of U.N. sanctions.
 
Japan said late on Tuesday that its military had spotted a North Korean-flagged tanker lying alongside a small vessel of unknown origin with Chinese characters on it in the East China Sea, indicating it was possibly an oil tanker from the southeastern Chinese province of Fujian.
 
Japan suspects they were conducting ship-to-ship transfers banned by the U.N. Security Council and has informed the Security Council and shared the information with other countries, Japan’s Foreign Ministry said. …
 
A confidential report by independent U.N. monitors to a U.N. Security Council sanctions committee, seen by Reuters earlier this month, said they had investigated cases of ship-to-ship transfers of petroleum products in violation of sanctions and that the network behind the vessels was primarily based in Taiwan.
 

The monitors said one country, which they did not name, told them North Korea had carried out such transfers off its ports of Wonsan and Nampo and in international waters between the Yellow Sea and East China Sea between October and January. … 

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NWS_a410. Space News: “National Space Council Backs Incremental Space Regulatory Reform”

(Source:
Space News, 21 Feb 2018.) [Excerpts.]
 
Vice President Mike Pence and members of the National Space Council approved a series of recommendations Feb. 21 that make modest, and expected, reforms to regulations of commercial space activities.
 
The Council, meeting at the Kennedy Space Center in its second public session since being reestablished last June, approved a set of four recommendations intended to streamline licensing and other regulatory activities that both government officials and industry witnesses warned could slow down emerging space ventures. …
 
A fourth and final recommendation asked the Council’s executive secretary, Scott Pace, to work with members of the Council to develop recommendations on export control reform. Those recommendations are due at the end of the year.
 

Ross noted that a commercial spacecraft that lands in another country, or in international waters, is considered an export. “This approach is a primary complaint of space companies,” he said. The recommendation, he said, would allow his department to continue working with the Departments of State and Defense on the issue “to enable more commercial activity while protecting national security.” … 

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NWS_a511. WorldECR News Alert of 22 Feb 

(Source:
WorldECR, 22 Feb 2018.)
 
  (1) UK under scrutiny for exporting surveillance equipment to the Philippines;
  (2) U.S. legislates to restrict defense trade with South Sudan;
  (3) U.S. takes action against Latvia’s ABLV Bank for money laundering;
  (4) Ukraine introduces e-licensing in state export control system; and
  (5) Check! Sanctions hit World Chess Federation.
 
[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

COMM_a01
12.
M. Volkov: “The Obvious Partnership – Compliance and Cybersecurity”

(Source:
Volkov Law Group Blog, 21 Feb 2018. Reprinted by permission.)
 
* Author: Michael Volkov, Esq., Volkov Law Group,
mvolkov@volkovlaw.com, 240-505-1992.
 
Cybersecurity compliance, like the compliance profession, is rapidly growing. The forces pushing cyber compliance are two-fold: the ever-increasing and changing nature of cyber threats and harms, and the logical application of compliance strategies.
 
Compliance has to work closely with in-house corporate information technology. To the extent a company outsources information technology to a cloud provider, compliance will serve an even more important function in coordinating with the cloud service to ensure adequate prevention.
 
In designing a cybersecurity compliance program, there are a number of elements that have to be addressed. From a risk perspective, there are a few key points to beginning this process. As Verizon’s 2017 Data Breach Report (here), 75 percent of data breaches are the result of an attack from outside the organization. Approximately 25 percent are conducted by bad actors within the organization.
 
There are two significant weaknesses that are commonly exploited when a data breach occurs.
 
First, company employees are often victims of a phishing attack that results in the installation of software, and in many cases, malware. According to the Verizon Data Breach Report, 66 percent of malware was installed via malicious email attachments.
 
Second, companies often fall victim to hacking attacks because of stolen or weak authentication and password protections.
 
According to the Verizon Data Breach Report, nearly 81 percent of hacking-related breaches leveraged either stolen and/or weak passwords. Interestingly, only 14 percent were the result of errors or privilege misuse.
 
Without glossing over all the other significant threats to a company and the cyber harms that can occur, there is an important point relating to compliance that should be made. The compliance profession is dedicated to the prevention of corporate harm. Compliance officers are trained to focus on proactive strategies to prevent employees from engaging in misconduct – thus, we see corporate compliance programs training employees, promoting a corporate culture of compliance, providing regular advice on compliance issues, and building in controls to prevent misconduct.
 
This same proactive strategy falls right within the core competencies of the compliance function when it comes to cybersecurity. If the company wants to reduce the risk of a cyberattack, the company has to provide compliance training, monitoring and accountability around controls needed to ensure that employees: (1) recognize phishing attacks and report them when they occur; and (2) maintain strong password and authentication protections to prevent hacking by exploiting authentication and passwords for access to company data.
 
Cyber threats can be mitigated by effective strategies that coordinate prevention for the organization and for individual employees. Of course, these new paradigm stretches to third-party risks because hackers have numerous avenues to attack a company and will look to exploit any cyber weakness. All of these risks are compounded by the ever-expanding Internet to include the Internet of Things. It is no wonder that corporate boards and senior executives complain of headaches and cascading risk scenarios to threaten real harm to the company.

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* Author: Gary Stanley, Esq., Global Legal Services, PC, (202) 352-3059, 
gstanley@glstrade.com.
 
Paragraph (a)(1) of the EAR’s definition of “specially designed” uses the broader term “items” (meaning commodities, technology and software) because it applies more broadly than paragraph (a)(2). Paragraph (a)(1) is primarily used for determining whether end items or materials are “specially designed.” In certain ECCN paragraphs, “parts,” “components,” “accessories,” “attachments” or “software” have a control parameter for “parts,” “components,” “accessories,” “attachments” or “software” “specially designed” for a particular function or performance characteristics and in these ECCNs an analysis of (a)(1) would be done.
 
For any item that is not a “part,” “component,” “accessory,” “attachment” or “software,” such as an “end item” or “material” (“end item” and “material” are defined in § 772.1 of the EAR) described in a paragraph that uses “specially designed,” paragraph (a)(1) functions as the entire “specially designed” definition – meaning (a)(1) acts as the ‘catch’ and ‘release.’ For example, if the end item meets the criteria of (a)(1), it is “specially designed.” If it does not meet the criteria of paragraph (a)(1), it is not “specially designed.”

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COMM_a3
14. R
.C. Burns: “Oxycodone, Testosterone, Night Vision, and eBay Do Not Mix”

(Source:
Export Law Blog, 21 Feb 2018. Reprinted by permission.)
 
* Author: R. Clifton Burns, Esq., Bryan Cave LLP, Wash DC,
Clif.Burns@bryancave.com, 202-508-6067).
 
Last week a
criminal indictment against Arkansas resident Scott Douglas Browning was unsealed after he was arrested on a number of charges including receiving property stolen from Fort Bragg, possessing testosterone and oxycodone, and exporting image intensification tubes and a thermal imaging monocular (pictured
here) to the Netherlands without a license.  According to the indictment, Browning listed the items on eBay and sold them to a buyer or buyers in the Netherlands. The items were all allegedly listed on the USML and would have required a license from DDTC.
 

I’ve said so many times that it almost goes without saying, but the Government, in order to convict Browning on the export charges, must prove that he knew that the export of these items required prior authorization and were illegal without such an authorization. We’ll leave aside what someone tweaked out on testosterone and whacked out on oxycodone would know about the legality of his exports. Still, it seems likely, at least to me, that this is going to an uphill battle for the prosecution. It’s not like the guys who stole the stuff from Fort Bragg gave it to him with a warning that the items were export controlled. And it’s not like the guy was trying to sell this stuff in secret. He listed the items on eBay after all. Last time I checked, that wasn’t exactly a dark web site. And although the indictment is sparse on details, there is nothing to suggest that any of the normal indicia of a guilty conscience – false description of the item on shipping documents, confessions of guilt to undercover agents, etc. – are present here.  Of course, the export charges may be the least of his worries here.

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TEEX/IM TRAINING EVENTS & CONFERENCES

TE_a115.

ECS Announces “ITAR/EAR Boot Camp” on 12-13 Sep in Annapolis, MD

 
* What: ITAR/EAR Boot Camp, Annapolis, MD
* When: September 12-13, 2018
* Where: Chart House Restaurant on Spa Creek
* Sponsor: Export Compliance Solutions (ECS)
* ECS Speaker Panel:  Suzanne Palmer, Mal Zerden
* Register:
Here or by calling 866-238-4018 or e-mail
spalmer@exportcompliancesolutions.com 
* Discount: Daily Bugle subscribers get a 10% discount when they use the coupon code: ECS10PERBUGLE when registering for this event.

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ENEDITOR’S NOTES

*
George Washington (22 Feb 1732 – 14 Dec 1799; was an American statesman and soldier who served as the first President of the United States from 1789 to 1797 and was one of the Founding Fathers of the United States. He served as Commander-in-Chief of the Continental Army during the American Revolutionary War, and later presided over the 1787 convention that drafted the United States Constitution. He is popularly considered the driving force behind the nation’s establishment and came to be known as the “father of the country,” both during his lifetime and to this day.)
  – “To be prepared for war is one of the most effective means of preserving peace.”
  – “It is better to offer no excuse than a bad one.”

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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: 22 Feb 2018: 83 FR 7608-7610: Technical Amendment to List of User Fee Airports: Name Changes of Several Airports and the Addition of Five Airports
 
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: 
16 Feb 2018:
83 FR 6949-6956
: Russian Sanctions: Addition of Certain Entities to the Entity List [Addition of 21 Entities to 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: 8 Feb 2018: 83 FR 5674: Technical Corrections to the Harmonized Tariff Schedule of the United States [Concerns HTSUS Chapter 99, Subchapter III]

  – 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: 14 Feb 2018: 83 FR 6457-6458: Amendment to the International Traffic in Arms Regulations: Addition of South Sudan [Amends ITAR Part 126.] 

  – The only available fully updated copy (latest edition: 14 Feb 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_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

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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, DOE/NRC, DOJ/ATF, DoD/DSS, DoD/DTSA, FAR/DFARS, 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.

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