18-0308 Thursday “Daily Bugle”

18-0308 Thursday “Daily Bugle”

Thursday, 8 March 2018

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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[No items of interest noted today.] 

  1. Items Scheduled for Publication in Future Federal Register Editions
  2. Commerce/BIS: (No new postings.)
  3. DHS/CBP Posts E-Commerce StrategyDHS/CBP
  4. DoD/DSCA Releases Policy Memo 18-14
  5. DoD/DSS Knowledge Center Experiences Disruptions in Service
  6. State/DDTC: (No new postings.)
  7. EU Amends Implementing Regulation Concerning Irreversible Deactivation Standards and Techniques for Firearms
  1. Datanami: “‘Dual-Use’ AI Poses New Security Threats”
  2. GeekWire: “Magic Leap Files Preemptive Lawsuit Against ‘Disgruntled’ Security Exec for Alleged Extortion”
  3. Global Trade News: “EU and Japan Leaders to Sign Free Trade Deal by Summer”
  4. ST&R Trade Report: “CBP Issues E-Commerce Strategy”
  5. WorldECR News Alert of 8 Mar
  1. M. O’Kane: “New UK Guidance on Licensing Legal Services”
  2. P. LeCour, T. Carlile & Z. Chin: “U.S. Department of Justice (DOJ) – Enhanced Security Plan Sets Best Practices for Use of Cloud Services for Sensitive Data”
  3. Gary Stanley’s EC Tip of the Day
  1. ECS Presents “ITAR/EAR Boot Camp,” 10-11 Jul in Orlando, FL
  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 (5 Mar 2018), FTR (20 Sep 2017), HTSUS (27 Feb 2018), ITAR (14 Feb 2018) 
  3. Weekly Highlights of the Daily Bugle Top Stories 



[No items of interest noted today.

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OGS_a11. Items Scheduled for Publication in Future Federal Register Editions
(Source: Federal Register)

* Treasury; Foreign Assets Control Office; NOTICES; Blocking or Unblocking of Persons and Properties [Publication Date: 9 March 2018.]
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DHS/CBP, 7 Mar 2018.)
E-Commerce is a growing segment of the U.S. economy and has been increasing significantly for the past several years. Consumer habits are changing as the internet empowers individuals to make purchases online. These advances in economic activity have led to increasing volumes of imports of small, just-in-time packages, creating inspection challenges for CBP. E-Commerce shipments pose the same health, safety, and economic security risks as containerized shipments, but the volume is higher and growing. Additionally, transnational criminal organizations are shipping illicit goods to the United States via small packages due to a perceived lower interdiction risk and less severe consequences if the package is interdicted. Furthermore, new or infrequent importers often possess less familiarity with U.S. customs laws and regulations, which can lead to the importation of non-compliant goods. CBP must increase its ability to address the administrative and resource challenges this creates, particularly when coupled with the growing volume of e-commerce trade.
To address these challenges effectively, CBP has developed an e-commerce strategy. This strategy highlights private industry and foreign governments as key resources in CBP’s continuous assessment of the e-commerce environment. The strategy includes efforts to educate the public and trade community to ensure they understand their responsibilities as importers to comply with customs regulations. The strategy also emphasizes enforcement initiatives, such as streamlining enforcement processes affected by increasing e-commerce volumes, leveraging enforcement partnerships with partner government agencies and foreign governments, and improving data collection from CBP targeting systems and field personnel.
[Editor’s Note: The E-Commerce Strategy can be found
HERE. A summary of the document can also be found in item #11 of this Daily Bugle.]

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DoD/DSCA, 8 Mar 2018.)
* DSCA Policy Memo 18-14 Information on Identification, Friend or Foe (IFF) Systems has been posted.
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DoD/DSS, 8 Mar 2018.)
The DSS Knowledge Center is currently experiencing intermittent disruptions in our service and will possibly be down through the remainder of the day.

We apologize for any inconvenience this may have caused.

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* Commission Implementing Regulation (EU) 2018/337 of 5 March 2018 amending Implementing Regulation (EU) 2015/2403 establishing common guidelines on deactivation standards and techniques for ensuring that deactivated firearms are rendered irreversibly inoperable
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8. Datanami: “‘Dual-Use’ AI Poses New Security Threats”
(Source: Datanami, 21 Feb 2018.)
While the genie may already be out of the bottle, the rapid growth and broad availability of AI and machine learning technology along with a growing list of development tools is prompting critics to highlight future security concerns and the need to consider upfront the potential for malicious use of the technology.
A report released this week by researchers in the U.S. and U.K., including members of OpenAI, a group that promotes “safe artificial general intelligence,” urges greater consideration of unforeseen security threats posed by ubiquitous AI.

Among the first steps is acknowledging the “dual-use” nature of AI that can be used for “public good or harm,” notes the report released Tuesday (Feb. 20) by a cross-section of AI researchers affiliated with the Future of Humanity Institute at the University of Oxford.
The study focuses on security domains as a way of underscoring the up- and downside of AI and machine learning, to wit: The same algorithm use to spot junk mail that ends up in your spam folder also has potential malware applications. The researchers argue that these malicious uses must be considered and mitigated before code is released to the open-source community or new algorithms are written and deployed.

  “It is clear that AI will figure prominently in the security landscape of the future, that opportunities for malicious use abound and that more can and should be done,” warns the report.
Focusing on digital, physical and political security (e.g., “fake news” and information warfare), the report examines a range of unintended consequences posed by dual-use AI. Among them are the expansion of existing security threats, including the potential proliferation of attacks as well as potential targets.

AI systems could also be misused to introduce new threats beyond the capabilities of human hackers. One recent example are the social media bots unleashed by “troll farms” to stoke domestic political tensions.
The authors also warn of evolving security threats. “We believe there is reason to expect attacks enabled by the growing use of AI to be especially effective, finely targeted, difficult to attribute and likely to exploit vulnerabilities in AI systems.”

Among those vulnerabilities, observers note, is a lack of understanding about how current AI systems learn and infer from large datasets, an uncertainty that makes those systems prone to manipulation.
The authors therefore offer a set of “look-before-you-leap” recommendations for blunting the potential malicious use of AI technologies. Along with bringing policymakers into the mitigation and prevention process, the report urges AI developers to “take the dual-use nature of their work seriously.”

There are indications that those recommendations are already being implemented in the form of “beneficial AI” conferences and other technical efforts designed to rein in malicious AI applications.
The ongoing problem, the report notes, is the accelerating pace of AI and machine learning development along with open-source availability of code and development tools.
OpenAI and other groups have attempted to tackle the “AI safety” problem by generating possible scenarios for malicious use of the technology. Among the scenarios they considered were “persuasive ads” generated by AI systems to target security system administrators. Another involves using neural networks and “fuzzing” techniques to create computer viruses capable of automating exploits.
  “AI challenges global security because it lowers the cost of conducting many existing attacks, creates new threats and vulnerabilities and further complicates the attribution of specific attacks,” OpenAI noted in a blog post.  

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NWS_a29. GeekWire: “Magic Leap Files Preemptive Lawsuit Against ‘Disgruntled’ Security Exec for Alleged Extortion”
(Source: GeekWire, 6 Mar 2018.) [Excerpts.]
Florida augmented reality company Magic Leap filed a lawsuit last week against its current senior director of global security Todd Keil, alleging that he is trying to “extort millions of dollars” with “frivolous legal claims” against the company.
In the lawsuit, filed in U.S. District Court in Eastern Texas, Magic Leap alleges that Keil delivered a draft lawsuit against the company in December. Magic Leap’s lawsuit documents and attempts to head off Keil’s alleged claims, which include violations of the federal Defend Trade Secrets Act stemming from the unanticipated arrival of several Microsoft HoloLens devices at company offices. Magic Leap also attempts to discredit alleged violations of U.S. Export Administration Regulations and International Traffic in Arms Regulations surrounding its internship program, which in 2016 included several interns from Iran and China, and its dealings with a London-based company that was acquired by a Chinese firm with ties to the military. …

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NWS_a310. Global Trade News: “EU and Japan Leaders to Sign Free Trade Deal by Summer”
(Source: Integration Point Blog, 8 Mar 2018.)
Japan and the European Union (EU) finalized negotiations on an agreement in December to create one of the world’s biggest economic blocs. Lead negotiators on both sides hope that the trade deal will take effect by early 2019, ideally before the British exit from the EU.
  “This is the largest trade agreement that has been negotiated for the European Union,” said EU Trade Commissioner Cecilia Malmstrom.
With this trade agreement, Japan will remove tariffs on 94% of all imports from the EU, including 82% of farm and fishery products. Japan is also removing the 30% tariff on EU cheese and 15% tariff on EU wine, as well as allowing the EU to increase beef and pork exports.
In return, the EU will cancel tariffs on 99% of imports from Japan. Notably, the EU is removing its 10% tariff on Japanese cars.
Once adopted, the trade deal will gradually enhance the economic ties between the two major economies and set global standards for the countries with which they trade.
The two sides have not yet decided on a plan to resolve investment disputes and will continue negotiations on the issue.
You can read more about this trade deal on The Japan Times, Japan Today, and The Mainichi

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NWS_a411. ST&R Trade Report: “CBP Issues E-Commerce Strategy”

U.S. Customs and Border Protection issued March 6 an electronic commerce strategy aimed at addressing the growing volume of small package imports as well as the challenges and opportunities that direct-to-consumer e-commerce presents for the economy and security of the U.S. The strategy covers a range of issues of particular importance, including legal and regulatory reform, operational changes and enhancements at CBP, private sector compliance through enforcement and incentives, and international trade standards for e-commerce. 

CBP defines e-commerce for purposes of its strategy as high-volume, low-value shipments entering U.S. port limits. The number of Americans shopping online has grown from 22 percent to 79 percent since 2000, increasing the opportunity for illicit and dangerous products to cross U.S. borders. This presents a significant challenge for CBP because the agency’s current operational structure is focused on scanning for risks around high-value, containerized shipments, which require importers to submit certain data elements in advance of the physical arrival of a shipment. According to the strategy, since CBP receives less actionable data on e-commerce shipments it must put into place new protocols that allow for effective identification, enforcement, and deterrence of trade violations in the e-commerce environment.
Additionally, the growing volume of e-commerce shipments is taxing existing agency resources. To illustrate the challenge, at the end of fiscal year 2017 one port that has an express consignment hub received an estimated 25 million predominantly informal and de minimis value shipments, up from an average of only 2.4 million shipments between 1997 and 1999. The U.S. Postal Service has also experienced a considerable increase in the number of international mail packages bound for addressees in the U.S. and industry projections point to further growth in air freight traffic as the volume of online sales continues to rise over the next decade.
CBP is restructuring its framework for ensuring compliance of informal entries in order to adapt to this changing environment, including through the creation in September 2016 of the E-Commerce and Small Business Branch within the Office of Trade. This branch was tasked with strengthening compliance of e-commerce transactions and developing CBP’s e-commerce strategy, which sets forth the following goals.  
Legal and Regulatory Authorities
. Enhance legal and regulatory authorities to better posture CBP and interagency partners to address emerging threats such as dangerous contraband and counterfeits by (1) reviewing existing legal and regulatory authorities to develop risk segmentation processes, improve targeting, and realign resources; (2) developing a plan that will incentivize compliance from all stakeholders within the e-commerce supply chain; and (3) building upon existing legal authorities to enhance partnerships with domestic and international stakeholders that address small parcel shipments.
CBP Operations
. Enhance and adapt all affected CBP operations to respond to emerging supply chain dynamics created by the rapid growth of e-commerce by (1) enabling risk-based enforcement to increase operational efficiency; (2) determining highest risk e-commerce packages utilizing a counter network approach including state-of-the-art techniques and technology; and (3) optimizing workforce, policies, and procedures to adapt CBP to the evolving e-commerce environment.
Private Sector Compliance
. Drive private sector compliance through enforcement resources and incentives by (1) strengthening e-commerce compliance through enforcement mechanisms, both civil and criminal; (2) incentivizing compliance through an e-commerce known shipper program; and (3) leveraging partner government agency networks to enhance enforcement procedures for e-commerce shipments.
International Trade Standards
. Facilitate international trade standards for e-commerce to support economic prosperity by (1) leading standards and best practices development with the interagency and international customs community; (2) exploring technology options to increase the exchange of e-commerce information; and (3) educating the e-commerce community to promote an understanding of applicable cross-border trade rights and responsibilities.
CBP intends to measure the success of achieving its strategic e-commerce goals through internal, targeted performance measures. To do this, the agency will create a baseline for data, set key measurement targets, and report on its progress.

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NWS_a512. WorldECR News Alert of 8 Mar
(Source: WorldECR, 8 Mar 2018.)
  (1) US re-issues updated North Korea Sanctions Regulations
  (2) UK updates ECO 2008, consolidated list, and four OGELs
  (3) EU and US extend asset freeze over misappropriation of Ukrainian state funds
  (4) OFAC acts against Mexican drug traffickers
  (5) OFSI: Licence to represent sanctioned parties ‘strongly encouraged’
[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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13. M. O’Kane: “New UK Guidance on Licensing Legal Services”

(Source: European Sanctions Blog, 7 Mar 2018.)
* Author: Michael O’Kane, Esq., Peters & Peters Solicitors LLP, mokane@petersandpeters.com.
OFSI has updated its general guidance on providing legal advice to designated persons (FAQs 3.4.1 and 3.4.2). The new guidance states that obtaining a license before providing substantive legal services is encouraged rather than required, but that no payment for legal services by or on behalf of a designated person should be received before obtaining a license (since that would be dealing with frozen funds or making funds available to or for the benefit of a designated person). OFSI also states that it encourages you to obtain a license, for the legal fees you intend to charge, as soon as possible if you would like certainty on the fees and expenses you will be able to recover while the individual or entity remains subject to sanctions. Any unreasonable legal fees or expenses won’t be licensed for payment.

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Deloitte, 7 Mar 2018.)
* Authors: Pablo LeCour, Partner, plecour@deloitte.co.uk; Tina Carlile, Senior Manager, ticarlile@deloitte.co.uk; and Ziyu Chin, Senior Consultant, ziyu.chin@deloitte.co.uk. All of Deloitte.
In December 2017 a global software company serving the telecommunications industry settled charges with the U.S. Department of Justice for violating U.S. controls on foreign access to sensitive data, including export controlled information. As part of the settlement, the company agreed to implement an Enhanced Security Plan designed to increase information security by regulating remote access to company networks and transfers of sensitive data.
The Enhanced Security Plan is a helpful benchmark for network providers seeking to protect sensitive information about U.S. telecommunications networks and other critical infrastructure.

Many tech companies develop software using foreign technical personnel both inside and outside of the U.S. The use of a global technical workforce increases the risk of unauthorised access to U.S. controlled information, including sensitive network data and data critical to the U.S. domestic communications infrastructure. Unauthorised access has consequences from an export controls perspective – under the U.S. Export Administration Regulations (EAR) and U.S. International Traffic in Arms Regulations (ITAR) licenses might be required to store U.S. sensitive data in overseas servers or for non-U.S. persons to handle, transmit or access controlled software, technology or technical data that is subject to U.S. jurisdiction. The Enhanced Security Plan provides an example of how these information security requirements can be met by:
  – Requiring authentication and tracking of changes to systems software through code-signing and other means;
  – Restricting access, transmission and storage of certain sensitive data to U.S.-based servers and U.S.-based network infrastructure; and
  – Controlling access by non-U.S. persons and implementing procedures for the proper vetting and licensing of non-U.S. employees and agents.
Additionally, the Enhanced Security Plan recommends an effective compliance programme that includes the following:
  – Appointing a Security Director with appropriate authority, reporting lines, independence, skills, and resources to ensure compliance;
  – Implementing a Security Policy that describes the management of user identity and access, and building systems that monitor unauthorised attempts to access and screen personnel;  
  – Conducting periodic third-party audits of the security procedures and their implementation; and
  – Engaging a third-party auditor to ensure compliance.
Companies doing business with the U.S. government or in connection with critical U.S. infrastructure, as well as companies that handle or use export-controlled technology, software, technical data, and cloud or network services, should review the DOJ Enhanced Security Plan requirements and consider including them within their own compliance programmes. 

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15. Gary Stanley’s EC Tip of the Day
(Source: Defense and Export-Import Update; 7 Mar 2018. Available by subscription from
* Author: Gary Stanley, Esq., Global Legal Services, PC, (202) 352-3059,
If a term on the Commerce Control List (CCL; Supplement No. 1 to EAR Part 774) uses double quotes it means there is a defined term in EAR Part 772. However, the absence of double quotes does not mean that a term used on the CCL is not defined in Part 772. Because the CCL includes many terms that are defined in Part 772, BIS’s practice is to use double quotes for certain key terms and to use double quotes when needed for consistency with multilateral export control regime-based entries, such as many derived from control lists, in particular for the Wassenaar Arrangement that also uses the double quotes convention. However, because of the large number of defined terms used on the CCL and a desire to avoid hindering readability by placing quotes around too many words used in particular ECCNs, BIS’s practice is to not add double quotes around certain terms, such as items and commodities. This convention also applies to the use of double quotes within the Definition of Terms section under Part 772.
The CCL also includes a convention regarding the use of single quotes. Single quotes on the CCL identify a term as a defined term in the context of a particular ECCN. This convention also applies to the use of single quotes within the Definition of Terms section under Part 772.

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* What: ITAR/EAR Boot Camp, Orlando, FL
* When: July 10-11, 2018
* 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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Oliver Wendell Holmes (Oliver Wendell Holmes, Jr.; 8 Mar 1841 – 6 Mar 1935; was an American jurist who served as an Associate Justice of the U.S. Supreme Court from 1902 to 1932, and as Acting Chief Justice of the United States from January-February 1930. Noted for his long service, his concise and pithy opinions, and his deference to the decisions of elected legislatures, he is one of the most widely cited United States Supreme Court justices in history, particularly for his “clear and present danger” opinion for a unanimous Court in the 1919 case of 
Schenck v. United States. Holmes retired from the Court at the age of 90, making him the oldest Justice in the Supreme Court’s history.
  – “A mind that is stretched by a new experience can never go back to its old dimensions.”
  – I have no respect for the passion of equality, which seems to me merely idealizing envy – I don’t disparage envy, but I don’t accept it as legitimately my master.”

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. Are Your Copies of Regulations Up to Date?
(Source: Editor)

The official versions of the following regulations are published annually in the U.S. Code of Federal Regulations (C.F.R.), but are updated as amended in the Federal Register.  The latest amendments to applicable regulations are listed below.
: 27 CFR Part 447-Importation of Arms, Ammunition, and Implements of War
  – Last Amendment: 15 Jan 2016: 81 FR 2657-2723: Machineguns, Destructive Devices and Certain Other Firearms; Background Checks for Responsible Persons of a Trust or Legal Entity With Respect To Making or Transferring a Firearm. 
: 19 CFR, Ch. 1, Pts. 0-199
  – Last Amendment: 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

  – 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 

: 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.]

: 31 CFR, Parts 500-599, Embargoes, Sanctions, Executive Orders

  – Last Amendment: 5 Mar 2018:
83 FR 9182-9204: North Korea Sanctions Regulations

: 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
  – 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.
, 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: 27 Feb 2018:
Harmonized System Update 1802
, containing 164 ABI records and 38 harmonized tariff records.

  – HTS codes for AES are available here.
  – HTS codes that are not valid for AES are available here.


  – 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 

, 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
. BAFTR subscribers receive a 25% discount on subscriptions to the BITAR, please
contact us
to receive your discount code.

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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 

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* 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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