18-1217 Monday “Daily Bugle'”

18-1217 Monday “Daily Bugle”

Monday, 17 December 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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[No items of interest noted today.]

  1. Items Scheduled for Publication in Future Federal Register Editions
  2. Commerce/BIS: (No new postings.)
  3. DHS/OIG: “CBP’s Searches of Electronic Devices at Ports of Entry”
  4. Justice: “Former Florida CEO Pleads Guilty To Export Violations And Agrees To Pay Record $17 Million To Department Of Commerce”
  5. State/DDTC: (No new postings.)
  6. EU Commission Decisions of Interest
  1. Expeditors News: “Manifest Required for Section 321 Truck Shipments in January”
  2. The New York Times: “Trump’s Push for Trade Win Could Undermine Sanctions Enforcement”
  3. Reuters: “Czech Cyber Watchdog Calls Huawei, ZTE Products a Security Threat”
  4. ST&R Trade Report: “China Tariff Hike Delay Formalized; Beijing to Lower Import Duties on U.S. Autos”
  1. G.R. Tuttle III: “TFTEA Drawback Claims Accelerated Payment Processing Regulations Are Now Effective”
  2. M. Volkov: “Episode 69 – Update on DOJ Corporate Enforcement Policies”
  3. T. McBride: “OFAC Dings U.S. Defense Contractor for Sanctions Violations, Inadequate Screening”
  1. Monday List of Ex/Im Job Openings: 155 Openings Posted This Week, Including 37 New Openings
  1. ECTI Presents United States Export Control (ITAR/EAR/OFAC) Seminar Series in Orlando, FL
  2. FCC Presents “Designing an Internal Compliance Program for Export Controls & Sanctions”, 5 Feb 2019 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 (29 Nov 2018), DOD/NISPOM (18 May 2016), EAR (2 Nov 2018), FACR/OFAC (15 Nov 2018), FTR (24 Apr 2018), HTSUS (1 Nov 2018), ITAR (4 Oct 2018) 
  3. Weekly Highlights of the Daily Bugle Top Stories 



[No items of interest noted today.]

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

* DHS/CBP; RULES; Modernized Drawback [Pub. Date: 18 Dec 2018.]

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Commerce/BIS: (No new postings.)


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 DHS/OIG: “CBP’s Searches of Electronic Devices at Ports of Entry”

DHS/OIG, 3 Dec 2018.) 
The Department of Homeland (DHS) Security’s Office of Inspector General (OIG) assessed the policies and procedures used by CBP in searching electronic devices (laptops and mobile phones mostly) of persons crossing the border into the United States. To read its findings, click 

[Editor’s Note: as pointed out by Gray Robinson’s Peter Quinter (
peter.quinter@gray-robinson.com) and Vince Draa, (
vince.draa@grainger.com), according to the Electronic Frontier Foundation, the January 4, 2018 CBP Directive on ”
Border Search of Electronic Devices” still violates the 4th Amendment prohibiting unconstitutional searches and seizures. The Federal case of Alasaad v. Nielsen provides an analysis for those interested in the conflict between digital privacy and border search authority.] 

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Justice: “Former Florida CEO Pleads Guilty To Export Violations And Agrees To Pay Record $17 Million To Department Of Commerce”

Justice, 14 Dec 2018.) [Excerpts.] 
Eric Baird, the former owner and Chief Executive Offer (CEO) of a Florida-based package consolidation and shipping service, has pleaded guilty to one count of felony smuggling and admitted to 166 administrative violations of U.S. export control laws as part of a global settlement with the U.S. Department of Justice (DOJ) and the U.S. Department of Commerce’s Bureau of Industry and Security (BIS).  
On December 12, 2018, Baird’s criminal plea was accepted by a federal judge in the U.S. District Court for the Middle District of Florida, and BIS issued an Order outlining the administrative violations and imposing civil penalties of $17 million, with $7 million suspended, and a 5-year denial of export privileges, of which one year is suspended.  The civil penalty is the largest to be paid by an individual in BIS history. In February 2017, Access USA settled with BIS and agreed to an administrative civil penalty of $27 million, with $17 million suspended. 
As part of the administrative settlement, Baird admitted to violations of the Export Administration Regulations committed from August 1, 2011, through January 7, 2013, during his tenure as CEO of Access USA Shipping, LLC d/b/a MyUS.com (“Access USA”). Baird founded Access USA and developed its business model, which provided foreign customers with a U.S. address that they used to acquire U.S.-origin items for export without alerting U.S. merchants of the items’ intended destinations.  Under Baird’s direction, Access USA developed practices and policies which facilitated concealment from U.S. merchants.  Access USA would regularly change the values and descriptions of items on export documentation even where it knew the accurate value and nature of the items. Among the altered descriptions were some for controlled items listed on the Commerce Control List (CCL).  For example, laser sights for firearms were described as “tools and hardware,” and rifle scopes were described as “sporting goods” or “tools, hand tools.” 
Additionally, Baird established and/or authorized Access USA’s “personal shopper” program.  As part of this program, Access USA employees purchased items for foreign customers from a shopping list while falsely presenting themselves to U.S. merchants as the domestic end-users of the items.  In some cases, Baird directed or authorized Access USA employees to use his personal credit card information, and in others Baird personally asked Access USA employees to apply for and use personal credit cards of their own to make such purchases and have the items sent to their personal addresses.  As a result, in addition to being misled to believe that a domestic customer and end-user was involved when the items were in fact intended for export, the U.S. merchant would be misled to believe that Access USA itself was not involved in the transaction.  
The activities that Baird knowingly authorized and/or participated in resulted in unlicensed exports of controlled items to various countries, as well as repeated false statements on Automated Export System (AES) filings.  As early as September 2011, Baird was made aware that undervaluing violated U.S. export laws, including the EAR.  In fact, Baird received e-mails on this subject from his Chief Technology Officer, who stated, “I know we are WILLINGLY AND INTENTIONALLY breaking the law.”  (Emphasis in original).  In the same email chain, Baird suggested that Access USA could falsely reduce the value of items by 25% on export control documentation submitted to the U.S. government and if “warned by [the U.S.] government,” then the company “can stop ASAP.”
  “It was through the outstanding investigative skills and dedication of the special agents of the Department of Commerce and the Department of Homeland Security, that enabled us to protect our country’s national security by detecting, disrupting and prosecuting a complex illegal export scheme led by Access USA’s former owner and CEO, Eric Baird.  The message must be received that individuals, as well as companies, are equally liable for their illegal activities,” said BIS Special Agent-in-Charge Robert Luzzi. “BIS brought this action because of the serious potential harm to national security inherent in a business model where companies consolidating or forwarding packages abroad conceal from U.S. merchants the location of foreign customers and the fact that items are intended for export. As a result of these deceptive practices, U.S. merchants’ compliance programs may be unable to detect potential unlicensed exports and other violations.”
  “We expect companies and individuals to adhere to our nation’s strict import and export laws,” said U.S. Attorney Chapa Lopez. “Shipping and freight forwarding companies must take sufficient steps to ensure that they are always in compliance with United States law, in order to protect our borders and prevent potentially dangerous items from reaching the hands of our adversaries.” … 

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State/DDTC: (No new postings.)


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EU Commission Decisions of Interest 

Official Journal of the European Union, 17 Dec 2018.)

Commission Decision (EU) 2018/1996 of 14 December 2018 laying down internal rules concerning the provision of information to data subjects and the restriction of certain of their rights in the context of the processing of personal data for the purpose of trade defense and trade policy investigations.

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Expeditors News: “Manifest Required for Section 321 Truck Shipments in January” 

Expeditors News, 14 Dec 2018.)
On January 1, 2019, U.S. Customs and Border Protection (CBP) will require all commercial truck shipments containing Section 321 merchandise to file an advance electronic manifest according to Cargo Systems Messaging Service (CSMS) #18-000731.
The advance electronic manifest will require a four letter Standard Carrier Alpha Code (SCAC) issued by the National Motor Freight Traffic Association.
CBP lists three ways for an importer to file the manifest:
  (1) Apply for a free ACE Portal carrier account for filing online directly to CBP; 
  (2) Contract with a third-party software vendor or manifest filing service; or
  (3) Develop software to file directly with CBP.
CBP provides additional links for assistance on each of the above three options, which may be found 

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New York Times: “Trump’s Push for Trade Win Could Undermine Sanctions Enforcement”

The New York Times, 14 Dec 2018.) [Excerpts.] 
President Trump suggested that he would be willing to intervene in an effort to extradite and prosecute Meng Wanzhou, a senior executive at Huawei, if it would help gain trade concessions from China. 
When President Trump suggested that he may intervene in the arrest of a Chinese tech executive, he was seeking to leverage her case into a win on trade. But law enforcement officials say the president’s comments could ultimately undermine America’s ability to enforce tough sanctions on Iran and other rogue nations.
Mr. Trump threw himself into the middle of a diplomatic crisis on Tuesday by indicating that he may stop an effort to extradite and prosecute Meng Wanzhou, a top executive at the telecommunications giant Huawei who was arrested in Canada on Saturday on suspicion of fraud related to Iran sanctions, if it would help secure trade concessions from China. … 

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Reuters: “Czech Cyber Watchdog Calls Huawei, ZTE Products a Security Threat”
Reuters, 17 Dec 2018.) 
The Czech cyber watchdog warned network operators on Monday against using software or hardware made by Chinese telecom equipment suppliers Huawei and ZTE, saying they posed a security threat.
Huawei, the world’s biggest producer of telecoms equipment, faces intense scrutiny in the West over its ties to the Chinese government and concerns its equipment could be used by Beijing for spying. The company has repeatedly denied the allegations.
  “China’s laws … require private companies residing in China to cooperate with intelligence services, therefore introducing them into the key state systems might present a threat,” Dusan Navratil, director of the Czech National Cyber and Information Security Agency (NCISA), said in a statement.
System administrators in critical information infrastructure, whether in the state or private sector, should take “adequate measures” against the threat, Navratil said.
The Czech government agency added that its warning notice was based on its findings and on those of allies.
In response, a Huawei spokesman said: “We categorically deny any suggestion that we pose a threat to national security. We call for NCISA to provide evidence instead of tarnishing Huawei’s reputation without any proof.”
Cyber security had always been Huawei’s top priority and Huawei was a trusted partner for all the main telecom carriers in Czech Republic, he said.
  “There are no laws or regulations in China to compel Huawei, or any other company, to install ‘mandatory back doors’,” he said, a reference to U.S. warnings that Huawei’s network gear could contain ‘back doors’ that would allow Chinese spies to hack into critical network infrastructure.
“Huawei has never received any such request from any government and we would never agree to it,” the spokesman said.
A call to ZTE’s office in London was not answered.
Some operators have tested 5G in some locations in the Czech Republic, while the investment group PPF, which owns the leading infrastructure provider, CETIN, has signed a memorandum of understanding with Huawei to cooperate on 5G. An auction of frequencies for the 5G transmission is planned for 2019.
U.S. government officials have been pressuring Deutsche Telekom, the majority owner of T-Mobile US, to stop using Huawei equipment, sources say.
Japan plans to ban government purchases of equipment from Huawei and ZTE to beef up its defenses against intelligence leaks and cyber attacks, sources told Reuters this month.
New Zealand’s intelligence agency last month rejected a telecoms provider’s request to use Huawei 5G equipment and Australia has banned Huawei from supplying 5G equipment. Both countries cited national security concerns.
The arrest of a top Huawei executive in Vancouver at the request of U.S. authorities on Dec. 1 has sparked a diplomatic dispute. Meng Wanzhou, Huawei’s chief financial officer and the daughter of its founder, faces U.S. allegations that she misled multinational banks about Iran-linked transactions, putting the banks at risk of violating U.S. sanctions.

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ST&R Trade Report: “China Tariff Hike Delay Formalized; Beijing to Lower Import Duties on U.S. Autos” 

Sandler, Travis & Rosenberg Trade Report, 17 Dec 2018.)
A planned increase from 10 percent to 25 percent in the Section 301 additional tariff on $200 billion worth of imports from China is being delayed from Jan. 1 to March 2. At the same time, China has announced plans to suspend a higher duty on U.S. automobiles and auto parts and to increase purchases of U.S. soybeans and corn. (Click 
herefor more details on these and other developments in the U.S. Section 301 case against China.)
During a meeting earlier this month, President Trump and Chinese President Xi Jinping agreed to various measures to create a more favorable environment for negotiations on what the White House called “structural changes with respect to forced technology transfer, intellectual property protection, non-tariff barriers, cyber intrusions and cyber theft, services and agriculture.” The two sides said they would work to complete such talks within 90 days; if no agreement is reached within that time, the 10 percent additional tariff currently in place on so-called List 3 items from China will be increased to 25 percent.
The Office of the U.S. Trade Representative published on its web site Dec. 14 a formal notice of the tariff increase delay that is expected to be published in the Federal Register in the coming days. As a result, U.S. Customs and Border Protection should be able to quickly make the necessary changes in the Automated Commercial Environment to ensure that the additional tariff does not increase to 25 percent until 12:01 a.m. on March 2. As a result, Sandler, Travis & Rosenberg’s Tom Gould said, there is less need for importers to consider electing the arrival date as the entry date for shipments due to arrive in the coming weeks.
For its part, China appears to have begun to implement a commitment to purchase a “very substantial” amount of agricultural, energy, industrial, and other products from the U.S. to reduce its trade surplus with the U.S. This includes reported commitments to buy more than one million tons of U.S. soybeans and possibly another three million tons of U.S. corn.
Further, China has reportedly said it will roll back from 40 percent to 15 percent its tariffs on automobiles and auto parts imported from the U.S. for three months, starting Jan. 1. That move would essentially suspend the tariff increase Beijing imposed earlier this year in retaliation for a U.S. tariff hike on $34 billion worth of goods from China.

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G.R. Tuttle III: “TFTEA Drawback Claims Accelerated Payment Processing Regulations Are Now Effective”

(Source: Tuttle Law Newsletter, 17 Dec 2018.) [Available by subscription via 
* Author: George R. Tuttle, III is an attorney with the Law Offices of George R. Tuttle in the San Francisco Bay Area.
Today in 
CSMS #18-000737, CBP announced that the Modernized Drawback Final Rule has been posted online for public inspection and that the regulations necessary for CBP to begin processing payments for Accelerated Payment (AP) on 
Trade Facilitation and Trade Enforcement Act 
(TFTEA) drawback claims are now effective. The final rule [to be published in tomorrow’s Federal Register, ed.] can be viewed 
CBP is returning certain TFTEA drawback claims to trade control in anticipation that these claims will be resubmitted with a request for AP.
Below lists the process for resubmitting TFTEA drawback claims with a request for AP:
  (1) TFTEA claims with bond information on file will be placed in trade control.
  (2) The filer will select the AP indicator.
  (3) The filer will resubmit the claim.
Resubmission will not change the original claim date, and claimant must have the appropriate approved privileges on file. Upon claim acceptance by CBP, AP processing will take place generally within 3 weeks of the claim resubmission date.
If a TFTEA claim with 1A bond data was accepted by CBP prior to December 17, 2018 and the claim is not returned to trade control as noted above, claimant should email the claim number to the OT mailbox – 
Certain claims require additional steps to request AP as outlined below:
  (1) TFTEA manufacturing claims – Trade must update claims on file with the new manufacturing ruling number after receiving an approval letter for TFTEA modification from CBP. Once the claims are updated with the new ruling number, claimants should select the AP indicator and resubmit the claim.
  (2) TFTEA substitution drawback claims potentially subject to limitations on internal revenue tax refunds (accounting class code 365) – Trade is advised not to submit additional AP claims with the accounting class code 365 until notified by CBP to do so. If an AP claim is submitted prior to notification from CBP to do so, there is a risk of bond decrementation and loss of AP for the life of the claims. The above guidance regarding TFTEA substitution claims with class code 365 does not apply to the Oil Spill Tax and the Harbor Maintenance Tax.

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M. Volkov: “Episode 69 – Update on DOJ Corporate Enforcement Policies”

Volkov Law Group Blog, 16 Dec 2018. Reprinted by permission.) 
* Author: Michael Volkov, Esq., Volkov Law Group, 
mvolkov@volkovlaw.com, 240-505-1992. 
The Department of Justice (DOJ) has announced a number of modifications to its policies governing prosecution of corporations for criminal and civil violations of law.  In 2017, DOJ announced its FCPA Corporate Enforcement Policy.  Over the last year, DOJ expanded this policy to apply to non-FCPA corporate violations, as well as mergers and acquisitions.  In addition, DOJ recently announced the adoption of an Anti-Piling on Policy, as well as revisions to its Yates Memorandum governing prosecution of culpable individuals.   
this episode, Michael Volkov reviews DOJ’s corporate enforcement policies to provide a current picture of these policies and the impact they have on corporate criminal and civil enforcement.

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T. McBride: “OFAC Dings U.S. Defense Contractor for Sanctions Violations, Inadequate Screening”

Bass Berry & Sims PLC, 12 Dec 2018.) 
* Author: Thad McBride, Esq. Bass, Berry & Sims PLC; 
(202) 827-2959,


Key Points
  – Penalties imposed for violations of U.S. sanctions on Russia and Ukraine
  – Violations identified during pre-acquisition due diligence on contractor
  – Denied persons screening was conducted but missed prohibited parties
In late November 2018, the U.S. Treasury Department, Office of Foreign Assets Control (OFAC) 
announced that Cobham Holdings, Inc. agreed to pay $87,507 to settle violations of U.S. sanctions on Ukraine and Russia.
Violations Identified During Pre-Acquisition Due Diligence
According to OFAC, the violations were committed by Cobham’s former subsidiary, Metelics, prior to the sale of Metelics to MACOM. It was MACOM that identified the violations during due diligence related to its acquisition of Metelics. And it was presumably MACOM that required Cobham to make the voluntary disclosure to OFAC that led to the penalty in this matter.
The penalty is small by recent OFAC standards. (For example, it is about 620 times less than 
Societe Generale paid to OFAC as part of its global settlement of sanctions violations.)
But as a cautionary tale, the Cobham matter is important to any exporter.
Products Sold to Entity Blocked Under U.S. Sanctions

According to OFAC, during a six-month period in 2014 and 2015, Metelics sold products through distributors in Canada and Russia to a blocked entity under U.S. sanctions. That entity – Almaz Antey Telecommunications LLC (AAT) – was not explicitly named as a blocked party on the OFAC List of Specially Designated Nationals and Blocked Persons (the SDN List).
Yet AAT was nonetheless a blocked person because it was 51 percent-owned by a party – JSC Almaz-Antey – that was named on the SDN List. As 
OFAC has made abundantly clear, any entity that is owned 50 percent or more by one or more blocked persons is a blocked entity itself.
Any blocked person, whether named on the SDN List or not, is effectively off limits to U.S. companies and individuals.
Screening Challenges Lead to Violations
The chronology of this matter demonstrates the challenges exporters face when screening third party business parties.
According to OFAC, on June 18, 2014, Metelics agreed to sell products to AAT through a Canadian distributor. On June 19, Metelics screened AAT against its prohibited parties screening software. At that time, JSC Almaz-Antey was not a prohibited party – and thus neither was AAT.
On June 27, Metelics shipped products to AAT. In connection with that shipment, Metelics again conducted denied parties screening and identified no match for AAT.
None of this is surprising or problematic from OFAC’s standpoint because JSC Almaz-Antey was not designated as an SDN until July 16, 2014. That is when things get more interesting.
On July 31, 2014, Metelics made another shipment to AAT. In connection with this shipment, Metelics again conducted denied parties screening for AAT and again did not identify any matches – even though JSC Almaz-Antey, the majority owner of AAT, was now named on the SDN List.
Based on this, OFAC deemed the screening effort to be insufficient. OFAC emphasized that Metelics proceeded with shipment to AAT “despite the inclusion of two uncommon terms [‘Almaz’ and ‘Antey’] in the names of both the SDN and [AAT].” OFAC’s statement suggests that the screening software should have identified at least a potential match, which Metelics would presumably have reviewed further before continuing with the transaction.
Notably, there is no indication that Metelics somehow set the software or screening mechanism to avoid identifying a match with AAT. In fact, in its press release, OFAC states that the screening software was set-up to identify “fuzzy” search criteria yet missed the similarities between AAT and JSC Almaz-Antey.
It thus appears that Metelic was not entirely to blame for these apparent violations. Yet in explaining the penalty in this case, OFAC also notes that Metelics “was subject to a consent agreement for violations of the International Traffic in Arms Regulations [ITAR]… resulting from recurring compliance failures.” Arguably those ITAR compliance failures should have made Metelics particularly vigilant about protecting against failures with its screening system.
While OFAC does not name the provider of the screening software in this case, the agency does state that “[p]ersons employing sanctions screening software should take steps to ensure it is sufficiently robust.” In other words, simply because a company uses software to conduct screening does not mean that software is adequate to protect against violations.
This may be a tough lesson for exporters to absorb.  It’s not clear that many exporters conduct quality control checks of their screening software. The raison d’etre for such software is to identify actual or potentially prohibited parties based on name similarities. That is exactly what Metelics expected its software to do.
The proliferation of prohibited and restricted parties – and the lists of such parties – makes it impossible for most companies to keep up-to-date with those lists on their own. That’s the reason so many companies seek software solutions to help meet their compliance obligations. It is the responsible thing to do.
Which makes it a little jarring to read the following exhortation from OFAC:
It is essential that companies engaging in international transactions maintain a culture of compliance where front line staff are encouraged to follow up on sanctions issues, including by promptly reporting to compliance personnel transactions suspected to involve sanctioned parties.
That is surely good advice but it is not clear how it pertains to the facts in the Cobham matter. There is no indication that any Metelics employee was aware of a transaction suspected to involve sanctioned parties – or that any employee ducked their head in the sand.
Nevertheless, it is useful to remember the value of periodic risk assessments during which compliance policies, procedures, and processes are reviewed. Potential weaknesses can be identified and addressed before they lead to violations.

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MS_a114. Monday List of Ex/Im Job Openings: 155 Openings Posted This Week, Including 37 New Openings

(Source: Events & Jobs Editor) 

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


” New or amended listing this week


Acco Brands; Lake Zurich, IL; 
North America Trade Compliance Specialist Classification
Addison Group; Tulsa, OK; 
Senior Compliance Analyst

# Agility; Atlanta, GA; 
Air Export Coordinator;

Agility; Basel, Switzerland; SachbearbeiterIn Ocean Freight Export;

Agility; Carson, CA; 
Air Import Coordinator

Agility; Charlotte, NC; 
Air/Ocean Export Supervisor

* Agility; Charlotte, NC;
Import Manager/Licensed Customs Broker

Agility; Dallas, TX; 
Air Import Coordinator

Agility; Dallas, TX; 
Air Import Supervisor

Agility; Dallas, TX; 
Ocean Export Coordinator
Agility; East Boston, MA; 
Air Export Coordinator

Agility; East Boston, MA; 
Import Coordinator / Customs Entry Writer
Agility; Houston, TX; Air Freight Export Account Executive;

Agility; Houston, TX; 
Ocean Export Coordinator
Agility; Houston, TX; Ocean Export Team Leader;
Agility; Montreal, Canada; Senior Ocean Export Coordinator;

Agility; Philadelphia, PA; Ocean Import Coordinator;
Agility; Queens, NY; Air Import Coordinator;

Airbus; Getafe, Spain; Export Control Officer; Requisition ID: 
10397123 ML EN EXT 6

Ajilon; Grapevine, TX; 
Import/Export Compliance Manager

 Alcoa Group; Knoxville, TN;
Trade Compliance Administrator

AM General; Auburn Hills, MI; International Compliance Analyst

Amazon; Washington D.C., DC; Manager, Export Control & Trade Compliance;

American Trucking Associations (ATA); Arlington, VA;
Mgr Customs, Immigration & Cross-Broder Ops
Analog Devices; Chelmsford, MA; 
Import-Export Analyst

BAE Systems; Arlington, VA; 
HR Operations & Compliance Specialist
; Requisition ID: 43632BR

BAE Systems; Kingsport, TN; 
Procurement Compliance Analyst
; Requisition ID: 43934BR

BAE Systems; Louisville, KY; 
Director Supply Chain Compliance
; Requisition ID: 43499BR

BAE Systems; Nashua, NH; 
Procurement Compliance
; Requisition ID: 

BAE Systems; Sterling Heights, MI; 
Senior Procurement Compliance Analyst
; Requisition ID: 

BAE Systems; York, PA; 
Senior Procurement Compliance Analyst
; Requisition ID: 

ConvaTec; Greensboro, NC; Associate Manager, Customs & Trade; Requisition ID: JR0000536

* Curtiss-Wright Corporation; Bournemouth, Dorset, UK; Senior Trade Compliance Manager; Requisition ID: 3621
Defense Trade Solutions; Washington D.C; Consultant;

Doosan; West Fargo, ND; 
Director Customs & Trade Compliance
DuPont; Neu-Isenburg, Germany; Logistics Specialist Customs & Trade Compliance EMEA; Requisition ID: SOU00001629;
DynCorp International; Forth Worth, TX; 
Trade Compliance Analyst II
DynCorp International; Forth Worth, TX; 
Trade Compliance Manager
; Requisition ID: 1804484

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

Eaton; Titchfield, United Kingdom; Senior Global Trade Analyst; Requisition ID: 056506;

ELTA North America; Baltimore, MD; 
Compliance Officer

Energy Resourcing Group; Houston, TX; Trade Compliance Manager;
Erickson Inc.; Portland or Central Point, OR; Import SpecialistSusan Colletto; Requisition ID 927130;

ESG; Fürstenfeldbruck, Germany; Specialist Export Control Compliance (M/W) (Processes, Implementation & IT);

* Esri; Redlands, CA; Export Compliance Specialist;

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

* Expeditors; Bedfont, United Kingdom; 
District Trade Compliance Manager
* Expeditors; Dusseldorf, 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;

* Export Solutions, Inc.; San Jose, CA; 
Director of Global Trade & Compliance;

* Flash Global; Sao Paolo, Brazil; 
Import and Export Analyst III

* FLIR; Irvine, CA; 
Sr. Manager Export Compliance

* FLIR; Nashua, NH; 
Global Trade Compliance Analyst, Traffic
 FLIR; Billerica, MA; 
Global Trade Compliance Analyst, Licensing

* FLIR; Goleta, CA; Global Trade Compliance Analyst, Traffic

* Full Circle Compliance; Bruchem, Netherlands; 
Legal Analyst, Manager

GCP Applied Technologies; Cambridge, MA; 
Trade Compliance Manager

* General Atomics; San Diego, CA; 
Experienced Project Manager – Compliance Management
; Requisition ID: 20913BR

* General Atomics; San Diego, CA; 
Senior Government Compliance Specialist
; Requisition ID: 20736BR
Gibson Brands, Inc.; Nashville, TN; 
Import/Export Compliance Manager;

Google; Mountain View, CA; Trade Specialist, Export Compliance
GSK, London, United Kingdom; Global Logistics Compliance Manager; Requisition ID: 

* Harris Corporation; Melbourne, FL; Corporate Trade Compliance Investigations LeadRequisition ID: CHQ20182007-26042 

* Henderson Group Unlimited, Inc; State Dept, DDTC; Washington, DC; 
Defense Trade Control Compliance Analyst
* Henderson Group Unlimited, Inc; State Dept, DDTC; Washington, DC; 
Commodities Jurisdiction Analyst

Henkel AG; Rocky Hill, CT; Global Trade Defense Information Manager;

* Honeywell International Inc.; Sunnyvale, CA or Lincolnshire, IL; Sr. Import/Export Analyst; HRD32371
Hypertherm; Hanover, NH; Senior Trade Compliance & Logistics Specialist;

Ascent Aerospace; Lake Orion, MI; 
ITAR/EAR/Export Compliance Manager

BAE Systems; Poznań, Poland; Export Control Officer;

Beiersdorf; Hamburg, Germany; International Trade Expert;

Boeing; Everett, WA; 
Export Compliance Specialist
; Requisition ID: 1800090316

Boeing; Berlin, Germany; Trade Control Specialist;

* Bio-Rad Laboratories: Hercules, CA;
Regional Trade Compliance Manager – Americas
; Requisition ID: 2018-8158; kelly_demorais@bio-rad.com;
* Bio-Rad Laboratories; Hercules, CA;
Sr. Trade Compliance Specialist
; Requisition ID: 2018-8159; kelly_demorais@bio-rad.com;

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

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

* Boeing; Zoushan, China; 
 Compliance Analyst
* Boeing; Zoushan, China;
Trade Compliance Manager;

CISCO; Amsterdam, The Netherlands; 
Global Export Trade Manager – EMEAR

Cobham Advanced Electronic Solutions; Colorado Springs, CO; 
Export Compliance Manager
; Requisition ID: req2102;

* iDirect; Herndon, VA;
Senior Regulatory Compliance Engineer
; Requisition ID: 2018R-4700-56

# Infineon; El Segundo, CA; 
Manager, Export Control; Requisition ID: 33841
Infineon Technologies, El Segundo, CA; 
Senior Export Compliance Specialist
# Infineon; El Segundo, CA; 
Senior Export Compliance Specialist; Requisition ID: 31215 

 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;

 IPG Photonics; Oxford, MA;
Global Director Trade Compliance
ITT Inc.; Irivine, CA; 
Trade Compliance Coordinator

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

Kforce Inc; St. Louis, MO; Trade Compliance Analyst;

KIA Motors; West Point; GA; Specialist, General Purchasing (Trade Compliance Logistics)
Kulicke & Sofa; Fort Washington, PA; Import/Export, Trade Compliance Analyst;

* Leonardo DRS; Melbourne, FL; 
Senior Supply Chain Analyst – Small Business Compliance
; Requisition ID: 91669

Leonardo DRS; Philadelphia, PA; 
Manager of Import/Export
; Requisition ID: 1530; 

* Lockheed Martin; Bethesda, MD; 
Regulatory Compliance Analyst
; Requisition ID: 449353BR

Lockheed Martin; 
Grand Prairie, TX; 
International Trade Compliance Specialist / International Licensing Analyst
Requisition ID: 459286BR

Lockheed Martin, Grand Prairie, TX OR Orlando, FL.; 
International Trade Compliance Engineer Staff
; Requisition ID 462509BR

Lockheed Martin, Orlando, FL.; 
International Licensing Analyst
; Requisition ID 460554BR

Medtronic; Minneapolis, MN; 
Associate Export Controls Analyst
; Requisition ID: 18000K22

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

MEGGITT Control Systems; North Hollywood, CA; 
Sr. Trade Compliance Specialist

MIT Lincoln Laboratory; Cambridge, MA; 
Export Compliance & Document Control Analyst;

Mitsubishi Hitachi Power Systems Americas, Inc.; Houston, TX; 

Mohawk Global Trade Advisors; Chicago, IL; Vice President and General Manager of Consulting Division; Contact: CSardella@mohawkglobal.com;  

MSC Mediterranean Shipping Company; Chicago, IL; 
US Export Compliance Analyst

* 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
 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.
Muscogee International, LLC; Washington, D.C.; 
DDTC Office Support
; Apply 
 or contact their 
recruiting team
NASA jet Propulsion Laboratory; Pasadena, CA; 
Export Compliance Advisor

# Newell Brands; Norwalk, CT; 
Manager of Trade Operations

NXP; Eindhoven, Netherlands; 
Trade Compliance Coordinator
Oerlikon; Old Westbury; NY; 
Local Trade Control Specialist

Ormco; Amersfoort, The Netherlands; 
EU Trade Compliance Specialist;

Panalpina; Sterling, VA; Government Operations Associate;

Philips; Eindhoven, The Netherlands; 
Export Control Officer

* Polaris; Minneapolis, MN;
Sr. Global Trade Compliance Specialist, Tariff Classification
; Requisition ID: 11770BR
PrincetonOne; Franksville, WI; 
Customs Compliance Manager
Raytheon; Dulles, VA; 
Principal Global Trade License

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

* Raytheon; Billerica, MA; 
Mgr I Export-Import Control
; Requisition ID: 
Raytheon; Dulles, VA; Senior Trade Counsel/Regulatory Compliance Director; Requisition ID: 128137

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

Regal Beloit Corporation; Franksville, WI; Trade Compliance Analyst;

Richemont; Forth Worth, TX; 
Import/Export Manager
; Requisition ID: 8057

Rohde Schwarz; Munich, Germany; 
Spezialist Exportkontrolle (m/w)

 SABIC; Houston TX; 
Senior Analyst, Trade Compliance

; Requisition ID: 8411BR

Signify; Eindhoven, The Netherlands; 
Global Trade Compliance Officer Export Controls

SpaceX; Hawthorne, CA; Counsel, Export Compliance Officer;

Takeaway.com; Voort, the Netherlands; 
Medewerker Inkoop Support

* The Safariland Group; Jacksonville, FL; Sr. Export Compliance Specialist;
Teledyne Technologies Inc.; Hawthorne, CA; 
Sr. International Trade Compliance Specialist
TLR Inc.; Portland, OR; 
Export Compliance Specialist

TE Connectivity; El Cajon, CA or Middletown, PA; 
International Trade Compliance Specialist

; Requisition 39143

TE Connectivity; El Cajon, CA or Middletown, PA; 
Licensing Specialist
; Requisition 40514

* Textron Aviation; Wichita, KS; 
Trade Compliance Analyst
; Requisition ID: 269127
Thales; Arlington, VA; 
Trade Compliance Officer
; Requisition ID: R0044069

Thales; New Delhi, India; 
Manager – Trade Compliance
; Requisition ID:
The Toro Company; Bloomington, MN; 
Customs Compliance Specialist

Toyota Tsusho America; Georgetown, KY; 
Import Export Compliance Specialist;
 Tradeweb; Amsterdam, The Netherlands; 
Trade Surveillance & Compliance Officer
Trek Bicycle; Waterloo, WI; Trade Compliance Specialist

Triniseo; Frankfurt, Germany; International Trade & Compliance Specialist EMEA;
United Launch Alliance; Denver, CO; Global Trade Operations Specialist 4; Contact amandaf@us.ibm.com; Requisition ID: 

United Technologies – Aerospace Systems; Windsor Locks, CT; Manager – International Trade Compliance; Requisition ID 

United Technologies – Pratt & Whitney; East Hartford, CT; 
International Trade Compliance Specialist

Requisition ID 72822BR

United Technologies – Pratt & Whitney; East Hartford, CT; 
Sr. Manager International Trade Compliance

Requisition ID 75970BR

United Technologies – Pratt & Whitney; East Hartford, CT; 
International Trade Compliance Authorizations Owner
; Requisition ID: 72822BR

United Technologies – Pratt & Whitney; East Hartford, CT; ITC Site Lead, Hot Section Module Center; Requisition ID: 71012BR

University of California; San Francisco, CA; 
Export Control Officer; Requisition ID: 51010;

* Vitol Group; Rotterdam, The Netherlands; KYC Compliance Analyst EMEA & Asia

* VT iDirect; Herndon VA;
Manager, Global Logistics
; Requisition ID: 2018R-3120-1;

* Wesco International; Houston, TX; Export Compliance Specialist;

WestRock Company; Atlanta, GA; 
International Logistics Coordinator
World Wide Technology; Edwardsville, IL; 
International Trade Compliance Specialist

World Wide Technology; Oude Meer, Netherlands; 
Trade and Compliance Specialist

* Xilinx; San Jose, CA;
Trade Compliance Specialist
; Requisition ID: 155901

XPO Logistics; Amsterdam, Netherlands; Compliance Officer

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


TE_a115ECTI Presents United States Export Control (ITAR/EAR/OFAC) Seminar Series in Orlando, FL 

(Source: J. Kincaid, 
* What: United States Export Controls (ITAR/EAR/OFAC) Seminar Series in Orlando, FL
* When: ITAR Seminar:  February 18-19, 2019; EAR/OFAC Seminar: February 20-21, 2019
* Where: Orlando, FL: Embassy Suites Orlando-Jamaican Court
* Sponsor: Export Compliance Training Institute (ECTI)
* ECTI Speaker Panel: Scott Gearity, Greg Creeser, Marc Binder, and Melissa Proctor
* Register: 
or contact Jessica Lemon at 540-433-3977 or 

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

TE_a216FCC Presents “Designing an Internal Compliance Program for Export Controls & Sanctions”, 5 Feb 2019 in Bruchem, the Netherlands

(Source: Full Circle Compliance, 
The next Full Circle Compliance (FCC) academy course is specifically designed for beginning compliance professionals who aim to enhance their organization’s compliance efforts.  The course will cover multiple topics and tackle various questions, including but not limited to:
 – Setting the Scene: ensuring compliance in the export control and sanctions arena
 – What is expected from your organization? A closer look at the frameworks and guidelines from U.S. and European government agencies (incl. State/DDTC, Commerce/BIS, Treasury/OFAC, European Union, The Netherlands, and Germany) 
 – Key elements of an Internal Compliance Program
 – Strategic benefits of an Internal Compliance Program
 – Best practice tips for enhancing your compliance activities
 – Compliance Toolkit: internal controls samples (policies, procedures, instructions, checklists)
* What: Designing an Internal Compliance Program for Export Controls & Sanctions 
* When: Tuesday, 5 Feb 2019, 9.00 AM – 4.30 PM (CET)
* Where: Landgoed Groenhoven, Bruchem, the Netherlands
* Sponsor: 
Full Circle Compliance (FCC)
* Instructors: Drs. Ghislaine C.Y. Gillessen RA, Marco F.N. Crombach MSc
* Information & Registration: via the 
event page, via
events@fullcirclecompliance.eu or call +31 (0)23 – 844 – 9046.

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


Jane Austen (16 Dec 1775 – 18 Jul 1817; was an English novelist known primarily for her six major novels, which interpret, critique and comment upon the British landed gentry at the end of the 18th century.  Her best-known novels were Sense and Sensibility (1811), Pride and Prejudice (1813), and Mansfield Park (1814).
  – “There is no charm equal to tenderness of heart.”
Margaret Mead (16
Dec 1901 – 15 Nov 1978; was an American 
cultural anthropologist and author, and was a proponent of broadening sexual conventions within a context of traditional Western religious life.
best-known book,
Coming of Age in Samoa, detailing the attitudes towards sex in indigenous South Pacific cultures, influenced the 1960s sexual revolution, was controversial, and its facts were disputed by later authors. The Intercollegiate Review, published by the Intercollegiate Studies Institute, listed the book as #1 on its “The Fifty Worst Books of the Century” list.)
“Always remember that you are absolutely unique. Just like everyone else.”
John Greenleaf Whittier (17 Dec 1807 – 7 Sep 1892; was an American Quaker poet.  Frequently listed as one of the Fireside Poets, he was influenced by the Scottish poet Robert Burns. Whittier is remembered particularly for his anti-slavery writings as well as his novel,
“For all sad words of tongue and pen, The saddest are these, ‘It might have been’.”

Monday is pun day:  

* What’s the difference between a poorly dressed man on a bicycle and a nicely dressed man on a tricycle?  A tire.
* I got my girlfriend a “get better soon” card. She’s not sick, I just think she could get better.
* I can’t believe I got fired from the calendar factory. All I did was take a day off.

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

. 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: 19 Sep 2018: 83 FR 47283-47284: Extension of Import Restrictions Imposed on Archaeological Material From Cambodia  


  – Last Amendment: 18 May 2016: Change 2
: Implement an insider threat program; reporting requirements for Cleared Defense Contractors; alignment with Federal standards for classified information systems; incorporated and cancelled Supp. 1 to the NISPOM (Summary 

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

  – Last Amendment: 2 Nov 2018: 
83 FR 55099: Wassenaar Arrangement 2017 Plenary Agreements Implementation [Correction to 24 Oct EAR Amendment Concerning Supplement No. 1 to Part 774, Category 3.]

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

  – Last Amendment: 15 Nov 2018: 83 FR 57308-57318: Democratic Republic of the Congo 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: 1 Nov 2018: 
Harmonized System Update 1819, containing 1,200 ABI records and 245 harmonized tariff records.

  – HTS codes for AES are available 
  – HTS codes that are not valid for AES are available 
  – Last Amendment:
4 Oct 2018: 83 FR 50003-50007: Regulatory Reform Revisions to the International Traffic in Arms Regulations.

  – The only available fully updated copy (latest edition: 4 Oct 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.

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

Weekly Highlights of the Daily Bugle Top Stories

(Source: Editor) 

Review last week’s top Ex/Im stories in “Weekly Highlights of the Daily Bugle Top Stories” published 

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


* The Ex/Im Daily Update is a publication of FCC Advisory B.V., compiled by: Editor, James E. Bartlett III; Assistant Editors, Alexander P. Bosch and Vincent J.A. Goossen; and Events & Jobs Editor, Alex Witt. The Ex/Im Daily Update is emailed every business day to approximately 6,000 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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