19-0104 Friday “Daily Bugle”

19-0104 Friday “Daily Bugle”

Friday, 4 January 2019

TOPThe Daily Bugle is a free daily newsletter from Full Circle Compliance, containing changes to export/import regulations (ATF, DOE/NRC, Customs, NISPOM, EAR, FACR/OFAC, FAR/DFARS, FTR/AES, HTSUS, and ITAR), plus news and events. Subscribe here for free subscription. Contact us for advertising inquiries and rates

[No items of interest noted today.] 

  1. Items Scheduled for Publication in Future Federal Register Editions 
  2. Commerce/BIS: (No new postings.)
  3. DHS/CBP Posts Reminder on Ace Account Password Reset and Account Restoration Instructions
  4. DoD/DSS Knowledge Center Open for Business
  5. State/DDTC: (No new postings.)
  1. Sputnik News: “Two Belgian CEOs Could Get Jail Terms on Syria Chemicals Export Charges – Report”
  2. ST&R Trade Report: “Dates and Deadlines: AES, Export Controls, Forced Labor, Import Restrictions”
  1. W. Nauwelaerts & P. Greaves: “EU Commission Decision Reconciles Data Protection Rules with the Need for Effective Trade Defence and Trade Policy Investigations”
  1. ECS Presents “Seminar Level II: Managing ITAR/EAR Complexities” in Scottsdale, AZ on 26-27 Mar
  2. ECS Presents “Web Meeting Series – How to Submit the Winning License Application for your Foreign National Employees”, 16 Jan
  3. List of Approaching Events: 66 Events Posted This Week, Including 9 New Events
  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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. Items Scheduled for Publication in Future Federal Register Editions

Federal Register)
[No items of interest noted today.]  

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Commerce/BIS: (No new postings.)


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3. DHS/CBP Posts Reminder on Ace Account Password Reset and Account Restoration Instructions

(Source: CSMS #19-000003, 3 Jan 2019.)
ACE users who are receiving error messages when logging in to the portal can reset their account passwords or restore account access using the instructions below.
Password recovery: You can retrieve a forgotten password through the ACE Secure Data Portal with an ACE user ID. Enter your UserID and select “Forgot Your Password?” If you’re unable to reset your own password, reach out to your company’s Account Owner or a designated proxy.
Account access is disabled/dormant: Contact your company’s Account Owner or a Proxy Account Owner to have your account unlocked. If you’re unable to reach them you may contact the ACE Help Desk by following the instructions on our ACE Support page.
More information can be found here.

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4. DoD/DSS Knowledge Center Open for Business

(Source: DoD/DSS, 3 Jan 2019.)
The DSS Knowledge Center is operating under normal hours and is not affected by the partial government shutdown. We look forward to assisting you with your e-QIP pin resets/lockouts and Personnel Security inquiries. Please call the Knowledge Center at 1-888-282-7682, Option #2, available Monday through Friday, 8 a.m.-5 p.m. ET, excluding federal holidays.

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5. State/DDTC: (No new postings.)
(Source: State/DDTC)
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Sputnik News, 4 Jan 2019.)
Information on the case emerged in April when media reports said that 3 Flemish companies (AAE Chemie, ANEX and Danmar Logistics) were summoned by an Antwerp court for having exported 96 tonnes of isopropanol to Syria in violation of EU sanctions introduced in 2013.
The Antwerp court has obliged the companies to obtain special export licenses for this certain substance to allow deliveries to the Middle Eastern country.
The three companies have said they had been exporting the product to Syria for over 10 years, noting that the customs office, which controlled exports to Syria, had never told them anything was wrong with their shipments. The Belgian Finance Ministry, which oversees the customs, subsequently offered a financial settlement to the companies. However, they refused to accept it.
The 7sur7 news outlet reported yesterday (Thursday) that prosecutors had asked the court to fine the companies 750,000 euros ($854,000) and to sentence heads of two companies to 18 months in prison.
The defendants’ lawyers said their clients had not been aware of the restrictions on chemicals deliveries to Syria, asking for them to be acquitted. The lawyers also claimed that the customs had failed to manage effectively the firms’ export operations.
The customs, in turn, defended itself by saying that the export document had not been filled in correctly by the companies, and launched a criminal investigation into the controversial shipments.
The verdict in the case is expected to be made in late January. Isopropanol, commonly known as rubbing alcohol, might be reportedly used for the chemical weapons production.

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Sandler, Travis & Rosenberg Trade Report, 4 Jan 2019.) [Excerpts.] 
Following are highlights of regulatory effective dates and deadlines, federal agency meetings, and other trade-related events coming up in the next week. … 
  – Jan. 7 – deadline for comments to Census Bureau on
AES information collections
  – Jan. 10 – deadline for comments to BIS on
export controls on emerging technologies 

  – Jan. 11 – deadline for comments to ITC on potential import restrictions on industrial automation systems

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* Authors: Wim Nauwelaerts, Esq.,
wnauwelaerts@sidley.com, +32 2-504-6210; and Paul Greaves, Esq.,
pgreaves@sidley.com, +32 2-504-6461. Both of Sidley Austin LLP.
On December 17, 2018, European Commission Decision (EU) 2018/1996 (the ‘Decision‘) was published in the Official Journal of the European Union. The Decision lays down rules designed to reconcile the rights of individuals respecting their personal data, with the need for effective trade defence and trade policy investigations in the EU.
The power to adopt the Decision is provided for by
EU Regulation 2018/1725 (the ‘
Regulation‘), which regulates the processing of personal data by the European Union’s institutions, bodies, offices and agencies (‘
Union Institutions and Bodies‘). The Regulation imposes obligations on Union Institutions and Bodies with respect to personal data, many of which reflect the rules that the EU General Data Protection Regulation (the ‘
GDPR‘) imposes on companies, individuals and other organizations. The rules imposed by the Regulation include:
  – Obligations to provide certain ‘transparency’ information to individuals when processing those individuals’ personal data;
  – Obligations to comply with requests from individuals where they wish to, for example, access their personal data, have such personal data deleted, or restrict the processing of their personal data; and
  – Obligations to inform individuals, in certain circumstances, where there has been a data breach involving those individuals’ personal data.
The Decision recognises that during trade defence and trade policy investigations, the European Commission (the ‘
Commission‘) will inevitably collect and process personal data (for example, during verification visits). In some circumstances, the Commission’s compliance with certain obligations under the Regulation could jeopardize the Commission’s trade defence and trade policy activities. The Decision therefore sets out, for example:
  – Rules to be followed by the Commission to inform individuals of the processing of their personal data when the Commission is conducting those investigations;
  – The conditions under which the Commission can restrict the application of certain rights and obligations provided for by the Regulation; and
  – Additional requirements to be complied with where the Commission restricts the application of those rights and obligations. This includes a requirement on the Commission to keep a record which, amongst other things, sets out the justification for the restriction.

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9. ECS Presents “Seminar Level II: Managing ITAR/EAR Complexities” in Scottsdale, AZ on 26-27 Mar 

* What: Seminar Level II – Managing ITAR/EAR Complexities; Scottsdale, AZ
* When: March 26-27, 2019
* Sponsor: Export Compliance Solutions (ECS)
* ECS Speaker Panel:  Suzanne Palmer, Lisa Bencivenga
* Register here or by calling 866-238-4018 or e-mail spalmer@exportcompliancesolutions.com

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10. ECS Presents “Web Meeting Series – How to Submit the Winning License Application for your Foreign National Employees”, 16 Jan 
(Source: Suzanne Palmer, spalmer@exportcompliancesolutions.com)
* What: Web Meeting Series – How to Submit the Winning License Application for your Foreign National Employees
* When: January 16, 2019; 1:00-2:30 p.m. EST
* Where: Online
* Sponsor:  Export Compliance Solutions & Consulting (ECS)
* ECS Instructors: Suzanne Palmer, Melva Exner
* Register here or by calling 866-238-4018 or by emailing spalmer@exportcompliancesolutions.com.

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List of Approaching Events: 66 Events Posted This Week, Including 9 New Events
(Sources: Editor and Event Sponsors)

Published every Friday or last publication day of the week, o
ur overview of Approaching Events is organized to list c
ontinuously available training, training events, s
eminars & conferences, and 
Please, submit your event announcement to Alexander Witt, Events & Jobs Editor (email: 
), composed in the below format:

#” = New or updated listing  

Continuously Available Training
* E-Seminars: “US Export Controls” / “Defense Trade Controls“; Export Compliance Training Institute; danielle@learnexportcompliance.com 

* Webinar: ”
Company-Wide US Export Controls Awareness Program“; Export Compliance Training Institute;

* E-Seminars: “ITAR/EAR Awareness“; Export Compliance Solutions;
* Online: “Simplified Network Application Process Redesign (SNAP-R)“; Commerce/BIS; 202-482-2227
* E-Seminars: “Webinars On-Demand Library“; Sandler, Travis & Rosenberg, P.A.
* Online: “International Trade Webinars“; Global Training Center
Online: “On-Demand Webinars“; “General Training“; Center for Development of Security Excellence; Defense Security Service (DSS)
* Online: “ACE Reports Training and User Guide“; DHS/CBP

* Online: ”
Increase Your International Sales – Webinar Archive“; U.S. Commercial Service

* Web Form: “Compliance Snapshot Assessment“; Commonwealth Trading Partners (CTP)
* Online: “
Customs Broker Exam Prep Course
“; The Exam Center
Seminars and Conferences


Jan 15: Arlington, VA; “
Voluntary Disclosure/Voluntary Self-Disclosure Seminar
“; SIA

Jan 21-24: San Diego, CA; “ITAR Defense Trade Controls / EAR Export Controls Seminar”; ECTI; 540-433-3977

* Jan 28-Apr 8: Wilmington, CA; “
Customs Brokers License Exam Course
;” FTA

Jan 29: Rotterdam, The Netherlands; “
Awareness training Export Control, Dual-use en Sancties

Jan 29-30: Toronto, ON; “U.S. Export & Re-Export Compliance for Canadian Operations;” The Canadian Institute

* Jan 30-31, 2019: Pittsburgh, PA; “
Complying with U.S. Export Controls
“; Commerce/BIS

* Jan 30-31: Washington, DC; “
5th National Forum on CFIUS
;” American Conference Institute (ACI)
Feb 5; Bruchem, the Netherlands; “
Designing an Internal Compliance Program for Export Controls & Sanctions
“; Full Circle Compliance 

* Feb 6-7: Scottsdale, AZ;

Complying with U.S. Export Controls
“; Commerce/BIS
Feb 6-7: Washington , D.C.; “International Technology Transfers, Cloud Computing & Deemed Export Compliance“; American Conference Institute

* Feb 11-12: Orlando, FL; “
Boot Camp: Achieving ITAR/EAR Compliance
“; Export Compliance Solutions (ECS)

* Feb 12-13: Washington, D.C.; “
2019 Legislative Summit
“; National Association of Foreign Trade Zones (NAFTZ)

* Feb 13: Southampton; “
UK Export Control Awareness Breakfast
“; Hampshire Chamber of Commerce, ECJU, and Trethowans LLP

* Feb 18-21: Orlando, FL; “
ITAR Defense Trade Controls / EAR Export Controls Seminar

* Feb 26-27: Miami, FL; “
Complying with U.S. Export Controls
“; Commerce/BIS

Mar 4-6: Savannah, GA; “
2019 Winter Back to Basics Conference
“; SIA

* Mar 5-6: San Diego, CA; “
Complying with U.S. Export Controls
“; Commerce/BIS

Mar 5-7:  Orlando, FL; “
‘Partnering for Compliance’ Export/Import Control Training and Education Program
“; Partnering for Compliance

* Mar 6-7: San Diego, CA;

Complying with U.S. Export Controls
“; Commerce/BIS

 Mar 9: Orlando, FL; “
Customs/Import Boot Camp
;” Partnering for Compliance

* Mar 12-14: Dallas, TX;

Complying with U.S. Export Controls
“; Commerce/BIS
* Mar 12-14: Dallas, TX;

How to Build an Export Compliance Program
“; Commerce/BIS

* Mar 18-21: Las Vegas, NV; “
ITAR Defense Trade Controls / EAR Export Controls Seminar

* Mar 26-27: Scottsdale, AZ; “
Seminar Level II: Managing ITAR/EAR Complexities
“; Export Compliance Solutions

Mar 27-28: San Francisco, CA; “Global Encryption, Cloud & Cyber Trade Controls;” American Conference Institute

* Apr 1-4: Washington, DC;ITAR Defense Trade Controls / EAR Export Controls Seminar“; ECTI

* Apr 3-4: Denver, CO;

Complying with U.S. Export Controls
“; Commerce/BIS
Apr 9: Bruchem, The Netherlands; “Awareness Course U.S. Export Controls: ITAR & EAR from a Non-U.S. Perspective“; Full Circle Compliance
* Apr 23-24: Portsmouth, NH;

Complying with U.S. Export Controls
“; Commerce/BIS
Apr 25: Portsmouth, NH;

Technology Controls
“; Commerce/BIS

 Apr 30-May 1: Nashville, TN: “Seminar Level III-Mastering ITAR/EAR Challenges“; Export Compliance Solutions (ECS);

May 2-3: Washington DC; “Economic Sanctions Enforcement and Compliance;” American Conference Institute

* May 5-7: Savannah, GA; “2019 Spring Seminar“; National Association of Foreign Trade Zones (NAFTZ)

May 6-7: Atlanta, GA; “
2019 Spring Conference
“; SIA
May 7: Bruchem, The Netherlands; “An Introduction to EU / Dutch Dual-Use and Military Export Controls“; Full Circle Compliance

* Jun 5-6: Seattle, WA; “
Complying with U.S. Export Controls
“; Commerce/BIS

Jun 10: Cleveland, OH; “
Letters of Credit
“; Global Training Center
Jun 11: Cleveland, OH; “
Export Doc & Proc
“; Global Training Center
Jun 12: Cleveland, OH; “
Tariff Classificatio
n“; Global Training Center
Jun 13: Cleveland, OH; “
NAFTA Rules of Origin
“; Global Training Center
Jun 14: Cleveland, OH; “
Incoterms® 2010 Rules
“; Global Training 
* Jun 17-20: San Diego, CA; “ITAR Defense Trade Controls / EAR Export Controls“; ECTI

Jul 8 – 10: National Harbour, MD; “
2019 Summer Back to Basics Conference
“; SIA

Jul 10-11: Seattle, WA: “Seminar Level I-Boot Camp: Achieving ITAR/EAR Compliance“; Export Compliance Solutions (ECS);

* Aug 20-21: Cincinnati, OH;

Complying with U.S. Export Controls
“; Commerce/BIS

* Aug 20-21: Milpitas, CA;

Complying with U.S. Export Controls
* Aug 22: Milpitas, CA:

Encryption Controls

* Sep 8-11: Chicago, IL; “2019 Annual Conference and Exposition“; National Association of Foreign Trade Zones (NAFTZ)

Sep 17-19: Annapolis, MD; “
The ECS 2nd Annual ITAR/EAR Symposium
“; ECS
Oct 1: Bruchem, The Netherlands; “The Export Administration Regulations (EAR) from a non-U.S. Perspective“; Full Circle Compliance

Oct 28-29: Washington D.C.; “
2019 Fall Advanced Conference
“; SIA
Nov 26: Bruchem, The Netherlands; “The International Traffic in Arms Regulations (EAR) from a non-U.S. Perspective“; Full Circle Compliance
# Dec 4-5: New York, NY; “10th Annual New York Forum on Economic Sanctions;” American Conference Institute 


Jan 16: Webinar: “Supply Chain Symposium 2019: Mandatory FAR Flow-Down Clauses and Best Practices“; Public Contracting Institute

* Jan 17: Webinar: “Sanctions & Export Controls for Non-U.S. Companies“; Akin Group

Jan 22: Webinar: “Trade in Turmoil [Monthly Update];” Sandler Travis & Rosenberg, P.A.


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. Bartlett’s Unfamiliar Quotations

(Source: Editor)
* Henry George Bohn (4 Jan 1796 – 22 Aug 1884; was a British publisher. He is principally remembered for the Bohn’s Libraries which he inaugurated. These were begun in 1846, targeted the mass market, and comprised editions of standard works and translations, dealing with history, science, classics, theology and archaeology.)
  – “Violence in the voice is often only the death rattle of reason in the throat.”
* Paramahansa Yogananda (5 Jan 1893 – 7 Mar 1952; born Mukunda Lal Ghosh, was an Indian yogi and guru who introduced millions of Indians and westerners to the teachings of meditation and Kriya Yoga through his organization Yogoda Satsanga Society of India and Self-Realization Fellowship. In 1946, he published his autobiography, titled Autobiography of a Yogi which is on the list of the “100 best spiritual books of the 20th Century.” The book has been regularly reprinted ever since, and is known as “the book that changed the lives of millions.”)
 – “The season of failure is the best time for sowing the seeds of success.”
  – “Remain calm, serene, always in command of yourself. You will then find out how easy it is to get along.”
Friday funnies: 
* Never criticize someone until you have walked a mile in their shoes.  That way, when you criticize them, you’ll be a mile away, and you’ll have their shoes.
* Q. What do Alexander the Great and Winnie the Pooh have in common?
   A. Same middle name.
* I couldn’t believe that the highway department accused my son of being a thief.  But when I got home, all the signs were there.

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EN_a213. Are Your Copies of Regulations Up to Date?
(Source: Editor)

The official versions of the following regulations are published annually in the U.S. Code of Federal Regulations (C.F.R.), but are updated as amended in the Federal Register.  The latest amendments to applicable regulations are listed below.

: 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  

: 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.]
: 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
  – 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 
.  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 

: DoD 5220.22-M. Implemented by Dep’t of Defense.
  – 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 

: 10 CFR Part 810; Implemented by Dep’t of Energy, National Nuclear Security Administration, under the 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.

; 10 CFR Part 110; Implemented by Dep’t of Energy, U.S. Nuclear Regulatory Commission, under the Atomic Energy Act of 1954.
  – Last Amendment: 20 Nov 2018, 10 CFR 110.6, Re-transfers.

: 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: 26 Dec 2018: 
83 FR 66514-66554
: Bump-Stock-Type Devices

: 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 
. BAFTR subscribers receive a $25 discount on subscriptions to the BITAR, please
contact us
to receive your discount code.
: 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
, 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 
  – HTS codes that are not valid for AES are available 

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. Weekly Highlights of the Daily Bugle Top Stories
(Source: Editor)

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

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* The Ex/Im Daily Update is a publication of FCC Advisory B.V., compiled by: Editor, James E. Bartlett III; Assistant Editors, Alexander P. Bosch and Vincent J.A. Goossen; and Events & Jobs Editor, 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 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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