18-0430 Monday “Daily Bugle”

18-0430 Monday “Daily Bugle”

Monday, 30 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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  1. Commerce/Census Amends FTR, Clarifies Data Collection and Confidentiality Concerning Kimberley Process Certificates 
  1. Items Scheduled for Publication in Future Federal Register Editions
  2. Commerce/BIS: (No new postings.)
  3. Justice: “Executives of Iranian Auto Parts Manufacturer Arrested and Indicted for Violating Iranian Sanctions Statute”
  4. Justice: “Morris County, New Jersey, Woman Charged with Smuggling American Aircraft Components to Iranian Airline Companies”
  5. State/DDTC Launches Redesigned Website
  6. Treasury/OFAC Issues Belarus General License 2E
  1. Defense News and Aerospace Industries Associate Head Discuss U.S. Arms Export Rules
  2. Expeditors News: “Working Group on E-Commerce Finalizes Framework of Standards on Cross-Border E-Commerce”
  3. Reuters: “Arms Maker Diehl Calls for Harmonized Export Rules in Europe”
  4. Taipei Times: “MediaTek to Seek ZTE Export Permit”
  1. J. Treanor: “Treasury Eases Sanctions on Russian Aluminum Company”
  2. T. Murphy: “Section 232/Section 301 Update”
  3. Gary Stanley’s EC Tip of the Day
  1. ECS Presents “Level III: Mastering ITAR/EAR Challenges”
  2. Monday List of Ex/Im Job Openings: 191 Jobs Posted
  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 (24 Apr 2018), HTSUS (25 Apr 2018), ITAR (14 Feb 2018) 
  3. Weekly Highlights of the Daily Bugle Top Stories 



Commerce/Census Amends FTR, Clarifies Data Collection and Confidentiality Concerning Kimberley Process Certificates

Federal Register, 24 Apr 2018.) [Excerpts.] 
83 FR 17749-17751: Foreign Trade Regulations (FTR): Clarification on the Collection and Confidentiality of Kimberley Process Certificates
* AGENCY: Bureau of the Census, Commerce Department.
* ACTION: Final rule.
* SUMMARY: The Bureau of the Census (Census Bureau) issues this final rule amending its regulations to clarify that the data collected from the Kimberley Process Certificates (KPCs) are collected in compliance with the Clean Diamond Trade Act. In addition, this rule clarifies the submission requirements and permissible uses of the KPCs.
This final rule is effective July 23, 2018. … 
* SUPPLEMENTARY INFORMATION: … The Census Bureau is amending the Foreign Trade Regulations (FTR) (15 CFR part 30) to clarify that the Kimberley Process Certificates (KPCs) are not collected under Title 13, United States Code (U.S.C.). Instead, the KPCs are collected under the Clean Diamond Trade Act (CDTA) (Pub. L. 108-19, 19 U.S.C. 3901, et seq.) and Executive Order 13312, entitled “Implementing the Clean Diamond Trade Act” (68 FR 45151, July 29, 2003). The CDTA and Executive Order 13312 require that the importation into, and exportation from, the United States of any rough diamonds be controlled through the Kimberley Process Certification Scheme (KPCS). The KPCS calls on Participants (i.e., governments participating in the KPCS), including the United States, to ensure that any shipment of rough diamonds exported to, or imported from, the territory of a Participant be accompanied by a valid KPC, and maintain and publish statistics on the importation and exportation of rough diamonds. The CDTA further provides that the United States should produce statistics on imports and exports of rough diamonds and make these statistics available for analysis by interested parties, including other governments participating in the KPCS.
  Consistent with the CDTA, Executive Order 13312, and the KPCS, the Office of Foreign Assets Control’s Rough Diamonds Control Regulations (31 CFR part 592) require that an original KPC accompany all shipments of rough diamonds imported into, or exported from, the United States. The FTR requires that Participants provide an original KPC to the Census Bureau for all import and export shipments of rough diamonds. The data collected from the KPCs are separate and distinct from the statistical data collected under Title 13, U.S.C., and are not governed by the confidentiality provisions of that title.
  Finally, the U.S. Department of Homeland Security and the U.S. Department of State concur with the revisions to the FTR as required by 13 U.S.C. 302 and Public Law 107-228, div. B, title XIV, section 1404. … 
Changes to the Proposed Rule Made by This Final Rule … 
[T]he Census Bureau includes in this final rule an additional clarifying sentence at the end of the language in the proposed rule regulatory text for the Note to Sec. 30.60. For clarification, consistent with terminology used in the FTR, the Census Bureau also includes in this final rule the addition of the phrase “by the USPPI or U.S. authorized agent” to the proposed rule regulatory text revising Sec.  30.7(c).
Program Requirements
  This final rule amends relevant sections of the FTR in order to clarify requirements, consistent with the CDTA and Executive Order 13312. Specifically, in addition to the clarifying changes described above, this final rule makes the following revisions to the FTR in 15 CFR part 30:
  – Revise Sec.  30.1(c) to add the definition “Kimberley Process Certificate” as a technical amendment.
  – Revise Sec.  30.1(c) to add the definition “Voided Kimberley Process Certificate” to clarify the term.
  – Revise Sec.  30.4 to add paragraph (e) to clarify the filing procedures for voided KPCs and to address that the collection of KPCs is not pursuant to Title 13, United States Code.
  – Revise Sec.  30.7(c) to clarify that KPCs must be provided to the Census Bureau immediately after export of the shipment from the United States.
  – Revise Sec.  30.50(c) to clarify that KPCs must be provided to the Census Bureau immediately after entry of the shipment in the United States.
  – Revise Sec.  30.60 to add a note clarifying that KPCs are not considered Electronic Export Information (EEI) and are not confidential under Title 13, U.S.C.
  – Revise Sec.  30.70 to clarify how violations of the CDTA will be enforced. … 
  Dated: April 17, 2018.
Ron S. Jarmin, Associate Director for Economic Programs, performing the non-exclusive functions and duties of the Director, Bureau of the Census.

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

* Commerce/BIS; NOTICES; Agency Information Collection Activities; Proposals, Submissions, and Approvals:
  – Procedures for Submitting Request for Exclusions from the Section 232 National Security Adjustments of Imports of Steel and Aluminum; and 
  – Procedures for Submitting Requests for Objections from the Section 232 National Security Adjustments of Imports of Steel and Aluminum [Publication Dates: 1 May 2018.]
* Treasury/OFAC; NOTICES; Blocking or Unblocking of Persons and Properties [Publication Date: 1 May 2018.]
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Justice, 27 Apr 2018.) [Excerpts.]
U.S. Citizens Provided Services, Materials, and Equipment for Use by Their Company in Tehran, Iran
Sadr Emad-Vaez, Pouran Aazad, and Hassan Ali Moshir-Fatemi made their initial appearances in district court today after being indicted on April 19, 2018, for violating export control laws under the International Emergency Economic Powers Act (IEEPA)… 
The defendants were charged in a three-count indictment with the following crimes: conspiracy to violate the IEEPA, in violation of 50 U.S.C. §§ 1701-1705; a substantive violation of the IEEPA, 50 U.S.C. § 1705; and smuggling, in violation of 18 U.S.C. §§ 554(a) and 2.  The indictment alleges the defendants engaged in transactions involving the illegal export of goods and services to Iran and financial transactions designed to evade the Iranian Transactions Sanctions Regulations (ITSR).  Under the IEEPA and the ITSR, it is illegal for a United States citizen to, among other things, export, reexport, sell, or supply, directly or indirectly, any goods, technology, or services to Iran or the government of Iran, without a license granted by the Department of Treasury, Office of Foreign Asset Control, or to engage in financial transactions supporting such activities.
According to the indictment, the defendants, all naturalized U.S. citizens who lived variously in Tehran and the Northern District of California, participated in the operation of the Ghare Sabz Company, aka GHS Technology, a large manufacturing corporation in Tehran, Iran.  Emad-Vaez allegedly has described himself as the “Managing Director,” Aazad as the “Chief Financial Officer,” and Moshir-Fatemi as the “Engineering Manager” of the corporation.  The defendants are alleged to have acquired and engaged in attempts to acquire components from manufacturers all over the world (including the U.S.), in order to funnel them to GHS in Tehran.  They also allegedly used elaborate systems of international wire transfers-including through prohibited financial institutions-to fund the effort.    
Defendants Emad-Vaez and Aazad were arrested at their residence in Los Altos Hills on April 7, 2018, and were brought before Magistrate Judge Elizabeth D. Laporte for their initial appearance on April 9, 2018.  Defendant Moshir-Fatemi was arrested near San Francisco Airport on April 11, 2018, and similarly was brought before Magistrate Laporte.  All three defendants have been released on secured bonds. The defendants’ next scheduled appearance is at 10:00 a.m. on July 11, 2018, before the Honorable Charles R. Breyer, U.S. District Judge.  . . .  
If convicted of violating the IEEPA, the defendants face a maximum sentence of 20 years in prison, and a fine of $1,000,000. If convicted of smuggling, the defendants face a maximum penalty of 10 years in prison and a $250,000 fine.  … 

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Justice: “Morris County, New Jersey, Woman Charged with Smuggling American Aircraft Components To Iranian Airline Companies”

Justice, 25 Apr 2018.) [Excerpts.] 
A Morristown, New Jersey, woman appeared in federal court today to face charges for her alleged role in an international procurement network that smuggled over $2 million worth of aircraft components from the United States to Iran in violation of export control laws, U.S. Attorney Craig Carpenito announced.
Joyce Eliabachus, a/k/a “Joyce Marie Gundran Manangan,” 55, a naturalized U.S. citizen born in the Philippines, was arrested at her home on April 24, 2018, following a joint investigation by the U.S. Department of Homeland Security, Homeland Security Investigations (HSI) and the U.S. Department of Commerce, Office of Export Enforcement.
Eliabachus is charged in a three-count criminal complaint with conspiracy to violate the Iranian Transactions and Sanctions Regulations (ITSR), conspiracy to commit money laundering, and conspiracy to smuggle goods from the United States. She made her initial appearance this afternoon before U.S. Magistrate Judge Mark Falk in Newark federal court and was released on $100,000 unsecured bond with home confinement.
  According to the complaint:
Eliabachus – the principal officer and operator of Edsun Equipments LLC, a purported New Jersey-based aviation parts trading company run out of her Morristown residence – is allegedly part of a sophisticated procurement network that has secretly acquired large quantities of license-controlled aircraft components from U.S. manufacturers and vendors, and exported those parts to Iran through freight-forwarding companies located in the United Arab Emirates (UAE) and Turkey, in violation of U.S. export control laws.
From May 2015 through October 2017, Eliabachus and her conspirators facilitated at least 49 shipments containing a total of approximately 23,554 license-controlled aircraft parts from the U.S. to Iran, all of which were exported without the required licenses.
Eliabachus conspired with the owner of an Iranian-based procurement firm, identified in the complaint as “CC-1,” whose international network helped initiate the purchase of U.S.-origin aircraft components on behalf of CC-1’s clients in Iran. The network’s client list was comprised of Iranian airline companies, several of which have been officially designated by the U.S. government as posing a threat to the country’s national security, foreign policy, or economic interests, including Mahan Air Co., Caspian Airlines, and Kish Air, among others.
Using Edsun Equipment in New Jersey, Eliabachus finalized the purchase and acquisition of the requested components from the various U.S.-based distributors. She then re-packaged and shipped the components to shipping companies in the UAE and Turkey, including Parthia Cargo and Reibel Tasimacilik Ve Tic A.S., where her Iranian conspirators directed trans-shipment of the components to locations in Iran.
In order to obscure the extent of the network’s procurement activities, Eliabachus routinely falsified the true destination and end-user of the aircraft components she acquired. She also falsified the true value of the components being exported in order to evade the necessity of filing export control forms, which further obscured the network’s illegal activities from law enforcement.
The funds for the illicit transactions were obtained from the various Iranian purchasers, funneled through Turkish bank accounts held in the names of various shell companies controlled by the Iranian conspirators, and ultimately transferred into one of Edsun Equipments’ U.S.-based accounts. The network’s creation and use of multiple bank accounts and shell companies abroad was intended to conceal the true sources of funds in Iran, as well as the identities of the various Iranian entities who were receiving U.S. aircraft components.
  “Eliabachus and others allegedly ran an international smuggling ring that shipped $2 million in aircraft parts to multiple Iranian airlines, including an airline that has provided financial, material, and technological support to the Islamic Revolutionary Guard Corps,” U.S. Attorney Carpenito said. “This arrest, which was made possible by a close collaboration between our office and its partners at Homeland Security Investigations and the Office of Export Enforcement, has snuffed out another source of funds and goods to overseas entities that may endanger our national and economic security.” … 

The charge of conspiracy to violate the ITSR carries a maximum penalty of 20 years in prison and a $1 million fine. The charge of conspiracy to commit money laundering carries a maximum penalty of 20 years in prison and a $500,000 fine. The charge of conspiracy to smuggle goods carries a maximum penalty of five years in prison and a $250,000 fine. … 

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(Source: Editor, 30 Apr 2018.) 

The State Department’s Directorate of Defense Trade Controls (DDTC) is pleased to announce the launch of its 
redesigned website today. The updated website features a number of significant enhancements including navigation, searchability, and accessibility, with a consistent, full-featured experience across mobile devices.  Updates to DDTC’s website will continue as part of a broader Department of State effort to improve
and to
 facilitate a more consistent and unified experience across Department sites.  DDTC staff will be available to answer any questions users may have at (202) 663-1282 or

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Treasury/OFAC, 27 Apr 2018.)
The Department of the Treasury’s Office of Foreign Assets Control, in consultation and coordination with the Department of State, is authorizing by 
general license transactions involving certain Belarusian entities blocked pursuant to Executive Order (E.O.) 13405. This general license does not authorize the release of property blocked pursuant to E.O. 13405. This authorization expires on October 30, 2018, unless extended or revoked.

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Defense News and Aerospace Industries Associate Head Discuss U.S. Arms Export Rules  

Defense News, 30 Apr 2018.) [Video.] 
Defense News has released a video in which Aerospace Industries Association head Eric Fanning talks with Defense News Deputy Editor Aaron Mehta about the Trump administration’s new arms export rules. 
The video is available 

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Expeditors News: “Working Group on E-Commerce Finalizes Framework of Standards on Cross-Border E-Commerce” 

Expeditors News, 27 Apr 2018.)
The World Customs Organization (WCO) Working Group on E-Commerce (WGEC) met from April 9 to April 12, 2018 to finalize a draft framework of standards on cross-border e-commerce.
The WGEC had over 150 delegates from Customs administrations, other government agencies, the private sector, other international organizations, e-vendors/platforms, express service providers, postal operators, freight forwarders, customs brokers and academia develop the final draft of the framework of standards.
The WGEC expects this framework of standards to act as a comprehensive instrument for assisting in developing e-commerce strategic and operational frameworks. The framework will be supported by an implementation strategy and action plan based on national and regional needs. According to the WGEC, technical specifications, guidelines and case studies will be added to the framework at a later time.
The WCO press release may be found 

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Reuters: “Arms Maker Diehl Calls for Harmonized Export Rules in Europe”

Reuters, 26 Apr 2018.) 
German arms maker Diehl called for harmonized export rules in Europe, as German companies seek to take advantage of greater worldwide spending on defense programs.
Diehl, which focuses on missiles and ammunition, said if not European-wide standards, then there should at least be joint export rules between France and Germany, which are planning closer cooperation, such as on a future combat air system centered around a new fighter jet.
“As a minimum, if you have joint projects, then you should say from the start how you want to want to approach exports of the product,” Carl Guenther, head of Diehl Defense told journalists at the Berlin air show on Thursday.
Germany imposes very tight rules on arms exports, with the right to approve them vested in a committee of senior ministers. The current conservative-Social Democrat government has adopted even more restrictive rules, banning the export of weapons to countries involved in war in Yemen.
Like rivals, Diehl currently benefits from increased spending on defense, with the market for military products boosted by discussion among NATO countries on reaching the 2 percent of GDP spending target.
Guenther said though that the German government needed to do more to foster acceptance of the German army and its partners on missions.
  “And we must also have acceptance of the necessity of a German weaponry industry,” he said, saying it was important for German troops to be supplied with German equipment.
MTU Aero Engines’ Chief Program Officer Michael Schreyoegg also said the program offered a chance to boost the European defense supply chain, though repeated comments that politicians needed to move fast to determine the requirements so that the companies could get to work on the technology.
  “We will of course work with others and we do,” Diehl’s Guenther said as he unveiled a partnership with Boeing for a precision-guided weapon.
“But we think we need the lead in certain things that are important to us,” he said.

Attitudes towards the army are complicated in Germany, where shame felt at professional soldiers’ crimes in World War Two is tempered by pride some feel in the dovish posture of the post-war Federal Republic, whose army was placed under strict parliamentary control to make it better able to resist illegal or immoral orders.

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11. T
aipei Times: “MediaTek to Seek ZTE Export Permit”

Taipei Times, 30 Apr 2018.) 
Handset chip designer MediaTek Inc. on Saturday said it is preparing to apply for a permit to continue exporting to ZTE Corp, after the government announced new restrictions on high-tech exports to the Chinese firm.
MediaTek plans to follow requirements set out by the Ministry of Economic Affairs in applying for the export permit, a company filing with the Taiwan Stock Exchange said, adding that it hopes to continue sending shipments to its customer with only minor disruption.
The ministry late on Friday announced new measures for shipments from local companies to ZTE and its subsidiary, ZTE Kangxun Telecommunications Ltd, two weeks after the US banned US companies from selling products to the two Chinese companies for seven years.
In a statement posted on the ministry’s Web site, the Bureau of Foreign Trade said it informed trade associations on April 23 that all Taiwanese companies that ship “strategic, high-tech commodities” to the two Chinese firms must obtain export permits from the ministry to clear customs.
Domestic companies would receive export permits in three to five days after applying if the goods being shipped to ZTE do not involve “nuclear, biotech or chemical developments for military weapons,” the bureau said.
However, goods that cause concern would necessitate other government agencies participating in the review, which would possibly delay receipt of the permits, with companies having to wait 10 to 15 days, the bureau added.
Asked if the government’s measures aim to bar local companies from doing business with ZTE, bureau Director-General Yang Jen-ni told the Chinese-language Liberty Times (sister publication of the Taipei Times) on Saturday that the permit requirements are to serve as a reminder for local companies of the “red line” drawn by the US government and ensure that their dealings with the Chinese firms are legal.
Taiwan in July 1995 started its strategic high-tech commodities export control system to adhere to a control list set by the Coordinating Committee for Multilateral Export Controls agreement, Yang said.
US trade sanctions were imposed on ZTE and its subsidiary on April 15, after they failed to comply with an agreement with Washington to discipline employees who had violated US restrictions on exports of US technology to Iran and North Korea, but instead paid them bonuses.

While the seven-year ban – which took effect on April 15 and is to continue through March 13, 2025 – might jeopardize ZTE’s development, MediaTek has little exposure to the Chinese firm, it told a teleconference on Friday, adding that the US penalties imposed on ZTE would have no significant effect on its short-term operations.

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J. Treanor: “Treasury Eases Sanctions on Russian Aluminum Company”

Cadwaler Cabinet, 23 Apr 2018.) 
* Author: James Treanor, Esq., 
James.Treanor@cwt.com;, Cadwalader, Wickersham & Taft LLP. 
The U.S. Department of the Treasury Office of Foreign Assets Control (“OFAC”) 
extended a “maintenance and wind-down” period during which U.S. persons are permitted to engage in certain transactions involving a Russia-based aluminum company, United Company RUSAL PLC (“RUSAL”). RUSAL was 
placed on the Specially Designated Nationals and Blocked Persons list (“SDN list”) due to its ties with Russian oligarch Oleg Deripaska.
General License 14 under the Ukraine-/Russia-related Sanctions Regulations authorizes, through 12:01 a.m. Eastern Daylight Time on October 23, 2018, transactions and activities involving RUSAL and its property that are “necessary to the maintenance or wind-down of operations, contracts, or other agreements.” To qualify for the General License, such operations, contracts, or other agreements must have been in effect prior to April 6, 2018. U.S. persons engaging in transactions under General License 14 are not required to direct payments to or for the benefit of RUSAL or its subsidiaries into a blocked, interest-bearing account, as is the case for payments to other sanctioned companies covered by 
General License 12A. Finally, OFAC 
explained that it will not pursue secondary sanctions against non-U.S. persons for engaging in the same types of transactions and activity with RUSAL.
Treasury Secretary Steven T. Mnuchin stated that the maintenance and wind-down period was extended in light of the impact of the sanctions on “partners and allies,” and the action would give Treasury time to consider RUSAL’s removal from the SDN list. In an 
accompanying FAQ, OFAC indicated that the only likely path “for the United States to provide sanctions relief [to RUSAL] is through divestment and relinquishment of control of RUSAL by Oleg Deripaska.”

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T. Murphy: “Section 232/Section 301 Update”

(Source: Author)
* Author: Ted Murphy, Esq., Partner, Baker McKenzie; 
I wanted to share with you a couple of thoughts on the Section 232/Section 301 process that I thought might be helpful.
The first is a reminder.  The temporary exclusions from the Section 232 duties on steel (an additional 25%) and aluminum (an additional 10%) granted to products of Canada, Mexico, Australia, Argentina, Brazil and the EU expire at midnight today, Monday, April 30th.  While there have been some reports that the Administration intends to extend the temporary exclusions for some countries (
i.e., those who have expressed a willingness to negotiate a voluntary export restraint-type agreement), that is not likely to extend to all countries.  Based on what the EU has said publicly about its willingness to accept a VER, it seems likely that the additional duties will go into effect on Tuesday.
The second is also a reminder.  As companies grapple with the Section 232/Section 301 duties, many are reviewing their imports and determining whether articles are correctly classified or not (
e.g., if an article is on the list of products proposed to be subject to the Section 301 duties, can the article be re-classified in a different HTS provision not on the list?).  Many companies are also reviewing the publicly-available data of their competitors. …
As many of you know, U.S. Customs and Border Protection makes available to the public manifest data for import and export shipments.  The manifest data includes information such as the name and address of the foreign shipper & U.S. consignee/notify party, the ports of lading and unlading, the carrier, a description of the goods, weight, etc.  This data is obtained by private companies that repackage it (and often add their best guess at classification, entered value, etc.) and then sell it to the public for a fee.  
You may also know that CBP allows companies to request confidential treatment for their manifest data.  Under the regulations, if a company requests confidential treatment, CBP will not disclose the names and addresses of the importer/consignee, foreign shipper or notify party and any other identifying marks. 

The process to obtain confidential treatment is pretty straight-forward (it involves submitting a letter to CBP HQ) and we recommend that all clients pursue confidential treatment every 2 years.

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Gary Stanley’s EC Tip of the Day
(Source: Defense and Export-Import Update; 27 Apr 2018. Available by subscription from 
* Author: Gary Stanley, Esq., Global Legal Services, PC, (202) 352-3059,
For ITAR § 126.18(c)(2), the foreign licensee or sublicensee is responsible for maintaining all records regarding the screening to include the NDA. The U.S. applicant is only required to maintain NDAs for dual or third country nationals requested pursuant to ITAR § 124.8(5).

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MS_a115. ECS Presents: “Level III: Mastering ITAR/EAR Challenges”

(Source: Export Compliance Solutions) 

* What: Level III: Mastering ITAR/EAR Challenges
* When: 22-23 May, 2018
* Where: Chart House Restaurant on Spa Creek, Annapolis, MD
* Sponsor: Export Compliance Solutions (ECS)
* ECS Instructors: Suzanne Palmer; Lisa Bencivenga; Timothy Mooney, Commerce/BIS; Matt Doyle, Lockheed Martin; Matt McGrath, McGrath Law, Debi Davis, Esterline 
* Register here or by calling 866-238-4018, or e-mail

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MS_a216. Monday List of Ex/Im Job Openings; 191 Jobs Posted This Week

(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

* 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 (Early Career)
; Requisition ID: 1800030412

* 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

* Leonardo DRS; St. Louis;
Trade Compliance Specialist
; Requisition ID: 88127, or contact 

 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

* Meggit; Akron, OH; Manager, Trade Compliance;
* 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;
# PerkinElmer, Inc.; Shelton, CT; Systems Analyst, Trade Compliance Solutions;
* 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

* 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

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


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

. 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: 24 Apr 2018: 3 FR 17749-17751: Foreign Trade Regulations (FTR): Clarification on the Collection and Confidentiality of Kimberley Process Certificates
  – HTS codes that are not valid for AES are available
  – The latest edition (30 Apr 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: 25 Apr 2018: Harmonized System Update 1806
[contains 5,993 ABI records and 1,287 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: 25 Apr 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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