18-0424 Tuesday “Daily Bugle”

18-0424 Tuesday “Daily Bugle”

Tuesday, 24 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/BIS: (No new postings.)
  3. DHS/CBP Posts FDA Supplemental Guide 2.5.1, Releases New ACE Reports Videos
  4. DoD/DSCA Publishes Policy Memo 18-26
  5. State/DDTC: (No new postings.)
  1. ExecutiveGov: “Commerce Undersecretary for Export Administration Mira Ricardel Named Deputy National Security Adviser”
  2. Reuters: “U.S. Extends Deadline for Rusal Sanctions, Aluminum Prices Dive”
  3. ST&R Trade Report: “Steel and Aluminum Tariff Exclusion Process Criticized as BIS Chief Leaves”
  1. C. Tinaves: “OFAC Tries the Carrot and the Stick Approach with Russian Aluminum Giant”
  2. The Export Compliance Journal: “Why Are We Screening Against Restricted and Denied Parties Lists?”
  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 (16 Apr 2018), ITAR (14 Feb 2018) 
  3. Weekly Highlights of the Daily Bugle Top Stories 



[No items of interes noted today.]

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

* State/DDTC; NOTICES; Arms Export Control Act and International Traffic in Arms Regulations: Statutory Debarment [Publication Date: 25 Apr 2018.]

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Commerce/BIS: (No new postings.)


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DHS/CBP Posts FDA Supplemental Guide 2.5.1, Releases New ACE Reports Videos

CSMS# 18-000300, and 
CSMS# 18-000302, both of 23 Apr 2018.)
FDA Supplemental Guide 2.5.1
The FDA Supplemental Guide for the PGA Message Set has been updated. In this version (2.5.1), FDA has included clarifications for certain data elements based on feedback from trade, and removed several optional data elements. Please review the change log for specific details. An updated version of the FDA message set samples will be available soon. 
In addition, this version refers to a new affirmation of compliance (VQI) that is not yet implemented. Please note that VQI is currently expected to be available in Production in October. A CSMS will be issued later, with the CERT and PROD dates. 
The updated document can be found on CBP.gov/ACE or 
New ACE Reports Videos 
Two additional ACE Reports training videos are now available via the main ACE Training and Reference Guides page, found 
here. They are embedded as video players, and can be found at the bottom of the page. The two videos and topics are as follows:

QTV 12 – Nested Filters – covers the basics of how to use a “nested” query filter in a custom ad-hoc report. Nested report filters allow users to further refine the scope of their queries to more complex/specific logical combinations of data elements. In order to provide users examples of where the functionality would be useful, the video walkthrough uses a practical example for limiting the scope of a query to the data elements defined in a specific “Additional U.S. Notes” portion of the Harmonized Tariff Schedule of the United States (HTSUS).

QTV 13 – Pasting a List of Values – covers how a user can paste a list of values into one of the query filters in ACE Reports in order to reduce the processing burden associated with having to manually type each value out or find them from the list of values in the application. The video walkthrough uses Excel and Word, however the concept should translate to other word processing/table based applications.

  – Related CSMS No. 17-000795

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DoD/DSCA Publishes Policy Memo 18-26
DoD/DSCA, 24 Apr 2018.)
[Editor’s Note: yesterday, Policy Memos 18-23 and 18-24 were published.]

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State/DDTC: (No new postings.)

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ExecutiveGov: “Commerce Undersecretary for Export Administration Mira Ricardel Named Deputy National Security Adviser”

ExecutiveGov, 23 Apr 2018.) [Excerpts.] 
Mira Ricardel, undersecretary for export administration at the Commerce Department, will serve as deputy to national security adviser John Bolton, Politico reported Friday.
Ricardel’s appointment to the National Security Council came nearly two weeks after Bolton assumed his current post to replace the retiring Army Lt. Gen. H.R. McMaster. … 
Ricardel was involved in the development of national security policies and programs during her tenure at the departments of State and Defense. Her career at DoD included roles such as deputy defense assistant secretary for Eurasia, acting assistant secretary for international security policy and principal adviser to the defense secretary. 
She led the DoD transition team following the 2016 presidential election and previously served as vice president of programs at nonprofit organization Freedom House.
Ricardel spent nearly 10 years at 
Boeing, where she served as a vice president with oversight on business development teams responsible for cybersecurity, satellites and missile defense markets.

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Reuters: “U.S. Extends Deadline for Rusal Sanctions, Aluminum Prices Dive”

Reuters, 23 Apr 2018.) [Excerpts.] 
The United States on Monday gave American customers of Russia’s biggest aluminum producer more time to comply with sanctions, and said it would consider lifting them if United Company Rusal Plc’s major shareholder, Russian tycoon Oleg Deripaska, ceded control of the company. … 
Treasury gave Americans until Oct. 23 instead of June 5 to wind down business with Rusal. It said it would not impose secondary sanctions on non-U.S. entities engaged with Rusal or its subsidiaries.

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ST&R Trade Report: “Steel and Aluminum Tariff Exclusion Process Criticized as BIS Chief Leaves” 

Sandler, Travis & Rosenberg Trade Report, 24 Apr 2018.)
The White House announced April 20 that Mira Ricardel, who has led the Department of Commerce’s Bureau of Industry and Security since last August, will be leaving that post to become deputy national security advisor. The departure comes as BIS is under mounting pressure to handle the voluminous amount of product-specific exclusions companies are seeking from the additional tariffs President Trump imposed on imports of steel and aluminum products as of March 23.
In an April 19 letter, Senate Finance Committee Chairman Orrin Hatch, R-Utah, and Ranking Member Ron Wyden, D-Ore., urged the DOC to make improvements to the exclusion request process, which they said has so far lacked “basic due process and procedural fairness for stakeholders” as well as “appropriate mechanisms” to ensure the process is not “abused for anticompetitive purposes.” For example, the letter said, the forms for requesting exclusions collect information on more than 70 attributes of each product and an additional form is apparently required whenever a single attribute differs between products. This process “increases the burden on businesses that purchase or produce products with even minor variations,” the letter said, and “appears to bar small businesses from relying on trade associations to consolidate product information and make submissions on behalf of multiple businesses.”
The letter also highlighted a lack of information on issues such as (1) the circumstances in which BIS will approve the broader application of a product-based exclusion to additional importers or how importers may request such an exclusion, (2) a clear process for protecting business proprietary information, (3) how BIS intends to address purchasers and producers of customized articles for which the required information may be unavailable until the article has been purchased, (4) whether and how BIS will inform petitioners and objectors that it has issued a determination, and (5) whether and how BIS intends to ensure it issues consistent determinations across similarly-situated petitioners and objectors. 
The senators urged Commerce Secretary Wilbur Ross to make improvements in these areas “as soon as practicable” and to provide an update within two weeks on his progress in addressing their concerns.
Press reports indicate that one of the primary complaints about the exclusion request process is how long it takes. When the process was announced BIS said reviews would normally not exceed 90 days, but the letter noted that as of April 18 BIS had posted for comment fewer than 100 of the more than 3,800 requests received so far. Since the date a request is posted for public comment is the date back to which any exclusion granted will be retroactive, the letter said the “significant delays” in posting these requests “risk serious and permanent financial harm to many petitioners that, even in DOC’s judgment, should not be subject to the Section 232 tariffs.”
It is unclear what effect the departure of BIS chief Mira Ricardel may have on these delays. Ricardel, a former official in the departments of Defense, Commerce, and State as well as a senior defense industry executive, was named April 19 as deputy to National Security Advisor John Bolton. Bolton cited her expertise in “national security matters related to our alliances, defense posture, technology security, foreign security assistance, and arms control” among the reasons for his choice.

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C. Tinaves: “OFAC Tries the Carrot and the Stick Approach with Russian Aluminum Giant”

CTP, 23 Apr 2018.)
* Author: Chalinee Tinaves, Esq., Commonwealth Trading Partners (CTP), 
In case you missed the flurry of Russian sanctions news over the past few weeks, you may have missed an addition to the sanctions that could impact your business, especially if you’re in the aluminum market. On 
April 6, 2018
, the Treasury Department’s Office of Foreign Assets Control (OFAC) added a number of prominent Russian individuals and entities, including Russian government officials, to its Specially Designated Nationals and Blocked Persons List (SDN List). Among those was the designation of Russian oligarch, Oleg Deripaska. If the name doesn’t sound familiar to you, the 
aluminum magnate
 is tied up in allegations regarding interactions with former Trump campaign chairman, Paul Manafort, related to the 2016 presidential election.
Mr. Deripaska was one of seven Russian oligarchs designated by OFAC pursuant to Executive Order 13661 for having acted or purported to act for or on behalf of a senior official of the Russian government as well as pursuant to Executive Order 13662 for operating in the energy sector of the Russian economy.  Also caught in OFAC’s snare were the following companies in which he maintained ownership or control:  Basic Element Limited, EN+ Group PLC, EuroSibEnergo, United Company RUSAL PLC (RUSAL), Russian Machines, GAZ Group, and Agroholding Kuban. All were designated based on Deripaska’s ownership or control. Over a month 
prior to Mr. Deripaska’s designation, the company had moved to distance itself from him by re-designating him from serving as the president of the company to serving as a non-executive director to the company effective March 15, 2018. However, that did not appear to be enough to prevent OFAC’s designation of RUSAL.
At that time, OFAC published two general licenses authorizing the following:
General License No. 12, which provided a brief two month reprieve for companies to take actions ordinarily incident and necessary to the maintenance or wind down of operations, contracts, or other agreements with the designated entities including payments to blocked persons within a blocked, interest-bearing account in the U.S. until June 5, 2018; and
General License No. 13, which authorized all transactions and activities ordinarily incident and necessary to divest or transfer debt, equity, or other holdings in EN+Group PLC, GAZ Group, and RUSAL to a non-U.S. person, or to facilitate the transfer of debt, equity, or other holdings in these entities by a non-U.S. person to another non-U.S. person until May 7, 2018.
FAQ #568 went as far as to state that further employment by U.S. person employees with one of these companies or participation on a designated company’s board would require a specific license from OFAC.  Yikes!
As the 
world’s second-largest aluminum producer and with the U.S. serving as its third largest foreign export market, it’s not surprising that RUSAL was quick to move to lessen the blow. The company petitioned OFAC to be removed from the SDN List. Recognizing the potential impact to the U.S. domestic industry and the time it could take for a company to walk back its business dealings and wind down any transactions, today OFAC has issued 
General License No. 14, published amended 
General License No. 12A, and made some updates to its FAQs. In a 
statement issued by Treasury Secretary Steven Mnuchin, the company had petitioned to be removed and given the impact to U.S. partners and allies, it made sense for OFAC to publish General License No. 14 and amend General License No. 12A to extend the maintenance and wind-down period while the agency considered the company’s petition.
Under General License No. 14, companies get an extra four months from the prior deadline to take actions ordinarily incident and necessary to the maintenance or wind down of operations, contracts or other agreements with RUSAL, including importing goods, services, or technology into the U.S. Further, exports during this time are permitted so long as it is within the scope of the general license and compliant with export control regulations. Funds previously blocked before today are still blocked but the General License authorizes companies to use this money for the maintenance and wind down activities. Keep in mind that this applies not only to RUSAL or its subsidiaries but also any other entity in which RUSAL owns a 50% or greater interest in, directly or indirectly.
General License No. 12A was revised to allow for payments authorized under General License 14. Specifically, payments to or for the direct benefit of RUSAL and entities owned, directly or indirectly, by RUSAL are not required to make payments in a blocked, interest-bearing account in the U.S. for activities ordinarily incident and necessary to the maintenance or wind down of operations or existing contracts with these entities that were in effect 
prior to April 6, 2018. For any company that may have had an import shipment coming previously, you’re able to accept the goods as long as it is within the scope of the general license. Payments to RUSAL and those owned, directly or indirectly, at a 50% or greater interest by RUSAL, that are within the scope of the general license  are not required to be deposited in a blocked account at a U.S. financial institution. For payments to all other blocked entities listed in (a) of General License No. 12A, they must still be deposited in a blocked account at a U.S. financial institution. Lastly, for any unlucky employees or those working at an office of an entity designated on April 6, OFAC has issued further clarification to its stance under General License 12A. The good news is that the payment of salaries, pension payments, and other benefits by blocked entities and working for the blocked entity is within the scope of General License 12A and viewed as transactions ordinarily incident to the continuity of operations or to facilitate a wind down. The bad news: General License 12A is only valid until the clock strikes 12:01 am EST on June 5, 2018  and October 23, 2018 for RUSAL and RUSAL-owned or controlled entities until further notice. U.S. employees are urged to review the OFAC regulations and consider the applicability of the general license to employee activities and contact OFAC. 
The most interesting tidbit from today’s announcement was OFAC’s position in 
FAQ #576. In no uncertain terms, OFAC makes clear to RUSAL that the path for further sanctions relief is through the divestment and relinquishment of control of the company by Mr. Deripaska. According to RUSAL’s corporate announcement back in February re-designating him out from his President title, Mr. Deripaska held approximately 48.14% of total issued shares of the company.  With OFAC’s power move today, we shall see whether RUSAL and Mr. Deripaska take the carrot or opt for the stick.

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The Export Compliance Journal: “Why Are We Screening Against Restricted and Denied Parties Lists?”

The Export Compliance Journal, 19 Apr 2018.)
Recently, there has been much ado about the responsibilities of non-US businesses to perform restricted and denied parties screening against their non-US customers.
Likewise, what about the responsibilities of US businesses to screen other US businesses? While these questions are seemingly unrelated, they both stem from one major question: Do I really need to perform restricted party screening?
My business is not located within the US and does not ship within the US-why should we screen companies in my own country?

There are several reasons why companies should screen 
all of their business connections, even when not located within US. While limited scenarios may exist in which screening may not be require (see the caveat below), businesses are often more connected to the US business than they realize.
Are the goods being shipping of US origin?

In many cases, the answer is obvious, by remember that 
if a foreign-produced item contains a percentage of US origin commodities or technical data it may be subject to controls even when shipped domestically in a country other than the US. This percentage varies depending on the country group in which the recipient resides.
What about finances?

Many large shipments are facilitated in US Dollars, and processed through US Banks. These banks may freeze funds from being transferred to restricted parties or face penalties themselves. To avoid this possibility, screening is recommended, especially against OFAC’s Specially Designated Nationals (SDN) watch list.
Even if US restrictions do not apply, what are the local regulations?

The United States is not the only country to provide restricted, denied, or sanctioned party lists. Many foreign countries have their own laws which require the vetting of entities.  
The major 
 noted above is that some jurisdictions may limit or restrict the action of screening or recording of information related to one or more parties on a domestic transaction due to data privacy rules or other regulations.
What about domestic business within the US?

Again, if your business is not specifically exempt from screening your customers for each transaction (such as how most retail businesses would be), there are several reasons why restricted party screening will apply.
For example, is your customer really a “US person?” This is where some Orwellian logic may begin to apply. Your customer would, if they were shipping within the US, be subject to the same restrictions as a US person, regardless of their status. When shipping to that customer, that business is not considered a US person (regardless of location) if not incorporated or organized under US law, or is a branch, agency, division, or subdivision of a foreign government.
Moreover, what is the final destination of the businesses’ goods? Agents aren’t likely to be forgiving if screening was deemed to be domestic and a product shipped, only for that product to find itself in Cuba, Syria, or Iran.
Depending on the nature of your organization, assume for a moment that it is not a manufacturer or distributor, but instead a Government contractor, research facility or other organization, you may have other requirements that can be partially resolve with restricted party screening. The Office of the Inspector General list of medical professionals, the General Services Administration lists, or Federal Law enforcement lists may still be a required part of your screening.
Do I really need to perform restricted party screening?

While there are a number of circumstances where a business may not require US-based restricted party screening on their customers, vendors, etc., there are far more examples of businesses that are not strictly beholden to US regulations that screen for other purposes. Non-US regulations, origin of goods, restricted party lists with specific applicability, and financial transactions are all examples of where restricted party screening is a best practice.
In most cases, the only time there is no doubt is when screening is required by law. For those organizations in doubt, screening is always recommended.
A Glossary of ideas in this article
  – US Person: A US person is defined as any citizen or permanent resident of the United States or any corporation (business, partnership, etc.) organized under US law.
  – Goods of US Origin: Goods originating from the United States or goods that contain a certain percentage of US goods are considered goods of US origin for export purposes. The percentage varies depending on the destination of the goods in question. For example, goods containing 10% US commodities or technology would be restricted to the most controlled regions, like Cuba, North Korea, or Syria, among others.
  – Office of Foreign Assets Control (OFAC) and Specially Designated Nationals (SDN): Though these have been covered on this blog previously, it is worth restating the critical nature of these lists when it comes to large payments facilitated in US Dollars. When any restricted country or an individual on any OFAC list (SDN, Sanctioned and Embargoed Countries, Sectorial Sanctions, or others) are involved in a transaction, this could spell trouble for all parties involved. See the recent case of fines levied due to US Bank involvement in a transaction that involved only the Governments of Iran and Venezuela, for an example. [FN/1] 
  – Office of the Inspector General (OIG): The primary list cited with the OIG is the list of individuals excluded from federal health and Medicare programs, which may be of concern to organizations in related industries.
  – General Services Administration: The GSA, which utilizes its own Government site-SAM.GOV.-contains several lists commonly used in restricted party screening. These have to do with exclusions from participation in federal procurement, non-procurement, and reciprocal programs.
Iranian National Arrested for Scheme to Evade U.S. Economic Sanctions by Illicitly Sending More Than $115 Million From Venezuela Through the U.S. Financial System.
 News release. Department of Justice. March 30, 2018. Available 
. Accessed April 16.

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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: 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: 16 Apr 2018: 
Harmonized System Update 1805
[contains 267 ABI records and 60 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.

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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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