18-0802 Thursday “Daily Bugle”

18-0802 Thursday “Daily Bugle”

Thursday, 2 August 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. DHS/CBP Seeks Comments on Proposed Amendment to Drawback Regulations as Directed by TFTEA
  1. Items Scheduled for Publication in Future Federal Register Editions
  2. Commerce Announces Programs to Increase U.S. Commercial Engagement in the Indo-Pacific Region, Including Easing of Export Controls Against India
  3. Commerce/BIS: (No new postings.)
  4. State/DDTC Temporarily Modifies Category I of the USML
  5. UK Launches Public Consultation Concerning National Security and Investments
  1. Defense News: “A Jet Sale to Egypt Is Being Blocked By a U.S. Regulation, And France Is Over It”
  2. The New York Times: “Congress Strengthens Reviews of Chinese and Other Foreign Investments”
  3. Reuters: “U.S. Imposes Sanctions on Turkish Officials Over Pastor’s Detention”
  4. South China Morning Post: “U.S. Slaps Export Controls on Dozens of Chinese Firms Over ‘Threat To National Security’ As Trade Tensions Escalate”
  5. ST&R Trade Report: “New China Customs Declaration Required as of 1 Aug”
  1. M. Volkov: “Defining Deterrence in White Collar Crime Cases (Part III of III)”
  1. ECTI Presents “University Export Controls Program: Strength in Numbers” Webinar, 6 Sep
  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 (1 Aug 2018), FACR/OFAC (29 Jun 2018), FTR (24 Apr 2018), HTSUS (8 Jun 2018), ITAR (14 Feb 2018) 
  3. Weekly Highlights of the Daily Bugle Top Stories 



DHS/CBP Seeks Comments on Proposed Amendment to Drawback Regulations as Directed by TFTEA
Federal Register, 2 Aug 2018.) [Excerpts.] 
83 FR 37886-37990: Modernized Drawback
* AGENCY: U.S. Customs and Border Protection, Department of Homeland Security; Department of the Treasury.
* ACTION: Notice of proposed rulemaking.
* SUMMARY: This document proposes to amend U.S. Customs and Border Protection (CBP) regulations to implement changes to the drawback regulations as directed by the Trade Facilitation and Trade Enforcement Act of 2015 (TFTEA). These proposed regulations establish a new process for drawback pursuant to TFTEA which liberalizes the merchandise substitution standard, simplifies recordkeeping requirements, extends and standardizes timelines for filing drawback claims, and requires the electronic filing of drawback claims. TFTEA allows a transition period wherein drawback claimants will have the choice between filing claims under the existing process detailed in the current regulations or filing claims under the proposed new process. This document explains how filings during the transition period will work, discusses the interim policy guidance procedures for filing claims prior to these regulations becoming final, and proposes to make TFTEA-related changes, dealing with bonds, regarding joint and several liability for the importer of the goods and the drawback claimant, and technical corrections and conforming changes to CBP regulations. This document also proposes to clarify the prohibition on the filing of a substitution drawback claim for internal revenue excise tax paid on imported merchandise in situations where no excise tax was paid upon the substituted merchandise; or the substituted merchandise is the subject of a different claim for refund or drawback of tax under any provision of the Internal Revenue Code. CBP is proposing these amendments regarding excise taxes to protect the revenue by clarifying the relationship between drawback claims and Federal excise tax liability. Further, CBP proposes to add a basic importation and entry bond condition to foster compliance.
* DATES: Comments must be received on or before September 17, 2018.
You may submit comments, identified by docket number USCBP-2018-0029, by 
one of the following methods:
Federal eRulemaking Portal: 
. Follow the instructions for submitting comments.
Mail: Trade and Commercial Regulations Branch, Regulations and Rulings, Office of Trade, U.S. Customs and Border Protection, 90 K Street NE, 10th Floor, Washington, DC 20229-1177. … 
* FOR FURTHER INFORMATION CONTACT: Randy Mitchell, U.S. Customs and Border Protection, Office of Trade, Trade Policy and Programs, 202-863-6532, 
randy.mitchell@cbp.dhs.gov. … 
Kevin K. McAleenan, Commissioner, U.S. Customs and Border Protection.
Timothy E. Skud, Deputy Assistant Secretary of the Treasury.

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

* Commerce/BIS; 
     – Revision of Export and Reexport License Requirements for Republic of South Sudan Under the Export Administration Regulations; and
    – U.S.-India Major Defense Partners: Implementation of Membership in the Wassenaar Arrangement and Addition of India to Country Group A:5 [Publication Dates: 3 Aug 2018.];
* Commerce/BIS; NOTICES; Export Privileges; Denials: Narender Sharma and Hydel Engineering Products [Publication Date: 3 Aug 2018; included in the Daily Bugle of 1 Aug 2018.]
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Commerce Announces Programs to Increase U.S. Commercial Engagement in the Indo-Pacific Region, Including Easing of Export Controls Against India  

Commerce, 30 Jul 2018.) [Excerpts.] 
Following Secretary of Commerce Wilbur Ross’s participation in the Indo-Pacific Business Forum today, the Department of Commerce is announcing its plan to dedicate three of its upcoming flagship events to Indo-Pacific themes … 
Secretary Ross also announced that India’s status as a Major Defense Partner will allow it to receive more U.S. high technology and military items without individual export licenses.  India will be moved into Tier 1 of the Department of Commerce’s Strategic Trade Authorization (STA) license exception. STA Tier 1 treatment, comparable to NATO allies, will expand the scope of exports subject to the Export Administration Regulations (EAR) that can be made to India without individual licenses. This regulatory change will enhance the bilateral defense trade relationship and result in a greater volume of U.S. exports to India.  Over the last seven years, approximately $9.7 billion worth of licensed exports to India may now eligible for export under this license exception. 
  “India’s status as a Major Defense Partner led to its becoming a Strategic Trade Authorization (STA) Tier 1 country, comparable to our NATO allies, under the Department of Commerce’s Export Administration Regulations,” said Secretary Ross. “This reflects India’s membership in three of the four multilateral export control regimes, as well the development of its national export control system. U.S. companies will be able to more efficiently export a much wider range of products to Indian high technology and military customers.  India’s new status will benefit U.S. manufacturers while continuing to protect our national security.” 
The plans announced today represent a substantial dedication of the Department’s resources to the region and a prioritization by the Department of Commerce to direct U.S. trade and investment to Asia. Further details on these events and how to get involved will be forthcoming. … 

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State/DDTC, 2 Aug 2018.) 
As of July 31, 2018, and in compliance with the 
Temporary Restraining Order issued by the United States District Court for the Western District of Washington, in 
Washington v. U.S. Dep’t of State, No. C18-1115RSL, the Directorate of Defense Trade Controls (DDTC) is not implementing or enforcing the “Temporary Modification of Category I of the United States Munitions List” that was posted to the DDTC website on July 27, 2018, and has since been removed. 

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UK Launches Public Consultation Concerning National Security and Investments

UK ECJU, Notice to Exporters 2018/19, 25 Jul 2018.) [Excerpts.] 
On 24 July 2018 the UK Government published a white paper, 
national security and investment: proposed legislative reforms, and launched a public consultation.
The white paper sets out how the government will address the risks that can arise from hostile actors acquiring ownership of, or control over, businesses or other entities and assets that have national security implications. It follows the 
national security and infrastructure investment review green paper published in October 2017.
The government has reflected carefully on the feedback provided by a wide variety of stakeholders, including businesses, investors and law firms and a 
summary of responses is published alongside this white paper.
Only a small number of investment activities, mergers and transactions in the UK economy pose a risk to our national security. For the cases that pose a risk to our national security it is vital that the government is able to intervene in order to prevent or mitigate those risks.
The white paper sets out:
  – that the government will encourage parties to submit ‘valid notifications’ of transactions and other events that may give rise to national security risks
  – the ability for the government to ‘call in’ investments and other events which may raise national security concerns in whichever sector they occur, including those events which have not been notified
  – if the ‘call-in’ power is used, the government will undertake a full national security assessment which can take up to 30 working days, with the option of extending for a further 45 working days, or longer by agreement
  – at the end of the full national security assessment, if the government concludes that national security is at risk, it has the power to impose necessary and proportionate remedies – this could include, in rare circumstances, blocking or unwinding a deal
The government has also published a statement of policy intent alongside the white paper. This seeks to provide maximum certainty and clarity to business and investors by setting out how the ‘call-in’ power is expected to be used.

UK Government, including the UK Export Control Joint Unit (ECJU), welcomes your views on our proposals. Read the white paper and statement of policy intent. … 

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Defense News, 1 Aug 2018.) [Excerpts.]
France is seeking to reduce its reliance on U.S. approval for French arms exports as Washington withholds clearance for an American component on the French Scalp cruise missile, which blocks the sale of additional Rafale fighter jets to Egypt.
  “It is true that we depend on this [U.S. International Traffic in Arms Regulations] mechanism: We are at the mercy of the Americans when our equipment is concerned,” French Armed Forces Minister Florence Parly told the Committee for National Defense and Armed Forces of the lower-house National Assembly, according to recently released transcripts from July 4.
France lacks the means to be totally independent of the U.S., she said, adding that French authorities are looking for ways to boost its autonomy. Parly was answering a question from parliamentarian Jean-Jacques Ferrara on the blocked sale of a further batch of Rafale aircraft to Egypt.
  “Are we looking to improve the situation?” Parly said. “The answer is yes. In the case raised by Mr. Ferrara, we cannot get the U.S. to lift its opposition to the sale of Scalp missiles.”
  “What is the solution? That the manufacturer of these missiles, namely MBDA, make the investment in research and technology to be able to make a similar component, which would avoid ITAR,” she added.” “We are able to do it for this contract because the component can be built within a reasonable amount of time even if the client, naturally, sees it as too long.” … 
The ministry needs to adopt a more systematic approach – one that involves talking to industry as well as the Economy and Finance Ministry “to analyze” French dependence on the U.S., she said.
French authorities need to identify key components at risk due to U.S. refusal of clearance, she added, as well as how France can protect itself from American legislation, which successive U.S. administrations could use in policy shifts in response to factors beyond the control of France.

French President Emmanuel Macron sought to convince his U.S. counterpart, Donald Trump, to provide clearance for the cruise missile component during the former’s state visit to Washington in April, according to a French defense source, who spoke on condition of anonymity.  
The source also claimed Trump recommended French experts talk to their American counterparts to work out the clearance, but that it didn’t resolve the issue.
The U.S is the world leader in arms exports, accounting for more than a third of total foreign military sales, Parly told parliamentarians.
  “That has been the case for more than 70 years, and it looks like that will continue for some time,” she said. European nations will need to buy a little less from America to slightly reduce that supremacy, she said, adding that European states will be able to find European equipment due to initiatives being taken to promote European defense.
Europe could negotiate within the framework of ITAR to be less dependent on the U.S. and promote European autonomy and procurement, she said. “But we know very well that things are not going to change tomorrow,” she added.
Macron has asked for a French equivalent of the U.S. Foreign Military Sales program, which eases the way for government-to-government deals, she said. Client nations prefer that latter approach rather than dealing with companies.
The French Armed Forces and Economics and Finance ministries have drafted a framework agreement that will likely be adopted as the model for an intergovernmental arms contract, backed by a public tender and observing national and European law, she said.

The U.S. has been relaxing its rules on arms exports, with the State Department adopting the Conventional Arms Transfer policy, which eases the way for companies to directly pitch some types of weapons and drones without having to go to Washington for official approval. … 

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The New York Times, 1 Aug 2018.) [Excerpts.] 
Chinese investment in the United States is about to get a bit harder.
Legislation expanding the powers of a federal body that reviews foreign investments in the United States for national security threats passed the Senate 87-10 on Wednesday as part of a $717 billion 
defense policy bill, and it is now headed to President Trump for his signature.
The bill, known as the Foreign Investment Risk Review Modernization Act, broadens the jurisdiction of the Committee on Foreign Investment in the United States, or Cfius (pronounced SIFF-ee-yus). The committee will soon have more power to investigate, and possibly block, foreign deals.
  “We cannot continue to let bad actors, like China, erode our national security advantage by circumventing our laws,” said Senator John Cornyn, the Texas Republican sponsoring the bill. 
“This bill will modernize the process and help put an end to the backdoor transfer of dual-use technology that has gone unchecked for too long. … 

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Reuters, 1 Aug 2018.) [Excerpts.] 
The United States imposed sanctions on two top officials in Turkish President Tayyip Erdogan’s Cabinet on Wednesday in a new attempt to get NATO ally Turkey to turn over an American pastor accused of backing a coup attempt against Erdogan two years ago.
The U.S. Treasury Department acted against Justice Minister Abdulhamit Gul and Interior Minister Suleyman Soylu over the country’s imprisonment of Andrew Brunson. The United States has blamed both for being involved in Brunson’s arrest and detention.
Turkey’s Foreign Ministry called Washington’s action a “hostile stance” and said it would retaliate. Relations between the United States and Turkey have plummeted over Brunson, who was in custody for 21 months in a Turkish prison until he was transferred to house arrest last week. … 

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South China Morning Post: “U.S. Slaps Export Controls on Dozens of Chinese Firms Over ‘Threat To National Security’ As Trade Tensions Escalate”
South China Morning Post, 2 Aug 2018.) [Excerpts.] 
Washington has slapped restrictions on dozens of key Chinese companies – including state-owned developers of military-use technologies such as air defense and satellite systems – for reasons of national security.
The US Department of Commerce added 44 Chinese entities to its export control list on Wednesday for posing a “significant risk” to US national security or foreign policy interests in the midst of the heated trade spat between the world’s two largest economies.
In a direct challenge to China’s ambitions to become a technological superpower, driven by the Made in China 2025 policy, the new restrictions target some of the key elements of the policy including air defense systems, satellite communications systems, semiconductors and aerospace products. … 
The US controls will limit that companies’ access to products that the US commerce department deems could have dual military or civilian use and may deny them key components such as nuclear materials, telecoms equipment, lasers and sensors. … 

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ST&R Trade Report: “New China Customs Declaration Required as of 1 Aug” 

Sandler, Travis & Rosenberg Trade Report, 2 Aug 2018.)
Beginning 1 Aug, companies importing into China must file a new, single customs declaration that combines the requirements of the General Administration of Customs and China Inspection and Quarantine. However, there are already reports that confusion about the new declaration has resulted in shipment problems.
CIQ was recently merged into China Customs as part of an effort by Beijing to improve trade facilitation. CIQ is tasked with enforcing the national standards China imposes on all goods in the domestic market, while China Customs collects confirmation on the customs declaration that imported goods meet those standards. With the merger of the two agencies the customs declaration has been overhauled to require specific information and declaration pertaining to CIQ requirements. As a result, beginning 1 Aug importers must file one single declaration according to the new template provided at 
singlewindow.cn or 
online.customs.gov.cn rather than filing separate declarations as before.
The new declaration process is generally viewed as providing increased efficiency, as all declaration formalities for goods import or export will now be completed at one stop. The new customs declaration template eliminates the repetitive input of information and reduces the data required to 105 boxes.
It is noteworthy that the input of the HS code for individual imported goods has been increased from 10 digits to 13 digits in the new declaration template. There is no change to the usual 10-digit HS code used to classify imported goods; instead, the extra digits are reserved for the completion of the CIQ requirements. It is therefore imperative for importers to ascertain the CIQ examination standard clearly and correctly. In the past the separate declarations for CIQ and China Customs led to mismatches or incorrect declarations of the CIQ requirements against the imported goods, which resulted in inconsistency and even failure to obtain the requisite inspection certificate or import license. The new single declaration process should detect any such inconsistencies on a more timely basis and thus help avoid delays in the release of goods.
There are also other changes to the information required on the declaration, which must therefore be examined carefully before completion. Early reports indicate that confusion about these requirements is causing some shipments to be delayed.

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M. Volkov: “Defining Deterrence in White Collar Crime Cases (Part III of III)”

Volkov Law Group Blog, 1 Aug 2018. Reprinted by permission.) 
* Author: Michael Volkov, Esq., Volkov Law Group,
[Editor’s Note: Part I and II in this series were published in the Daily Bugle of 31 July and 1 August, respectively.]
There are two types of deterrence – specific and general.  Specific deterrence focuses on the risk of recidivism by the individual defendant.  General deterrence is focused on preventing others from engaging in similar misconduct.
Deterrence depends on three basic factors: certainty; severity and swiftness of punishment. The certainty of punishment is a significant factor for obvious reasons – if there is a little chance that a criminal’s misconduct will be detected, there is a greater likelihood an individual will commit the crime.  Society should invest significant resources to detect and investigate criminal activities. If the investigation and prosecution drags on for years, even if there is a certainty of being detected, the criminal may discount the impact of the ultimate punishment.
The severity of the punishment is a significant factor in the cost-benefit weighing of criminal activity. The punishment imposed reflects the harm of the conduct and a community’s disapproval of the conduct. Another way to say this is the punishment should be proportionate to the crime itself and the harm it caused to others.
In the federal system, judges are required to consider deterrence and retribution when sentencing a defendant.  The Federal Sentencing Guidelines note the need for a criminal sentence to be “just punishment” while affording “adequate deterrence to the criminal conduct.” When it comes to white-collar sentencing of corporations and individuals, judges place significant weight on the importance of deterrence.
The impact of such deterrence, however, may be neutralized when white-collar offenders rationalize their criminal conduct.  A businessperson may describe their behavior in terms that make such conduct acceptable and protecting their reputation as a law-abiding citizen or member of a community. From my vantage point, however, such explanations are usually post hoc rationalizations of known criminal behavior used to justify or excuse criminal conduct.  Because complex white-collar crimes usually focus on the actor’s intent, offenders often engage in denial by providing justifications for their actions. In many cases, the white-collar criminal blames overzealous prosecutors for his or her conviction rather than their own conscious choices and behaviors.
Whether deterrence has a significant impact on reducing white-collar crime is a fascinating question that requires further investigation and research.  Even setting side this question, the need for deterrence is an important factor for judges to consider.  Stiff sentences for white-collar offenders is consistent with society’s desire to prevent white-collar crime and harm to its victims. Further, the emphasis on deterrence restricts judicial sentencing at ranges that significant deviate from guideline recommended sentencing ranges.
Judges should consider whether a criminal sentence will send a message about white-collar criminal conduct and that such sentence reflects the harm to the victims and to society. Retribution is an important factor as well, especially when considering the impact of criminal conduct on victims. Similarly, judges should consider the need to disable a defendant by incarceration as a means to prevent the offender from engaging in future misconduct while incarcerated.
When comparing white-collar criminals to other classes of criminals, it is important for society to understand that criminal conduct should be avoided notwithstanding any positive contributions a specific offender may have made to his or her family, community or society.  In many cases, such considerations are only masks for protecting the wealthy and upper class criminal offenders who often understand completely the difference between legal and illegal conduct.  Such principles promote the overall fairness of our criminal justice system by reducing sentencing disparities among criminal defendants.

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ECTI Presents “University Export Controls Program: Strength in Numbers” Webinar, 6 Sep

(Source: Danielle Hatch, 
* What: University Export Controls Program: Strength in Numbers
* When: September 6, 2018; 1:00 p.m. (EDT)
* Where: Webinar
* Sponsor: Export Compliance Training Institute (ECTI)
* ECTI Speaker: Jennifer Saak
* Register: 
Here or Danielle Hatch, 540-433-

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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 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 

: 15 CFR Subtit. B, Ch. VII, Pts. 730-774

  – Last Amendment: 1 Aug 2018: 83 FR 37423-37433: Addition of Certain Entities; and Modification of Entry on the Entity List [Addition of 44 Entities in China to Entity List, Modification of 1 Entry in China.]

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

  – Last Amendment: 29 June 2018: 83 FR 30541-30548: Global Magnitsky Sanctions Regulations; and 83 FR 30539-30541: Removal of the Sudanese Sanctions Regulations and Amendment of the Terrorism List Government Sanctions Regulations 

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

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

* 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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