18-0627 Wednesday “Daily Bugle”

18-0627 Wednesday “Daily Bugle”

Wednesday, 27 June 2018

TOPThe 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 here for free subscription. Contact us for advertising inquiries and rates

[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 Updates CATAIR and Error Dictionary
  4. Foreign Affairs Committee: “House Protects U.S. National Security, Economic Prosperity”
  5. State/DDTC: (No new postings.)
  6. Treasury/OFAC Revokes JCPOA-Related General Licenses, Amends Iranian Transactions and Sanctions Regulations, and Publishes Updated FAQ
  7. UK Amends Arms Export Control Policy Concerning Argentina
  1. Financial Review: “Australian Universities Helping China to Modernize its Military””
  2. The New York Times: “Trump May Soften Sweeping Plan to Restrict Chinese Investments”
  3. Unian: “Ukraine Lifts Restrictions on Arms Imports for Defense Ministry”
  1. A. Josselyn, C. Kimball & K. King: “New Restrictions on Chinese Participation in US Technology Sector Anticipated This Week”
  2. Crane Worldwide Logistics: “Tariff Increase Section 301 – China Imports”
  3. Elazar Advisors LLC: “Tech Export Control Risk Moving Right Along”
  1. “9th Annual ‘Partnering for Compliance™’ West Export/Import Control Conference”, 16-18 Oct, Ft. Worth, TX; Customs/ Import Boot Camp on 19 Oct
  1. Bartlett’s Unfamiliar Quotations 
  2. Are Your Copies of Regulations Up to Date? Latest Amendments: ATF (15 Jan 2016), Customs (12 Jun 2018), DOD/NISPOM (18 May 2016), EAR (6 Jun 2018), FACR/OFAC (19 Jun 2018), FTR (24 Apr 2018), HTSUS (8 Jun 2018), ITAR (14 Feb 2018) 
  3. Weekly Highlights of the Daily Bugle Top Stories 



[No items of interest noted today.]

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. Items Scheduled for Publication in Future Federal Register Editions

Federal Register)
* Justice/ATF; NOTICES; Agency Information Collection Activities; Proposals, Submissions, and Approvals:
Application for Explosives License or Permit [Publication Date: 28 Jun 2018.]
* Treasury/OFAC; RULES; Iranian Transactions and Sanctions Regulations [Publication Date: 28 Jun 2018.]

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Commerce/BIS: (No new postings.)
(Source: Commerce/BIS)

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DHS/CBP Updates CATAIR and Error Dictionary 

CSMS# 18-000400, 26 Jun 2018.)

An updated Drawback CATAIR is now posted with a corrected Table of Changes.

The updated Drawback CATAIR can be found 
here. Additionally, an updated Drawback Error dictionary was posted and that can be found 

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Foreign Affairs Committee: “House Protects U.S. National Security, Economic Prosperity”

Foreign Affairs Committee, 26 Jun 2018.) [Excerpts.] 
Today, the House of Representatives passed the Foreign Investment Risk Review Modernization Act (FIRRMA), a bipartisan agreement to protect both our national security and economic prosperity. Specifically, this bill significantly strengthens national security reviews of certain proposed foreign investments by the cross-agency Committee on Foreign Investment in the United States (CFIUS) and also reforms and modernizes U.S. controls over exports of certain “dual-use” and military items.
On the House floor prior to the vote, Chairman Royce delivered the following remarks (as prepared for delivery):
  “Over the past decade, we’ve seen rapid technological advances and an increase in foreign investment in the United States – especially from countries like China and Russia that pose national security concerns. Of great alarm, our regulatory system has not kept pace. Mr. Pittenger’s bill before us today seeks to change that.
The Foreign Investment Risk Review Modernization Act (FIRRMA) represents a broad bipartisan agreement to reform our regulatory systems to protect both our national security and our economic prosperity. Specifically, this bill strengthens national security reviews of certain commercial transactions conducted by CFIUS, as well as reforms and modernizes the outdated U.S. export control regime. … 
Mr. Speaker, this body has not addressed exports of dual-use items – products and services that have both commercial and military application – since the Export Administration Act of 1979. Since the EAA’s lapse nearly 25 years ago, successive administrations have relied on emergency authorities that have not kept pace with technological advances.
Today we are acting to fix that problematic lapse, because the United States’ position as the world’s largest exporter of goods and services is at risk. We will lose many good-paying jobs if we don’t better secure advanced technology and intellectual property.
That’s why this spring, the Foreign Affairs Committee passed the Export Control Reform Act of 2018. Under this approach, reflected in Title VIII of the bill before us, modernized U.S. export control laws and regulations will continue to have broad authority, governing the transfer of dual-use items and technology to foreign persons – whether that transfer takes place abroad or here in the United States.
Let me just highlight a few critical features of the export control provisions of this legislation. This title of the bill:
  – Requires that export controls be calibrated and continually updated to ensure lasting U.S. leadership in science, technology, engineering, manufacturing, and other sectors critical to the industrial base.
  – Ensures that sensitive manufacturing ‘know-how’ – which may include such items as written or oral communications, blueprints, engineering designs and specifications – are subject to appropriate export controls regardless of the nature of the underlying transaction.
  – Establishes a new authority for the U.S. export control agencies and the Department of Defense to identify and appropriately control emerging and foundational technologies that may be critical to U.S. national security. This includes artificial intelligence, robotics, augmented and virtual reality, new biotechnologies, new financial technologies, and advanced materials.
Ten years ago, Mr. Sherman and I held a series of hearings to examine China’s increasingly aggressive policies in the wake of the EAA’s expiration. I appreciate his passion for these issues, and his understanding of the need to balance our economic and national security interests. We need a nimble, adaptable system that protects but doesn’t unduly burden our world class industries.
Modernized U.S. export controls and CFIUS reforms are critical responses to the challenges posed by China, Russia, and others. This bill will help keep America safe and strong.”

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State/DDTC: (No new postings.)


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Treasury/OFAC Revokes JCPOA-Related General Licenses, Amends Iranian Transactions and Sanctions Regulations, and Publishes Updated FAQ

Treasury/OFAC, 27 Jun 2018.) 
The Department of the Treasury’s Office of Foreign Assets Control (OFAC) has revoked Iran-related General Licenses H and I, which were issued in connection with the Joint Comprehensive Plan of Action (JCPOA).  
OFAC also 
amended the Iranian Transactions and Sanctions Regulations, 31 C.F.R. part 560 (ITSR), in order to narrow the scope of the general licenses authorizing the importation into the United States of, and dealings in, Iranian-origin carpets and foodstuffs, as well as related letters of credit and brokering services, to the wind down of such activities through August 6, 2018 and to issue two new general licenses authorizing the wind down, through August 6, 2018, of transactions previously authorized under General License I, and the wind down, through November 4, 2018, of transactions previously authorized under General License H.  The amendment of the ITSR is effective today [and will be published in the Federal Register tomorrow.]
OFAC has also 
updated Frequently Asked Questions (FAQs) 4.3, 4.4, and 4.5 from its FAQs Regarding the Re-Imposition of Sanctions Pursuant to the May 8, 2018 NSPM Relating to the JCPOA.
These actions are in furtherance of the President’s May 8, 2018 decision to withdraw from the JCPOA and to begin re-imposing the U.S. nuclear-related sanctions that were lifted to effectuate the JCPOA sanctions relief, following a wind-down period.
Archival versions of General Licenses H and I will remain available on OFAC’s website to assist persons in determining which activities were not sanctionable or prohibited while those authorizations were in effect and how best to wind down such activity.

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UK Amends Arms Export Control Policy Concerning Argentina 

UK Export Control Joint Unit, 27 June 2018.)  
The restrictions imposed in 2012 on military and dual-use exports to military end users in Argentina have changed. Under those restrictions, it has been the UK government’s policy not to grant an export license for any military or dual use goods and technology being supplied to military end users in Argentina, except in exceptional circumstances.
Since the election of President Macri in December 2015, the UK’s relationship with Argentina has been improving, with closer co-operation across our bilateral relationship. Following these positive developments, the government believes it is appropriate now to lift the additional restrictions that were imposed in 2012.
In a written statement to the House of Commons and House of Lords, the government set out a revised policy.
The UK’s general position now will be to continue to refuse licenses for export and trade of goods judged to enhance Argentine military capability. However, where like-for-like equipment is no longer available, we may grant licenses where we judge they are not detrimental to the UK’s defense and security interests.
License applications for equipment and defense technology which meet the above criteria will still be assessed on a case by case basis against the consolidated EU and national arms export licensing criteria.
Key Changes

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Financial Review: “Australian Universities Helping China to Modernize its Military”

Financial Review, 27 Jun 2018.) [Excerpts.] 
China’s Communist Party is seeking to exploit academic collaborations in Australia to modernize its defense capability, prompting a prominent think tank to call for export controls and investment restrictions on companies developing artificial intelligence and big data applications with dual military and civilian use.
The report by 
Elsa Kania for the Australian Strategic Policy Institute (ASPI) recommends a radical overhaul of how universities and the federal government approach collaborations with Beijing, which it portrays as a hostile actor at a time of heightened strategic conflict.
  “The core dilemma is that the Chinese party-state has demonstrated the capacity and intention to co-opt private tech companies and academic research to advance national and defense objectives in ways that are far from transparent,” she writes.
Ms Kania highlights AI, which relies heavily on big data, as the main area where technology can have both civilian and military uses. … 

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The New York Times: “Trump May Soften Sweeping Plan to Restrict Chinese Investments”
The New York Times, 26 Jun 2018.) [Excerpts.] 
President Trump signaled on Tuesday that the White House may soften a plan to impose sweeping new investment restrictions on China, saying he supported giving more power to an existing government body that reviews foreign investments for national security threats.
No final decisions have been made and Mr. Trump could ultimately decide to move ahead with the type of tough bans on Chinese investment in American companies that he has been threatening as part of his crackdown on Beijing’s trade practices. The administration, which has already threatened China with tariffs on as much as $450 billion worth of its products, had promised to outline by Saturday proposed restrictions on Chinese investment to protect American companies it says were pressured to hand over valuable technology and trade secrets to operate in China. … 

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Unian: “Ukraine Lifts Restrictions on Arms Imports for Defense Ministry”

Unian, 27 Jun 2018.) [Excerpts.] 
[Ukrainian] President Petro Poroshenko has signed a decree that brings into effect the decision of the National Security and Defense Council of Ukraine on liberalizing foreign economic activity for Ukraine’s defense companies, NSDC Secretary Oleksandr Turchynov told a briefing on Tuesday, June 26, the Council’s press service reported.
  “Imports of military products are allowed for the needs of manufacturers of military equipment and weapons, as well as imports for non-state enterprises that have direct dealership agreements with foreign arms manufacturers,” Turchynov said, adding that the decision provides for the liberalization of foreign economic operations of defense companies, “in particular, the permission to all manufacturers of military equipment and weapons regardless of form of ownership to export their products without the mediation of state-owned specialized companies.”
He added that also the decision of the National Security and Defense Council removed restrictions on direct contracts of the national ministries of the power bloc, in particular, the Ministry of Defense, on the purchase of arms and military equipment abroad.
The NSDC secretary also said that to implement this decision, the Council had instructed the government to amend the relevant Cabinet regulations.
Turchynov called such a decision “a very serious step that will significantly strengthen our defense capability and provide a powerful impetus to the development of the defense industry.”
Turchynov also stressed that the liberalization of foreign economic operations of Ukraine’s arms manufacturers “will not weaken the reliable export control and compliance of all actors in the area with international agreements signed by Ukraine.”

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A. Josselyn, C. Kimball & K. King: “New Restrictions on Chinese Participation in U.S. Technology Sector Anticipated This Week”
Cooley LLP, 25 Jun 2018.) 
* Authors: Amy Josselyn, Esq., 
ajosselyn@cooley.com; Christopher Kimball, Esq., 
ckimball@cooley.com; and Kevin King, Esq., 
kking@cooley.com. All of Cooley LLP.
The U.S. government is poised to announce restrictions on Chinese participation in designated U.S. technology sectors. The restrictions, which the Trump Administration is expected to release on June 29, 2018, are reported to include restrictions on Chinese investment as well as enhanced controls on U.S. technology exports to China. For purposes of these restrictions, the Trump Administration is expected to invoke the president’s authority under the International Emergency Economic Powers Act (IEEPA), which is a statute that allows the president to exercise broad authorities to regulate commerce after declaring a national emergency. It is the same statute that is often used to impose economic embargoes and trade sanctions against foreign countries and territories (e.g., Crimea, Cuba, Iran, North Korea and Syria).
The new investment restrictions are expected to include prohibitions or limitations on Chinese investment in designated technology sectors, including:
  – integrated circuits
  – next generation information technology
  – numerical control machinery and robotics
  – aviation and aerospace
  – maritime engineering equipment and high-tech vessel manufacturing
  – advanced rail equipment
  – green technologies and electric vehicles
  – advanced materials
  – biomedicine and medical devices
  – agricultural machinery and equipment
The Chinese government identified these sectors in its “Made in China 2025” plan as critical to the development of Chinese domestic capabilities. They were also the focus of 
a recent report by the Office of the U.S. Trade Representative that was highly critical of Chinese efforts to acquire U.S. intellectual property in many of these fields.
The enhancement of U.S. export controls is expected to apply to US technology exports (e.g., hardware, software and technology) to China, Chinese companies and Chinese nationals. It is unclear, however, whether the enhanced controls will be implemented through existing regulations or imposed directly by the president under this IEEPA authority. Further, it is not known whether the controls will be applied to items (i.e., commodities, software and technology) that are currently controlled under the Commerce Control List or whether the U.S. Government will identify new items for control. 
To date, the Trump Administration has not released detailed descriptions of the specific restrictions contemplated. Companies operating in the technology sectors listed above will need to be prepared to assess the impact of these measures on current and future investments by Chinese investors and make changes to their export compliance policies and procedures in response to any newly announced restrictions.

Cooley will be monitoring developments with respect to the anticipated restrictions and will issue an updated alert after they are issued. In the interim, please contact a member of our team if you have questions regarding the potential impact of the anticipated restrictions on current or future trade or investment activity related to China. 

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Crane Worldwide Logistics: “Tariff Increase Section 301 – China Imports”
Crane Worldwide Logistics, June 2018.) [Excerpts.]
On June 14, 2018, the office of the U.S. Trade Representative (USTR) published 
the much anticipated list of Chinese origin goods that are to be subjected to a 25% additional tariff under Section 301 of the U.S. Trade Act of 1974 effective July 6, 2018. 
The broad list of 818 tariff items represent approximately $34 billion in imports from China and includes engines, semiconductors, medical products, earth moving equipment, electric motors, among other various categories. Noticeably absent from the list included many consumer goods such as televisions, furniture, and wearing apparel. 
An additional second list of 284 proposed tariff items targeted at China’s “Made in China 2025” industrial policy will be published in the Federal Register and subject to public comment prior to implementation. This second list representing approximately $16 billion in imports from China also avoided many consumer goods, but contains items such as motorcycles, mobile cranes, gas meters, railcars, and integrated circuits. Imposition of a 25% tariff for items on this second list is not expected until Fall 2018. 
In its announcement, the USTR suggested that some form of an exclusion process would be available to U.S. companies and that specifics would be addressed in the coming weeks. 
The Section 301 tariffs stem from a March 22, 2018 memorandum from President Trump instructing the USTR to take all appropriate actions to “address the acts, policies, and practices of China that are unreasonable or discriminatory and that burden or restrict U.S. commerce” following a 2017 USTR study into China’s trade practices. … 

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Elazar Advisors LLC: “Tech Export Control Risk Moving Right Along”
Elazar Advisors LLC, 26 Jun 2018.) 
wrote yesterday that mixed signals were coming out of the White House about the extent of new trade measures.

the media felt the White House may have backed down from its harsh stance after seeing the market spill on Monday. But that may not be the case.

President Trump now packaging new foreign investment limits within previous legislation was interpreted by the media as backing down. But, to us that legislation would confirm Monday’s concerns not cancel them.

Our bigger issue is that of export limits and there too legislation is moving right along. I don’t see that as Trump backing down. I doubt China would view today’s news as the U.S. backing down.

Export limits would mean that high tech companies could not partner or send goods to a country where their intellectual property was at risk.

Even though the Wall Street Journal reported that Trump “eases” his plans they went on to say, “A bill to make CFIUS reviews even tougher is making its way through Congress. It would create a new export control system to review whether overseas joint ventures are improperly transferring critical technologies to foreign companies.”

The Wall Street Journal calls “even tougher” “eases.” Not sure how. Sounds like export control legislation risk is moving right along.

Why we’re worried about export control is because it would mean that if exports are denied rights to be sold companies lose revenues which hit earnings. That would hit stock prices.

And as for backing down from export control Commerce Secretary Wilbur Ross 
said Sunday, “All possibilities that would better protect American technology, including potential changes to export controls, are under review.”

It doesn’t sound like there’s been any change there. If anything it sounds like the U.S. found its mechanism to move forward.

With this legislation moving right along, export control could risk revenues of companies with Chinese exposure.

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. “
9th Annual ‘Partnering for Compliance™’ West Export/Import Control Conference”, 16-18 Oct, Ft. Worth, TX; Customs/ Import Boot Camp on 19 Oct

(Source: A. E. NicPhaidin, 
* What: The 9th Annual “Partnering for Compliance™” West will focus intensely on a broad spectrum of export/import regulatory and compliance matters of current relevance to companies and individuals involved in global trading. Senior-level government officials and trade experts will provide first-class training. 
* Where: Dallas-Fort Worth Marriott South Airport Hotel (completely renovated)
* When:
  – Tue – Thurs, 16-18 Oct: “9th Annual ‘Partnering for Compliance™’ West Export Control Program
  – Fri, 19 Oct: 1-Day Program “Customs/Import Boot Camp”
* Speakers confirmed: DoS/DDTL: Terry Davis plus 1 other; DoS/DDTC: Daniel Cook (Invited); DoC/BIS: Bryce Bewley &  Mary Quach & OEE James Fuller; DoD/DTSA: Ken Oukrop; OFAC: Michael Szustakowski (plus licensing officer: Invited); Census Bureau: Dale Kelly; DHS/CBP: O’Ruill D. McCanlas; ICE: Dean Fittz; UK/EU: David Hayes Export Controls;  Imports: Braumiller Law Group PLLC: Adrienne Braumiller & Bruce Leeds; and U.S. trade.
* Opening Keynote Address: TBA (Invited)
* Cost: Export 3-day program: $650. Customs/Import 1-day program: $250. Both programs: $900. 
* Remarks: Maximum capacity is 200 participants to maintain informal and collaborative environment. 
* As time permits, all Government and trade speakers will informally hold short “one-to-one” meetings with participants on a “first-come, first-served” basis. 
* Certificates of Completion granting: 4.5 IIEI CEUs and 20 
CES NCBFAA Credits for 3-day Exports program, and 6.5 CCS NCBFAA Credits for 1-day Customs/Import Boot Camp will be awarded for each program. 
* More information: 

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. Bartlett’s Unfamiliar Quotations

(Source: Editor)

Helen Keller
 (Helen Adams Keller; 27 Jun 1880 – 1 Jun 1968; was an American author, political activist, and lecturer. She was the first deaf-blind person to earn a bachelor of arts degree.)
  – “
Optimism is the faith that leads to achievement. Nothing can be done without hope and confidence.”
  – “
Never bend your head. Always hold it high. Look the world straight in the eye.

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EN_a216. Are Your Copies of Regulations Up to Date?
(Source: Editor)

The official versions of the following regulations are published annually in the U.S. Code of Federal Regulations (C.F.R.), but are updated as amended in the Federal Register.  The latest amendments to applicable regulations are listed below.

ATF ARMS IMPORT REGULATIONS: 27 CFR Part 447-Importation of Arms, Ammunition, and Implements of War
  – Last Amendment: 15 Jan 2016: 
81 FR 2657-2723: Machineguns, Destructive Devices and Certain Other Firearms; Background Checks for Responsible Persons of a Trust or Legal Entity With Respect To Making or Transferring a Firearm. 

CUSTOMS REGULATIONS: 19 CFR, Ch. 1, Pts. 0-199
Last Amendment:
12 Jun 2018: 83 FR 27380-27407: Air Cargo Advance Screening (ACAS)

  – 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 


Last Amendment: 6 June 2018: 83 FR 26204-26205: Unverified List (UVL); Correction 


FOREIGN ASSETS CONTROL REGULATIONS (OFAC FACR): 31 CFR, Parts 500-599, Embargoes, Sanctions, Executive Orders

  – Last Amendment:
 19 June 2018: 83 FR 28370-28375: Rough Diamonds Control Regulations



  – Last Amendment: 24 Apr 2018:
83 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 April 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 
BITAR 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
* HARMONIZED TARIFF SCHEDULE OF THE UNITED STATES (HTS, HTSA or HTSUSA), 1 Jan 2018: 19 USC 1202 Annex. (“HTS” and “HTSA” are often seen as abbreviations for the Harmonized Tariff Schedule of the United States Annotated, shortened versions of “HTSUSA”.)

Last Amendment: 8 Jun 2018: Harmonized System Update 1809, containing 901 ABI records and 192 harmonized tariff records. 

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


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

  – The only available fully updated copy (latest edition: 25 Apr 2018) of the ITAR with all amendments is contained in Bartlett’s Annotated ITAR
(“BITAR”), by James E. Bartlett III. The BITAR contains all ITAR amendments to date, plus a large Index, over 800 footnotes containing amendment histories, case annotations, practice tips, DDTC guidance, and explanations of errors in the official ITAR text. Subscribers receive updated copies of the BITAR in Word by email, usually revised within 24 hours after every ITAR amendment.
 The BITAR is available by annual subscription from the Full Circle Compliance 
. 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 Daily Bugle Top Stories” posted here.

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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.  If you would to submit material for inclusion in the The Export/Import Daily Update (“Daily Bugle”), please find instructions here.

* CAVEAT: The contents 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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