19-0102 Wednesday “Daily Bugle'”

19-0102 Wednesday “Daily Bugle”

Wednesday, 2 January 2019

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. [The Daily Bugle was not released yesterday, Tuesday, 1 January 2019, a U.S. Federal Holiday.] 

[No items of interest noted today.] 

  1. Items Scheduled for Publication in Future Federal Register Editions
  2. Commerce/BIS: (No new postings.)
  3. State/DDTC Posts Reminder on Seeking Comments on Request to Change End User, End Use and/or Destination of Hardware
  4. Hong Kong/TID Posts Notice on Air Transshipment Cargo Exemption Scheme for Specified Strategic Commodities
  1. New York Times: “Curbs on A.I. Exports? Silicon Valley Fears Losing Its Edge”
  2. ST&R Trade Report: “Inadequate Compliance Efforts Yield Sanctions Violations, $7.77 Million Penalty”
  1. M. Volkov: “Episode 70 – FCPA Year in Review and Predictions for 2019”
  2. R.C. Thomsen II, A.D. Paytas & M.M. Shomali: “U.S. Export Controls Past, Present, and Future (2018 Edition)”
  1. FCC Presents Renewed U.S. Export Controls Awareness Course: “ITAR & EAR from a non-U.S. Perspective”, 9 April in Bruchem, the Netherlands
  1. Bartlett’s Unfamiliar Quotations 
  2. Are Your Copies of Regulations Up to Date? Latest Amendments: DHS/Customs (18 Dec 2018), DOC/EAR (20 Dec 2018), DOC/FTR (24 Apr 2018), DOD/NISPOM (18 May 2016), DOE/AFAEC (23 Feb 2015), DOE/EINEM (20 Nov 2018), DOJ/ATF (26 Dec 2018), DOS/ITAR (4 Oct 2018), DOT/FACR/OFAC (15 Nov 2018), HTSUS (19 Dec 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)


[No items of interest noted today.]  

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Commerce/BIS: (No new postings.)


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State/DDTC, 2 Jan 2018.)
The Department of State submitted on 26 Dec 2018 the information collection described below to the Office of Management and Budget (OMB) for approval. In accordance with the Paperwork Reduction Act of 1995 we are requesting comments on this collection from all interested individuals and organizations. The purpose of this Notice is to allow 30 days for public comment.

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The Trade and Industry Department implements the Air Transshipment Cargo Exemption Scheme for Specified Strategic Commodities (SCTREX) (referred below as “the Scheme”) to facilitate the air transshipment of specified strategic commodities through Hong Kong. Registrants under the Scheme are, subject to certain conditions, exempted from licensing requirements under the Import and Export Ordinance (Cap. 60) and the Import and Export (Strategic Commodities) Regulations (Cap. 60G) (referred below as “the Regulations”) in respect of air transshipment cargo of specified strategic commodities.
Scope of Exemption
The Scheme applies to airlines, ground handling agents and freight forwarders successfully registered and granted with a Certificate of Exemption by the Director-General of Trade and Industry.
The Scheme covers specified strategic commodities listed in Schedule 1 to the Regulations, except products listed in Schedule 2, which are air transshipment cargo handled by registrants under the Scheme and remain within the confines of the cargo transshipment area of the Hong Kong International Airport pending onward flights. The licensing requirements for the import and export of strategic commodities specified in Schedule 1 that are not on the air-to-air transshipment mode and those in Schedules 2, 3 and 4 of the Regulations are not affected by the Scheme. Transshipment of strategic commodities not granted exemption under the Scheme must be covered by valid import and export license.
Valid Registrants
As at 1 January 2019, the following 19 companies are registered under the Scheme:


If you have any inquiry concerning the Scheme, please contact the following officers or send email to us at stc@tid.gov.hk.

Name of Officer
Telephone No.
2398 5577
Mr Daniel LEUNG
2398 5592


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New York Times, 1 Jan 2019.) [Excerpts.]
The Commerce Department is considering national security restrictions on artificial intelligence. Some worry they could stunt the industry in the U.S.
A common belief among tech industry insiders is that Silicon Valley has dominated the internet because much of the worldwide network was designed and built by Americans.
Now a growing number of those insiders are worried that proposed export restrictions could short-circuit the pre-eminence of American companies in the next big thing to hit their industry, artificial intelligence.
In November, the Commerce Department released a list of technologies, including artificial intelligence, that are under consideration for new export rules because of their importance to national security.
Technology experts worry that blocking the export of A.I. to other countries, or tying it up in red tape, will help A.I. industries flourish in those nations – China, in particular – and compete with American companies. …

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. ST&R Trade Report: “Inadequate Compliance Efforts Yield Sanctions Violations, $7.77 Million Penalty”

A holding company (ed. Zoltek Companies, Inc.) headquartered in the U.S. has agreed to pay $7.77 million to settle its potential civil liability for 26 apparent violations of the Belarus Sanctions Regulations. According to the Treasury Department’s Office of Foreign Assets Control, this enforcement action highlights the risks for companies with overseas operations that do not implement OFAC compliance programs or that implement compliance programs that fail to address OFAC-administered sanctions regulations. OFAC states that effective sanctions compliance programs have policies, procedures, and controls designed to identify prospective and in-process transactions, as well as customers and counter-parties, for potential OFAC issues, as well as mechanisms designed to adequately respond to warning signs and raise sanctions-related issues to a sanctions compliance officer or point of contact.
Additionally, OFAC states, this case highlights the need for U.S. parent companies to take care to segregate certain business operations of their overseas subsidiaries so that the U.S. parent and its employees do not violate U.S. sanctions regulations by facilitating the actions of its subsidiaries.
According to OFAC, for a number of years the foreign subsidiary of the U.S. company at issue purchased acrylonitrile, a chemical used in the production of carbon fiber, from a Belarusian entity identified on OFAC’s List of Specially Designated Nationals and Blocked Persons. Throughout this period, purchase decisions made by the subsidiary were reviewed and approved by senior-level executives of the parent company in the U.S., even when they knew of the seller’s status as an OFAC-sanctioned party.
The statutory maximum civil monetary penalty amount for the apparent violations was $37.8 million and the base penalty amount was $12.0 million.
OFAC considered the following to be aggravating factors.
  – The company acted with reckless disregard for U.S. economic sanctions requirements and/or failed to exercise a minimal degree of caution or care in avoiding the conduct that led to the apparent violations and failed to incorporate OFAC compliance checks in its overall risk mitigation strategy.
  – Multiple parent company personnel, including senior and executive-level managers, as well as individuals from the subsidiary, were aware of and participated in the conduct that led to the apparent violations.
  – The parent company approved the subsidiary’s purchase of a significant volume of ACN from the sanctioned party for several years, resulting in significant harm to the sanctions program objectives of the BSR and conferring more than $18 million to a Belarusian government entity.
  – The companies at issue are large entities that engage in a significant volume of international trade and cross-border transactions.
  – Senior parent company personnel, including executive-level managers, actively discussed U.S. sanctions issues related to the sanctioned party raised by third parties but did not review the company’s U.S. legal obligations and continued to approve transactions with the sanctioned party.
On the other hand, OFAC considered the following to be mitigating factors.
  – Neither the parent company nor its subsidiary have received a penalty notice or finding of violation from OFAC in the five years preceding the earliest date of the transactions giving rise to the apparent violations.
  – Both companies cooperated with OFAC’s investigation, including by voluntarily self-disclosing the apparent violations and providing detailed and well-organized information for OFAC’s review.
  – The parent company and its U.S.-based subsidiary confirmed that they have terminated the conduct that led to the apparent violations and taken the following steps to minimize the risk of recurrence of similar conduct in the future:
(1) expanded the director of global compliance position to include U.S. sanctions issues,
(2) implemented the use of sanctions software to screen vendors and their parent and subsidiary companies against government restricted lists on a daily basis, and
(3) created a “learning academy” to train all new and current employees on U.S. economic sanctions and adherence to U.S. export controls.

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Volkov Law Group Blog, 1 Jan 2019. Reprinted by permission.)
* Author: Michael Volkov, Esq., Volkov Law Group,
mvolkov@volkovlaw.com, 240-505-1992.
The Justice Department and the Securities and Exchange Commission had another strong year in FCPA enforcement. The numbers for 2018 tell a compelling story.
$950 million
$380 million
$1.33 billion
In this episode, Michael Volkov reviews FCPA enforcement for 2018 and outlines interesting trends and developments.

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(Source: Thomsen and Burke LLP, 1 Jan 2018. Available by subscription via 
* Authors: Roszel C. Thomsen II, Esq., +1 410-539-2596, 
roz@t-b.com; Antoinette D. Paytas, Esq., +1 410-539-2655, 
toni@t-b.com; and Maher M. Shomali, Esq., +1 410-539-6336, 
maher@t-b.com. All of Thomsen and Burke LLP. 
As is our custom, at the end of each year, we reflect on developments in the field of U.S. and multilateral export controls, gaze into our crystal balls, and offer some recommendations for 2019 in the linked
End of Year Summary.
We also include a summary of all final rules, proposed rules and notices published during 2018 by the Departments of Commerce, State, and Treasury affecting export controls, in the linked
2018 Regulatory Summary.
Highlights for 2018 include:
The U.S. Government implemented significant changes to export control laws and regulations in 2018, including the Department of Commerce’s Bureau of Industry and Security (BIS), Department of the Treasury’s Office of Foreign Assets Control (OFAC), the Department of State and the Office of the US Trade Representative (USTR):
The President signed the John S. McCain National Defense Authorization Act (NDAA) for Fiscal Year 2019 (H.R. 5515). The NDAA includes export control reform provisions requiring the Commerce Department to establish export controls on emerging and foundational technologies, which are still being defined. BIS has since published an Advanced Notice of Proposed Rulemaking (ANPRM) in the Federal Register which sought public comment on criteria for identifying emerging and foundational technologies, which are due on January 10, 2018. The NDAA is also designed to strengthen the current Committee on Foreign Investment in the United States (CFIUS) process, which reviews proposed foreign investments in the U.S. in order to determine the effect of such transactions on the national security of the U.S.
Throughout the year, the USTR announced multiple rounds of new import tariffs on Chinese-origin items pursuant to a Section 301 action. The tariffs impact a wide range of goods that range from an additional 10% to 25% duty on the import of Chinese-origin goods into the U.S. The first 3 lists of items subject to the Section 301 tariffs have been finalized and the tariffs are now implemented. The changes included some reorganization of the Harmonized Tariff Schedule (HTS), including subheading 8517.62, which covers several types of telecommunications equipment.
There were significant enforcement actions in 2018. The ZTE case was settled this year, and resulted in more than a $1 billion fine and other compliance measures. BIS also issued the largest civil penalty to be paid by an individual in BIS history. There were also penalties assessed to companies for a failure in its third-party screening software, as well as a failure to screen against entities blocked under OFAC’s “50% rule.”
There have been several changes to the sanction’s programs implemented by OFAC and the State Department. The U.S. officially ceased its participated in the Joint Comprehensive Plan of Action (Iran Nuclear Deal), and certain sanctions against Iran were re-imposed under OFAC’s Iranian Transactions and Sanctions Regulations. There were also additional sanctions implemented against Russia and Venezuela, as well as the removal of OFAC’s Sudanese Sanctions Regulations.
BIS revised several Export Control Classification Numbers to reflect changes to the control lists various multilateral regimes, including the Wassenaar Arrangement, Australia Group, Missile Technology Control Regime, and Nuclear Suppliers Group.
Recommendations for 2019 include:
We anticipate the following actions in 2019, which you can begin preparing for now:
We are likely to see the impact of the NDAA’s Export Control Reform Act early in the New Year. BIS has solicited comments on the criteria for defining emerging and foundational technologies in the areas of biotechnology, artificial intelligence and machine learning, microprocessor technology, data analytics technology, robotics, and more. This could lead to export licensing requirements for these technologies, even if they are not currently controlled under the EAR. Since the comment period has been extended until January 10th, we recommend providing comments to BIS, even if your company’s technology is not included in the initial categories of emerging technologies. The comment may address how to define and identify emerging technologies and the impact these controls would have on U.S. technological leadership.
The NDAA’s Foreign Investment Risk Review Modernization Act will also be addressed in the New Year. FIRRMA’s Pilot Program already expands the CFIUS review process of foreign investments in the U.S., and creates mandatory filing requirements, and includes certain non-controlling investments in US businesses involved in critical technologies related to specific industries. We are likely to see further clarifications on the definition of critical technologies early in the New Year, but U.S. companies should already be reviewing any possible foreign investment under the expanded scope of FIRRMA.
The Section 301 tariffs have already had a significant impact on U.S. importers of Chinese-origin items, and we anticipate changes to the tariffs in 2019. The List 3 tariff rate on the $200 billion worth of Chinese-origin items is set to increase to 25% on March 1st. List 3 includes telecommunications routing and switching apparatus under HTS code 8517.62.0090. There have also been discussions about adding a List 4 of items to the China import tariffs, although nothing has been formally announced. We recommend reviewing the HTS classification of all Chinese-origin imports to determine if your items are already subject to the Section 301 tariffs or future tariffs. If so, you should consider ways of mitigating the impact of the tariffs including adjusting supply chain operations or utilizing a bonded warehouse or drawback program.
Based on our review of enforcement actions in 2018, we recommend that exporters review their internal screening process to mitigate the risk of an export violation. The Cobham/Metelics case included a failure in the third-party screening software to detect a partial match of a denied party, as well as the failure to identify a party that was blocked pursuant to OFAC’s 50% rule, which blocks transactions with entities majority-owned by a denied party, even if the entity, itself, is not included on the denied party list. This requires enhanced due diligence by exporter, who can no longer solely rely on the third-party screening results. Exporters should consider an internal audit of its existing screening process, and enhanced end-user/end-use certifications for transactions with countries of concern.
There have been continued developments in the export/import control regulations of various foreign governments. The focus in 2018 was on China, which introduced retaliatory tariffs against U.S.-origin items, and implemented its cybersecurity law. We have also continued to see enforcement of foreign governments’ import controls on encryption products. Many of these issues will be addressed at the annual American Conference Institute’s Advanced Industry Forum on Global Encryption, Cloud & Cyber Export Controls. The 9th year of the conference will be held on March 27 – 28 in San Francisco, California, and will once again be co-chaired by Roz Thomsen. In addition to foreign importers and exporters and importers, this conference will be of interest to companies that are facing obstacles are the use and provision of cloud-based services becomes more widespread. Please let us know if you are interested in attending so you can take advantage of our registration discount code. Additional information can be found on the conference website.
Finally, a reminder to exporters of encryption products that the end of the year marks the close of the reporting period for annual encryption and semi-annual ENC reports. As we continue to see streamlining changes being made to encryption products, many items no longer require reporting. This is a good time to prepare required reports, which are due no later than February 1, 2019 and to analyze current products to determine if reporting is no longer required.
Additional details are found in the linked
End of Year and
Regulatory summaries.

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TE_a19FCC Presents U.S. Export Controls Awareness Course: “ITAR & EAR from a non-U.S. Perspective”, 9 April in Bruchem, the Netherlands

Our next academy course is specifically designed for beginning compliance professionals and those in a similar role who aim to stay up-to-date with the latest U.S. export control requirements that apply to non-U.S. transactions, and industry’s best practices.
The course will cover multiple topics relevant for organizations outside the U.S. that are subject to U.S. export controls, including: the U.S. regulatory framework, key concepts and definitions, tips regarding classification and licensing, essential steps to ensure a U.S. export control compliant shipment, how to handle a (potential) non-compliance issue, recent enforcement trends, and the latest and anticipated regulatory amendments.  Participants will receive a certification upon completion of the training.
* What: Awareness Course U.S. Export Controls: ITAR & EAR from a Non-U.S. Perspective 
* When: Tuesday, 9 Apr 2010, 9.30 am – 4.30 pm (CET)
* Where: Landgoed Groenhoven, Bruchem, the Netherlands
* Sponsor: Full Circle Compliance (FCC)
* Instructors: Michael E. Farrell and Drs. Alexander P. Bosch 
* Information & Registration: HERE, email 
 or call us at +31 6 15 65 02 09.
Register now and get a 10% Early Bird discount 
on the course fee!

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J. Edgar Hoover (John Edgar Hoover (1 Jan 1895 – 2 May 1972; was the first Director of the U.S. Federal Bureau of Investigation (FBI), where he remained for over 37 years until his death in 1972.)
  – “The cure for crime is not the electric chair, but the high chair. No amount of law enforcement can solve a problem that goes back to the family.”
* William Lyon Phelps (2 Jan 1865 – 21 Aug 1943; was an American author, critic, and scholar. He was a well-known speaker who drew large crowds. He had a radio show, wrote a daily syndicated newspaper column, lectured frequently, and published books and articles.)
  – “The final test of a gentleman is his respect for those who can be of no possible service to him.”
  – “If at first you don’t succeed, find out if the loser gets anything.”
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. Are Your Copies of Regulations Up to Date?
(Source: Editor)

* DHS CUSTOMS REGULATIONS: 19 CFR, Ch. 1, Pts. 0-199.  Implemented by Dep’t of Homeland Security, U.S. Customs & Border Protection.
  – Last Amendment: 18 Dec 2018: 83 FR 64942-65067: Modernized Drawback  

DOC EXPORT ADMINISTRATION REGULATIONS (EAR): 15 CFR Subtit. B, Ch. VII, Pts. 730-774. Implemented by Dep’t of Commerce, Bureau of Industry & Security.
  – Last Amendment: 20 Dec 2018: 83 FR 65292-65294: Control of Military Electronic Equipment and Other Items the President Determines No Longer Warrant Control Under the United States Munitions List (USML); Correction [Concerning ECCN 7A005 and ECCN 7A105.]
* DOC FOREIGN TRADE REGULATIONS (FTR): 15 CFR Part 30.  Implemented by Dep’t of Commerce, U.S. Census Bureau.
  – Last Amendment: 24 Apr 2018: 83 FR 17749-17751: Foreign Trade Regulations (FTR): Clarification on the Collection and Confidentiality of Kimberley Process Certificates
  – HTS codes that are not valid for AES are available here.
  – The latest edition (1 Jan 2019) 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 website.  BITAR subscribers are entitled to a 25% discount on subscriptions to the BAFTR. Government employees (including military) and employees of universities are eligible for a 50% discount on both publications at www.FullCircleCompiance.eu.   


  – 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.)
DOE ASSISTANCE TO FOREIGN ATOMIC ENERGY ACTIVITIES: 10 CFR Part 810; Implemented by Dep’t of Energy, National Nuclear Security Administration, under Atomic Energy Act of 1954.
  – Last Amendment: 23 Feb 2015: 80 FR 9359, comprehensive updating of regulations, updates the activities and technologies subject to specific authorization and DOE reporting requirements. This rule also identifies destinations with respect to which most assistance would be generally authorized and destinations that would require a specific authorization by the Secretary of Energy.
DOE EXPORT AND IMPORT OF NUCLEAR EQUIPMENT AND MATERIAL; 10 CFR Part 110; Implemented by Dep’t of Energy, U.S. Nuclear Regulatory Commission, under Atomic Energy Act of 1954.
  – Last Amendment: 20 Nov 2018, 10 CFR 110.6, Re-transfers.

* DOJ ATF ARMS IMPORT REGULATIONS: 27 CFR Part 447-Importation of Arms, Ammunition, and Implements of War.  Implemented by Dep’t of Justice, Bureau of Alcohol, Tobacco, Firearms & Explosives.
  – 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.  


DOS INTERNATIONAL TRAFFIC IN ARMS REGULATIONS (ITAR): 22 C.F.R. Ch. I, Subch. M, Pts. 120-130. Implemented by Dep’t of State, Directorate of Defense Trade Controls.
  – 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: 1 Jan 2019) 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.
* DOT FOREIGN ASSETS CONTROL REGULATIONS (OFAC FACR): 31 CFR, Parts 500-599, Embargoes, Sanctions, Executive Orders. 

Implemented by Dep’t of Treasury, Office of Foreign Assets Control.

  – Last Amendment: 15 Nov 2018: 83 FR 57308-57318: Democratic Republic of the Congo Sanctions Regulations
* USITC HARMONIZED TARIFF SCHEDULE OF THE UNITED STATES (HTS, HTSA or HTSUSA), 1 Jan 2018: 19 USC 1202 Annex. Implemented by U.S. International Trade Commission. (“HTS” and “HTSA” are often seen as abbreviations for the Harmonized Tariff Schedule of the United States Annotated, shortened versions of “HTSUSA”.)
  – Last Amendment: 19 Dec 2018: Harmonized System Update (HSU) 1820, containing 19,061 ABI records and 3,393 harmonized tariff records.
  – HTS codes for AES are available here.
  – HTS codes that are not valid for AES are available here.

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Weekly Highlights of the Daily Bugle Top Stories

(Source: Editor) 

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

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* The Ex/Im Daily Update is a publication of FCC Advisory B.V., compiled by: Editor, James E. Bartlett III; Assistant Editors, Alexander P. Bosch and Vincent J.A. Goossen; and Events & Jobs Editor, Alex Witt. The Ex/Im Daily Update is emailed every business day to approximately 6,500 readers of changes to defense and high-tech trade laws and regulations. We check the following sources daily: Federal Register, Congressional Record, Commerce/AES, Commerce/BIS, DHS/CBP, DOE/NRC, DOJ/ATF, DoD/DSS, DoD/DTSA, FAR/DFARS, State/DDTC, Treasury/OFAC, White House, and similar websites of Australia, Canada, U.K., and other countries and international organizations.  Due to space limitations, we do not post Arms Sales notifications, Denied Party listings, or Customs AD/CVD items.

* RIGHTS & RESTRICTIONS: This email contains no proprietary, classified, or export-controlled information. All items are obtained from public sources or are published with permission of private contributors, and may be freely circulated without further permission, provided attribution is given to “The Export/Import Daily Bugle of (date)”. Any further use of contributors’ material, however, must comply with applicable copyright laws.  If you would to submit material for inclusion in the The Export/Import Daily Update (“Daily Bugle”), please find instructions here.

* CAVEAT: The contents of this newsletter cannot be relied upon as legal or expert advice.  Consult your own legal counsel or compliance specialists before taking actions based upon news items or opinions from this or other unofficial sources.  If any U.S. federal tax issue is discussed in this communication, it was not intended or written by the author or sender for tax or legal advice, and cannot be used for the purpose of avoiding penalties under the Internal Revenue Code or promoting, marketing, or recommending to another party any transaction or tax-related matter.

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