18-0807 Tuesday “Daily Bugle”

18-0807 Tuesday “Daily Bugle”

Tuesday, 7 August 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

  1. USTR Extends Deadline for Comments On Section 301: China’s Acts, Policies, and Practices Related to Technology Transfer, Intellectual Property, and Innovation
  1. Items Scheduled for Publication in Future Federal Register Editions 
  2. Commerce/BIS: (No new postings.)
  3. State/DDTC: (No new postings.)
  4. EU Implements Updated Blocking Statute In Response to U.S. Sanctions on Iran
  1. Defense Web: “France Looking To Circumvent U.S. Components In Scalp Missile”
  2. The Hill: “How 3D Guns Became A Free Speech Issue”
  3. Reuters: “Trump Says Firms Doing Business In Iran To Be Barred From U.S. As Sanctions Hit”
  4. ST&R Trade Report: “USTR to Review Turkey’s GSP Eligibility in Response to Retaliatory Tariffs”
  1. M. Lester: “Updated EU Blocking Statute Into Force on 7 Aug”
  2. M. Volkov: “The Revolution of Blockchain and Compliance (Part I of II)”
  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 (3 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 




USTR Extends Deadline for Comments on Section 301: China’s Acts, Policies, and Practices Related to Technology Transfer, Intellectual Property, and Innovation

(Source: Federal Register, 7 Aug 2018.) [Excerpts.] 
83 FR 38760-38761: Extension of Public Comment Period Concerning Proposed Modification of Action Pursuant to Section 301: China’s Acts, Policies, and Practices Related to Technology Transfer, Intellectual Property, and Innovation
* AGENCY: Office of the United States Trade Representative.
* ACTION: Extension of public comment period.
* SUMMARY: In a notice published on July 17, 2018 (83 FR 33608), the U.S. Trade Representative (Trade Representative) proposed a modification of the action taken in this investigation in the form of an additional 10 percent ad valorem duty on products of China with an annual trade value of approximately $200 billion. The July 17th notice sought public comment and provided notice of a public hearing regarding this proposed modification of the action in the investigation. On August 1, 2018, the Trade Representative announced that the President had directed the Trade Representative to consider raising the level of the additional duty in the proposed supplemental action from 10 percent to 25 percent. In light of this possible increase in the rate of additional duty, the Trade Representative is extending certain comment periods set out in the July 17th notice.
* DATES: To be assured of consideration, you must submit comments and responses in accordance with the following schedule:
  – August 13, 2018: The due date for filing requests to appear and a summary of expected testimony at the public hearing and for filing pre-hearing submissions is extended from July 27 to August 13, 2018.
  – September 6, 2018: The due date for submission of written comments is extended from August 17 to September 6, 2018.
  – August 20-23, 2018: The scheduled start date of the Section 301 hearing (August 20) has not changed. The Section 301 Committee may extend the length of the hearing depending on the number of additional interested persons who request to appear. The Section 301 Committee will convene the public hearing in the main hearing room of the U.S. International Trade Commission, 500 E Street SW, Washington, DC 20436 beginning at 9:30 a.m. on August 20, 2018.
  – September 6, 2018: The due date for submission of post-hearing rebuttal comments is extended from August 30 to September 6, 2018.
* ADDRESSES: USTR strongly prefers electronic submissions made through the Federal eRulemaking Portal: http://www.regulations.gov. Follow the instructions for submitting comments in sections E and F of the July 17th notice. The docket number–USTR-2018-0026–has not changed. … 
* SUPPLEMENTARY INFORMATION: … In the July 17th notice, the Trade Representative proposed 
modifying the action in this investigation by maintaining the original $34 billion action and the proposed $16 billion action, and by taking a further, supplemental action. In particular, the Trade Representative proposed a supplemental action of an additional 10 percent ad valorem duty on products of China covered in a list of 6,031 tariff subheadings in the Annex to the July 17th notice.
  On August 1, 2018, the Trade Representative announced that the President directed the Trade Representative to consider increasing the proposed level of the additional duty from 10 percent to 25 percent. This additional 25 percent duty would be applied to the proposed list of products in the Annex to the July 17th notice. The possible increase in the proposed rate of the additional duty is intended to provide the Administration with additional options to obtain the elimination of the acts, policies, and practices covered in the investigation. … 
Robert E. Lighthizer, United States Trade Representative.

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. Items Scheduled for Publication in Future Federal Register Editions

Federal Register)
* Commerce/BIS; NOTICES; Recruitment of Private-Sector Members: Emerging Technology Technical Advisory Committee [Publication Date: 8 Aug 2018.]

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(No new postings.)


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EU Implements Updated Blocking Statute In Response to U.S. Sanctions on Iran  

(Source: Editor, and 
Official Journal of the European Union, 7 Aug 2018.)
Today, the EU’s updated Blocking Statute enters into force to mitigate the impact of U.S. sanctions on the interests of EU companies doing legitimate business in Iran. 
What that means:
  (1) The EU aims to sustain the trade and economic relations between the EU and Iran. 
  (2) The Blocking Statute allows EU operators to recover damages arising from US extraterritorial sanctions from the persons causing them and nullifies the effect in the EU of any foreign court rulings based on them. 
  (3) To help EU companies with the implementation of the updated Blocking Statute the Commission published a 
Guidance note to facilitate understanding of the relevant legal acts. 
To read the related press release, see the Daily Bugle of Monday, 6 August 2018, item #6.


Commission Delegated Regulation (EU) 2018/1100 of 6 June 2018 amending the Annex to Council Regulation (EC) No 2271/96 protecting against the effects of extra-territorial application of legislation adopted by a third country, and actions based thereon or resulting therefrom

Commission Implementing Regulation (EU) 2018/1101 of 3 August 2018 laying down the criteria for the application of the second paragraph of Article 5 of Council Regulation (EC) No 2271/96 protecting against the effects of the extra-territorial application of legislation adopted by a third country, and actions based thereon or resulting therefrom

Commission Delegated Decision (EU) 2018/1102 of 6 June 2018 amending Annex III to Decision No 466/2014/EU of the European Parliament and of the Council granting an EU guarantee to the European Investment Bank against losses under financing operations supporting investment projects outside the Union, as regards Iran

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Defense Web, 7 Aug 2018.) [Excerpts.] 
France is looking for a way around the United States’ blocking of Scalp cruise missile technology for Egypt, and is exploring the possibility of replacing American components with alternatives so it can deliver the missiles as well as additional Rafale fighters to Egypt. 

French Defense Minister Florence Parly recently said in the country’s National Assembly that the decision by the United States to use the International Trade in Arms Regulation (ITAR) agreement to block the sale of Scalp missiles to Egypt could be circumvented if domestically-built parts are used instead.

  “In this case, we will not be able to lift the US opposition to the sale of Scalp missiles. The only thing we can do is for MBDA [which makes the missiles] to make some investment in research and development to be able to manufacture similar components that are not covered by ITAR,” Parly said last month. “We can do it for the Egyptian Scalp/Rafale in so far as the new missile can be built with a reasonable delay, though the customer might find this delay a bit too long.”

  “It is true that we depend on this [US International Traffic in Arms Regulations] mechanism: We are at the mercy of the Americans when our equipment is concerned,” she said. Because the United States will not lift its opposition to the sale of Scalp missiles, France has had to come up with alternatives.

Egypt has ordered 24 Rafale jets from France, and is looking to acquire 12 more, but only if it can buy Scalp missiles for them. 

It appears earlier reports that the impasse with the United States had been resolved, were premature. La Tribune reported that French President Emmanual Macron broached the Scalp issue during his visit to the United States in April. The newspaper in July reported that licenses had been granted to export components used in the missiles to Egypt while France is also in the process of finding alternative components for the missile that are ITAR-free.

In February it emerged that a plan to acquire 12 Rafales stalled after the United States refused to sell the manufacturer key components of the SCALP missile. The planned Egyptian acquisition of 12 Rafale fighter aircraft has been in the making since November 2017. It was billed to be a follow-up sale to a February 2015 agreement for an Egyptian acquisition of 24 Rafale fighter jets.

The new Egyptian defense minister Mohamed Ahmed Zaki Mohamed visited France in July, with Egypt expressing interest in acquiring 30 Patroller unmanned aerial vehicles and Cougar helicopters for the navy. Egypt was also interested in acquiring two additional Gowind corvettes but apparently negotiations are stalled over pricing and is now looking at German warships.

Forecast International notes that the deepening Egyptian-French relationship comes as the volume of U.S. sales to Egypt has waned after the US put a temporary hold on military sales and assistance to Egypt. … 

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The Hill, 7 Aug 2018.) [Excerpts.] 
In 2012, Defense Distributed, a non-profit organization, began posting online free downloads of computer files — codes — that would enable users to easily produce their own firearms and firearm components with 3D printers. In May 2013, the State Department informed Defense Distributed that sharing these files in this particular manner violated provisions of the Arms Export Control Act.
And just like that, 3D-printed guns became a free-speech issue wrapped up in all the societal trappings of a Second Amendment debate.

In short, the underlying dispute was one of interpretation: Were the codes for 3D-printed guns “technical data” for purposes of the United States Munitions List, and did making them available for international download constitute “exportation” of that regulated technical data? Defense Distributed argued that the codes weren’t regulated technical data, and that even if they were, the prohibition on publishing them was an unconstitutional prior restraint on speech. … 

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Reuters: “Trump Says Firms Doing Business In Iran To Be Barred From U.S. As Sanctions Hit”

Reuters, 7 Aug 2018.) [Excerpt.] 
Firms doing business with Iran will be barred from the United States, President Donald Trump said on Tuesday, as new U.S. sanctions took effect in spite of pleas from Washington’s allies.
Iran dismissed a last-minute offer from the Trump administration for talks, saying it could not negotiate while Washington had reneged on a 2015 deal to lift sanctions in return for curbs on Iran’s nuclear program.
Trump decided this year to pull out of the agreement, ignoring pleas from the other world powers that had co-sponsored the deal, including Washington’s main European allies Britain, France and Germany, as well as Russia and China.
European countries, hoping to persuade Tehran to continue to respect the deal, have promised to try to lessen the blow of sanctions and to urge their firms not to pull out. But that has proven difficult: European companies have quit Iran, arguing that they cannot risk their U.S. business.
  “These are the most biting sanctions ever imposed, and in November they ratchet up to yet another level. Anyone doing business with Iran will NOT be doing business with the United States. I am asking for WORLD PEACE, nothing less!” Trump tweeted on Tuesday. … 
Remove the Knife
Washington accepts that Iran has complied with the terms of the 2015 deal reached under Trump’s predecessor Barack Obama, but says the agreement is flawed because it is not strenuous enough. Iran says it will continue to abide by the deal for now, if other countries can help protect it from the economic impact of Washington’s decision to pull out.
Tuesday’s sanctions target Iran’s purchases of U.S. dollars, metals trading, coal, industrial software and auto sector. Global oil prices rose on Tuesday on concern sanctions could cut world supply, although the toughest measures targetting Iran’s oil exports do not take effect for four more months. … 
  “It is a reality check that this is happening and that Iran’s oil exports will be hurt when the oil sanctions hit it in November,” chief commodities analyst at Commerzbank Bjarne Schieldrop said.
In a speech hours before the sanctions were due to take effect, Iran’s President Hassan Rouhani rejected negotiations as long as Washington was no longer complying with the deal.
  “If you stab someone with a knife and then you say you want talks, then the first thing you have to do is remove the knife,” Rouhani said in a speech broadcast live on state television.
  “We are always in favor of diplomacy and talks…But talks need honesty,” Rouhani said. … 
Britain, France, Germany and the EU as a bloc said in a joint statement on Monday: “We deeply regret the reimposition of sanctions by the U.S.” … 
Few American companies do much business in Iran so the impact of sanctions mainly stems from Washington’s ability to block European and Asian firms from trading there.
Among large European companies that have suspended plans to invest in Iran are France’s oil major Total and its big carmakers PSA and Renault.
  “We have ceased our already restricted activities in Iran in accordance with the applicable sanctions”, said German car and truck manufacturer Daimler.

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ST&R Trade Report: “USTR to Review Turkey’s GSP Eligibility in Response to Retaliatory Tariffs” 

Sandler, Travis & Rosenberg Trade Report, 7 Aug 2018.)
USTR has launched a review of the eligibility of Turkey to participate in the Generalized System of Preferences based on concerns related to its compliance with the GSP market access criterion. This criterion, one of 15 defined by Congress in the statute authorizing the GSP program, covers the extent to which beneficiary countries have assured the U.S. reasonable and equitable access to their markets.
Specifically, USTR believes that Turkey’s imposition of additional tariffs on $1.78 billion worth of U.S. imports in response to the United States’ additional tariffs on imports of steel and aluminum products may violate the GSP’s market access criterion. Deputy U.S. Trade Representative Jerry Gerrish expressed hope that “Turkey will work with us to address the concerns that led to this new review of their duty-free access to the United States.” USTR notes that a public hearing and comment period for this review will be announced in an upcoming Federal Register notice.
The U.S. imported $1.66 billion from Turkey under the GSP program last year, representing 17.7 percent of total U.S. imports from that country. The leading GSP import categories were vehicles and vehicle parts, jewelry and precious metals, and stone articles.

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M. Lester: “Updated EU Blocking Statute Into Force on 7 Aug”

European Sanctions Blog, 6 Aug 2018.) 
* Author: Maya Lester, Esq., Brick Court Chambers,
maya.lester@brickcourt.co.uk, +44 20 7379 3550.
The European Commission 
announced today that the updated EU Blocking Statute (see 
previous blog) will enter into force on 7 August 2018 (tomorrow), in response to the re-imposition of US sanctions on Iran. They have also issued a document explaining its effect (
EU Commission Q&As) which states that:
  (1) The Blocking Statute aims at countering the effects of US sanctions on EU economic operators engaging in lawful activity with third countries.
  (2) It applies with regard to specific legislation listed in its Annex. It forbids EU residents and companies from complying with the listed legislation unless they are exceptionally authorized to do so by the Commission, allows EU operators to recover damages arising from that legislation from the persons or entities causing them, and nullifies the effect in the EU of any foreign court rulings based on it.
  (3) EU operators should inform the European Commission – within 30 days since they obtain the information – of any events arising from listed extra-territorial legislation that would affect their economic or financial interests.
  (4) EU operators can recover “any damages, including legal costs, caused by the application of the laws specified in its Annex or by actions based thereon or resulting therefrom” from “the natural or legal person or any other entity causing the damages or from any person acting on its behalf or intermediary”. The action can be brought before the courts of the Member States and the recovery can take the form of seizure and sale of the assets of the person causing the damage, its representatives or intermediaries.
  (5) Implementation of the Blocking Statute, including deciding on effective, proportionate and dissuasive penalties for possible breaches is the competence of Member States. It is also for Member States to enforce those penalties.
  (6) The European Commission gathers information from EU operators on possible cases of application of the listed extra-territorial legislation, liaises with national authorities from EU Member states concerning such cases in their jurisdiction and receives notification from and shares information with Member States on measures taken under the Blocking Statute and other relevant aspects.

  (7) The Commission can also, in exceptional cases, authorize an EU operator to fully or partially comply with the listed extra-territorial legislation if non-compliance would seriously jeopardies the interests of the operator or of the European Union. The Implementing Regulation containing the criteria on the basis of which the Commission will assess such requests for authorization will also be published tomorrow.

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M. Volkov: “The Revolution of Blockchain and Compliance (Part I of II)”

Volkov Law Group Blog, 6 Aug 2018. Reprinted by permission.) 
* Author: Michael Volkov, Esq., Volkov Law Group, 
mvolkov@volkovlaw.com, 240-505-1992. 
I am not one to engage in hyperbole.  But when it comes to blockchain technology and the implications for our economy, this is going to be the real deal.  In the world of ethics and compliance, blockchain has many possible applications that could easily transform compliance capabilities.
To show my age, let’s go back into time and remember when we all were buying personal computers – not laptops, but personal computers.  Bill Gates, the head of Microsoft, predicted that computing power would eventually move from laptops to the Internet and mobile devices.  In our short lifetime, we have witnessed the transformation of the computer industry from clunky personal computers in our home to cloud computing and rapid-fire access on our mobile phones.
I would suggest that the advent of blockchain will be just as revolutionary a new technology.  Our economy is built on intermediaries that perform a variety of functions that can be replaced through peer-to-peer trustless systems.  As blockchain grows, the role and need for intermediaries will decline.
We often hear the term these days – disruptive economies.  Marketplace innovation occurs so rapidly that we no longer characterize technologies as mature or maturing – new technologies disrupt to the point of making “old” technologies archaic in short periods of time.
In the compliance space, we hear often hear about “regtech,” meaning a new technology that solves regulatory and compliance requirements for financial businesses operating in digital markets.  Consumers have become digitally savvy and now demand rapid new technologies in the financial space.  Regtech has developed to meet the need for compliance while offering innovative products to these savvy consumers.
Financial businesses are under pressure to onboard a customer quickly, screen them and their transactions for AML compliance and satisfy the need for customers to engage in markets without any significant delay.  Financial firms are embracing a number of new technologies to meet consumer demand – data analytics, cloud computing, machine learning and blockchain.
Blockchain’s potential, however, is not limited to the financial industry.  To the contrary, blockchain will revolutionize ethics and compliance programs.
Let’s start with a basic understanding of distributed ledger technologies (“DLT”).
A distributed ledger is a database that is shared among multiple sites, locations and institutions. A DLT can be restricted to intra-company locations or it can be permissioned as needed to include business partners (e.g. accounting firm).  Those permissioned to access the blockchain can search the database, examine specific transactions, and “add” to the blockchain by making a new entry.  A user, however, cannot amend, delete or otherwise modify an existing blockchain database.  Every participant has access to an identical copy of the DLT. When a new transaction is added, everyone verifies the transaction, reaches a consensus, and then the blockchain is amended with the new transaction.  It is a shared ledger that is immutable and accessible to all users on a real-time basis.
The real-world application of blockchain will increase efficiency and accuracy of an infinite number of functions.  Blockchain can automate processes that often take days or weeks.  Blockchain automates and verifies trust – there is no need for a third-party intermediary who has to conduct transactions (e.g. banks, accountants, auditors).  The distributed ledger provides access to all transactions and therefore is trustworthy. Transactions can be completed quickly and with lower costs.  All permitted users wherever located will gain access to the same data.
As a consequence, data can be recorded and made available in near real-time.  An authorized user will not have to undergo verification his or her identity because the individual’s information will already exist in an encrypted, secure tamper-resistant database.  The bottom line is that a blockchain database will be immutable, immediate and transparent.

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. Bartlett’s Unfamiliar Quotations

(Source: Editor)

James Branch Cabell (1879 – 1958; was an American author of fantasy fiction and 
belles lettres. Cabell was well regarded by his contemporaries, including H.L. Mencken, Edmund Wilson, and Sinclair Lewis.) 
 – “There is not any memory with less satisfaction than the memory of some temptation we resisted.”

Francois de La Rochefoucauld (1613 – 1680; was a noted French author.)
  – Good advice is something a man gives when he is too old to set a bad example.

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EN_a213. 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 Amendments: 3 Aug 2018: 83 FR 38021-38023: Revision of Export and Reexport License Requirements for Republic of South Sudan Under the Export Administration Regulations; and 83 FR 38018-38021: U.S.-India Major Defense Partners: Implementation Under the Export Administration Regulations of India’s Membership in the Wassenaar Arrangement and Addition of India to Country Group A:5


FOREIGN ASSETS CONTROL REGULATIONS (OFAC FACR): 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 



  – 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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