19-0122 Tuesday “Daily Bugle'”

19-0122 Tuesday “Daily Bugle”

Tuesday, 22 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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[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: (No new postings.)
  4. EU Implements Restrictive Measures Concerning Situation in Ukraine and North Korea
  5. Hong Kong/TID Posts 6 Dec 2018 Seminar Materials on Strategic Trade Control
  1. Expeditors News: “WCO Members Discuss Best Practices in Transit”
  1. M.E. Leiter, I.A. Schlager & D.L. Vieira: “Enhanced US Export Controls and Aggressive Enforcement Likely to Impact China”
  2. M. Volkov: “Merging Trade Compliance and Ethics and Compliance Silos”
  1. ECS Presents “Boot Camp: Achieving ITAR/EAR Compliance” on 11-12 Feb in Orlando, FL
  1. Bartlett’s Unfamiliar Quotations 
  2. Are Your Copies of Regulations Up to Date? Latest Amendments: DHS/Customs (14 Jan 2019), 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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Official Journal of the European Union, 22 Jan 2019.)
* Council Implementing Regulation (EU) 2019/92 of 21 January 2019 implementing Regulation (EU) No 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine
* Council Implementing Regulation (EU) 2019/93 of 21 January 2019 implementing Regulation (EU) 2017/1509 concerning restrictive measures against the Democratic People’s Republic of Korea
* Council Decision (CFSP) 2019/95 of 21 January 2019 amending Decision 2014/145/CFSP concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine
* Council Decision (CFSP) 2019/96 of 21 January 2019 amending Decision (CFSP) 2016/849 concerning restrictive measures against the Democratic People’s Republic of Korea

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Hong Kong Trade and Industry Department, 22 Jan 2019.)
The Trade and Industry Department of the Government of the HKSAR and the Department of Commerce of the US Government jointly organised a seminar on strategic trade control on 6 Dec 2018, introducing the strategic trade control systems in Hong Kong and the US.
click here for the seminar information and materials.

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NWS_a16. Expeditors News: “WCO Members Discuss Best Practices in Transit”
(Source: Expeditors News, 21 Jan 2019.)
Between January 8, 2019 and January 10, 2019, select members of the World Customs Organization (WCO) Asia-Pacific region met in Faridabad, India for a workshop to discuss best practices in the area of transit.
According to the WCO, the workshop covered all sections of the WCO Transit Guidelines that launched in 2017. Participants shared and discussed, “…good practices, challenges and measures for further improvement of the various aspects of transit.”
The workshop was the fifth in a series of regional events organized by the WCO.
The WCO press release may be found
The WCO Transit Guidelines may be found

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* Authors: Michael E. Leiter, Esq.,
michael.leiter@skadden.com, +1 202-371-7540; Ivan A. Schlager, Esq.,
ivan.schlager@skadden.com, +1 202-371-7810; and Donald L. Vieira, Esq.,
donald.vieira@skadden.com, +1 202-371-7124. All of Skadden, Arps, Slate, Meagher & Flom LLP.
Tariffs targeting Chinese imports into the United States garnered headlines throughout 2018. (See ”
Tariff-Related Measures.”) However, during the latter part of the year, the U.S. government more quietly initiated efforts that in 2019 and beyond could be more effective than tariffs in leveraging changes to Chinese behavior, particularly with respect to intellectual property protection. These efforts also could severely constrain Chinese growth, thereby preserving U.S. technological leadership. The moves are particularly aimed at the business sectors that comprise the “Made in China 2025” initiative. While these quieter efforts could benefit U.S. companies engaging with China over the long term, in the short term they are likely to increase the regulatory burdens associated with a variety of business relationships with China, including collaborative research and development projects or joint venture arrangements.
Specifically, the U.S. government:
  (1) proposed that a wide array of emerging technologies be subjected to enhanced controls under the Export Administration Regulations (EAR), which are administered by the Department of Commerce’s Bureau of Industry and Security (BIS);
  (2) initiated a comprehensive review of the Commerce Control List (CCL) under the EAR to assess current controls on items to embargoed destinations, such as China;
  (3) sanctioned a Chinese semiconductor manufacturer under export-related authorities without a corollary finding of EAR violations; and
  (4) publicized significant enforcement matters pertaining to Chinese entities, including, in particular, Huawei Technologies Co., Ltd.
Treatment of Emerging and Foundational Technologies
On August 13, 2018, President Donald Trump signed into law the John S. McCain National Defense Authorization Act (NDAA) for Fiscal Year 2019. A key focus of the law is the protection of U.S. technological advances through closer scrutiny of technology transfers to foreign persons and their implications for U.S. national security and foreign policy. In addition to the Foreign Investment Risk Review Modernization Act, which enhanced reviews of foreign investment, the NDAA included the Export Control Reform Act (ECRA). The ECRA directed the establishment of a formal, ongoing interagency process to identify and review “emerging and foundational technologies that are essential to the national security of the United States” and required appropriate export controls for these technologies. The process involves the Departments of Commerce, Defense, State and Energy, along with other federal agencies as appropriate, and will identify “emerging and foundational technologies” through publicly available and classified information, as well as information derived from Commerce advisory committees and the Committee on Foreign Investment in the United States (CFIUS).
A key focus of the law is the protection of U.S. technological advances through closer scrutiny of technology transfers to foreign persons and their implications for U.S. national security and foreign policy.
On November 19, 2018, BIS published an
advance notice of proposed rulemaking soliciting comments on the criteria to be used to identify emerging technologies that are essential to U.S. national security. Such technologies could include those that have potential uses in connection with conventional weapons, intelligence collection, weapons of mass destruction or terrorist applications; or could provide the United States with a qualitative military or intelligence advantage. In publishing the notice, BIS compiled a list of technologies (
e.g., additive manufacturing, artificial intelligence and machine learning, biotechnology, microprocessors, robotics) for which export controls are only in place for comprehensively embargoed countries (such as Iran), countries designated as supporters of international terrorism (such as Sudan), and restricted end users or end uses. BIS says it will assess this representative list of technologies through the interagency process to identify any specific emerging technologies that are important to U.S. national security, for which effective controls can be implemented without negatively impacting U.S. leadership in the science, technology, engineering or manufacturing sectors. Enhanced licensing requirements are likely to inhibit exports of these technologies to China, thereby curtailing China’s ability to rapidly scale domestic development in certain key industries.
Comments were due by January 10, 2019. As a next step, BIS will publish further proposed rules regarding the controls to be applied to specific emerging technologies, though there is no established timetable for the issuance of these rules.
BIS is expected to publish a similar notice soliciting comments regarding the identification of foundational technologies in early 2019. It has publicly suggested that such technologies are likely to be drawn from those that are currently subject only to unilateral anti-terrorism controls due to their removal from various multilateral control lists.
Comprehensive CCL Review
The ECRA also required the Departments of Commerce, State, Defense and Energy, along with other federal agencies as appropriate, to conduct an immediate review of the license requirements for the export, re-export and in-country transfer of items to countries subject to a comprehensive arms embargo (including China). The focus of this review is to assess existing export controls on items that currently do not require an export license and items destined for military end uses or end users. Commerce must implement any changes to existing export controls by May 2019. This review is likely to result in tighter controls on exports, re-exports and in-country transfers to China, in particular with an emphasis on technology with potential military applications and with military or government end users. As a consequence of this review, BIS likely will, for example, require licenses for items that currently do not require them or implement denial policies for license applications that otherwise would have been considered on a case-by-case basis.
Addition of Fujian Jinhua to BIS Entity List
Effective October 30, 2018, BIS added Fujian Jinhua Integrated Circuit Company, Ltd., a state-owned Chinese semiconductor manufacturer, to the BIS Entity List because the company “poses a significant risk of becoming involved in activities that could have a negative impact on the national security interests of the United States.” The BIS Entity List comprises businesses, research institutions, government and private organizations, individuals, and other types of legal persons subject to specific license requirements for the export, re-export and in-country transfer of specified items that are supplemental to those found elsewhere in the EAR.
As a consequence, a specific BIS license is required for any person – whether located in the United States or not – to export, re-export or transfer (in-country) any commodities, software or technology that are “subject to the EAR” to Fujian Jinhua. The company is heavily reliant on U.S.-sourced hardware, and the impact of this action could cripple its ability to manufacture semiconductors. Any such license application will be reviewed in accordance with a policy of presumptive denial.
Notably, the listing of Fujian Jinhua did not appear to be based on any specific activity by the company in violation of the EAR. Rather, it appeared to be tied to the November 1, 2018, indictment by a federal grand jury of Fujian Jinhua, among others, for alleged crimes related to a conspiracy to steal, convey and possess the stolen trade secrets of Micron Technology, Inc., an American semiconductor company. This novel offensive use of the BIS Entity List, even in the absence of a specific violation of the EAR, may be a harbinger of how the U.S. government intends to punish alleged trade secret theft in the future.
The BIS Entity List listing and indictment are consistent with the prior blocking of Chinese-backed semiconductor-related transactions by Presidents Barack Obama and Trump in accordance with recommendations made by CFIUS as well as the increased focus on the protection of U.S. semiconductor technology as embodied in the January 2017 “Report to the President: Ensuring Long-Term U.S. Leadership in Semiconductors,” by the President’s Council of Advisors on Science and Technology. The actions also are consistent with the November 1, 2018, U.S. Department of Justice (DOJ) announcement of the “China Initiative,” which will be dedicated to the aggressive investigation and prosecution of Chinese companies for alleged trade secret theft, economic espionage, Foreign Corrupt Practices Act offenses and other violations of U.S. law. Taken together, these measures reflect a coordinated and sustained U.S. government response to Chinese economic development, particularly with respect to the “Made in China 2025” initiative – restricting Chinese access to sensitive U.S. technology, either via export or investment, and aggressively pursuing alleged trade secret theft, which will curb China’s ability to rapidly scale development in certain key industries.
Notable Chinese-Related Export Enforcement
Bringing a notable U.S. export controls and sanctions-related enforcement action to a close in early December 2018, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced that Yantai Jereh Oilfield Services Group Co., Ltd. had agreed to pay $2.77 million to settle the potential civil liability stemming from violations of the Iranian Transactions and Sanctions Regulations. Yantai Jereh was alleged to have exported or re-exported, or attempted to export or re-export, U.S.-origin goods ultimately intended for end users in Iran by way of China. Yantai Jereh also allegedly exported certain U.S.-origin items with knowledge or reason to know that the items were intended for production of, for commingling with or for incorporation into goods made in China to be supplied, transshipped or re-exported to end users in Iran. Yantai Jereh, which also appears on the BIS Entity List, agreed to pay $600,000 to BIS for the same conduct.
Also in early December 2018, Canadian authorities, at the behest of the DOJ, arrested the chief financial officer of Huawei, allegedly in connection with ongoing OFAC and BIS investigations into U.S. sanctions violations. Like its competitor Zhongxing Telecommunications Equipment Corporation (ZTE), which was added to and subsequently removed from the BIS Entity List and remains subject to a suspended denial order, Huawei is alleged to have engaged in re-exports of U.S.-origin equipment to embargoed destinations, such as Iran. However, it is believed that Huawei will not be listed, primarily due to its much larger size and the adverse economic consequences such a listing would have for U.S. suppliers. Nevertheless, the threat of such a listing may well be sufficient leverage to extract trade-related concessions from the Chinese government. And Huawei is not likely to escape entirely. Indeed, it has been widely reported that BIS already has declined to renew an export license required by Huawei’s Silicon Valley research and development unit, and potentially substantial penalties may yet be imposed.
BIS clearly is putting Chinese companies on notice that it will vigorously pursue export-related violations, particularly those involving U.S.-embargoed countries, and has expressed a willingness – as evidenced by the ZTE action – to choke off critical supplies of U.S.-origin hardware, software and technology. U.S. suppliers should be especially mindful of this latter risk as well as of more aggressive Chinese retaliation, including, for example, delays in processing regulatory approvals and, as with the Huawei matter, detentions of personnel traveling in China.

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Volkov Law Group Blog, 22 Jan 2019. Reprinted by permission.)
* Author: Michael Volkov, Esq., Volkov Law Group,
mvolkov@volkovlaw.com, 240-505-1992.
Business operations can be riddled with inefficiencies. It is easy to spot them inside a company. The same rule applies to ethics and compliance programs.
Given a specific global business configuration, ethics and compliance programs have to be designed efficiently to support the business. For some reason, a number of compliance programs have been built with two separate silos – one for trade compliance and one for other risks.
From my perspective, such an organization makes no sense whatsoever. An ethics and compliance program should include as part of its overall responsibilities a trade compliance program.
Depending on a company’s business (e.g. ITAR/military items, EAR/dual use, and/or sanctions), the extent of a trade compliance program can vary significantly. Whatever scope is required, a trade compliance program should sit within the company’s ethics and compliance program so that it is part of the overall risk assessment, policies and procedures, training, auditing, and monitoring functions. By definition, separation of these operations contains duplicative functions that are bettered addressed through a “single” and larger ethics and compliance program.
A trade compliance program includes specific policies and procedures that are employed to address anti-boycott, licensing, export control, sanctions and other risks.   All of these issues have to be addressed as part of the overall company culture of compliance. To separate the two functions into separate silos is difficult to justify.
The US State Department, Treasury Department, Commerce Department, and Justice Department expect companies to design and implement effective compliance programs in response to a company’s risk profile. Such programs are essential for companies to maximize the potential benefits from a voluntary disclosure program.
The elements of trade compliance programs are the same as compliance programs keyed to anti-corruption, anti-money laundering, and other risks. As a result, a company can achieve basic economies of scope and scale by conducting a risk assessment to address trade compliance and implementing a compliance program in response to a risk-ranking analysis.
The Treasury Department’s Office of Foreign Asset Control intends to issue updated guidance on compliance program expectations. As OFAC’s sanctions enforcement program matures, companies should be mindful of addressing trade compliance risks. A paper or non-existent trade compliance program will only exacerbate a potential enforcement action or voluntary disclosure by inviting government enforcement agencies to mandate specific remediation and guarantee some form of ongoing monitoring of a company’s compliance efforts.
To gain efficiencies and ensure proactive compliance, companies have to break down the two silos into a single – ethics and compliance program. There is no rational justification for continuing the separate treatment of company risks and it is important to address legal and compliance risks with a holistic approach.
If the compliance profession is truly committed to the creation and promotion of a specific expertise, then it is time for companies to recognize this fact. Compliance professionals have a unique perspective as subject matter experts, and there is nothing so unique or special about trade compliance that could justify continued separation of trade compliance from other significant risks.

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TE_a19. ECS Presents “Boot Camp: Achieving ITAR/EAR Compliance” on 11-12 Feb in Orlando, FL

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

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 Francis Bacon (22 Jan 1561 – 9 Apr 1626; was an English philosopher and statesman who served as Attorney General and Lord Chancellor of England. His works are credited with developing the scientific method. Bacon has been called the father of empiricism.  His works argued for the possibility of scientific knowledge based only upon inductive reasoning and careful observation of events in nature.)
  – “Age appears to be best in four things; old wood best to burn, old wine to drink, old friends to trust, and old authors to read.” 
  – “I will never be an old man. To me, old age is always 15 years older than I am.”
* Lord Byron (George Gordon Byron; 22 Jan 1788 – 19 Apr 1824; was a British poet, peer, politician, and leading figure in the Romantic movement. He is regarded as one of the greatest British poets, and remains widely read and influential. Among his best-known works are the lengthy narrative poems Don Juan and Childe Harold’s Pilgrimage; many of his shorter lyrics in Hebrew Melodies also became popular.
  – “There is pleasure in the pathless woods, there is rapture in the lonely shore, there is society where none intrudes, by the deep sea, and music in its roar; I love not Man the less, but Nature more.”
  – “Always laugh when you can. It is cheap medicine.”
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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: 14 Jan 2019: 84 FR 112-116: Extension of Import Restrictions Imposed on Certain Archaeological and Ecclesiastical Ethnological Material from Bulgaria; and 84 FR 107-112: Extension of Import Restrictions Imposed on Certain Archaeological Material From China 

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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