18-1218 Tuesday “Daily Bugle'”

18-1218 Tuesday “Daily Bugle”

Tuesday, 18 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 
here for free subscription. Contact us
for advertising inquiries and rates. 

  1. DHS/CBP Publishes Modernized Drawback Final Rule 
  1. Items Scheduled for Publication in Future Federal Register Editions
  2. Commerce/BIS: (No new postings.)
  3. DHS/CBP Issues Blanket Authorization for Immediate Delivery Procedures at Year-End”
  4. State/DDTC: (No new postings.)
  5. White House Releases Notice on “Continuation of the National Emergency with Respect to Serious Human Rights Abuse and Corruption”
  6. EU Amends Restrictive Measures Concerning Libya, Supports Efforts Against Illicit Proliferation and Trafficking of Small Arms, Light Weapons, and Ammunition
  1. Reuters: “China Hopes For ‘Orderly’ Brexit, Calls for More Open EU Economy”
  2. Reuters: “U.S. Cuba Lobby Celebrates a Farm Bill Win Despite Worsening Ties”
  3. ST&R Trade Report: “Drawback Regulations Updated; Changes Include Streamlined and Simplified Claims”
  4. Yonhap News Agency: “South Korea’s Arms Procurement Agency Revises Offset Trade Policy Guidelines”
  1. M. Caruso-Cabrera: “Huawei Case Shows How China’s Ambitions Are on a Collision Course with The U.S.”
  1. ECS Presents “Seminar Level I – Boot Camp: Achieving ITAR/EAR Compliance” in Orlando, FL on 11-12 Feb 2019
  1. Bartlett’s Unfamiliar Quotations 
  2. Are Your Copies of Regulations Up to Date? Latest Amendments: ATF (15 Jan 2016), Customs (18 Dec 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 


DHS/CBP Publishes Modernized Drawback Final Rule

Federal Register, 18 Dec 2018.) [Excerpts.] 
83 FR 64942-65067: Modernized Drawback
* AGENCY: U.S. Customs and Border Protection, Department of Homeland Security; Department of the Treasury.
* ACTION: Final rule.
* SUMMARY: This document adopts as final, with changes, proposed amendments to the U.S. Customs and Border Protection (CBP) regulations implementing changes to the drawback regulations, as directed by the Trade Facilitation and Trade Enforcement Act of 2015 (TFTEA). These regulations establish new processes for drawback pursuant to TFTEA, which liberalize the merchandise substitution standard, simplify recordkeeping requirements, extend and standardize timelines for filing drawback claims, and require the electronic filing of drawback claims. This document also provides details with respect to the process required to perfect TFTEA-based claims filed under CBP’s Interim Guidance procedures. Further, this document also finalizes regulations clarifying the prohibition on the filing of a substitution drawback claim for internal revenue excise tax in situations where no excise tax was paid upon the substituted merchandise or where the substituted merchandise is the subject of a different claim for refund or drawback of tax.
* DATES: This final rule, with the exception discussed below, is
effective on December 17, 2018. The effective date for amendments regarding the drawback of excise taxes (§§190.22(a)(1)(ii)(C), 190.32(b)(3), 190.171(c)(3), 191.22(a), 191.32(b)(4), and 191.171(d)) is February 19, 2019. 
* FOR FURTHER INFORMATION CONTACT: Randy Mitchell, CBP Office of Trade, Trade Policy and Programs, 202-863-6532, 
I. TFTEA-Drawback
A. Section 906 of the Trade Facilitation and Trade Enforcement Act … 
B. Transition Period and Interim Guidance … 
C. Proposed Rulemaking … 
D. Difference Between the Interim Guidance and the NPRM … 
E. Perfection of Previously Filed Claims … 
II. Discussion of Comments
A. General Matters 
  1. Proposed Regulations … 
  2. TFTEA-Drawback Definitions … 
  3. Economic Analysis … 
B. Filing Requirements 
  1. Complete Claim … 
  2. Filing Deadline … 
  3. Recordkeeping … 
  4. Protests … 
  5. Proof of Export … 
C. Refund Amount
  1. Refund Methodology … 
  2. Valuation … 
  3. First Filed and Mixed Claims … 
D. Specific Claims
  1. Unused Merchandise … 
  2. Rejected Merchandise … 
  3. Manufacturing Rulings … 
  4. Packaging Materials … 
  5. North American Free Trade Agreement … 
E. Bonding
  1. Bond Type … 
  2. Joint and Several Liability … 
F. Federal Excise Tax and Substitution Drawback Claims
  1. Double Drawback Generally … 
  2. Harbor Maintenance and Oil Spill Liability Taxes … 
  3. Statutory Prohibition on Double Drawback and Legislative Intent … 
  4. Trade Trends and Economic Effects of Double Drawback … 
  5. Revenue Loss Estimates of Double Drawback … 
G. Miscellaneous
  1. Assignment of Drawback Rights … 
  2. Successorship … 
  3. CBP Form 7553 Notice of Intent … 
  4. Privileges …
III. Technical Corrections … 
IV. Conclusion … 
V. Statutory and Regulatory Requirements  … 
A. Inapplicability of Delayed Effective Date … 
B. Executive Order 13563 (Improving Regulation and Regulatory Review) and Executive Order 12866 (Regulatory Planning and Review) …
C. Executive Order 13771 (Reducing Regulation and Controlling Regulatory Costs) … 
D. Regulatory Flexibility Act … 
E. Paperwork Reduction Act … 
VI. Signing Authority … 
List of Subjects … 
Regulatory Amendments … 

[Editor’s Note: for a more detailed treatment concerning this final rule, see item #10 below.]

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


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

* Treasury/OFAC; NOTICES; Blocking or Unblocking of Persons and Properties [Pub. Date: 19 Dec 2018.]
* USTR; NOTICES; Modification of Section 301 Action: 
China’s Acts, Policies, and Practices Related to Technology Transfer, Intellectual Property, and Innovation [Pub. Date: 19 Dec 2018.]

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

Commerce/BIS: (No new postings.)


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

DHS/CBP Issues Blanket Authorization for Immediate Delivery Procedures at Year-End”

CSMS# 18-000743, 18 Dec 2018.) 
CBP’s Office of Trade is issuing a blanket authorization for Immediate Delivery (ID) procedures for merchandise to be released on or after December 17, 2018 through December 31, 2018, in accordance with 19 CFR § 142.21(i). The authorization is offered to filers who may elect to take advantage of the interim Harmonized Tariff Schedule changes, which take effect on or after January 1, 2019. 
This blanket authorization does not apply to absolute quota merchandise and merchandise moved under an immediate transportation entry (type 61). Tariff rate quota merchandise previously authorized for ID release under 19 CFR § 142.21 (e) may still be released; however, the entry summary shall be presented within the time specified in 19 CFR § 142.23 or within the quota period, whichever expires first. 
ABI entry transmissions, including the “paperless” provisional messages, will establish the desired entry date by using the estimated entry date in the summary transmission (“AE” transmissions). This will identify the change from “Entry” to “Immediate Delivery” and will allow filers to elect a date of entry in order to take advantage of tariff changes or special programs. Under ID procedures, the entry/entry summary must be filed within 10 working days after release. This blanket authority only extends to shipments released December 17, 2018 through December 31, 2018. No grace period will be granted for the purpose of timely filing ID entry summaries under this one-time allowance.
Questions regarding this policy should be addressed to the Commercial Operations, Revenue and Entry Division at 

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

State/DDTC: (No new postings.)


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

White House Releases Notice on “Continuation of the National Emergency with Respect to Serious Human Rights Abuse and Corruption” 

The White House, 18 Dec 2018.)
Text of a Notice on the Continuation of the National Emergency with Respect to Serious Human Rights Abuse and Corruption
On December 20, 2017, by Executive Order 13818, the President declared a national emergency with respect to serious human rights abuse and corruption around the world and, pursuant to the International Emergency Economic Powers Act (50 U.S.C. 1701 et seq.), took related steps to deal with the unusual and extraordinary threat to the national security, foreign policy, and economy of the United States.
The prevalence and severity of human rights abuse and corruption that have their source, in whole or in substantial part, outside the United States, continue to pose an unusual and extraordinary threat to the national security, foreign policy, and economy of the United States.  For this reason, the national emergency declared on December 20, 2017, must continue in effect beyond December 20, 2018.  Therefore, in accordance with section 202(d) of the National Emergencies Act (50 U.S.C. 1622(d)), I am continuing for 1 year the national emergency declared in Executive Order 13818 with respect to serious human rights abuse and corruption.
This notice shall be published in the Federal Register and transmitted to the Congress.

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

EU Amends Restrictive Measures Concerning Libya, Supports Efforts Against Illicit Proliferation and Trafficking of Small Arms, Light Weapons, and Ammunition

Official Journal of the European Union, 18 Dec 2018.)

Council Regulation (EU) 2018/2004 of 17 December 2018 amending Regulation (EU) 2016/44 concerning restrictive measures in view of the situation in Libya

Council Decision (CFSP) 2018/2012 of 17 December 2018 amending Decision (CFSP) 2015/1333 concerning restrictive measures in view of the situation in Libya

Council Decision (CFSP) 2018/2010 of 17 December 2018 in support of countering illicit proliferation and trafficking of small arms, light weapons (SALW) and ammunition and their impact in Latin America and the Caribbean in the framework of the EU Strategy against Illicit Firearms, Small Arms & Light Weapons and their Ammunition ‘Securing Arms, Protecting Citizens’

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



Reuters: “China Hopes For ‘Orderly’ Brexit, Calls for More Open EU Economy” 

Reuters, 18 Dec 2018.) 
China hopes Britain’s exit from the European Union can happen in an orderly way and that the bloc will reduce hurdles to Chinese investment and keep its markets open, China’s foreign ministry said on Tuesday.
China, the world’s second-largest economy, has watched Brexit nervously, worried not only about potential market turmoil from a disorderly departure but about losing Britain’s supportive voice for free trade within the EU.
  “China hopes to see Brexit proceed in an orderly fashion and stands ready to advance China-EU and China-UK relations in parallel,” the ministry said in a lengthy policy document on EU ties.
The EU and China are often at loggerheads over trade and other issues, with the EU sharing many of the same concerns as the United States about market access, trade imbalances and intellectual property rights protection.
The bloc is China’s largest trading partner while China is its biggest trading partner after the United States.
The EU has been pressing for better access to the Chinese market for its companies, while China has complained about what it sees as unfair restrictions on Chinese investments in the EU.
Despite events such as Brexit, China said the EU has remained committed to integration, pressed on with reforms and played a major role in regional and international affairs.
Beijing has promised to look at the possibility of reaching a “top notch” free trade deal with Britain post-Brexit.
The Brexit process is currently deadlocked with just over 100 days until Britain is due to leave the EU.
On trade, China’s white paper said the EU should ease high-tech export controls on China and facilitate mutual investment.
The government will significantly ease market access and endeavour to foster a “stable, fair, transparent, law-based and predictable business environment that protects the legitimate rights and interests of foreign investment and treats Chinese and foreign firms registered in China as equals”, it said.
  “China hopes that the EU will keep its investment market open, reduce and eliminate investment hurdles and discriminatory barriers, and provide Chinese companies investing in Europe a fair, transparent and predictable policy environment and protect their legitimate rights and interests.”
The EU last month provisionally agreed on rules for a far-reaching system to coordinate scrutiny of foreign investments into Europe, notably from China in the wake of a surge in Chinese investments, to end what a negotiator called “European naivety”.

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

Reuters: “U.S. Cuba Lobby Celebrates a Farm Bill Win Despite Worsening Ties”

Reuters, 18 Dec 2018.) [Excerpts.] 
U.S. legislation funding $867 billion in food and agriculture programs scheduled to be signed by U.S. President Donald Trump this week includes Department of Agriculture funds to help American farmers promote their products in Communist-run Cuba.
The measure is the first approved by Congress related to heavily sanctioned Cuba in nearly two decades and represents a symbolic victory for the lobby favoring normalization of ties whose fortunes rose under former president Barack Obama and have crashed under Trump.
Congress first authorized agricultural sales to Cuba for cash in 2000.
The farm bill approved by both houses of Congress last week goes a step further by including Cuba for the first time in the Market Access Program and Foreign Market Development program which help U.S. farmers offset the costs of overseas marketing, although it still does not provide credit for such sales.
  “Now, we can interact with more levels of Cuban society including cooperatives, farmers, and end-users to do research and market our products,” Paul Johnson, Chair of the U.S. Agricultural Coalition for Cuba, said. … 
Trump, in alliance with hard-line Cuban exiles, has promised to undo the fragile detente begun by his predecessor.
The administration has tightened travel regulations, forbidden doing business with or patronizing military-controlled Cuban entities and cut back on the negotiations begun by the Obama administration.
Under Trump, the State Department last year slashed staff at the newly opened U.S. Embassy in Havana and expelled 17 diplomats from Cuba’s Embassy in Washington after a series of still unexplained health incidents that affected 25 U.S. diplomats. … 
Despite the deteriorating political climate between the old Cold War foes, much of the economic thaw begun under Obama, from food sales to travel and communications, remains in place. That is in large part due to the political clout of agricultural groups whose membership often support the Republican Party. 
  “Agriculture does have an advantage despite the current political environment,” Johnson said. “The agriculture issue has bipartisan support, and the fact that food touches everyone’s life in Cuba rather than one sector or group of people.”

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


ST&R Trade Report: “Drawback Regulations Updated; Changes Include Streamlined and Simplified Claims”

Sandler, Travis & Rosenberg Trade Report, 18 Dec 2018.)
Claims for drawback of duties and taxes should be easier to file and process under new U.S. Customs and Border Protection regulations scheduled to take effect Dec. 18. This rule [see item #1 above, ed.], which implements the changes to drawback law made by the Trade Facilitation and Trade Enforcement Act (TFTEA), will also revise how CBP treats drawback of excise and other federal taxes as of Feb. 19, 2019.
Drawback is the refund of up to 99 percent of certain duties, internal revenue taxes, and fees collected on imports once either the imported substituted product or the article that has been manufactured from that product has been exported or destroyed.
According to CBP, this rule establishes new processes for drawback pursuant to TFTEA that liberalize the merchandise substitution standard, simplify recordkeeping requirements, extend and standardize timelines for filing drawback claims, and require the electronic filing of drawback claims. This rule also allows mixed TFTEA and non-TFTEA substitution drawback claims and includes the following changes from the proposed rule.
  – removes the proposed requirement for joint and several liability bonds
  – codifies existing CBP drawback practices, such as allowing waivers of prior notice for rejected merchandise and accepting continuous bonds for drawback claims with pending accelerated payment approval
  – eases documentation requirements for transferred merchandise
  – standardizes document submission timelines
  – reduces drawback claim data submission requirements
CBP states that the benefits of this rule include streamlined claim submissions and processing for trade members and CBP, increased time for trade members to claim drawback, added administrative review time for CBP, a strengthened ability for CBP to validate drawback claims and recoup inaccurately over-claimed drawback, a simplified drawback process for trade members and CBP, added reassurance for trade members that rulings with potentially business-sensitive information will not be available for public consumption, and decreased business costs for trade members.
Accelerated Payment
This rule also enables accelerated payment as to drawback claims made under the TFTEA. As a result, CBP is returning certain TFTEA drawback claims to trade control in anticipation that these claims will be resubmitted with a request for accelerated payment. The process for resubmission is as follows.
  –  TFTEA claims with bond information on file will be placed in trade control
  – the filer will select the AP indicator and resubmit the claim
  – resubmission will not change the original claim date
  – claimant must have appropriate approved privileges on file
  – upon claim acceptance, accelerated payment processing will generally take place within three  weeks of the claim resubmission date
However, for TFTEA manufacturing claims, claims on file must be updated with the new manufacturing ruling number once an approval letter for TFTEA modification is received from CBP. After the claims are updated with the new ruling number, claimants will select the AP indicator and resubmit the claim.
In addition, CBP has maintained its controversial elimination of substitution drawback for excise taxes in certain situations. Specifically, the new rule considers as drawback situations where products such as alcohol and tobacco are exported free of excise tax and prohibits what CBP sees as a “double drawback.” For TFTEA substitution drawback claims potentially subject to this limitation (accounting class code 365), additional accelerated payment claims should not be submitted with the accounting class code 365 until CBP notifies the filer to do so; otherwise, there is a risk of bond decrementation and loss of accelerated payment for the life of the claims.

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


Yonhap News Agency: “South Korea’s Arms Procurement Agency Revises Offset Trade Policy Guidelines”

Yonhap News Agency, 17 Dec 2018.) [Excerpts.] 
South Korea’s arms procurement agency on Monday unveiled a set of revisions to its offset trade policy guidelines as part of efforts to boost defense exports and create new jobs.
The Defense Acquisition Program Administration (DAPA) has made the revisions to shift its policy focus to what it calls industrial cooperation with foreign firms and away from technology transfers, which have been limited due to increasingly tighter export controls.
Under the offset trade program introduced in the early 1980s, Seoul has set conditions, such as technology transfers, before selecting foreign contractors to supply defense goods, including fighter jets and other high-tech weapons systems.
Among the revisions is one to increase the benefits for a foreign company buying components from South Korean small and medium-sized enterprises (SMEs). The benefits will be double those it is to get from trading with big Korean firms, DAPA said.
DAPA will also introduce a “banking” system in which a foreign firm can accumulate its records of past transactions with Korean firms and use them in future bids to win defense projects with other Korean firms.
Moreover, the revisions include the introduction of an “industrial 
cooperation quota” system, which requires foreign exporters to supply defense products partly made with components produced in Korea. … 

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


M. Caruso-Cabrera: “Huawei Case Shows How China’s Ambitions Are on A Collision Course with The U.S.”

The Washington Post, 17 Dec 2018.) [Excerpts.] 
* Author: Michelle Caruso-Cabrera, CNBC contributor. 
The arrest in Canada this month of Meng Wanzhou, the chief financial officer of the world’s largest wireless equipment company, headquartered in China, is the clearest sign yet that the war over who will control global communications in the future has spilled dramatically into the open.
It would be easy to mistake Meng – now free on bail, under house arrest and round-the-clock surveillance in Vancouver – as a bargaining chip in the fight between China and the United States over tariffs and trade practices. President Donald Trump himself suggested as much earlier this week, when he said he might intervene on her behalf if the United States received favorable treatment in trade talks from Beijing in return.
In fact, Meng’s arrest has little to do with trade and goes far beyond the fraud charges levied against her. The arrest masks a much larger fight about whose values will drive the vital telecommunications of the next 30 years: the United States and the West, or an autocratic Chinese Communist Party. …

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


TE_a113ECS Presents “Seminar Level I – Boot Camp: Achieving ITAR/EAR Compliance” in Orlando, FL on 11-12 Feb 2019

(Source: S. Palmer, spalmer@exportcompliancesolutions.com.)
* What: Seminar Level I – Boot Camp: Achieving ITAR/EAR Compliance; Orlando, FL
* When: February 11-12, 2019
* Sponsor: Export Compliance Solutions (ECS)
* ECS Speaker Panel:  Suzanne Palmer, Mal Zerden
* Register here or by calling 866-238-4018 or email 

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


Joseph Stalin (born Ioseb Besarionis dze Jughashvili; 18 Dec 1878 – 5 Mar 1953; was a Soviet revolutionary and politician of Georgian ethnicity. He ruled the Soviet Union from 1922 until his death in 1953.  He became the de facto dictator of the Soviet Union by the 1930s. Ideologically committed to the Leninist interpretation of Marxism, Stalin helped to formalize these ideas as Marxism-Leninism, while his own policies became known as Stalinism.)
  – “The people who cast the votes don’t decide an election, the people who count the votes do.”
  – “Education is a weapon whose effects depend on who holds it in his hands.”

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

. 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: 18 Dec 2018: 
83 FR 64942-65067: Modernized Drawback


  – 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.

Scroll to Top