19-0213 Wednesday “Daily Bugle'”

19-0213 Wednesday “Daily Bugle”

Wednesday, 13 February 2019

  1. State/DDTC Seeks Comments on Form DS-2032, Statement of Registration
  1. Items Scheduled for Publication in Future Federal Register Editions
  2. Commerce/BIS: (No new postings.)
  3. State/DDTC: (No new postings.)
  4. Australia DoD/DEC Posts Notice on Review of the Defence Trade Controls Act 2012
  5. Hong Kong/TID Posts Notice on End-Use/Catch-All Control
  1. Reuters: “U.S. Senators to Again Try to Pass Russia Sanctions Bill”
  2. ST&R Trade Report: “Section 301 Tariff Exclusions Now Being Accepted by CBP”
  1. M. Daniels & J. Krige: “The Fight Over High-Tech Supremacy Isn’t New. We Just Haven’t Learned Our Lesson”
  2. R. Chesney: “Project Raven: What Happens When U.S. Personnel Serve a Foreign Intelligence Agency?”
  3. T. Murphy: “U.S. – Updates to the ‘Buy American, Hire American’ Initiative”
  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 (12 Feb 2019) 
  3. Weekly Highlights of the Daily Bugle Top Stories 


Federal Register, 13 Feb 2019.) [Excerpts.]
84 FR 3846-3847: 30-Day Notice of Proposed Information Collection: Statement of Registration
* ACTION: Notice of request for public comment and submission to OMB of proposed collection of information. …
* DATES: Submit comments directly to the Office of Management and Budget (OMB) up to March 15, 2019.
* ADDRESSES: Direct comments to the Department of State Desk Officer in the Office of Information and Regulatory Affairs at the Office of Management and Budget (OMB). You may submit comments by the following methods:
   – Email: oira_submission@omb.eop.gov. You must include the DS form number, information collection title, and the OMB control number in the subject line of your message.
   – Fax: 202-395-5806. Attention: Desk Officer for Department of State.
* FOR FURTHER INFORMATION CONTACT: Direct requests for additional information regarding the collection listed in this notice, including requests for copies of the proposed collection instrument and supporting documents, to Andrea Battista, who may be reached on 202-663-3136 or at battistaal@state.gov.
  – Title of Information Collection: Statement of Registration.
  – OMB Control Number: 1405-0002.
  – Type of Request: Revision of a Currently Approved Collection.
  – Originating Office: Directorate of Defense Trade Controls (DDTC).
  – Form Number: DS-2032.
  – Respondents: Respondents are any person/s who engages in the United States in the business of manufacturing or exporting or temporarily importing defense articles.
  – Abstract: Pursuant to Part 122 of the International Traffic in Arms Regulation (ITAR), and section 38 of the Arms Export Control Act, 22 U.S.C. 2778, any person who engages in the United States in the business of manufacturing or exporting or temporarily importing defense articles or furnishing defense services is required to register with the Department of State, Directorate of Defense Trade Controls (DDTC). Pursuant to Part 129 of the ITAR, any U.S. person wherever located, and any foreign person located in the United States or otherwise subject to the jurisdiction of the United States, who engages in the business of brokering activities, is required to register with DDTC. DDTC uses the information provided by registrants to meet the mandates described in Part 122 and Part 129 of the ITAR. As appropriate, such information may be shared with other U.S. Government entities. This information is currently used in the review and action on registration requests and to ensure compliance with defense trade laws and regulations. …
  Anthony M. Dearth, Chief of Staff, Directorate of Defense Trade Controls, U.S. Department of State.
* * * * * * * * * * * * * * * * * * * *


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


[No items of interest noted today.]  

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

Commerce/BIS: (No new postings.)


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

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

Australia DoD/DEC, 13 Feb 2019.)
The Report of the Independent Review of the 
Defence Trade Controls Act 2012 was tabled in Parliament on 13 February 2019. The report is available
The initial Government response to the Report was also tabled and is available

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

Hong Kong Trade and Industry Department, 13 Feb 2019.)
This circular seeks to remind traders of the import / export licensing requirement for articles or documents due to their end-use, which is commonly known as “End-use” or “Catch-all” Control.    
The Legal Basis
In accordance with the Import and Export Ordinance (Chapter 60, Laws of Hong Kong) and the Import and Export (Strategic Commodities) Regulations (Cap 60G) (“the Regulations”), articles specified in the four Schedules to the Regulations are subject to licensing requirements.  Schedule 1 is the full list of strategic commodities subject to import and export licensing requirements.  Schedule 2 extracts from Schedule 1 the more sensitive strategic commodities for which import and export licensing requirements are imposed even if they are only “articles in transit” through Hong Kong.  Schedules 3 and 4 are the legal basis for “End-use” or “Catch-all” Control.

End-use / Catch-all Control
As provided by the Regulations and its Schedules 3 and 4 (
Appendix A), any articles or technological documents are subject to import and export licensing control, insofar as the importer / exporter knows or suspects that they will be or may be used for activities related to nuclear, chemical or biological weapons or missile capable of delivering them (i.e., weapons of mass destruction (“WMD”) purposes).  In other words, even for articles / documents which are not listed strategic commodities on Schedule 1 to the Regulations (e.g., low-end dual-use goods like test equipment, electronics parts, machine tools, etc. which are commonly available in the market), their import / export must be covered by licences if they will be or may be used for WMD purposes.
Know the Customer, End-user and End-use
For each and every business transaction / order / enquiry, traders must make their best efforts to check and get to know the customer, the end-user and the intended end-use of the articles / documents.  Traders are strongly advised to conduct at least the following:
  – Customer and End-user screening: to determine the bona fides of the customer / end-user and whether they are subject to any sanction / embargo / special restrictions by the United Nations or the government(s) of the articles’ original exporting country (place);
  – End-use screening: to determine the legitimacy of the stated end-use and to ensure it will not be used for WMD purposes;
  – Transaction screening: to view the transaction as a whole in order to make a judgement as to whether it is legitimate; and
  – Destination screening: to determine if the country (place) is of any specific concern, particularly whether it is subject to sanction / embargo / special restrictions by the United Nations or the government(s) of the articles’ original exporting country (place).
Results of the checking / screening together with other related information (e.g., customer’s proposed shipping arrangement) would help traders come to a judgement about the risk the articles / documents will be / may be used for WMD purposes.  In this connection, some of the factors that may indicate a dubious transaction (also known as ‘Red-flag indicators’) are set out in
Annex (pdf format) for traders’ reference.

If any business transaction / order / enquiry is suspected or considered for WMD purposes, traders are advised to seek consultation and make a licence application for Trade and Industry Department (“TID”)’s consideration (see paragraph 7 below).

Making Licence Application
To obtain an import / export licence for articles or documents which are subject to End-use / Catch-all control, traders should provide in writing to TID with the following information / supporting document(s):
  (1) the name, full address and business registration number/HKID number/passport  number of the importer and/or exporter;
  (2) the name and telephone number of the contact person;
  (3) the name and full address of the foreign exporter and/or consignee;
  (4) the name and full address of the end-user;
  (5) the specific end-use of the goods concerned;
  (6) the shipment details, e.g. foreign exporting country (place), destination, arrival date, departure date, vessel/flight/vehicle number;
  (7) the consignment details, i.e. brand name, model number, full product description, country (place) of origin, quantity and value;
  (8) if any, the authorisation type, reference number, issuing country (place), issue date of the export authorisation of foreign exporting or product’s originating country (place) and/or import authorisation of product’s final destination; and
  (9) an original end-user statement (
Appendix B) duly completed and signed by the end-user
All the above should be sent to the Customer Service Centre of Strategic Trade Controls Branch (address: Room 1619, 16/F, Trade and Industry Tower, 3 Concorde Road, Kowloon City, Hong Kong).
Sanction / Embargo / Special Restriction
As mentioned above, traders are strongly advised to conduct screenings and checks for each and every business transaction / order / enquiry.  In conducting these screenings and checks, traders may refer to the websites of the foreign government agencies and the United Nations [FN/1] for the most updated information on the persons / companies / countries / places that are subject to sanction / embargo / special restriction.  They may also contact their overseas exporters, manufacturers or the overseas licensing authorities direct for the detailed export control information in respect of individual cases.
TID’s Strategic Commodities Control System’s Website provides hyperlinks to the websites of some major foreign government agencies.  From time to time, TID organises outreach seminars on various topics of strategic trade control system.  Some are organised in collaboration with foreign government agencies.  Invitations to the seminars are announced in our website.  For reference, traders may also see the relevant page of
our website for information on previous seminars, including the presentation materials.
Section 6A of the Import and Export Ordinance stipulates that no person shall import or export any article specified in the Schedules to the Import and Export (Strategic Commodities) Regulations except under and in accordance with a licence issued by the Director-General of Trade and Industry.  Any person who contravenes the provision commits an offence and is liable:
  (1) on summary conviction to a fine of HK$500,000 and to imprisonment for two years; and 
  (2) on conviction on indictment to an unlimited fine and to imprisonment for seven years
In addition to prosecution, the Department may impose administrative actions against these persons. Such administrative actions may involve but shall not necessarily be confined to, suspension of a licence, refusal to issue a licence, debarment from all licensing facilities, etc.
If you have any enquiry concerning licensing requirements on end-use / catch-all control, please contact our Licensing Section at 2398 5575.  For specific technical questions or matters concerning classification of the goods and the pre-classification service, please contact our Classification Section at 2398 5587.  Enquiry could also be sent by fax to 2396 3070 (Licensing Section) or 3525 1526 (Classification Section) or by email to

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


NWS_a17. Reuters: “U.S. Senators to Again Try to Pass Russia Sanctions Bill”

(Source: Reuters, 13 Feb 2019.) [Excerpts.]
U.S. Republican and Democratic senators on Wednesday will introduce a bill seeking to punish Russia for meddling in U.S. elections and for its aggression in Ukraine by imposing sanctions on its banking, energy sector and foreign debt.
The bill will be introduced by Republican Senator Lindsey Graham and Democratic Senator Bob Menendez and is a tougher version of the one the two lawmakers backed last year but which failed to pass, Menendez’s office said. The bill has been seen by Reuters.
Among other things, it would impose sanctions on Russian banks that support efforts to interfere in foreign elections, sanction Russian liquefied natural gas projects outside of Russia, sanction the country’s cyber sector, impose sanctions on new sovereign debt and sanction individuals deemed to “facilitate illicit and corrupt activities, directly or indirectly, on behalf of (Russian President Vladimir) Putin.” …

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

NWS_a28. ST&R Trade Report: “Section 301 Tariff Exclusions Now Being Accepted by CBP”
As of 10 Feb 2019, U.S. Customs and Border Protection is accepting in the Automated Commercial Environment entries of products that have been excluded from the Section 301 additional tariffs on imports from China. The exclusions granted thus far, which apply only to so-called List 1 goods subject to a 25 percent additional tariff, are retroactive to July 6, 2018, and will be effective until Dec. 28, 2019. (
Click here for more information on this Section 301 case.) 
The scope of each exclusion is governed by the scope of the 10-digit HTSUS
subheadings and product descriptions in the official notice, not by the product descriptions set out in any particular exclusion request. Further, exclusions are available for any product that meets the description in the official notice, regardless of whether the importer filed an exclusion request.

CBP states that when submitting entries for excluded products, importers should report HTSUS 9903.88.05 in addition to the regular HTSUS chapters 84, 85, and 90 classification. However, importers should not submit the corresponding Chapter 99 number for the Section 301 duties when HTSUS 9903.88.05 is submitted.
Refunds of Section 301 tariffs paid on imports of excluded products on or after July 6, 2018, will not be automatic. Instead, importers can request such refunds by filing post-summary corrections following the instructions set forth above. If the entry has already liquidated, importers may protest the liquidation.

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


Fortune, 12 Feb 2019.) [Excerpts.]
* Authors: Mario Daniels, Visiting Professor at the BMW Center for German and European Studies at Georgetown University; John Krige, Professor at the School of History and Sociology at Georgia Tech.
The U.S. is intensifying its competition with China for high-tech supremacy. Just two weeks ago, the Department of Justice 
released a major indictment against Chinese telecommunications company Huawei for allegedly violating U.S. sanctions against Iran. But that’s just one piece of a much larger puzzle.
Over the last two years, the U.S. has invoked a wide range of instruments to restrict Chinese access to cutting edge technology. Conditions for foreign investment in U.S. based high-tech firms were 
tightened. It has become more 
difficult for Chinese graduate students to get visas to study in sensitive fields like robotics. And concerns about China acquiring more advanced A.I. have led to 
calls for stronger controls on exports of this technology. …
But the confrontational approach the Trump administration is now using against China is not a new strategy. The current U.S. policies echo those of the 1980s …

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

Lawfare, 11 Feb 2019.) [Excerpts.]
* Author: Robert “Bobby” Chesney, Professor in Law and Associate Dean for Academic Affairs at the University of Texas School of Law.
It’s been known since 2012 that a Baltimore-based company called Cyber Point had a contract with the United Arab Emirates (UAE) to assist its newly-established signals intelligence agency (then called the National Electronic Security Authority) with “advice on cyberdefense and policy,” as Ellen Nakashima
reported at the time for the Washington Post. Later, there were suggestions that Cyber Point might be involved in helping the UAE service acquire malware that the UAE used to support surveillance activities that included monitoring of political opponents. And now, Reuters has a remarkable piece from Chris Bing and Joel Schactman, published last week, that goes deeper and raises important questions about the role of U.S. citizens in working for foreign intelligence agencies. …
What policy concerns, precisely, does this story illustrate? …
[Editor’s Note: due to copyright restrictions, we are not authorized to include the entire item. To read the remaining sections, please click on the source link below the item title.]

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

International Trade Compliance Blog, 11 Feb 2019.)
* Author: Ted Murhpy, Esq., Baker & Mckenzie,
There have been two recent updates to the ‘Buy American, Hire American’ initiative (aka ‘the better enforce our government procurement rules of origin’ initiative) that we believe will have consequences for companies that sell products to the government directly or indirectly.
The first is a recent United States General Accountability Office (GAO) report entitled ”
Buy American Act: Actions Needed to Improve Exception and Waiver Reporting and Selected Agency Guidance” (December 2018).  The GAO looked at how the Buy
American Act of 1933 has been implemented in the $500+ billion federal procurement market.  In particular, the GAO examined (i) how the federal government procures foreign (non-US) products through
Buy American Act waivers and exceptions, and (ii) how 4 selected agencies (DOD, HHS, DHS, and the VA) provide training and guidance to implement the
Buy American Act.  In short, the GAO concluded that, of the $508 billion the federal government spent in FY2017, approximately $7.8 billion was spent on foreign end products (using waivers, exceptions or concluding that the Buy American Act did not apply).  That said, the GAO also found that, due to limitations in how the data is reported/captured, the inconsistent training provided contracting officers across the agencies, and the mistakes uncovered in the sample contracts that were reviewed, this amount could well be higher.  In short, federal agencies are not doing as well as they should in applying the
Buy American Act provisions to their procurements.
The second is the executive order President Trump signed late last month entitled ”
Executive Order on Strengthening Buy-American Preferences for Infrastructure Projects” (January 31, 2019).  While this order generally restates the principles set forth in the previous order, it extends those principles to the financial assistance federal agencies provide to non-federal recipient organizations (i.e., loans, loan guarantees, grants, etc.).  According to the Administration, federal agencies award more than $700 billion a year in financial assistance to such organizations and that, often, the recipients do not include Buy American considerations in their contracts.  This executive order requires federal agencies to “encourage recipients of new Federal financial assistance awards . . . to use, to the greatest extent practicable, iron and aluminum as well as steel, cement, and other manufactured products produced in the United States in every contract, subcontract, purchase order, or sub-award that is chargeable against such Federal financial assistance award.”  In short, federal agencies that provide financial assistance to non-federal entities (e.g., state or municipalities) for projects need to “encourage” the entities that received federal financial assistance to include Buy American-type provisions in their contracts.
As a result of these developments, we expect that
Buy American Act/Trade Agreements Act compliance will become an even bigger enforcement priority.  We expect that contracting entities, both at the federal and sub-federal level, will begin scrutinizing certifications as to country of origin/compliance more closely than has generally been done in the past.  Accordingly, if you are selling directly or indirectly to the government, we recommend that you review your processes for ensuring that your “Buy America” certifications are accurate and auditable (i.e., make sure you are conducting the right analysis and retaining the right supporting documentation).  Companies that are confident in their programs should have a distinct advantage in this space for the foreseeable future.

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


* Thomas Malthus (Thomas Robert Malthus; 13 Feb 1766 – 23 Dec 1834; was an English cleric and scholar.  In his 1798 book An Essay on the Principle of Population, Malthus observed mankind had a propensity to use abundance of food production for population growth rather than for maintaining a high standard of living, a view that has become known as the “Malthusian trap” or the “Malthusian spectre”.)
 – “Each pursues his own theory, little solicitous to correct or improve it by an attention to what is advanced by his opponents.”

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

. 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 2019: 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 Update: 12 Feb 2019: 
Harmonized System Update 1901 [contains 397 ABI records and 89 harmonized tariff records.] 

  – HTS codes for AES are available here.
  – HTS codes that are not valid for AES are available here.

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

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 6,500 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.

* 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