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18-0820 Monday “Daily Bugle”

18-0820 Monday “Daily Bugle”

Monday, 20 August 2018

TOP
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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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: “ACS Broker Statistics to be Turned Off on 22 Sep”
  4. DoD/DSS Publishes DISS Tips and Tricks
  5. State/DDTC: (No new postings.)
  6. Singapore Customs Releases Notice Concerning Permit Requirements for Shipments To and From North Korea
  1. Expeditors News: “USTR Removes Exemptions of Certain U.S. Goods Returned for Section 301 Tariffs”
  2. ST&R Trade Report: “Facilitating Illicit Shipments to North Korea Nets Sanctions”
  3. ST&R Trade Report: “Imports of 27 Chemical Substances to Require Advance Notice”
  1. B. Egan, E.T. Abrams & Z. Wang: “Changes Afoot for CFIUS and U.S. Export Controls as the Dust Settles on FIRRMA” (Part I of II)
  2. M. Volkov: “New Episode Everything Compliance: The Five-Year Retrospective Edition”
  3. T. Murphy: “Section 301 – Latest Update”
  1. NDAA Changes “Under Secretary of Commerce for Export Administration” to “Under Secretary of Commerce for Industry and Security”
  2. Monday List of Ex/Im Job Openings: 200 Openings Posted This Week, Including 38 New Openings
  1. FCC to Present U.S. Export Controls Awareness Training Course for Non-U.S. Organizations, 2 Oct in Bruchem, the Netherlands
  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 Aug 2018), FACR/OFAC (29 Jun 2018), FTR (24 Apr 2018), HTSUS (14 Aug 2018), ITAR (14 Feb 2018) 
  3. Weekly Highlights of the Daily Bugle Top Stories 

EXIMITEMS FROM TODAY’S FEDERAL REGISTER

EXIM_a1

[No items of interest noted today.]

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

OGSOTHER GOVERNMENT SOURCES

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

[No items of interest noted today.]

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

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

(Source: 
CSMS# 18-000488, 20 Aug 2018.) 
 
Entry summary filing has been transitioned to ACE for over two years. As such, the Broker Statistics (application code OR) related to these Automated Commercial System (ACS) transactions will be turned off on 22 September 2018.

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

OGS_a44. 
DoD/DSS Publishes DISS Tips and Tricks
(Source: 
DoD/DSS, 20 Aug 2018.)
 
To help Industry with the ongoing provisioning of the Defense Information System for Security (DISS), the Defense Manpower Data Center offers some 
DISS tips and tricks.

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

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

(Source: 
Singapore Customs, Notice No. 14/2018, 10 Aug 2018.)
 
Singapore Customs has released a new notice concerning permit requirements for the import, export, transshipment, and bringing-in-transit of goods originating from or destined for North Korea. 
 
The circular is available 
here.
 

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

NWSNEWS

(Source: 
Expeditors News, 17 Aug 2018.) 
 
On August 16, 2018, the Office of the U.S. Trade Representative (USTR) removed exemptions on U.S. goods returned after alteration, repair, assembly, or processing and will become subject to the Section 301 tariffs on China.
 
An additional duty rate of 25% will apply to subheadings 9802.00.40, 9802.00.50, and 9802.00.60 and “…will apply to the value of the repairs, alterations, or processing performed abroad, as described in the applicable subheading.” The additional 25% tariff will also apply to subheading 9802.00.80 on the “…value of the article less the cost or value of such products of the United States, as described in heading 9802.00.80.”
The changes will apply to products entered for consumption or withdrawn from warehouse for consumption on or after August 23, 2018.
 
The Federal Register Notice (FRN) may be found 
here.

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

 
One entity and three individuals in China, Russia, and Singapore have been hit with sanctions by the Treasury Department’s Office of Foreign Assets Control for their involvement in facilitating illicit shipments on behalf of North Korea. These sanctions are a reminder to the shipping industry, including flag states, ship owners and operators, crew members and captains, insurance companies, brokers, oil companies, ports, classification service providers, and others, of the significant risks posed by North Korea’s shipping practices.
 
The sanctions are being imposed under executive order 13810 issued in September 2017, which significantly expanded Treasury’s authorities to target those who enable the North Korean regime’s activity wherever they are located. This includes (a) targeting those conducting significant trade in goods, services, or technology with North Korea and banning them from interacting with the U.S. financial system, (b) blocking and freezing the assets of actors supporting North Korea’s textiles, manufacturing, information technology, fishing, and other industries, and (c) suspending U.S. correspondent account access to any foreign bank that knowingly conducts or facilitates significant transactions tied to trade with North Korea or certain designated persons.
 
OFAC has designated a China-based company and its Singapore-based affiliate for working together to facilitate illicit shipments to North Korea using falsified shipping documents, including exports of alcohol, tobacco, and cigarette-related products. OFAC has also designated a Russia-based port service agency (and its director general) for providing port services to North Korea-flagged vessels even after its employees knew of oil-related sanctions on North Korea.
 
Any property or interests in property of the designated persons in the possession or control of U.S. persons or within the U.S. may not be transferred, paid, exported, withdrawn, or otherwise dealt in, and U.S. persons are prohibited from dealing with any of the designated parties.

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

NWS_a39. 
ST&R Trade Report: “Imports of 27 Chemical Substances to Require Advance Notice” 
(Source: 
Sandler, Travis & Rosenberg Trade Report, 20 Aug 2018.)
 
The Environmental Protection Agency has issued a 
direct final rule requiring persons who intend to manufacture (including import) or process any of 27 specified chemical substances for an activity designated as a significant new use by this rule to notify the EPA at least 90 days before commencing that activity. Persons may not commence manufacture or processing for the significant new use until the EPA has conducted a review of the notice, made an appropriate determination, and taken such actions as are required with that determination.
 
Importers must certify that shipments of these substances comply with all applicable rules and orders under the Toxic Substances Control Act, including any SNUR requirements. In addition, any persons who export or intend to export any of these substances on or after Sept. 19 are subject to the export notification provisions of 15 USC 2611(b) and must comply with the export notification requirements in 40 CFR part 707, subpart D.
 
This rule will be effective as of Oct. 19. If the EPA receives written adverse or critical comments, or notice of intent to submit such comments, by Sept. 19 it will withdraw the relevant sections of this rule before Oct. 19 and proceed with a related proposed rule.

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

COMMCOMMENTARY

COMM_a0
10. 
B. Egan, E.T. Abrams & Z. Wang: “Changes Afoot for CFIUS and U.S. Export Controls as the Dust Settles on FIRRMA” (Part I of II)

(Source: 
Steptoe & Johnson LLP, 16 Aug 2018.)
 
* Authors: Brian Egan, Esq., 
began@steptoe.com; Evan T. Abrams, Esq., 
eabrams@steptoe.com; and Zhu (Judy) Wang, Esq., 
zwang@steptoe.com. All of Steptoe & Johnson LLP.
 
[Editor’s Note: Part 2 will be published in the Daily Bugle of tomorrow.]
 
After months of hearings and other deliberations, Congress passed, and President Trump signed into law on August 13, 2018, the Foreign Investment Risk Review Modernization Act of 2018 (FIRRMA). FIRRMA marks the first update to the Committee on Foreign Investment in the United States (CFIUS) in over a decade and will considerably expand the jurisdiction of the Committee and make other important changes to its rules. A text of the final version of FIRRMA (Sections 1701 to 1728 of the National Defense Authorization Act for Fiscal Year 2019 (NDAA)), is available 
here. The NDAA also includes comprehensive US export control reform legislation that (among other things) mandates increased US export controls over “emerging and foundational technologies” to address some of the US national security concerns that had led to calls for CFIUS reform. FIRRMA has gone through a number of revisions as it advanced in Congress and earlier versions of the bill are discussed in our previous International Law Advisories from 
June and 
January of this year.
 
The changes to CFIUS in FIRRMA are far-reaching. First, and most significantly, CFIUS’s jurisdiction will expand to cover additional investments in US critical infrastructure and critical technology companies and US companies that deal with substantial amounts of US personal data, certain real estate transactions, and concessions at ports and airports. This change will not go into effect until CFIUS updates its regulations and defines a number of key terms. Second, a new “declaration” filing mechanism could simplify the review process for some transactions – if CFIUS shows a willingness to accept these filings. Third, CFIUS is no longer a wholly voluntary process, as some transactions will now require filing with CFIUS. Fourth, the timeline for CFIUS review will be lengthened, and CFIUS will be authorized to charge “filing fees” for the first time.
 
Expansion of CFIUS Jurisdiction
 
Prior to the passage of FIRRMA, CFIUS had the authority to review any transaction, by or with a foreign person, that could result in foreign control of a US business. Such transactions are known as “covered transactions.” FIRMMA expands CFIUS’s jurisdiction in three significant respects:
(1) Real Estate Deals and Airport and Maritime Port Concessions
 
For the first time, some purchases or leases of US real estate will be subject to CFIUS review regardless of whether they are part of an acquisition of a US business. Similarly, concessions granted to foreign companies at US airports, marine ports, and military bases will be subject to CFIUS review. Specifically, FIRRMA extends CFIUS’s jurisdiction over real estate transactions to include any purchase or lease by, or concession to, a “foreign person” of real estate that is located in the United States and is either (1) part of an airport or maritime port, or (2) in “close proximity” to a US military installation or other sensitive US government facility and that could facilitate intelligence collection or foreign surveillance at that facility.
 
FIRRMA includes some provisions that will limit the scope of CFIUS’s review of these transactions. It will require CFIUS to promulgate regulations that define “close proximity” in order to ensure that it is limited to distances within which the relevant real estate could pose a national security risk. CFIUS is also required through regulation to limit the term “foreign person” for purposes of real estate transactions to “certain categories” of foreign persons where the connection between the foreign person and a foreign country or government affects US national security. In addition, real estate transactions related to single housing units will be excluded from CFIUS review. Transactions related to real estate in “urbanized areas” as defined by the Census Bureau will also be excluded, unless CFIUS implements regulations that require otherwise.
 
While expanding CFIUS’s jurisdiction to a broader class of real estate transactions is new, proximity to sensitive government or military installations is already a consideration CFIUS takes into account when considering covered transactions. Most notably, in 2014, the Obama Administration ordered Ralls Corp. to 
divest from a wind farm facility in close proximity to a US Department of Defense installation. While FIRRMA expands the scope of transactions subject to review, it reflects national security sensitivities that have long been part of the CFIUS process.
(2) “Other Investments” in Businesses with Critical Infrastructure, Critical Technology, or Personal Data
 
FIRRMA will also extend CFIUS’s jurisdiction to a broad range of investments in critical technology and critical infrastructure companies, and in companies that maintain or collect sensitive personal information. Specifically, FIRRMA authorizes CFIUS review of “other investments” (beyond those that result in control of a US business) by a foreign person in any “unaffiliated United States business” that (1) “owns, operates, manufactures, supplies, or services critical infrastructure,” (2) “produces, designs, tests, manufactures, fabricates, or develops one or more critical technologies,” or (3) “maintains or collects sensitive personal data of United States citizens that may be exploited in a manner that threatens national security.”
 
The “other investments” covered by this provision are very broad – they include any investment that provides (1) access to “material non-public technical information,” [FN/1] (2) membership or other board of director rights, or (3) other involvement in certain substantive decision-making by the company.
 
The definitions of “critical infrastructure” and “critical technologies” track the current definitions used by CFIUS for those terms, with one key expansion – “critical technologies” also includes “emerging and foundational technologies” that (as discussed below) will now be subject to US export controls. As is true with real estate transactions, CFIUS will be required to limit the term “foreign person” for purposes of this category of transactions to “certain categories” of foreign persons where the connection between the foreign person and a foreign country or government affects US national security.
 
CFIUS has long identified critical infrastructure and critical technology companies as US investment targets that pose particular vulnerabilities. CFIUS’s interest in companies that handle large amounts of sensitive US personal data is of more recent vintage. FIRRMA significantly expands CFIUS’s jurisdiction over non-controlling foreign investments in these industries and areas.[FN/2]
 
(3) Addressing other “Gaps” in the Committee’s Existing Authorities
 
FIRRMA will also explicitly extend CFIUS’s jurisdiction in two areas that are natural offshoots of CFIUS’s existing jurisdiction:
  – Any changes in the rights of a pre-existing foreign investor that could result in foreign control of a US business or meet the definition of “other investment” (defined above)
  – Transactions “designed or intended to evade or circumvent” the Committee’s jurisdiction
 
CFIUS will be required to issue implementing regulations on transactions that “evade or circumvent” CFIUS. One question is the extent to which these regulations will cover transactions that are designed legitimately to avoid CFIUS’s jurisdiction. Even after FIRRMA, CFIUS does not have jurisdiction over all, or even most, foreign investments in the United States. Particularly in light of uncertainties in the current CFIUS process, many foreign investors do not want to make investments that could be subject to CFIUS jurisdiction, and they seek transactions that avoid CFIUS’s jurisdiction (for example, by not taking a controlling interest in a US business). It remains to be seen when CFIUS will consider such transactions as designed or intended to “evade or circumvent” CFIUS.  
 
Abbreviated “Declarations” in Lieu of Longer “Notices”
 
Under current rules, parties to covered transactions who seek CFIUS review must file lengthy written notices with CFIUS (frequently dozens of pages or longer) with detailed information about each company and its product lines, business operations, and personnel. FIRRMA creates an alternative, more streamlined process, by which parties to covered transactions can choose to submit “a declaration with basic information regarding the transaction” instead of a longer traditional written notice. While the requirements for such a declaration will be determined by CFIUS regulations, the declaration “would not generally exceed five pages in length.”
 
Not later than 30 days after receiving such a declaration, CFIUS must take one of several actions. The Committee could complete its review on the basis of the short-form “declaration,” it could request that the parties file a longer written notice, or it could unilaterally initiate a full-scale review of the transaction.
 
The creation of this more streamlined declaration process could prove to be a useful innovation that will allow CFIUS to “triage” its caseload and conduct a summary review of transactions that raise little concern. At this point, however, it is not clear whether this new procedure will prove to be a viable alternative to a full “written notice.” CFIUS will retain the authority to require a full written notification in every case, and it is possible that CFIUS will conclude that it requires a full notification in most cases – which could result in increased review time and cost for parties that elect to file a declaration.
—– 
  [FN/1] Material nonpublic technical information means information that (1) “provides knowledge, know-how, or understanding, not available in the public domain, of the design, location, or operation of critical infrastructure” or (2) “is not available in the public domain, and is necessary to design, fabricate, develop, test, produce, or manufacture critical technologies, including processes, techniques, or methods.” The bill specifies that “financial information regarding the performance of a United States business” does not constitute material nonpublic technical information.
  [FN/2] Certain US-managed investment funds with foreign limited partners serving on the fund advisory board, or similar body, may be exempt from the definition of “other investment” if such advisory board cannot control the fund and meets other statutorily defined criteria. 

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COMM_a01
11. 
M. Volkov: “New Episode Everything Compliance: The 5-Year Retrospective Edition”

(Source: 
Volkov Law Group Blog, 19 Aug 2018. Reprinted by permission.) 
 
* Author: Michael Volkov, Esq., Volkov Law Group,
 
mvolkov@volkovlaw.com, 240-505-1992.
 
Tom Fox, Matt Kelly, Jonathan Armstrong, Jay Rosen, and I recently recorded a new episode of “Everything Compliance — Five-Year Retrospective Edition.”  You can listen to it 
here.
Everything Compliance is the only roundtable podcast in compliance, with four of the top compliance practitioners around. This week the gang returns to its four focused topics on its Five-Year Retrospective Edition.
 
  (1) Matt Kelly considers how did the 2013 Internal Controls Framework and the 2016 ERM Framework change things (or not)? He notes the two Frameworks provided widely distributed information to consider compliance in a disciplined way. Matt rants on Elon Musk.
 
  (2) Mike Volkov explores FCPA enforcement over the past 5 years. He lists the top 3 developments: (1) the long road to the FCPA Corporate Enforcement Policy; (2) The Yates Memo and individual prosecutions and (3) The global framework, built by the DOJ and SEC for anti-corruption investigation and enforcement. Mike rants on disgraced Representative Chris Collins.
  (3) Jonathan Armstrong focuses on the evolution of data privacy. Numerous actors, including legislatures, regulators, individuals and pressure groups have all influenced EU/UK policy in this area. Further as US companies have become larger and larger, EU/UK Fair Trade/anti-trust and privacy laws will be used to greater effect on these entities. Armstrong shouts out to compliance when walking one’s bovine in Norwich City.
  (4) Jay Rosen considers changes in compliance from the vendor perspective. He notes that many vendors brought a business process approach to not only how law firms and investigative firms worked but also how companies approached compliance programs. Jay rants on the NFL owners attempting to stop players from exercising free speech.  
  (5) Tom throws in a shout out for retiring Wall Street Journal reporter Ben DiPietro, who retires from the WSJ Risk and Compliance Journal on August 14.
 
The members of the Everything Compliance panelist are:
 
  – Jay Rosen– Jay is Vice President, Business Development Corporate Monitoring at Affiliated Monitors. Rosen can be reached at 
JRosen@affiliatedmonitors.com
  – Mike Volkov– One of the top FCPA commentators and practitioners around and the Chief Executive Officer of The Volkov Law Group, LLC. Volkov can be reached at 
mvolkov@volkovlawgroup.com.
  – Matt Kelly– Founder and CEO of Radical Compliance. Kelly can be reached at 
mkelly@radicalcompliance.com
  – Jonathan Armstrong– Rounding out the panel is our UK colleague, who is an experienced lawyer with Cordery in London. Armstrong can be reached at 
armstrong@corderycompliance.com

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COMM_a3
12.
T. Murphy: “Section 301 – Latest Update”

(Source: Author, 20 Aug 2018.)
 
* Author: Ted Murphy, Esq., Baker & McKenzie LLP, 
ted.murphy@bakermckenzie.com, +1 202 452 7000.
 
Just a quick update on Section 301, and the process surrounding List 3, in particular. 
 
As you know, the U.S. Trade Representative is considering whether to impose an additional 25% duty on a list of tariff provisions that represent $200 billion worth of imports from China (this is ‘List 3’).  The Section 301 Interagency Committee will be holding a public hearing on the scope of List 3 beginning this week.  The USTR will hear testimony from approximately 350 interested parties over 6 days.  The list of parties testifying is attached here for your reference.
 
In addition, we wanted to let you know that, as of last Thursday, the USTR had received 386 product exclusion requests under List 1.  The oldest request was filed on July 16, 2018.  So far, none of the 386 product exclusion requests have been acted upon. A list of the exclusion requests is attached for your reference.  The USTR is expected to publish a notice in the Federal Register opening the exclusion process for List 2 shortly.  A similar notice (presumably) will be published for List 3 shortly after that list is finalized (expected in mid-to-late September).  Remember, it is better to file your exclusion request as early in the process as possible (it is going to be a long line!).
 
Finally, there will be a meeting in Washington between Chinese and U.S. officials later this week. This meeting is billed as being between “mid-level” officials on both sides (so, it is likely a meeting about whether it makes sense to keep meeting). While this is a positive sign, it does not mean that the end is near (by any stretch).  For one reason, the U.S. delegation is being lead by a Treasury Department official.  The trade agenda (at least when it comes to China) is being driven by the White House, Commerce Department and USTR (not by Treasury).  As a result, no major breakthroughs are expected at this meeting. That said, it is also being reported that there could be a possible meeting between President Trump and President Xi at one of the international meetings both will be attending in November. While a resolution may not seem likely, President Trump has demonstrated a certain penchant for ‘declaring victory’ after in-person meetings with world leaders (and leaving the details to be worked out by others later – e.g., the Singapore summit with North Korea, the White House meeting with EU Commission President Juncker last month).  Nothing would surprise me at this point.

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

MSEX/IM MOVERS & SHAKERS

MS_a013NDAA Changes “Under Secretary of Commerce for Export Administration” to “Under Secretary of Commerce for Industry and Security”

(Source: Editor, 20 Aug 2018.)
 
Section 1781 of the National Defense Authorization Act for FY 2019 (NDAA) gives that Under Secretary a new title:
 
SEC. 1781. UNDER SECRETARY OF COMMERCE FOR INDUSTRY AND SECURITY.
  (a) IN GENERAL. — On and after the date of the enactment of this Act, any reference in any law or regulation to the Under Secretary of Commerce for Export Administration shall be deemed to be a reference to the Under Secretary of Commerce for Industry and Security. 
  (b) TITLE 5. — Section 5314 of title 5, United States Code, is amended by striking ”Under Secretary of Commerce for Export Administration” and inserting ”Under Secretary of Commerce for Industry and Security”.
  (c) CONTINUATION IN OFFICE. — The individual serving as Under Secretary of Commerce for Export Administration on the day before the date of the enactment of this Act may serve as the Under Secretary of Commerce for Industry and Security on and after that date without the need for renomination or reappointment.

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

MS_a114. Monday List of Ex/Im Job Openings: 200 Openings Posted This Week, Including 38 New Openings

(Source: Editor) 
 

Published every Monday or first business day of the week. Please, send job openings in the following format to 
jobs@fullcirclecompliance.eu
.

 
* COMPANY; LOCATION; POSITION TITLE (WEBLINK); CONTACT INFORMATION; REQUISITION ID
 

#
” New or amended listing this week

* Aerojet Rocketdyne; Huntsville, AL; 
International Trade and Compliance Specialist;

* Aerojet Rocketdyne; Camden, AR;
International Trade and Compliance Specialist;
 
* Aerojet Rocketdyne; Canoga Park, CA; 
Manager, Industrial Security & Compliance
;

* Agility; Atlanta, GA; Ocean Import Coordinator

* Agility; Bensenville, IL; Ocean Export Coordinator;


Agility; Basel, Switzerland; 
International Exhibition Coordinator
 

* Agility; East Boston, MA; 
Customs/Entry Writer Coordinator


Agility; Houston, TX; 
Air Freight Export Account Executive;

* Agility; Queens, NY; Air Export Coordinator;
* Agility; Queens, NY; Air Export Coordinator;

* Albemarle Corporation; Baton Rouge, LA; Logistics Specialist – Trade Compliance and Marine Specialist

*
 Alcoa Group; Knoxville, TN;
Trade Compliance Administrator
;

* Amazon; Seattle, WA; Head, Global Trade and Product Compliance
;
* Amazon; Seattle, WA;
 
Global Trade Compliance Analyst;

*
Amazon; Seattle, WA; US Export Compliance PM;

* Arrow; Shanghai, China; Compliance Manager;

*
Augusta Westland; Philadelphia, PA;
Manager, Import Export
;

* BAE
 Systems; Kingsport, TN; 
Government Compliance Manager
; Requisition ID: 41212BR

* BAE Systems; Rockville, MD; Compliance Specialist Senior; Requisition ID: 35809BR
* BAE Systems; Sterling, VA; Compliance Specialist Senior; Requisition ID: 36370BR

* Boeing; Dallas, TX; 
Global Regulatory and Compliance Specialist 4
; Requisition ID: 12795

* Boeing; Englewood, CO;
Compliance Specialist 4
; Requisition ID: 1268;

* Boeing; Manassas, VA; 
Export Control Manager
; Requisition ID: 1900

Boeing; Saint Louis, MO;
Trade Control Specialist
; Requisition ID: 1800068012
* Boeing; Zoushan, China; 
 Compliance Analyst
* Boeing; Zoushan, China;
Trade Compliance Manager;

CGI, Fairfax, VA; 
Trade Compliance Analyst/Manager
Requisition ID: J0818-1218

Cinemark; Plano, TX; 
Import Export Purchasing Analyst
 

Cobham; Lansdale, PA; Export Compliance Officer; Ali Neice Alicia.Neice@yoh.com; Requisition ID 1611

* Cree, Inc.; Durham, NC; Export Compliance Specialist
Contact asignorelli@cree.com;
Requisition ID: 2018-630
0

* Destaco; Auburn Hills, MI; 
Manager, Global Compliance
; Clenetta Frazier; 
cfrazier@destaco.com
; Requisition ID:  16261


* Disney Parks & Resorts; Kissimmee, FL;
Senior Manager, Trade Compliance
; Requisition ID: 552655BR;

* The Dow Chemical Company; Drusenheim, France; International Trade Compliance Specialist; Requisition ID: 
1805345

DuPont; Wilmington, DE;
Trade Compliance Leader
; Requisition ID: 196737W-01

*
 DynCorp International; Tampa, FL; Foreign Disclosure Officer; Requisition ID: PR1701977

* Eaton; Hungary; Manager Global Trade Management EMEA – Imports (in any EMEA location)Requisition ID: 052687

* Eaton; Multiple Locations: Cleveland, Ohio; Moon Township, Pennsylvania; Eden Prairie, Minnesota; Peachtree City, Georgia; Galesburg, Michigan; Manager, Supply Chain Governance, Risk & ComplianceRequisition ID: 054321

* Eaton; Syracuse, NY; Global Logistics Manager; Requisition ID: 036620 

Embraer; Fort Lauderdale, FL;
Compliance Specialist II
; Requisition ID: 170685;
* Ensign-Bickford Aerospace & Defense Co.; Moorpark, CA;
Import/Export Specialist; Missy Clark;
maclark@eba-d.com;
* EoTech Technologies; Ann Arbor, MI; Trade Compliance Manager; Requisition ID: 092335 

*
 Expeditors; Krefeld, Germany; 
Clerk Import / Export
;
*
 Expeditors; Bedfont, United Kingdom;
Customs Brokerage Clerk
;

* Expeditors; Bedfont, United Kingdom; 
District Trade Compliance Manager
;
* Expeditors; Detroit, MI; US Export Compliance Consultant;
* Expeditors; Dublin, IE; Consultant – Customs and Trade Compliance;
* Expeditors; Dusseldorf, Germany; Clerk, Airfreight Import;

*
 Expeditors; Krefeld, Germany; 
Clerk, Airfreight Import
; 
* Expeditors; Plainfield, IN; District Trade Compliance Manager;
* Expeditors; Sunnyvale, CA, USA; Customs Compliance Coordinator;
* Expeditors; Sunnyvale, CA, USA; Customs Compliance Specialist;
* Expeditors; Stockholm, SE; District Trade Compliance Manager;


* Export Solutions Inc.; Melbourne FL; 
Trade Compliance Specialist
;
info@exportsolutionsinc.com

Exterran; Houston, TX; 
Trade Control Manager
;

* Flash Global; Mountain Lakes, NJ;
Import and Export Specialist;

* FLIR; Billerica, MA; US Customs Analyst
; 

* FLIR; Meer, Belgium; GTC EMEA Customs Analyst;
* FLIR; Irving, CA; 
Sr. Manager Export Compliance;

* FLIR; Nashua, NH; 
Global Trade Compliance Analyst, Traffic
;
 
*
 FLIR; Billerica, MA;
Global Trade Compliance Analyst, Licensing
;
* Full Circle Compliance; Bruchem, Netherlands;
Legal Analyst, Manager

* General Atomics; San Diego, CA;
Director, Compliance
; Requisition ID: 18549BR

* General Atomics; San Diego, CA;
Associate Compliance Specialist
; Requistion ID: 19856BR;
* General Atomics; San Diego, CA;
Government Compliance Specialist
; Requisition ID: 19499BR;

* General Atomics; San Diego, CA; 
Import/Export Trade Compliance Administrator – Licensing
Requisition ID: 17968BR

* General Atomics; San Diego, CA; Senior Director of Import/Export Compliance; Requisition ID: 13892BR

* General Atomics; San Diego, CA;
Senior Government Compliance Specialist
; Requisition ID: 19500BR;

* General Electric; Ft Worth TX, Chicago IL, or Erie, PA; 
Senior Project Manager, Customs & Brokerage, Transportation
; Requisition ID: 3134046

* General Electric; Lynn, MA;
Senior Export Control Specialist, Aviation
; Requisition ID: 3146429

* GHY International; Pembina, ND (or remote); Ocean & Air Import Coordinator;
* Harris Corporation; Van Nuys, CA; Trade Compliance Senior Specialist; Requisition ID: ES20180706-25145

* Henderson Group Unlimited; Inc; Washington, DC; 
Defense Control Analyst

* Henkel Corp.; Rocky Hill, CT;
Global Trade Defense Information Manager; Requisition ID: 
180002QT

* Honeywell International Inc.; Sunnyvale, CA or Lincolnshire, IL; Sr. Import/Export Analyst; HRD32371

* Infineon Technologies; Milpitas, CA;
Export Compliance Specialist; Requisition ID: 26988
* Infineon Technologies; Munich, Germany; Manager Export Control;
* Infineon Technologies; Munich, Germany; Specialist Export Control;

*
 InteliTrac Global Solutions; Herndon, VA; 
ITAR Compliance Official / Deputy Facility Security Officer
;

*
 InteliTrac Global Solutions; Herndon, VA;
ITAR Compliance Official
;


IPG Photonics; Oxford, MA; Global Director Trade Compliance;

* Johnson Controls; Boca Raton, FL; Licensing Coordinator; Requisition ID: 
WD30047852135
* Johnson Controls; Boca Raton, FL; Licensing Coordinator; Rquisition ID: 
WD30047853135
* Johnson Controls; Milwaukee, WI; Trade Compliance Analyst; Requisition ID: WD30047348124
* Johnson Controls; Tamaulipas, Matamoros, Mexico; Trade Compliance Specialist; Requisition ID: EB00064420180


Kohls; Menomonee Falls, WI; Senior Manager, Customs Compliance

* Komatsu; Milwaukee, WI; Senior International Trade Compliance AnalystRequisition ID: 12728

* Lam Research Corp.; Shanghai, China; 
Foreign Trade (FT) Analyst;
 

* Leonardo DRS; Arlington, VA; 
Trade & Compliance Director

Requisition ID: 91287
* Leonardo DRS; Cypress, CA; 
Contracts & Compliance Manager
; Requisition ID: 91594
* Leonardo DRS; Dallas, TX; 
 Contracts & Compliance Administrator
; Requisition ID: 91611
* Leonardo DRS; Dallas, TX; 
Contracts & Compliance Manager
; Requisition ID: 91608
* Leonardo DRS; Melbourne, FL; 
Senior Manager Contract and Compliance
; Requisition ID: 90731
* Leonardo DRS; Melbourne, FL; 
Senior Supply Chain Analyst – Small Business Compliance
; Requisition ID: 91669

* Leonardo DRS; St. Louis;
Trade Compliance Specialist
; Requisition ID: 88127, or contact 
brandy.mormino@drs.com 

* Lincoln Electric; Cleveland, OH; 
Trade Compliance Manager;

Livingston; Alberta, Canada; 
Senior Customs & Trade Advisor

Livingston; CA; 
Import Analyst; 
Requisition ID: 60988

Livingston; CA; 
Import Specialist; 
Requisition ID: 57981

Livingston; CA; 
Import Specialist; 
Requisition ID: 59161

Livingston; CA; 
Import Specialist; 
Requisition ID: 60644

Livingston; FL; 
Import Analyst; 
Requisition ID: 59941

Livingston; GA; 
Import Specialist; 
Requisition ID: 61165

Livingston; IL; 
Import Specialist; 
Requisition ID: 60803

Livingston; IL; 
Import Specialist; 
Requisition ID: 60905

Livingston; IL; 
Client Import Analyst; 
Requisition ID: 60963

Livingston; IL; 
Client Import Analyst; 
Requisition ID: 60964

Livingston; IL; 
Client Import Analyst; 
Requisition ID: 60965

Livingston; Itasca, IL; 
Release Customs Analyst; 
Requisition ID: 61950

Livingston; Itasca, IL; 
Release Customs Analyst; 
Requisition ID: 61951

Livingston; Itasca, IL; 
Release Customs Analyst; 
Requisition ID: 61952

Livingston; NY; 
Client Import Analyst; 
Requisition ID: 57421

Livingston; NY; 
Client Import Analyst; 
Requisition ID: 61123

Livingston; NY; 
Import Specialist; 
Requisition ID: 61221

Livingston; NY; 
Release Customs Analyst; 
Requisition ID: 61508

Livingston; NY; 
Release Customs Analyst; 
Requisition ID: 61509

Livingston; NY; 
Release Customs Analyst; 
Requisition ID: 61513

Livingston; NY; 
Release Customs Analyst; 
Requisition ID: 61518

Livingston; OH; 
Import Analyst; 
Requisition ID: 60702

Livingston; Ontario, Canada; 
Release Classification Analyst; 
Requisition ID: 61613;

Livingston; TX; 
Release Customs Analyst; 
Requisition ID: 60993

Livingston; TX; 
Release Customs Analyst; 
Requisition ID: 61282

Livingston; TX; 
Release Import Analyst; 
Requisition ID: 60867

Livingston; VA; 
Import Specialist; 
Requisition ID: 61541

Livingston; VT; 
Release Customs Agents; 
Requisition ID: 61121

* Lockheed Martin; Arlington, VA; 
International Trade Compliance Engineer
; Job ID: 439787BR

* Lockheed Martin; Arlington, VA; 
Senior International Licensing Analy
st; ID: 
438635BR
* Lockheed Martin; Arlington, VA; 
International Trade Compliance Engineer
; ID: 
439787BR

* Lockheed Martin; Fort Worth, TX; Export and Import Compliance Investigations Lead; Job ID: 427872BR

* Lockheed Martin; Fort Worth, TX; 
Regulatory Compliance Analyst
; Job ID: 439674BR

* Lockheed Martin; Fort Worth, TX;
Regulatory Compliance Analyst Senior
; Requisition ID: 433405BR  

*
Lockheed Martin; Littleton, CO;
Supply Chain Management Compliance Analyst
; Requisition ID: 440613BR

* Lockheed Martin; Orlando, FL; 
Senior International Licensing Analyst
; Requisition ID: 
434225BR 
* Lockheed Martin; Orlando, FL; 
International Trade Compliance Manager; 
Job ID: 439904BR 
* Lockheed Martin; Stratford, CT; 
 Compliance Auditor
; Job ID; 434724BR


* Luminar Technologies; Orlando, FL;
Import/Export Trade Compliance Specialist
;

* L-3 Warrior Sensor Systems; Londonderry, NH; Purchasing & Compliance Manager; Requisition ID:096596
*
 L-3 Warrior Sensor Systems; Middle East;
International Business Development Manager – Middle East Region
; Requisition ID: 093343
* L-3; Ann Arbor, MI; Trade Compliance Manager; Requisition ID: 092335
* Maersk/DAMCO; Agent de transit IMPORT – EXPORT; Job Ref.: DC-164022
* Medtronic; Heerlen, The Netherlands;
Trade Compliance Analyst
; Requisition ID: 16000DYY

Medtronic; Minneapolis, MN;
Trade Compliance Program Manager
; Requisition ID: 18000BJW;

* Medtronic; Wash DC;
Global Trade Lawyer
;
stacy.m.johnson@medtronic.com
; Requisition ID: 170002ON

* Meggit; Akron, OH;
Senior Manager Trade Compliance;

* Mercury Systems; Andover, MA; International Trade Compliance Director; Requisition ID: 18-165
* Mitchell Martin, Inc.; Dallas, Texas;
Export Regulatory Trade Compliance Specialist
; Requisition ID: 104405

* Muscogee International, LLC; Washington, D.C.;
DDTC Compliance Specialist II; Apply
HERE or contact their
recruiting team.

* Muscogee International, LLC; Washington, D.C.;
DDTC Policy Analyst
Apply 
HERE
 or contact their 
recruiting team
.
* Muscogee International, LLC; Washington, D.C.; 
DDTC Records Auditor
Apply HERE or contact their recruiting team. 
* Muscogee International, LLC; Washington, D.C.; DDTC Contract AnalystApply HERE or contact their recruiting team.

* Muscogee International, LLC; Washington, D.C.; 
DDTC Service Support Desk Lead
Apply 
HERE
 or contact their 
recruiting team
.
* Muscogee International, LLC; Washington, D.C.; 
DDTC Service Support Desk
Apply HERE or contact their recruiting team. 
* Muscogee International, LLC; Washington, D.C.; DDTC Office Support IApply HERE or contact their recruiting team.
* Muscogee International, LLC; Washington, D.C.; DDTC Office Support IIApply HERE or contact their recruiting team.

* Muscogee International, LLC; Washington, D.C.; DDTC Office Support IIIApply HERE or contact their recruiting team.

*
Netflix; Los Angeles, CA;
Manager, Trade Compliance
;

* Northrop Grumman; Baltimore, MD; 
International Trade Compliance Analyst (level 2 or 3)- Import
; Requisition ID: 18013545
* Northrop Grumman; Baltimore, MD; 
International Trade Compliance Analyst (level 2 or 3)- Import
; Requisition ID: 18014715

* Northrop Grumman; Herndon, VA;
Manager, International Trade Compliance 2; Requisition ID: 18010381

* Northrop Grumman; Herndon, VA;
Manager, International Trade Compliance 2

Requisition ID

17022803
 
 

*
 Northrop Grumman; Herndon, VA;
Manager, International Trade Compliance 2
; Requisition ID: 17022805
* Northrop Grumman; Herndon, VA; International Trade Compliance Analyst 3; Requisition ID: 18007859
* Northrop Grumman; McLean, VA; International Trade Compliance Analyst 3; Requisition ID: 18012973

* Office of the Director of National Intelligence; McLean, VA;
Associate General Counsel
;

* Optics 1; Bedford NH, Senior Trade Compliance Administrator

* Oshkosh Corporation; Greenville, WI; Senior Global Trade Compliance Analyst – Licensing; ID: 
183273

* PerkinElmer, Inc.; Shelton, CT;
Systems Analyst, Trade Compliance Solutions;

* Raytheon; Billerica, MA;
Import Ctl&Compliance Advisor
; Requisition ID:
119749BR

* Raytheon; Billerica, MA; 
Mgr I Export-Import Control
; Requisition ID: 
118298BR

* Raytheon; El Segundo, CA; 
Import Control and Compliance Advisor
; APPLY Requisition ID 119247BR

* Raytheon; El Segundo, CA; Manager III, Global Trade Licensing; Requisition ID: 117235BR 
* Raytheon; El Segundo, CA; Fullerton, CA; Goleta, CA; Aberdeen, MD; Plano, TX; McKinney, TX; Principal Analyst, Global Trade Licensing; Requisition ID: 117247BR

* Raytheon; Tucson, AZ; Export Licensing And Compliance Specialist; Requisition ID: 114936BR  

Raytheon; Tucson, AZ; 
Import Ctl&Compliance Advisor
; Requisition ID:
119749BR

* Raytheon; Woburn, MA; 
Global Trade Export Licensing & Compliance Advisor
Requisition ID:
117939BR
* Raytheon; Woburn, MA; Supply Chain Compliance Advisor; Requisition ID:
115557BR

*
 SABIC; Houston TX; 
Senior Analyst, Trade Compliance
;
Danielle.Cannata@sabic.com
; Requisition ID: 8411BR


Thales; Cambridge, UK; 
Trade Compliance Officer
; Krista Helvey; Requisition ID R0034820;

Thales; Cambridge, UK; 
Trade Compliance Support Officer
; Krista Helvey; Requisition ID R0034813;

Thales; Various Locations, UK; 
Trade Compliance Analyst
; Requisition ID: R0035062;

* The Safariland Group; Jacksonville, FL; Counsel (International Trade Compliance)
* The Safariland Group; Jacksonville, FL; Sr. Export Compliance Specialist;

Spirent; Calabasas, CA;
Global Trade Compliance Specialist
; Requisition ID: 4088;

*
TLR; San Fransisco, CA;
Import CSR
; Requisition ID: 1040


Toro; Bloomington, MN; 
Import – Export Compliance Manager

* United Technologies – Pratt & Whitney; East Hartford, CT; 
International Trade Compliance Authorization Manager
; Requisition ID: 63222BR

* Varian; Paolo Alto, CA; Senior Trade Compliance Analyst; Requisition ID: 12735BR; Contact 
Uyen Tran at
Uyen.Tran@varian.com
* Varian; Paolo Alto, CA; 
Trade Compliance Analyst; 
Requisition ID: 
13097BR;

* Vigilant; Negotiable Location, USA;
Global Trade Compliance Analyst
;

* Vigilant; Negotiable Location, USA;  
Global Trade Account Manager
;

* Virgin Galactic; Las Cruces, NM; Export Compliance Officer; Requisition ID: 2018-3558

* World Wide Technology; Edwardsville, IL;
International Trade Compliance Specialist
;

* Xylem, Inc.; Bangalore, Karnataka, IndiaThird Party Contract & Compliance Coordinator;

* Xylem, Inc; Morton Grove, IL; 
Trade Compliance Specialist 

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

TECEX/IM TRAINING EVENTS & CONFERENCES

TEC_a115. 
FCC to Present U.S. Export Controls Awareness Training Course for Non-U.S. Organizations, 2 Oct in Bruchem, the Netherlands

(Source: Full Circle Compliance, events@fullcirclecompliance.eu.)
 
Our next academy course is specifically designed for beginning compliance officers and professionals who want to enhance their knowledge on the latest ITAR/EAR requirements and best practices.  The course will cover multiple topics regarding U.S. export controls that apply to organisations outside the U.S., such as: the regulatory framework, including the latest and anticipated regulatory amendments, key concepts and definitions, classification and licensing requirements, handling (potential) non-compliance issues, and practice tips to ensure compliance with the ITAR and EAR.
 
* What: Awareness Course U.S. Export Controls: ITAR & EAR From a Non-U.S. Perspective 
* When: Tuesday, 2 Oct 2018, 9 AM – 5 PM (CEST)
* Where: Landgoed Groenhoven, Bruchem, the Netherlands
* Sponsor: Full Circle Compliance (FCC)
* Instructors: Ghislaine Gillessen, Mike Farrell, and Alexander P. Bosch 
* Information & Registration: HERE or via events@fullcirclecompliance.eu

Register today and get a 10% Early Bird discount on the course fee!

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

ENEDITOR’S NOTES

John Dryden (19 Aug 1631 – 12 May 1700; was an English poet, literary critic, translator, and playwright who was made England’s first Poet Laureate in 1668.)
  – “We first make our habits, and then our habits make us.”
  – “
The sooner you treat your son as a man, the sooner he will be one.
 
Monday is Pun Day!
 
* I used to be a demolition expert – it was a blast!
* An anesthesiologist is a real knock-out.
* They come from a long line of bakers. They’re inbred.

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

EN_a317
. 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)
 
DOD NATIONAL INDUSTRIAL SECURITY PROGRAM OPERATING MANUAL (NISPOM): DoD 5220.22-M

  – 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 
here
.)


EXPORT ADMINISTRATION REGULATIONS (EAR)
: 15 CFR Subtit. B, Ch. VII, Pts. 730-774

  – 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 

 
*
FOREIGN TRADE REGULATIONS (FTR)
: 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
here.
  – 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.  
 
*
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: 14 Aug 2018: Harmonized System Update 1812, containing 27 ABI records and 6 harmonized tariff records.
 

  – HTS codes for AES are available 
here.
  – HTS codes that are not valid for AES are available 
here.
 
INTERNATIONAL TRAFFIC IN ARMS REGULATIONS (ITAR): 22 C.F.R. Ch. I, Subch. M, Pts. 120-130.

  – 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
 
website
. BAFTR subscribers receive a 25% discount on subscriptions to the BITAR, please
contact us

to receive your discount code.  

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

EN_a0318
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 
here

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

EPEDITORIAL POLICY

* 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, Alex Witt. 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.


* SUBSCRIPTIONS: Subscriptions are free.  Subscribe by completing the request form on the Full Circle Compliance website

* BACK ISSUES: An archive of Daily Bugle publications from 2005 to present is available HERE.

* TO UNSUBSCRIBE: Use the Safe Unsubscribe link below.

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