18-0416 Monday “Daily Bugle”

18-0416 Monday “Daily Bugle”

Monday, 16 April 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: “Secretary Ross Announces Activation of ZTE Denial Order in Response to Repeated False Statements to the U.S. Government”
  3. Commerce/BIS Activates ZTE Denial Order, Suspends ZTE’s Export Privileges for a Period of 7 Years
  4. DoD/DSCA Releases Policy Memo 18-09
  5. DoD/DSS Posts Notice Concerning DISS
  6. Justice: “Aruban Telecommunications Purchasing Official Pleads Guilty to Money Laundering Conspiracy Involving Violations of the FCPA”
  7. State/DDTC Welcomes Industry Feedback on Electronic Disclosure Form
  8. Treasury/OFAC: “Director John Smith Departing the Office of Foreign Assets Control”
  9. UK NCSS Issues Advise to UK Telecommunications Sector About ZTE”
  1. Reuters: “U.S. Bans American Companies from Selling to Chinese Phone Maker ZTE”
  2. RollCall: “Tech Companies Oppose Expanded Oversight of Sensitive Technology”
  3. ST&R Trade Report: “Environmental Goods Export Committee to Meet”
  4. Taipei Times: “U.S. Approves Submarine License”
  1. A. Smith, J.A. Lee & C. Timura: “Trump Administration Imposes Unprecedented Russia Sanctions” (Part I of II)
  2. L. van der Meer: “Export Controls & E. de Nyary Comandini: “UK Unpacks Encryption Controls”
  3. TMF Group: “Importing and Exporting Rules and Regulations in Hong Kong”
  4. Trade Collaboration Engine: “Protecting Export Controlled Data: Shulman’s Outgoing Guidance, DFARS, and What it Means for Your Trade Compliance Program”
  5. Gary Stanley’s EC Tip of the Day
  1. Monday List of Ex/Im Job Openings: 189 Jobs Posted, Including 13 New Jobs
  1. ECS Presents “Mastering ITAR/EAR Challenges” in Annapolis, MD, on May 22-23 
  1. Bartlett’s Unfamiliar Quotations 
  2. Are Your Copies of Regulations Up to Date? Latest Amendments: ATF (15 Jan 2016), Customs (12 Apr 2018), DOD/NISPOM (18 May 2016), EAR (5 Apr 2018), FACR/OFAC (19 Mar 2018), FTR (20 Sep 2017), HTSUS (30 Mar 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)

* DHS/CBP; NOTICES; Agency Information Collection Activities; Proposals, Submissions, and Approvals: Entry/Immediate Delivery Application and ACE Cargo Release [Publication Date: 17 Apr 2018.]

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Commerce, 16 Apr 2018.) [Excerpts.] 
Secretary of Commerce Wilbur L. Ross, Jr. today announced that the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) has imposed a denial of export privileges against Zhongxing Telecommunications Equipment Corporation, of Shenzhen, China (“ZTE Corporation”) and ZTE Kangxun Telecommunications Ltd. of Hi-New Shenzhen, China (“ZTE Kangxun”) (collectively, “ZTE”). 
In March 2017, ZTE agreed to a combined civil and criminal penalty and forfeiture of $1.19 billion after illegally shipping telecommunications equipment to Iran and North Korea, making false statements, and obstructing justice including through preventing disclosure to and affirmatively misleading the U.S. Government.  In addition to these monetary penalties, ZTE also agreed a seven-year suspended denial of export privileges, which could be activated if any aspect of the agreement was not met and/or if the company committed additional violations of the Export Administration Regulations (EAR). 
The Department of Commerce has now determined ZTE made false statements to BIS in 2016, during settlement negotiations, and 2017, during the probationary period, related to senior employee disciplinary actions the company said it was taking or had already taken.  ZTE’s false statements only were reported to the U.S. Government after BIS requested information and documentation showing that employee discipline had occurred. 
“ZTE made false statements to the U.S. Government when they were originally caught and put on the Entity List, made false statements during the reprieve it was given, and made false statements again during its probation.” said Secretary of Commerce Ross.
These false statements covered up the fact that ZTE paid full bonuses to employees that had engaged in illegal conduct, and failed to issue letters of reprimand.
  “ZTE misled the Department of Commerce.  Instead of reprimanding ZTE staff and senior management, ZTE rewarded them.  This egregious behavior cannot be ignored,” Secretary Ross said.
HERE to view the denial order. …
[Editor’s Note: See item #3 for a summary of the denial order.]  

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OGS_a33. Commerce/BIS Activates ZTE Denial Order, Suspends ZTE’s Export Privileges for a Period of 7 Years

Commerce/BIS, 16 Apr 2018.) [Summary.]
* Respondent: Zhongxing Telecommunications Equjpment Corporation (“ZTE”) of Nanshan District, Shenzen, China; and 
ZTE Kangxun Telecommunications Ltd. of Hi-New Shenzen, 518057, China (collectively, “ZTE”.)
* Charges: On March 23, 2017, the Acting Assistant Secretary of Commerce for Export Enforcement signed an Order approving the terms of the Settlement Agreement entered into in early March 2017, between the Bureau of industry and Security, U.S. Department of Commerce (“BIS”) and “ZTE”, hereinafter the “March 23, 2017 Order.” Under the terms of the settlement, ZTE agreed to a record-high combined civil and criminal penalty of $1.19 billion, after engaging in a multi-year conspiracy to violate the U.S. trade embargo against Iran to obtain contracts to supply, build, operate, and maintain telecommunications networks in Iran using U.S.-origin equipment, and also illegally shipping telecommunications equipment to North Korea in violation of the Export Administration Regulations (15 C.F.R. Parts 730-774 (2017)) (“EAR” or the “Regulations”). ZTE also admitted to engaging in an elaborate scheme to hide the unlicensed transactions from the U.S. Government, by deleting, destroying, removing, or sanitizing materials and information. 
  Under the terms of the Settlement Agreement and the March 23, 2017 Order, BIS imposed against ZTE a civil penalty totaling $661,000,000, with $300,000,000 of that amount suspended for a probationary period of seven years from the date of the Order. [FN/1] This suspension was subject to several probationary conditions stated in the Settlement Agreement and March 23, 2017 Order, including that ZTE commit no other violation of the Export Administration Act of 1979, as amended (50 U.S.C. §§ 4601-4623 (Supp. Ill 2015)), the Regulations, or the March 23, 2017 Order. The March 23, 20I7 Order also imposed, as agreed to by ZTE, a seven-year denial of ZTE’s export privileges under the EAR that was suspended subject to the same probationary conditions. The March 23, 2017 Order, like the Settlement Agreement, provided that should ZTE fail to comply with any of the probationary conditions, the $300 million suspended portion of the civil penalty could immediately become due and owing in full, as well as that BIS could modify or revoke the suspension of the denial order and activate a denial order of up to seven years.
  The Settlement Agreement and March 23, 2017 Order require that during the probationary period, ZTE is to, among other things, complete and submit six audit reports regarding ZTE’s compliance with U.S. export control laws. The Settlement Agreement and March 23, 2017 Order also include a broad cooperation provision during the period of the suspended denial order. This cooperation provision specifically requires that ZTE make truthful disclosures of any requested factual information. The Settlement Agreement and March 23, 20 17 Order thus, by their terms, essentially incorporate the prohibition set forth in Section 764.2(g) of the EAR against making any false or misleading representation or statement to BIS during, inter alia, the course of an investigation or other action subject to the EAR. …
BIS has determined that the company’s admission, in response to inquiries from BIS, that it made false statements to the U.S. Government during the probationary period under the Settlement Agreement and March 23, 2017 Order indicate that ZTE still cannot be relied upon to make truthful statements, even in the course of dealings with U.S. law enforcement agencies, and even with the prospect of the imposition of a $300 million penalty and/or a seven-year denial order. 
* Order: Activation of the suspended denial order in full and to suspend the export privileges of ZTE for a period of seven years, until March 13, 2025.
* Date of Order: 15 Apr 2018. 
  [FN/1] In addition to the BIS-ZTE settlement, ZTE Corporation entered into a plea agreement with the Justice Department’s National Security Division and the U.S. Attorney’s Office for the Northern District of Texas, and entered into a settlement agreement with the Treasury Department’s Office of Foreign Assets Control. The civil penalties (including the $661 million civil penalty imposed by BIS) and the criminal fine and forfeiture totaled, when combined, approximately $1.19 billion.

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DoD/DSCA, 16 Apr 2018.) 
* DSCA Policy Memo 18-09 
System-specific Checklists to Better Define Customer Requirements has been posted.
As directed in House Report 114-537, GAO reviewed the interagency processes for implementing FMF and FMS programs and released the report FOREIGN MILITARY SALES: Expanding Use of Tools to Sufficiently Define Requirements Could Enable More Timely Acquisitions, GA0-17-682, August 2017, which recommended IAs develop system specific checklists and post them to a public website. This memo updates 
Chapter 5 – FMS Case Development
 and inserts 
Figure C5.F14. Generic Letter of Request (LOR) Checklist.

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5. DoD/DSS Posts Notice Concerning DISS 

DoD/DSS, 16 Apr 2018.)
In preparation for accessing the Defense Information System for Security (DISS) portal, the Personnel Security Management Office for Industry offers ”
Preparing for DISS – Clean Up Your SMO.” 

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Justice, 13 Apr 2018.) [Excerpts.] 
Conspirators Paid Over $1.3 Million to Influence the Official and to Secure Business with State-Owned Telecommunications Company
An Aruban official residing in Florida pleaded guilty today to money laundering charges in connection with his role in a scheme to arrange and receive corrupt payments to influence the awarding of contracts with an Aruban state-owned telecommunications corporation. … 
Egbert Yvan Ferdinand Koolman, 49, a Dutch citizen residing in Miami, Florida, was an official of Servicio di Telecommunicacion di Aruba N.V. (Setar), an instrumentality of the Aruban government.  Koolman pleaded guilty before U.S. District Judge Frederico A. Moreno of the Southern District of Florida to one count of conspiracy to commit money laundering. He is scheduled to be sentenced on June 27.
In connection with the scheme, Lawrence W. Parker, Jr., 42, of Miami, pleaded guilty on Dec. 28, 2017 to one count of conspiracy to violate the Foreign Corrupt Practices Act (FCPA) and to commit wire fraud.  Parker’s sentencing is scheduled for April 30.
According to admissions made as part of his plea agreement, between 2005 and 2016, Koolman operated a money laundering conspiracy from his position as Setar’s product manager.  Koolman admitted that, as part of the scheme, he conspired with Parker and others to transmit funds from Florida and elsewhere in the United States to Aruba and Panama with the intent to promote a wire fraud scheme and a corrupt scheme that violated the FCPA.  Koolman was promised and received bribes from individuals and companies located in the United States and abroad in exchange for using his position at Setar to award lucrative mobile phone and accessory contracts, he admitted.  He received the corrupt payments via wire transfer from banks located in the United States, in cash during meetings in Miami and in Aruba, and by withdrawing cash in Aruba using a bankcard that drew money from a United States-based bank account, he further admitted.  In exchange for the more than $1.3 million in corrupt payments that he received, Koolman also admitted providing favored vendors with Setar’s confidential information.

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State/DDTC Welcomes Industry Feedback on Electronic Disclosure Form 
, 16 Apr 2018.) 
DDTC is developing an electronic version of the current DS-7787: Disclosure of Violations of the Arms Export Control Act (AECA) form, also known as Disclosures. 
 As an alternative to paper and mail, the online version will allow Industry personnel to submit Disclosures directly through DDTC’s Defense Export Compliance and Control System (DECCS).
In an effort to improve this electronic form, DDTC is enabling a test version of the new online process for Industry feedback between April 16, 2018 – April 30, 2018, prior to it being publicly available online. 
 If you are interested in participating, please go 
here for more information on how to access and use the test version.  Once you have completed testing, you can submit feedback or comments through the “Provide feedback” button in DECCS. 
Thank you in advance for your participation, and we look forward to your feedback!

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Treasury/OFAC: “Director John Smith Departing the Office of Foreign Assets Control”
Treasury/OFAC, 12 Apr 2018.) [Excerpts.]
The U.S. Department of the Treasury today announced that John E. Smith will be leaving his position as Director of the Office of Foreign Assets Control (OFAC) in early May. Mr. Smith has served as OFAC’s Director/Acting Director since February 2015 and has been with OFAC for over 11 years, previously serving as its Deputy Director and as an Associate Director. …  Under Mr. Smith’s direction, OFAC reinforced its reputation as a key player in addressing the nation’s most complex and challenging national security and foreign policy crises. He led the agency’s development and imposition of some of its most significant sanctions actions ever involving North Korea, Russia, Iran, Syria, supporters of terrorism, weapons of mass destruction proliferators, malicious cyber actors, and narcotics traffickers, as well as the agency’s implementation of statutes such as the Countering America’s Adversaries Through Sanctions Act of 2017 and the issuance of major enforcement actions against those who violated its sanctions. … 

Following Mr. Smith’s departure in early May, Deputy Director Andrea M. Gacki will serve as the Acting Director of OFAC. Ms. Gacki has been with OFAC in various leadership capacities for the past decade. OFAC’s Chief Counsel Bradley Smith will serve as Acting Deputy Director.

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UK NCSS Issues Advise to UK Telecommunications Sector About ZTE

UK GCHQ/NCSC, 16 Apr 2018.)
The National Cyber Security Centre (NCSC) [part of the UK Government Communications Headquarters (GCHQ)] is issuing advice to the UK telecommunications sector regarding the potential use of ZTE equipment and services.
Dr. Ian Levy (Technical Director of the National Cyber Security Centre) is writing to telecommunications organizations regarding the potential use of ZTE equipment and services in the UK telecommunications infrastructure environment. ZTE is a Chinese state-owned enterprise. His letter sets out the NCSC’s considered technical advice in regard to the potential use of ZTE equipment and services in the UK telecommunications infrastructure.
Dr. Ian Levy, Technical Director of the National Cyber Security Centre said: 
It is entirely appropriate and part of NCSC’s duty to highlight potential risks to the UK’s national security and provide advice based on our technical expertise.
NCSC assess that the national security risks arising from the use of ZTE equipment or services within the context of the existing UK telecommunications infrastructure cannot be mitigated.

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Reuters: “U.S. Bans American Companies from Selling to Chinese Phone Maker ZTE”

Reuters, 16 Apr 2018.) [Excerpts.] 
The U.S. Department of Commerce is banning American companies from selling components to leading Chinese telecom equipment maker ZTE Corp for seven years for violating the terms of a sanctions violation case, U.S. officials said on Monday.
The Chinese company, which sells smartphones in the United States, pleaded guilty last year in federal court in Texas for conspiring to violate U.S. sanctions by illegally shipping U.S. goods and technology to Iran. It paid $890 million in fines and penalties, with an additional penalty of $300 million that could be imposed.
As part of the agreement, Shenzhen-based ZTE Corp promised to dismiss four senior employees and discipline 35 others by either reducing their bonuses or reprimanding them, senior Commerce Department officials told Reuters. But the Chinese company admitted in March that while it had fired the four senior employees, it had not disciplined or reduced bonuses to the 35 others. … 
ZTE “provided information back to us basically admitting that they had made these false statements,” said a senior department official. “That was in response to the U.S. asking for the information.”
  “We can’t trust what they are telling us is truthful,” the official said. “And in international commerce, truth is pretty important.”
ZTE officials did not immediately respond to requests for comment.
Meanwhile, Britain’s main cyber security agency said on Monday it has written to organizations in the UK’s telecommunications sector warning about using services or equipment from ZTE.
‘Devastating to the Company’ 
Douglas Jacobson, an exports control lawyer who represents suppliers to ZTE, called the ban highly unusual and said it would severely affect the company.
  “This will be devastating to the company, given their reliance on U.S. products and software,” said Jacobson. “It’s certainly going to make it very difficult for them to produce and will have a potentially significant short and long-term negative impact on the company.”
  “This is going to tank their stock,” Jacobson added.
ZTE has sold handset devices to U.S. mobile carriers AT&T Inc, T-Mobile US Inc and Sprint Corp. It has relied on U.S. companies including Qualcomm Inc, Microsoft Corp and Intel Corp for components.
The U.S. action against ZTE is likely to further exacerbate current tensions between Washington and Beijing over trade. After the U.S. placed export restrictions on ZTE in 2016 for Iran sanctions violations, the China’s Ministry of Commerce and Foreign Ministry criticized the decision.
A five-year federal investigation found last year that ZTE had conspired to evade U.S. embargoes by buying U.S. components, incorporating them into ZTE equipment and illegally shipping them to Iran.
ZTE, which devised elaborate schemes to hide the illegal activity, agreed to plead guilty after the Commerce Department took actions that threatened to cut off its global supply chain.
The U.S. government had allowed the company continued access to the U.S. market under the 2017 agreement. American companies are estimated to provide 25 percent to 30 percent of the components used in ZTE’s equipment, which includes networking gear and smartphones.
The new restrictions stem from a Jan. 16 report by a U.S. monitor appointed by a federal judge in Texas who accepted the guilty plea in March 2017. Although Commerce Department officials would not discuss the report, they said the department followed up in February.
The U.S. government’s investigation into sanctions violations by ZTE followed reports by Reuters in 2012 that the company had signed contracts to ship millions of dollars’ worth of hardware and software from some of the best known U.S. technology companies to Iran’s largest telecoms carrier. 

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RollCall: “Tech Companies Oppose Expanded Oversight of Sensitive Technology”

RollCall, 16 Apr 2018.) [Excerpts.] 
Legislation focuses on foreign deals
Representatives of the technology industry are warning lawmakers that a plan to give an interagency panel authority over offshore sales or transfers of sensitive technology would impede routine business deals.
The House Financial Services Monetary Policy and Trade Subcommittee held its fourth and final hearing Thursday on a bill by Rep. 
Robert Pittenger, R-N.C., that would broaden the authority of the Committee on Foreign Investment in the United States (CFIUS) to include a range of business deals involving U.S. and foreign companies, including offshore joint ventures involving technology transfer.

Jonathan S. Kallmer, senior vice president of global policy for the Information Technology Industry Council, a trade group representing about 60 companies, criticized language in the bill giving CFIUS purview over joint ventures involving the contribution by a critical U.S. technology company of intellectual property and associated support to a foreign person through any type of arrangement. … 

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ST&R Trade Report: “Environmental Goods Export Committee to Meet” 

Sandler, Travis & Rosenberg Trade Report, 16 Apr 2018.)
The International Trade Administration’s Environmental Technologies Trade Advisory Committee will hold a public meeting via teleconference April 30. Members of the public wishing to participate must register by April 23.
The ETTAC advises the Environmental Trade Working Group of the Trade Promotion Coordinating Committee on the development and administration of programs to expand U.S. exports of environmental technologies, goods, services, and products. During the upcoming meeting the three ETTAC subcommittees (Trade Promotion and Export Market Development, Professional Services and Infrastructure Advancement, and Trade Policy and American Competitiveness) will discuss their top priorities for this charter period (which ends in August) with the goal of finalizing the committee’s recommendations. Topics under discussion include optimizing the U.S. government’s trade promotion programs, identifying market access barriers, pros and cons of existing trade agreements, and foreign procurement policy, including issues with financing mechanisms, localization requirements, and non-tariff barriers.

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Taipei Times: “U.S. Approves Submarine License”

Taipei Times, 8 Apr 2018.) [Excerpts.] 
The U.S. Department of State has approved a marketing license needed for U.S. manufacturers to sell technology to Taiwan that would enable the nation to build domestic submarines, the [Taiwanese] Ministry of National Defense said yesterday.
Ministry spokesman Major General Chen Chung-chi said in an interview that the ministry has received reports that the state department has agreed to grant the marketing license required for the sale of technology that Taiwan needs to develop indigenous submarines. … 
  “The announcement from the U.S. is the first step. Whether we are talking about components, systems or other technology, U.S. manufacturers would still need to obtain export permits,” [Democratic Progressive Party Legislator Wang Ding-yu] said. “Nevertheless, this act from the US Department of State is a great start.”

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A. Smith, J.A. Lee & C. Timura: “Trump Administration Imposes Unprecedented Russia Sanctions” (Part I of II) 

Gibson Dunn, 12 Apr 2018.) [Excerpts.] 
* Authors: Adam M. Smith, Esq., 
asmith@gibsondunn.com; Judith Alison Lee, Esq., 
jalee@gibsondunn.com; and Christopher T. Timura, Esq., 
ctimura@gibsondunn.com. All of Gibson Dunn, Washington DC. 
[Editor’s Note: Due to space limitations, this article has been divided into two parts. Publication Dates are Mon, 16 Apr 2018, and Tue, 17 Apr 2018.]
On April 6, 2018, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) significantly enhanced the impact of sanctions against Russia by blacklisting almost 40 Russian oligarchs, officials, and their affiliated companies pursuant to Obama-era sanctions, as modified by the Countering America’s Adversaries Through Sanctions Act (“CAATSA”) of 2017.  In announcing the sanctions, Treasury Secretary Steven Mnuchin cited Russia’s involvement in “a range of malign activity around the globe,” including the continued occupation of Crimea, instigation of violence in Ukraine, support of the Bashal al-Assad regime in Syria, attempts to subvert Western democracies, and malicious cyber activities. [FN/1] Russian stocks fell sharply in response to the new measures, and the ruble depreciated almost 5 percent against the dollar. [FN/2]
Although this is not the first time that the Trump administration imposed sanctions against Russia, it is the most significant action taken to date.  In June 2017, OFAC added 38 individuals and entities involved in the Ukraine conflict to OFAC’s list of Specially Designated Nationals (“SDNs”). [FN/3]  The April 6 sanctions added seven Russian oligarchs and 12 companies they own or control, 17 senior Russian government officials, the primary state-owned Russian weapons trading company and its subsidiary, a Russian bank, to the SDN List. [FN/4] These designations include major, publicly-traded companies that have been listed on the London and Hong Kong exchanges and that have thousands of customers and tens of thousands of investors throughout the world.
OFAC has never designated similar companies, and the potential challenges for global companies seeking to comply with OFAC measures are substantial.  An SDN designation prohibits U.S. persons-including U.S. companies, U.S. financial institutions, and their foreign branches-from engaging in any transactions with the designees or with entities in which they hold an aggregate ownership of 50 percent or more.  The designation of a small company in a regional market can be devastating for the company, but rarely would it impose meaningful collateral consequences on global markets or investors.  In this case, sanctions on companies such as EN+ and RUSAL (amongst others) have already impacted a substantial portion of a core global commodity (the aluminum market) while also preventing further trades in their shares, a move that could harm pension funds, mutual funds, and other investors that have long held stakes worth billions of dollars.
To minimize the immediate disruptions, OFAC issued two time-limited general licenses (regulatory exemptions) permitting companies and individuals to undertake certain transactions to “wind down” business dealings related to the designated parties. [FN/5] However, our assessment is that disruptions are inevitable and the size of the sanctions targets in this case means that the general licenses will have potentially limited effect in reducing dislocations.
OFAC’s April 6 designations mark a clear change in tone from the Trump administration, which had initially resisted imposing the full force of CAATSA’s sanctions.  For example, as we wrote in our 
2017 Year-End Sanctions Update, CAATSA required the imposition of secondary sanctions on any person the President determined to have been engaging in “a significant transaction with a person that is part, or operates for or on behalf of, the defense or intelligence sectors of the Government Russia.” [FN/6] On the day such sanctions were to be imposed, State Department representatives provided classified briefings to Congressional leaders to explain their decision 
not to impose any such sanctions under CAATSA, namely because the Trump administration felt that CAATSA was already having an deterrent effect which removed any immediate need to impose sanctions. [FN/7]
Section 241 of CAATSA also required OFAC to publish a report on January 29, 2018 identifying “the most significant senior foreign political figures and oligarchs in the Russian Federation,”[FN/8] (the “Section 241 List”).  The Treasury Department issued the report shortly before midnight on the due date, publicly naming 114 senior Russian political figures and 96 oligarchs.[FN/9] Although the report did not result in any sanctions or legal repercussions, the public naming of such persons did cause confusion for those who sought to engage with them in compliance with U.S. law.[FN/10] However, most observers were highly critical of the list, claiming that it demonstrated that the Trump administration was failing to adequately address Congressional intent to punish Moscow.  Interestingly, almost all of the oligarchs designated on April 6 originally appeared on the Section 241 List. [FN/11]
Included among the list of sanctioned parties were seven Russian oligarchs designated for being a Russian government official or operating in the energy sector of the Russian Federation economy, and 12 companies they own or control.  In its press release, OFAC warned that the 12 companies identified as owned or controlled by the designated Russian oligarchs “should not be viewed as exhaustive, and the regulated community remains responsible for compliance with OFAC’s 50 percent rule.”  This rule extends U.S. sanctions prohibitions to entities owned 50 percent or more, even if those companies are not themselves listed by OFAC.  The opacity of ownership in the Russian economy makes the 50 percent rule very difficult to operationalize.
In addition, OFAC designated 17 senior Russian government officials, a state-owned company and its subsidiary.  The sanctioned individuals and entities, as described by OFAC, are provided in the following table [available 
here.]. … 
All assets subject to U.S. jurisdiction of the designated individuals and entities, and of any other entities blocked by operation of law as a result of their ownership by a sanctioned party, are frozen, and U.S. persons are generally prohibited from dealings with them.  OFAC’s Frequently Asked Questions (“FAQs”) make clear that if a blocked person owns less than 50 percent of a U.S. company, the U.S. company will not be blocked.  However, the U.S. company (1) must block all property and interests in property in which the blocked person has an interest and (2) cannot make any payments, dividends, or disbursement of profits to the blocked person and must place them in a blocked account at a U.S. financial institution. [FN/12] 
Non-U.S. persons could face secondary sanctions for knowingly facilitating significant transactions for or on behalf of the designated individuals or entities.  CAATSA strengthened the secondary sanctions measures that could be used to target such persons, although such measures typically carry less risk because as a matter of implementation OFAC traditionally warns those who may be transacting with parties that could subject them to secondary sanctions and provides them with an opportunity to cure.  While this outreach and deterrence model of imposing secondary sanctions was developed under the Obama administration (and resulted in very few impositions of secondary sanctions), the Trump administration could theoretically change it and impose secondary sanctions without the traditional warning.  However, that appears unlikely and the Trump administration has indicated that it will continue to provide warnings before imposing secondary sanctions.
Two CAATSA provisions bear particular note as they are implicated by Friday’s actions:  section 226, which authorizes sanctions on foreign financial institutions for facilitating a transaction on behalf of a Russian person on the SDN List, and section 228, which seeks to impose sanction on a person who “facilitates a 
significant transaction…for or on behalf of any person subject to sanctions imposed by the United States with respect to the Russian Federation.” [FN/13] OFAC has clarified that the section 228 provision extends to persons listed on 
either the SDN or the Sectoral Sanctions Identifications (“SSI”) List, as well as persons they may own or control pursuant to OFAC’s 50 percent rule. [FN/14] As we noted when CAATSA was passed, despite the mandatory nature of these sections, the President appears to retain the discretion to impose restrictions based upon whether he finds certain transaction significant or for other reasons.  With the increase in the SDN list to include major players in global commodities such as EN+ or RUSAL, more companies around the world that rely on these companies could find themselves at least theoretically at risk of being sanctioned themselves.  Companies should also consider this risk where there is reliance on material produced by any company in the Russian military establishment and sold by the Russian state arms company such as Rosoboronexport, which was also sanctioned.
General Licenses 
In an effort to minimize the immediate disruptions to U.S. persons and global markets (especially given the sanctioning of major publicly traded corporations that have thousands of clients and investors throughout the world), OFAC issued General Licenses 12 and 13, permitting companies to undertake certain transactions and activities to “wind down” certain business dealings related to certain, listed designated parties.  These General Licenses only cover U.S. persons, which has led some non-U.S. companies to inquire whether their ability to wind down operations with respect to the SDN companies would place them at risk for secondary sanctions (as they would be engaging with sanctioned parties and perhaps trigger the CAATSA provisions above).  OFAC has noted in its FAQs that the U.S. Government would not find a transaction “significant” if a U.S. person would not need a specific license to undertake it. [FN/15] That is, it would seem that at least for the duration of the General Licenses a non-U.S. party can engage in similar wind down operations without risking secondary sanctions.
General License 12, which expires June 5, 2018, authorizes U.S. persons to engage in transactions and activities with the 12 oligarch-owned designated entities that are “ordinarily incident and necessary to the maintenance or wind down of operations, contracts, or other agreements” related to these 12 entities (as well as those entities impacted by operation of OFAC’s 50 percent rule).  This is a broader wind down provision than OFAC has issued in the past in that it allows not just “wind down” activities but also non-defined “maintenance” activities.  Despite this breadth it is already uncertain how this General License will actually work in practice.  Permissible transactions and activities include importation from blocked entities and broader dealings with them.  However, no payments are allowed to be made to blocked entities-rather such payments can only be made to the blocked entities listed in General License 12 into blocked, interest-bearing accounts and reported to OFAC by June 18, 2018 (10 business days after the expiration of the license).[FN/16]It is not clear why a sanctioned party would wish to deliver goods and services to parties if the sanctioned party cannot be paid.  In line with the FAQ noted above, for non-U.S. companies it would seem that in order to avoid secondary sanctions implications the same restrictions would apply-that is, continued transactions are permitted on a wind down basis, but transfer of funds to the SDN companies could be viewed as “significant” or otherwise sanctionable.
Recognizing how broad the sanctions are and how far they may implicate subsidiaries of SDN companies inside the United States, OFAC’s FAQs clarify that General License 12 generally permits the blocked entities listed to pay U.S. persons their salaries, pension payments, or other benefits due during the wind down period.  U.S. persons employed by entities that are not explicitly listed in General License 12-principally the designated Russian state-owned entities-do not have the benefit of this wind down period.  OFAC FAQs note that such U.S. persons may seek authorization from OFAC to maintain or wind down their relationships with any such blocked entity, but make clear that continued employment or board membership related to these entities is prohibited.[FN/17]The implications of these restrictions are significant where, as is the case with the blocked entities listed in General License 12, U.S. subsidiaries exist and U.S. persons are involved throughout company operations.
General License 13, which expires May 7, 2018, similarly allows transactions and activities otherwise prohibited under the April 6 sanctions.  This license allows transactions and activities necessary to “divest or transfer debt, equity, or other holdings” in three designated Russia entities:  EN+ Group PLC, GAZ Group, and United Company RUSAL PLC.  Permitted transactions include facilitating, clearing, and settling transactions.  General License 13, however, does not permit any divestment or transfer to a blocked person, including the three entities listed in General License 13. [FN/18] As with General License 12, transactions permitted under General License 13 must be reported to OFAC within 10 business days after the expiration of the license.
Once again, it is uncertain how the General License will work in practice.  Given the designations which have depressed the share prices of the sanctions parties it is unknown who might be willing to purchase the shares even if U.S. holders are permitted to sell them.
Other Ramifications for Investors, Supply Chains, and Customers
The April 6 sanctions raise other significant questions and practical challenges for U.S. and non-U.S. companies, with particular risks for investors as well as the manufacturers, suppliers, and customers of the SDN companies.
Investors and fund managers will need to conduct significant diligence into the participants and ownership structures of their funds, including fund limited partners, to determine whether sanctioned persons or entities are involved.  Moreover, for those who have seen the value of any assets tied to these companies decline significantly, they are allowed to continue to try sell their assets to non-U.S. persons.  However, given the challenge in finding buyers and evidence that certain financial institutions and brokers are already refusing to engage in any trades (even during the wind down period), the investment community needs to potentially prepare for long-term holding of blocked assets (by setting up sequestered accounts).
For those within the supply chains of sanctioned companies, from suppliers of commodities to finished goods, as well as customers of sanctioned companies, the concern will be to potentially replace key commercial relationships which will become increasingly difficult (if not prohibited) to maintain.  For companies that have relied on RUSAL, for example, as a source of aluminum or as a customer for their goods they will potentially need to find replacements.  While aluminum is not in short supply globally, in certain jurisdictions RUSAL has a commanding position and even a monopoly.  It is unclear how companies that seek to be compliant with OFAC regulations will navigate a world in which RUSAL has been a primary or secondary supplier (and there is no clear way to avoid such engagement so long as the company seeks to be active in that jurisdiction and in need of aluminum).  Moreover, it is not just U.S. person counterparties that are likely to be affected by prohibitions on dealing with sanctioned parties.  In line with the FAQ noted above, if non-U.S. companies were to make payments to the sanctioned companies for deliveries, these could be deemed “significant transactions” and could make the non-U.S. companies, themselves, the target of OFAC designations and/or secondary sanctions.  One option-reportedly pursued by one major trading company-is to declare force majeure on contracts with Rusal.
As noted above, relief contemplated by General Licenses 12 and 13 may be operationally difficult to implement.  The sanctions apply to companies that are 50 percent owned or controlled by blocked parties.  Companies will need to undertake, under a short time line, significant due diligence to determine whether any such companies are involved in its operations.  The wind down process may be further complicated by any Russian response to the U.S. sanctions.
  [FN/1] Press Release, U.S. Department of the Treasury, 
Treasury Designates Russian Oligarchs, Officials, and Entities in Response to Worldwide Malign Activity (Apr. 6, 2018), available 
  [FN/2] Natasha Turak, 
US sanctions are finally proving a ‘major game changer’ for Russia, CNBC, (Apr. 10, 2018), available 
  [FN/3] Press Release, U.S. Dep’t of the Treasury, 
Treasury Designates Individuals and Entities Involved in the Ongoing Conflict in Ukraine (June 20, 2017), available 
here.  Designated persons and entities included separatists and their supporters; entities operating in and connected to the Russian annexation of Crimea; entities owned or controlled by, or which have provided support to, persons operating in the Russian arms or materiel sector; and Russian government officials.
  [FN/4] U.S. Department of the Treasury, 
supra, n. 1.
  [FN/6] CAATSA, Title II, § 231 (a). Specifically, CAATSA Section 231(a) specified that the President shall impose five or more of the secondary sanctions described in Section 235 with respect to a person the President determines knowingly “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, including the Main Intelligence Agency of the General Staff of the Armed Forces of the Russian Federation or the Federal Security Service of the Russian Federation.”  The measures that could be imposed under Section 231 are discretionary in nature.  The language of the legislation is somewhat misleading in this regard.  Section 231 is written as a mandatory requirement-providing that the President “shall impose” various restrictions.  However, the legislation itself-and the October 27, 2017 guidance provided by the State Department-makes clear that secondary sanctions are only imposed after the President makes a determination that a party “knowingly” engaged in “significant” transactions with a listed party.  The terms “knowingly” and “significant” have imprecise meanings, even under the State Department guidance.  OFAC Ukraine-/Russia-related Sanctions FAQs (“OFAC FAQs”), OFAQ No. 545, available 
  [FN/7] Press Release, U.S. Dep’t of State, 
Background Briefing on the Countering America’s Adversaries Through Sanctions Act (CAATSA) Section 231 (Jan. 30, 2018), available 
 [FN/8] CAATSA, Title II, § 241.
 [FN/9] See U.S. Dep’t of the Treasury
, Report to Congress Pursuant to Section 241 of the Countering America’s Adversaries Through Sanctions Act of 2017 Regarding Senior Foreign Political Figures and Oligarchs in the Russian Federation and Russian Parastatal Entities (Unclassified) (Jan. 29, 2018), available 
See, e.g., Press Release, U.S. Dep’t of the Treasury, 
Treasury Releases CAATSA Reports, Including on Senior Foreign Political Figures and Oligarchs in the Russian Federation (Jan. 29, 2018), available 
 [FN/11] The one exception is Igor Rotenberg.  Although Igor Rotenberg did not appear on the Section 241 List, his father and uncle were included.  According to the April 6 OFAC announcement, Igor Rotenberg acquired significant assets from his father, Arkady Rotenberg, after OFAC designated the latter in March 2014.  Specifically Arkady Rotenberg sold Igor Rotenberg 79 percent of the Russian oil and gas drilling company Gazprom Burenie.  Igor Rotenberg’s uncle, Boris Rotenberg, owns 16 percent of the company.  Like his brother Arkady Rotenberg, Boris Rotenberg was designated in March 2014.
  [FN/12] OFAC FAQ No. 573.
  [FN/13] CAATSA, Title II, §228.
  [FN/14] OFAC FAQ No. 546.  In its implementing guidance, OFAC confirmed that Section 228 extends to SDNs and SSI entities but clarified that it would not deem a transaction “significant” if U.S. persons could engage in the transaction without the need for a specific license from OFAC.  In other words, only transactions prohibited by OFAC-specifically, transactions with SDNs and/or transactions with SSI entities that are prohibited by the sectoral sanctions-will “count” as significant for purposes of Section 228.  OFAC also noted that even a transaction with an SSI that involves prohibited debt or equity would not automatically be deemed “significant”-it would need to also involve “deceptive practices” and OFAC would assess this criteria on a “totality of the circumstances” basis.
 [FN/15] OFAC FAQ No. 574. 
 [FN/16] General License 12; OFAC FAQ No. 569.
 [FN/17] See also OFAC FAQ Nos. 567-568.
 [FN/18] See also OFAC FAQ Nos. 570-571.

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L. van der Meer & E. de Nyary Comandini: “UK Unpacks Encryption Controls” 

Trade and Manufacturing Monitor, 13 Apr 2018.) 
* Authors: Laura van der Meer, Esq., 
lvandermeer@kelleydrye.com; and Edouard de Nyary Comandini, Esq., 
edenyary@kelleydrye.com; Both of Kelley Drye. Brussels. 
Despite the fact that export controls on dual-use goods derive from international agreements such as the Wassenaar Arrangement, significant differences can be seen as controls are implemented by different countries. The same is true in the European Union notwithstanding the fact that the EU’s dual-use regulation (Council Regulation (EC) No. 428/2009) is binding on its 28 Member States.  Accordingly, while Regulation 428/2009 exempts telecom and information security equipment with encryption where there is limited cryptography functionality and/or products are mass-marketed and cannot be readily changed (the “Cryptography Note”), the exact scope of the exemptions is determined by each Member State.
On 3 April 2018, the UK released guidance on the application of the Cryptography Note to help exporters assess whether a license is necessary.  The guidance clarifies that to qualify for exemption under the Cryptography Note, the product must be intended for general public use and cannot be sold with limitation or qualification of the purchaser.  However, a product used by a specific group, such as items that are customized in accordance with a standard list of options, which can be also used by a wider range of industries may be exempt from controls.  Further, the guidance clarifies the requirement that exempt products must be able to be installed by the public without assistance from specialists.  It states that optional on-site installation support from the retail outlet, provision of installation instructions that are included in the product packaging, and/or assistance through a helpline or website where non-proficient users can ask questions about installation instructions do not necessarily disqualify the product from exemption. Finally, the guidance clarifies that offering an option to select algorithms from a pre-set list, or the ability to switch the function on or off would not disqualify a product from exemption relative to the requirement that the cryptographic functionality must be simple to manage to meet the requirements of the Cryptography Note.
In addition, the guidance addresses the applicability of controls to hardware components and executable software for devices discussed above.  It includes a list of items that would generally be exempt from controls such as wifi chips designed for an existing model of tablet or wearable device, and GSM modems because their main purpose is not information security.  The guidance cautions, on the other hand, that a crypto acceleration co-processor or chips with built-in tamper defense would not qualify for exemption. Other caveats are flagged.
As the UK heads toward Brexit and autonomous implementation of international obligations, this clarification of its views on which encryption technology should not be subject to export controls will be welcome for UK manufacturers and companies placing products on the UK market.

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TMF Group: “Importing and Exporting Rules and Regulations in Hong Kong”

TMF Group, 12 Apr 2018.) [Excerpts.] 
Trade with Hong Kong is booming. In such an energized marketplace, it is important to understand the legal parameters for importing and exporting. Local expertise can support your business expansion in the region and help you navigate the appropriate regulations. … 
In such an energized marketplace, it is important to understand the legal parameters for trade. Local expertise can support your business expansion in the region and help you navigate the appropriate regulations.
Business Opportunity
Hong Kong is a free port with no restrictions on the right to import and export goods. Any Hong Kong company or individual has the right to handle goods import and export, but even so, such businesses must comply with certain regulations. Companies set up by mainland enterprises in Hong Kong can also enjoy the same right.
There is no customs tariff on goods imported into the country. The HKSAR Government collects an excise duty on only four types of goods, irrespective of whether they are imported or locally manufactured: tobacco, hydrocarbon oil, alcoholic beverages, and methyl alcohol.
Usually, all cargo imported into or exported from HKSAR via air, land and sea is subject to Customs control, which is carried out primarily through inspection of documentation such as manifests. Physical examination of goods, if necessary, is mainly carried out on a selective basis.
For goods entering Hong Kong, the importer must complete customs clearance and declaration formalities with the Hong Kong Customs and Excise Department. Charges are based on the value and nature of goods imported, except for articles exempted from declaration charge.
Certain goods, such as food, pharmaceuticals, and vehicles, are subject to import/export control. If the goods to be imported or exported are “prohibited articles” or “reserved commodities” under the Import and Export Ordinance (Cap.60) and the Reserved Commodities (Control of Imports, Exports and Reserve Stocks) Regulations (Cap.296A), shipping companies, airlines and transportation companies must deliver the relevant manifests and import/export licences to the Trade and Industry Department within 14 days of the import/export, for manifest checking.
Hong Kong’s Strategic Commodities Control System requires companies wishing to import/export certain goods, such as military equipment or chemicals to register for a licence to do so. Goods in transit, provided they don’t leave the vehicle they are being transported in, are exempted from the import/export licensing requirements.
Anyone failing to complete the necessary customs clearance and declaration procedures, or who delays submission or gives false information is considered to have broken the law and is liable to penalty.
A delay in documentation, if the total value of goods is over HK$20,000, could trigger a fine of between HK$40-200 per declaration item. Giving false information risks a HK$10,000 fine. Heavier breaches risk imprisonment and somebody in breach of the law may be subject to administrative actions, such as suspension or revocation of licenses or registration concerned.
Export origins
To facilitate exports from Hong Kong the government operates a certification system on the origin of the goods to be sent abroad, to meet the requirements of overseas importing authorities. Imports do not require origin certification. The Export (Certificates of Origin) Regulations of the Import and Export Ordinance (Cap 60) empower the Director-General of Trade and Industry to issue Certificates of origin for any items manufactured, processed, or produced in Hong Kong.
Free trade agreements exist with China, New Zealand, and the European Free Trade Association. Plus, a new agreement has been forged with the Association of Southeast Asian Nations (ASEAN), and negotiations are ongoing for a free trade agreement with Australia. Hong Kong’s exports to these economies can enjoy preferential tariff treatment if they meet specific rules of origin – hence Hong Kong’s Rules of origin process of certification.

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Trade Collaboration Engine: “Protecting Export Controlled Data: Shulman’s Outgoing Guidance, DFARS, and What it Means for Your Trade Compliance Program”

(Source: Trade Collaboration Engine, 30 Mar 2018.)
The November 2, 2017, addition of Jim Bartlett’s 
Daily Bugle carried an article detailing guidance provided by 
Arthur Shulman, who was then the Acting Director, Office of Defense Trade Controls Compliance (DTCC). Mr. Shulman, speaking at Sheppard Mullin’s ”
Trends and Directions in the Aerospace and Defense Market,” noted that protecting technical data is one of industry’s most challenging tasks. As many of you know, Mr. Shulman has since accepted a position with The Boeing Company (congratulations to both), but his comments are worth examining. 
One of the key points stressed in the article concerns hacking. Mr. Shulman indicated that DDTC wants to be notified if a compromise results in the unauthorized access to technical data. As attribution is often difficult in a hacking event, companies may not be able to determine if a hacking event resulted in unauthorized exports. However, my recommendation is that, unless definitively proven otherwise, unauthorized exports should be assumed in a hacking event involving ITAR Export Controlled Data (ECD) and reported to DTCC. 
In the article, Mr. Shulman also commented on the quality of disclosures received, noting that many lacked evidence of a thorough investigation and clear plan for implementing corrective actions. When it comes to cyber incidents, thorough investigations and effective corrective actions cannot be accomplished without IT’s direct involvement. Readers should also note that any hacking event involving an IT ecosystem subject to DFARS 7012 must be reported to the 
Dibnet as part of a comprehensive security plan required by the regulation. 
Scott Edwards, President of Summit 7 Systems, a leading industry expert in DFARS 7012 and NIST 800-171 requirements, provides his thoughts on Mr. Shulman’s comments 
here. For anyone looking for more information on DFARS 7012, I highly recommend you follow 
Scott Edward’s blog
Mr. Shulman also provided recommendations on what companies should be doing to protect ITAR-controlled ECD within their environments, which were summarized in the article as follows: (1) Know what you have (proper classification), (2) Know where you have it, and (3) Know who has access to it.
Key Takeaways
  – If you’re not already, get engaged with your company’s efforts to comply with DFARS;
  – Familiarize yourself with 
NIST 800-171 controls, work with IT to understand the SSP and POA&M, and ensure these documents account for export compliance requirements. If you’re a Trade Compliance professional and aren’t familiar with DFARS 7012, Scott’s blog is an excellent starting point.
  – Trade Compliance personnel should be included in IT security incidents involving Export Controlled Data (ECD);
  – IT security personnel should be included in Trade Compliance incidents involving IT systems;
  – Unless definitively proven otherwise, unauthorized exports should be assumed in a hacking event where ITAR ECD is compromised, or likely to have been compromised;
  – Trade Compliance should be submitting Voluntary Disclosures when IT ecosystems containing ITAR ECD are hacked/compromised; 
  – When drafting Voluntary Disclosures involving electronic data, make sure IT is engaged. Leverage IT resources in the investigation, make sure controls are accounted for in the SSP, and corrective actions defined/planned/implemented through the POA&M. Use the POA&M to track implementation of corrective actions involving IT;
  – When implementing capabilities to identify ECD and ensure the location, access, and transfer of ECD is in compliance with export regulations, Trade Compliance should be working directly with IT security to ensure the capabilities are implemented through the POA&M and institutionalized in the SSP.  

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Gary Stanley’s EC Tip of the Day

(Source: Defense and Export-Import Update, 15 Apr 2018.  Available by subscription from
* Author: Gary Stanley, Esq., Global Legal Services, PC, (202) 352-3059,
Given ITAR Part 124 Warehouse and Distribution Agreements (WDAs) do not have value assigned to the overall agreement, the verification of whether the Congressional Notification threshold is met and any required notification are accomplished via the IFO license submissions. This ensures compliance with Congressional Notification requirements. Congressional Notification for IFO licenses for WDAs is based on the value of each individual license, not the sum of all DSP-5 IFO licenses over the entire life of the WDA.

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MS_a219. Monday List of Ex/Im Job Openings; 189 Jobs Posted This Week, Including 13 New Jobs

(Source: Editor) 

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


” New or amended listing this week (
13 New Jobs

* Abaco Systems, Inc.; Huntsville, AL; Trade Compliance Manager;
* Aerovironment; Simi Valley, CA; Trade Compliance Specialist II; Job ID: 18-017

* Aerovironment; Simi Valley, CA;
Trade Compliance Director
; Job ID: 18-018

AJC Logistics; Atlanta, GA; NVOCC Export Specialist;

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

* Arent Fox LLP; Washington, D.C.; International Trade Associate;

* Arent Fox LLP; Los Angeles, CA;
International Trade Associate

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

# BAE Systems; Huntsville, AL; Facility Security Officer, Security Manager; Requisition ID: 36821BR
# BAE Systems; Burlington, MA; Facility Security Officer (“FSO”); Requisition ID: 35499BR
# BAE Systems; Sterling Heights, MI; Procurement Compliance Specialist; Requisition ID: 32016BR

BAE Systems; Rockville, MD; Compliance Specialist Senior; Requisition ID: 35809 BR
# BAE Systems; Sterling, VA; Compliance Specialist Senior; Requisition ID: 36370BR
* Boeing; St. Louis, MO; Trade Control Specialist – Mid Career; Requisition ID: 1700022214

 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

* Crown Corporation; New Bremen, Ohio; Trade Compliance Specialist; Requisition ID: 45311

 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: 

* Curtiss-Wright Corporation; Los Angeles, CA;
Director, Trade Compliance

* Danaher Science and Technology; United States; Senior Global Trade Compliance ManagerJob ID: COR000942

* Danaher Science and Technology;
Biberach an der Riß, Germany
European Trade Compliance Specialist

Job ID: KAV001714 

* Danaher Science and Technology; Nationwide, India; Manager, International Regulatory Affairs
Job ID: CEP000339

* Dorman Products; Colmar, PA; Global Trade Compliance Specialist;
* DSJ Global; Minneapolis, MN; Director of International Logistics;
 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
* Eaton; Mississagua, Canada; Global Trade & Compliance Manager;

* Elbit Systems of America; Fort Worth, TX or Merrimack, NH;
Trade Compliance Manager
; 2018-5916

* Elbit Systems of America; Fort Worth, TX or Merrimack, NH;
Trade Compliance Officer
; 2018-5917

* EMD Serono; Milan, Italy;
Trade Compliance Associate Internship

* EMD Serono; Shanghai, China; Import Export Supervisor;

* Emerson; Mexico City, Mexico; Export and Trade Compliance Analyst; Requisition ID: 18001203
# Endeavor Robotics; Chelmsford, MA; Logistics and Compliance Analyst;
* Esterline; Xenia, OH; Manager, International Trade Compliance;

* Esterline; Hong Kong;
Regional ITC Manager
* Esterline; Singapore; Regional ITC Manager; 

* Esterline; Brea, CA; 
Senior Trade Compliance Specialist

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

 Expeditors; Sunnyvale, CA;
Customs Compliance Supervisor

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

 Expeditors; Dusseldorf, Germany;
Clerk, Airfreight Import

* Export Solutions Inc.; Melbourne FL; 
Trade Compliance Specialist

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

 FD Associates; Tysons Corner, VA; 
Senior Export Compliance Associate;
resume to and salary requirements to 

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

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

 FLIR; Billerica, MA;
Global Trade Compliance Analyst, Licensing
 FLIR; Arlington, VA;
Senior Analyst, Licensing
 FLIR; Billerica, MA;
Senior Analyst, Licensing
* Floor and Decor; Smyrna, GA; Customs Compliance Manager;
* Full Circle Compliance; Bruchem, Netherlands;
Legal Analyst, Manager

* FusionStorm; Newark, CA; Trade Compliance Specialist; Requisition ID: 2018-2350
* Garmin; Olathe, Kansas; International Trade Compliance Specialist; Requisition ID: 1800006

 General Atomics; San Diego, CA; 
Internship, Import/Export, Summer 2018
; Requisition ID: 15731BR 

* General Dynamics; Fairfax, VA; Export Policy Analyst; Job ID: 2018-36089 
* General Dynamics; Arlington, VA; Analyst, Export Control; Job ID: 2018-36963

* General Dynamics; Falls Church, VA;
Director, Trade Control
; Job ID: 2018-1122

* General Motors; Pontiac, MI; 
GM Defense Sub Export Compliance Officer
 (Full Time or Flex time)
; Requisition ID: GPS0003372
 Georgia-Pacific; Atlanta, GA; 
Sr. Analyst, International Trade
; Requisition ID: 052010

* GHY International; Manitoba, Canada; Trade Analyst;
* GHY International; Pembina, ND (or remote); Ocean & Air Import Coordinator
* Gilead Sciences; Foster City, CA; Manager, Global Trade Compliance; R0001742

* Harris Corporation; Roanoke, VA;
Trade Compliance Intern;
* Harris Corporation; Beaverton, OR;
Manager, International Government Relations;

* H.B. Fuller; St. Paul, MN; Global Trade Compliance Director;
* 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

* Hexcel Corporation; Dublin, CA or Salt Lake City, UT
; International Trade Compliance Analyst
Requisition ID: R011590

* Hubbell, Incorporated; Greenville, SC; Export Compliance Specialist;
* Hubbell, Incorporated; Shelton, CT; Export Compliance Specialist;
* Hubbell, Incorporated; Centralia, MO; Export Compliance Specialist;
 Honda of America Manufacturing; Marysvile, OH;
Import Specialist

* Illumina; San Diego, CA; Export Specialist;
 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

* JABIL; St. Petersburg, FL;
Trade Compliance Manager
; Requisition ID: 207029
* JABIL; St. Petersburg, FL;
Trade Compliance Specialist
; Requisition ID: 206581
* JABIL; Guadalajara, Mexico;
Classification & Export Licensing Analyst
; Requisition ID: 207594

* Johns Hopkins University; Baltimore, MD;
Assistant Director, Export Control and Facility Security;

# KEMET Electronics Corporation; Simpsonville, SC; Corporate Compliance Analyst;
* KPMG U.S.; San Francisco, CA; Associate, Trade & Customs;

* Leonardo DRS; Arlington, VA;
Senior Customs & Trade Compliance Manager
; Requisition ID: 87488
 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; Arlington, VA; Export Licensing Staff
Requisition ID 419903BR
* Lockheed Martin; Arlington, VA; International Trade Compliance Staff; Requisition ID 418761BR

* Luminar Technologies; Orlando, FL; Import/Export Trade Compliance Specialist;
 L-3 LINK Division; Tulsa, OK; 
Contracts Administrator 1
; Requisition ID: 091686
 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
* L-3; Ann Arbor, MI; Trade Compliance Manager; Requisition ID: 092335
* L-3; Greenville, TX; International Trade Compliance Administrator 3; Requisition ID: 095830
* L-3; Greenville, TX; Import/Export Administrator 3; Requisition ID: 095921
* L-3; Arlington, TX; Trade Compliance Practitioner, Empowered Official; Requisition ID: 089915
* Maersk/DAMCO; Agent de transit IMPORT – EXPORT; Job Ref.: DC-164022
# Mattson Technology; Fremont, California; Import/Export Compliance Analyst;
* Medtronic; Heerlen, The Netherlands;
Trade Compliance Analyst
; Requisition ID: 16000DYY
* Medtronic; Wash DC;
Global Trade Lawyer
; Requisition ID: 170002ON

* Mitchell Martin, Inc.; Dallas, Texas; Export Regulatory Trade Compliance Specialist; Requisition ID: 104405
* MTS Systems; Eden Prairie, MN;
Global Trade Compliance Manager
; Requisition ID: 37841
* NORDHAM; Tulsa, OK;
Global Trade Compliance Manager
; Requisition ID: 14080BR
* Northrop Grumman; Herndon, VA;
Manager, International Trade Compliance 2

Requisition ID

 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; El Segundo, CA; Supply Chain Logistics Spec 3; Requisition ID: 18004948

* Office of the Director of National Intelligence; McLean, VA;
Associate General Counsel
* 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

* PerkinElmer, Inc.; Shelton, CT; International Trade Compliance – Export Coordinator;
* PwC; Portland, OR; Compliance Senior Manager
* Raytheon Company; Doha, Qatar;
Global Trade Compliance Consulting Analyst
; Requisition ID: 110234BR

* Raytheon Company; El Segundo, CA; Senior Analyst, Global Trade Licensing; Requisition ID: 111121BR
* Raytheon Company; El Segundo, CA; Global Trade Manager; Requisition ID: 108227BR

* Raytheon Company; El Segundo, CA;
Principal, Global Trade Licensing
; Requisition ID: 

* Raytheon Company; Tucson, AZ;
Sr. Export Licensing Specialist
 Requisition ID: 

* Raytheon Company; Tucson, AZ;
Export Licensing Specialist
; Requisition 

ID: 108960BR; 

* Raytheon Company; Tucson, AZ;
Export License & Compliance Specialist
; Requisition ID: 

Raytheon Company; Tucson, AZ;
Trade Compliance Principal Investigator
; Requisition ID: 

* Raytheon Company; Tewksbury, MA;
Licensing Manager
; Requisition ID: 

* Raytheon Company; Waltham, MA; 
Licensing Manager
; Requisition ID: 
* Raytheon Company; El Segundo, CA; Licensing Director; Requisition ID: 110838BR

* Raytheon Company; Richardson, TX;  
Licensing Director
; Requisition ID: 110838BR 

* REDCOM Laboratories; Victor NY;  
Director of Trade Compliance
; Contact 
Chad Boehly 

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


 SABIC; Houston TX; 
Senior Analyst, Trade Compliance
; Requisition ID: 8411BR

* SABIC; Houston, TX; Senior Analyst, International Trade Compliance

Requisition ID 8655; OR Contact: Jason Washington
* SABIC; Houston, TX;
Senior Analyst, Trade Compliance
; Requisition ID: 8644BR

 SAFRAN Group; United Kingdom;
Trade Compliance Specialist

* Sig Sauer; Newington, New Hampshire; Trade Compliance Manager
* The Spaceship Company; Mojave, CA; Export Compliance Officer;
* Spirent; San Jose, CA;
Global Trade Compliance Specialist
; Requisition ID: 4088

# Talascend; Ft Worth, TX; Trade Compliance Classification Analyst;
* TE Connectivity; Middletown, PA; Manager II, Global Trade Compliance; Requisition ID: 17361
* Teledyne Benthos; Falmouth, MA; Export Compliance Manager
* Teledyne Geophysical; Houston, TX; Trade Compliance Specialist; Requisition ID: 2017-5459

* Teledyne Microwave Solutions; Mountain View, CA; 
Trade Compliance Specialist
; Requisition ID: 2018-6089

 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 

* Tenneco, Inc.; Lake Forest, IL;
Americas Global Trade Compliance Manager
; Requisition ID: 178693-846

* Tenneco, Inc.; Lake Forest, IL; Customs & Trade Compliance Coordinator; Requisition ID: 178353-846
* Terumo Medical Corporation; Somerset, NJ; Senior Global Trade Compliance Specialist;
 Textron; Hunt Valley, MD;
Senior Manager – Export Compliance

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

* Thermo Fisher Scientific; Shanghai, China; 
Trade Compliance Specialist
; Job ID: 57953BR 

* T
hermo Fisher Scientific; Franklin, MA; 
Trade Compliance Specialist
; Job ID: 

* T
hermo Fisher Scientific; Carlsbad, CA; 
Compliance Specialist II
; Job ID: 

* T
hermo Fisher Scientific; Suwanee, GA;
Export Compliance Specialist III
; Job ID:

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

* Toyota North America; Dallas, TX; Export Control Analyst
 Tradewin; Portland, OR;
U.S. Export Compliance Consultant

* Trek; Waterloo, WI; Global Trade & Logistics Specialist;

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

# United Technologies – Pratt & Whitney; East Hartford, CT;
International Trade Compliance Manager; Requisition ID:  62176BR

# United Technologies – Pratt & Whitney; East Hartford, CT;
International Trade Compliance Authorizations Manager; Requisition ID: 63222BR

# United Technologies – Pratt & Whitney, East Hartford, CT;
International Trade Compliance Technology Senior Manager; Requisition ID: 55944BR

* United Technologies Corp, Pratt & Whitney; East Hartford, CT;
ITC & ACE Compliance Program Manager, ASC
; Requisition ID: 58388BR

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

; Requisition ID: 12298
* Varian; Belgium, Switzerland, Netherlands, or UK; EMEIA Trade Lead – Senior Manager Trade Compliance; Requisition ID: 12301BR; Contact 
Gavin Tickner at 
* Varian; Paolo Alto, CA; Senior Trade Compliance Analyst; Requisition ID: 12735BR; Contact 
Uyen Tran at
* Varian; Beijing, China;
Trade Compliance Analyst
; Requisition ID: 
12297BR; Contact 
Susan Lin at
* 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
* Williams International; Pontiac, MI; Trade Compliance Specialist; Requisition ID: 17-0275

* World Wide Technology; Hong Kong;
Trade Compliance Specialist
; Requisition ID: 005

* World Wide Technology; Edwardsville, IL; International Trade Compliance Specialist; Requisition ID: 6110
 Xylem, Inc.; Remote, United States;
Manager, Global Ethics & Compliance

* Zeiss Group; Thornwood, NY;
Trade Compliance Specialist
* Zimmer Biomet; Warsaw, IN; Trade Compliance Manager

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


* What: Mastering ITAR/EAR Challenges, Annapolis, MD
* When: May 22-23, 2018
* Sponsor: Export Compliance Solutions (ECS)
* ECS Speaker Panel: Suzanne Palmer; Lisa Bencivenga; Timothy Mooney, Commerce/BIS; Matt Doyle, Lockheed; Matt McGrath, McGrath Law; Debi Davis, Esterline
* Register 
here, or by calling 866-238-4018, or by e-mailing

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


Leonardo da Vinci (Leonardo di ser Piero da Vinci; 15 Apr 1452 – 2 May 1519; was an Italian Renaissance polymath whose areas of interest included invention, painting, sculpting, architecture, science, music, mathematics, engineering, literature, anatomy, geology, astronomy, botany, writing, history, and cartography. He has been variously called the father of paleontology, ichnology, and architecture, and is widely considered one of the greatest painters of all time. Sometimes credited with the inventions of the parachute, helicopter and military tank, he epitomized the Renaissance humanist ideal. Many historians and scholars regard Leonardo as the prime exemplar of the “Universal Genius” or “Renaissance Man”, an individual of “unquenchable curiosity” and “feverishly inventive imagination”, and he is widely considered one of the most diversely talented individuals ever to have lived.”
– “Simplicity is the ultimate sophistication.”
  – “As a well-spent day brings happy sleep, so a life well spent brings happy death.” 

Anatole France (born François-Anatole Thibault; 16 Apr 1844 – 12 Oct 1924; was a French poet, journalist, and successful novelist with several best-sellers. Ironic and skeptical, he was considered in his day the ideal French man of letters. He was a member of the Académie française, and won the 1921 Nobel Prize in Literature “in recognition of his brilliant literary achievements, characterized as they are by a nobility of style, a profound human sympathy, grace, and a true Gallic temperament”.)
– “Nine tenths of education is encouragement.”
  – “Until one has loved an animal a part of one’s soul remains unawakened.”

Monday is Punday.
Q. Why did the physics teacher break up with the biology teacher?
A. There was no chemistry.
Q.  Which country’s capital is the fastest growing?
A.  Ireland’s. Every year it’s Dublin.

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

. 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: 12 Apr 2018: 83 FR 15736-15740: CBP Decision No. 18-04; Definition of Importer Security Filing Importer (ISF Importer)

  – 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: 
2 Apr 2018:
83 FR 13849-13862
: Implementation of the February 2017 Australia Group (AG) Intersessional Decisions and the June 2017 AG Plenary Understandings; Addition of India to the AG [Amendment of EAR Parts 738, 740, 745, and 774.]; and 5 Apr 2018: 83 FR 14580-14583: Reclassification of Targets for the Production of Tritium and Related Development and Production Technology Initially Classified Under the 0Y521 Series [Imposes License Requirements on Transfers of Specified Target Assemblies and Components for the Production of Tritium, and Related “Development” and “Production” Technology.]

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

  – Last Amendment: 19 Mar 2018:
83 FR 11876-11881: Inflation Adjustment of Civil Monetary Penalties 

: 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 (16 March 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 approximately 250 footnotes containing case annotations, practice tips, Census/AES guidance, and explanations of the numerous errors contained in the official text. Subscribers receive revised copies in Microsoft Word every time the FTR is amended. The BAFTR is available by annual subscription from the Full Circle Compliance websiteBITAR subscribers are entitled to a 25% discount on subscriptions to the BAFTR. Government employees (including military) and employees of universities are eligible for a 50% discount on both publications at www.FullCircleCompiance.eu.  
, 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: 30 Mar 2018:
Harmonized System Update 1804, containing 710 ABI records and 166 harmonized tariff records.
  – HTS codes for AES are available 
  – HTS codes that are not valid for AES are available 


  – 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.

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

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 

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


* 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.

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

* BACK ISSUES: An archive of Daily Bugle publications from 2005 to present is available HERE.

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