19-0415 Monday “Daily Bugle'”

19-0415 Monday “Daily Bugle”

Monday, 15 April 2019

  1. Commerce/BIS Starts Information Collection Activities Concerning Chemical Weapons Convention Declaration and Report Handbook and Forms 
  2. U.S.-China Economic and Security Review Commission Announces Public Hearing on 25 Apr in Washington DC 
  1. Items Scheduled for Publication in Future Federal Register Editions 
  2. Commerce/BIS: (No new postings.)
  3. State/DDTC: (No new postings.)
  4. Treasury/OFAC Reaches Settlement Agreements with UniCredit Group Banks in Austria, Germany, and Italy
  5. UK OFSI Publishes Sanctions Guidance Regarding Russia, South Sudan
  6. Australia DEC Announces Another Round of Outreach for 2019
  7. New Zealand Announces New Restrictions on Exports of Certain Semi-Automatic Weapons, Parts, and Magazines
  1. Reuters: “U.S. Slaps Sanctions on Four Shipping Firms, Nine Ships, Carrying Oil from Venezuela” 
  2. ST&R Trade Report: “Defense Trade, Air Cargo, Chemical Weapons Information Collections Under Review” 
  1. J.W. Boscariol & C. Francis: “Canada Prepares to Implement New Export Controls and Brokering Requirements” 
  2. O. Gonzalez: “Why Cats and Customs Brokers Hate Triennial Status Reports” 
  3. The FAQ of the Day: Shipping Defense Articles to the U.S. Government Overseas 
  1. Monday List of Ex/Im Job Openings: 147 Openings Posted This Week, Including 15 New Openings 
  1. ECS Presents “Mastering ITAR/EAR Challenges” on 30 Apr-1 May in Nashville, TN
  2. FCC Presents “An Introduction to EU / Dutch Dual-Use and Military Export Controls”, 7 May in Bruchem, the Netherlands
  1. Bartlett’s Unfamiliar Quotations 
  2. Are Your Copies of Regulations Up to Date? Latest Amendments: DHS/Customs (5 Apr 2019), DOC/EAR (11 Apr 2019), DOC/FTR (24 Apr 2018), DOD/NISPOM (18 May 2016), DOE/AFAEC (23 Feb 2015), DOE/EINEM (20 Nov 2018), DOJ/ATF (14 Mar 2018), DOS/ITAR (19 Mar 2018), DOT/FACR/OFAC (15 Mar 2018), HTSUS (2 Apr 2019) 
  3. Weekly Highlights of the Daily Bugle Top Stories 


Commerce/BIS Starts Information Collection Activities Concerning Chemical Weapons Convention Declaration and Report Handbook and Forms

Federal Register, 15 Apr 2019.) [Excerpts.]
84 FR 15178-15179: Submission for OMB Review; Comment Request
The Department of Commerce will submit to the Office of Management and Budget (OMB) for clearance the following proposal for collection of information under the provisions of the Paperwork Reduction Act (44 U.S.C. Chapter 35).
  – Agency: Bureau of Industry and Security.
  – Title: Chemical Weapons Convention Declaration and Report Handbook and Forms
  – Form Number(s): Form 1-1, Form 1-2, Form 1-2A, Form 1-2B.
  – OMB Control Number: 0694-0091.
  – Type of Review: Regular submission. …
  – Needs and Uses: The Chemical Weapons Convention Implementation Act of 1998 and Commerce Chemical Weapons Convention Regulations (CWCR) specify the rights, responsibilities and obligations for submission of declarations and reports and inspections of certain chemical facilities. This information is required for the United States to comply with the Chemical Weapons Convention (CWC), an international arms control treaty.
  – Affected Public: Business or other for-profit organizations. …
  – Respondent’s Obligation: Mandatory
This information collection request may be viewed at
reginfo.gov. Follow the instructions to view Department of Commerce collections currently under review by OMB.
  Written comments and recommendations for the proposed information collection should be sent within 30 days of publication of this notice to
Sheleen Dumas, Departmental Lead PRA Officer, Office of the Chief Information Officer, Commerce Department.

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Federal Register
, 15 Apr 2019.) [Excerpts.]

84 FR 15294: Notice of Open Public Hearing
* AGENCY: U.S.-China Economic and Security Review Commission.
* ACTION: Notice of open public hearing.
* SUMMARY: Notice is hereby given of the following hearing of the U.S.-China Economic and Security Review Commission.
The Commission is mandated by Congress to investigate, assess, and report to Congress annually on “the national security implications of the economic relationship between the United States and the People’s Republic of China.” Pursuant to this mandate, the Commission will hold a public hearing in Washington, DC on April 25, 2019 on “China in Space: A Strategic Competition?”
* DATES: The hearing is scheduled for Thursday, April 25, 2019 at 9:30 a.m.
* ADDRESSES: TBD, Washington, DC. A detailed agenda for the hearing will be posted on the Commission’s website at
www.uscc.gov. Also, please check the Commission’s website for possible changes to the hearing schedule. Reservations are not required to attend the hearing.
* FOR FURTHER INFORMATION CONTACT: Any member of the public seeking further information concerning the hearing should contact Leslie Tisdale Reagan, 444 North Capitol Street NW, Suite 602, Washington DC 20001; telephone: 202-624-1496, or via email at
lreagan@uscc.gov. Reservations are not required to attend the hearing.
* SUPPLEMENTARY INFORMATION: … This is the fourth public hearing the Commission will hold during its 2019 report cycle. This hearing will address the implications for the United States of China’s pursuit of space power as a means of strengthening its economic competitiveness, increasing its military capabilities, and raising its international status. The hearing will examine Administration views of U.S.-China space competition; China’s pursuit of global leadership in space; the role of military-civil fusion in China’s space ambitions, including China’s leveraging of U.S. and other foreign technology and talent to support its military goals; and China’s military space activities. The hearing will be co-chaired by Chairman Carolyn Bartholomew and Commissioner Michael McDevitt. Any interested party may file a written statement by April 25, 2019, by mailing to the contact above. A portion of each panel will include a question and answer period between the Commissioners and the witnesses. …
  Dated: April 10, 2019.
Daniel W. Peck, Executive Director, U.S.-China Economic and Security Review Commission.

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OGS_a13. Items Scheduled for Publication in Future Federal Register Editions
(Source: Federal Register)

 * Treasury/OFAC; NOTICES; Blocking or Unblocking of Persons and Properties [Pub. Date: 16 Apr 2019.]
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Treasury/OFAC Reaches Settlement Agreements with UniCredit Group Banks in Austria, Germany, and Italy
Treasury/OFAC, 15 Apr 2019.)
The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) today announced three separate settlements totaling $611 million with the following UniCredit Group banks: UniCredit Bank AG in Germany, UniCredit Bank Austria AG in Austria, and UniCredit S.p.A. in Italy.  The settlements resolve OFAC’s investigations into apparent violations of a number of U.S. sanctions programs, including those related to weapons of mass destruction proliferation, global terrorism, and the following countries: Burma, Cuba, Iran, Libya, Sudan, and Syria.
Between January 2007 and December 2011, UniCredit Bank AG processed over 2,000 payments totaling over $500 million through financial institutions in the United States in apparent violation of multiple U.S. sanctions programs.  During this time period, UniCredit operated U.S. dollar accounts on behalf of the Islamic Republic of Iran Shipping Lines (IRISL) and several companies owned by or otherwise affiliated with IRISL, and managed the accounts of those companies in a manner that obscured the interest or involvement of IRISL in transactions sent to or through U.S. intermediaries.  For a number of years up to and including 2011 (UniCredit Bank AG) and 2012 (UniCredit Bank Austria AG and UniCredit S.p.A.), all three banks processed payments to or through the United States in a manner that did not disclose underlying sanctioned persons or countries to U.S. financial institutions which were acting as financial intermediaries.
OFAC determined that the apparent violations largely constituted egregious cases and that the banks did not voluntarily self-disclose the apparant violations.
For more information, please visit the following web notice and settlement agreements: UniCredit Bank AG, UniCredit Bank Austria AG, and UniCredit S.p.A. 

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UK OFSI Publishes Sanctions Guidance Regarding Russia, South Sudan
UK OFSI, 15 Apr 2019.)
The UK Office of Financial Sanctions Implementation (OFSI) has published
guidance, which assists people in implementing and complying with the South Sudan (Sanctions) (EU Exit) Regulations 2019. It covers the prohibitions and requirements imposed by the regulations. It also provides guidance on best practice for:
– Complying with the prohibitions and requirements
– Enforcing them
– Circumstances where they do not apply
This guidance should be read alongside more detailed sanctions guidance published by OFSI.
In addition, OFSI created a
webpage that provides guidance on the UK’s sanctions regime on Russia, if the UK leaves the EU without a deal.

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OGS_a68. Australia DEC Announces Another Round of Outreach for 2019

Australia DEC, 10 Apr 2019.) [Excerpts.]
Australia Defense Export Controls (DEC), within the Department of Defense, will soon begin another round of Outreach for 2019.

Outreach is aimed at industry and research institutions that are involved in the export, supply, publication or other movement of military and dual-use goods and technology. The goal of this program is to raise awareness of export control law by looking at what is required of exporters, what to expect when applying, and the export landscape. This year, we will be visiting the following cities:

– Melbourne 1-2 May
– Sydney 11 June
– Adelaide 22 July
– Darwin 24 July (TBC)
– Brisbane 24 September
– Perth 3 October (TBC)
Registration and program details for our first event in Melbourne can be accessed
here. Dates, registration details and an outline of each city program, will be posted on our website in the coming months. …

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New Zealand Announces New Restrictions on Exports of Certain Semi-Automatic Weapons, Parts, and Magazines

New Zealand Foreign Affairs and Trade, 15 Apr 2019.)
Following the entry into force of the Arms (Prohibited Firearms, Magazines, and Parts) Amendment Act on 12 April 2019, the policy around the export of these prohibited items has been reassessed and aligned with the new Act. These changes are to ensure that such items that are prohibited in New Zealand are not exported to other countries where they would pose a similar risk. It will also no longer be permissible for items that are banned here to be imported solely for the purpose of re-export.
Two new criteria (numbers 13. and 17.)  have been added to the
Criteria for the Assessment of Export Applications.
Although applications for exports of items prohibited in New Zealand are likely to be declined by the Secretary of Foreign Affairs and Trade, there are some exceptions:
Transitional exceptions until the end of the amnesty period:  
  – Stock being returned by dealers to suppliers 
  – Items which are currently held at the border being returned to the supplier
  – Personal exports by people relocating overseas or possessing overseas citizenship.
Transitional exception until 31 December 2020:
  – Exports of certain items (magazines and parts) by existing manufacturing businesses and suppliers as defined by Transitional Regulation 28F
Permanent exceptions:
  – Exports by a person approved to hold prohibited items under the Arms Act, including dealers, collectors, approved pest controllers and entertainment industry permit holders
  – Exports by a person to whom the prohibited item has special significance as an heirloom or a memento, in personal circumstances such as moving overseas
  – Exports by the New Zealand Defense Force, Police or other government agencies when disposing of weapons.
Approval of items permitted for export under the above exceptions is not automatic. Applications would still need to be considered against the full Assessment Criteria.
Items which have already received a permit for export are unaffected by these changes.

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Reuters: “U.S. Slaps Sanctions on Four Shipping Firms, Nine Ships, Carrying Oil from Venezuela”  

Reuters, 12 Apr 2019.) [Excerpts.]
The United States on Friday announced more sanctions on shipping companies transporting oil from Venezuela, blacklisting four shipping companies and nine vessels, some of which the U.S. Treasury Department said carried oil to Cuba.
The U.S. Treasury identified the firms as Liberia-based Jennifer Navigation Ltd, Lima Shipping Corp and Large Range Ltd, and Italy-based PB Tankers S.P.A.
It blacklisted one tanker belonging to each of the Liberian firms and six owned by the Italian firm.
A Treasury statement said Venezuela’s oil sector continued “to provide a lifeline to the illegitimate regime” of Venezuelan President Nicolas Maduro.
  “We continue to target companies that transport Venezuelan oil to Cuba, as they are profiting while the Maduro regime pillages natural resources,” Treasury Secretary Steven Mnuchin said in the statement.
  “Venezuela’s oil belongs to the Venezuelan people, and should not be used as a bargaining tool to prop up dictators and prolong oppression,” he said.
The sanctions prohibit dealings with the firms by U.S. citizens and block the companies’ financial interests in the United States. …

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ST&R Trade Report: “Defense Trade, Air Cargo, Chemical Weapons Information Collections Under Review”
Sandler, Travis & Rosenberg Trade Report
, 15 Apr 2019.)

Bureau of Alcohol, Tobacco, Firearms, and Explosives
– ATF Form 6, application and permit for importation of firearms, ammunition, and defense articles (comments due by June 10).
Bureau of Industry and Security
– forms 1-1, 1-2, 1-2A, 1-2B, Chemical Weapons Convention declaration and report handbook and forms (comments due by May 15).
Transportation Security Administration
– air cargo security requirements (security programs, security threat assessments, known shipper data, indirect air carrier management system, and evidence of compliance recordkeeping; comments due by May 9).

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J.W. Boscariol & C. Francis: “Canada Prepares to Implement New Export Controls and Brokering Requirements”

McCarthy Tétrault LLP, 11 Apr 2019.)
* Authors: John W. Boscariol, Esq.,
jboscariol@mccarthy.ca, 416-601-7835; and Carmen Francis, Esq.,
cfrancis@mccarthy.ca, 416-601-8854. Both of McCarthy Tétrault LLP.
On March 16, the Canadian government published proposed regulations supporting amendments to Canada’s Export and Import Permits Act (EIPA) that, among other things, create a new control regime for Canadians engaged in “brokering” related to transactions involving the movement of certain controlled goods, services or technology from one foreign country to another. This is the first time Canada has imposed such controls and companies that may be potentially involved in such transactions should be reviewing the new regulations carefully.
The EIPA amendments and new regulations also implement other changes required as a result of Canada’s accession to the United Nations Arms Trade Treaty, including new permit and reporting requirements for certain goods and technology transfers to the United States.
Canada and the UN Arms Trade Treaty
On December 13, 2018, An Act to amend the Export and Import Permits Act (EIPA) and the Criminal Code (amendments permitting the accession to the Arms Trade Treaty and other amendments) (the “Act”) received royal assent. The Act enables Canada to join the 2014 UN Arms Trade Treaty (the “ATT”) that sets out standards for international trade in a broad range of conventional arms with the goal of ensuring that states have effective national systems to review and control arms trading.
New Human Rights Criteria for Issuing Permits
The Act establishes controls over brokering and creates new legal obligations for the Minister of Foreign Affairs to consider certain assessment criteria before granting either export or brokering permits – these include violations of international humanitarian or human rights law or international conventions relating to terrorism or trans­national organized crime, and acts of gender-based violence or violence against women and children. The Minister is authorized to deny the permit if there is a substantial risk of any of these negative consequences.
New Controls Over “Brokering”
To facilitate full implementation of and compliance with the ATT, Canada has developed a number of proposed regulations. These include a Brokering Control List, Brokering Permit Regulations, regulations specifying activities that do not constitute brokering (exclusions), and two proposed regulations on enhanced reporting requirements for ATT exports to the United States.
Pursuant to the draft regulations, subsection 2(1) of the amended EIPA will define “brokering” to include “arranging or negotiating a transaction that relates to the movement of goods or technology included in a Brokering Control List from a foreign country to another foreign country.” Note that, significantly, the reference to a “foreign country” means countries other than Canada. Consequently, the movement of items into or out of Canada is not captured within the newly-established definition of “brokering.”
Furthermore, with respect to brokering activities involving technology, a “transaction that relates to the movement of technology” will, pursuant to subsection 2(1.1) of the EIPA, include a transaction that relates to the disclosure of its contents. Although the government’s summary of the amendments notes that a “transaction that relates to the movement of technology” must include the disclosure of the contents of that technology and not just the passage of the technology itself (e.g. on a USB key that remains unopened) from one place to another, this does not appear to be explicitly reflected in text of the amendments.
The proposed Brokering Control List consists of a list of goods and technologies for which a brokering permit is required. It covers all military goods and technologies listed in Group 2 of the Export Control List, any other Export Control List item, including dual-use items, that is likely to be used as weapons of mass destruction, as well as the eight ATT categories of full-system conventional arms that form the new Group 9 under the Export Control List. The Group 9 items will also require permits for export to the United States.
While Canadian business has enjoyed permit-free export and transfer of most military items to the United States since World War II, compliance with Article 13 of the ATT will require that Canada now report on its export of full-system conventional arms, including those shipped to the United States. To satisfy this ATT obligation, Canada has created the eight ATT categories of full-system conventional arms that will require a permit to be exported to the United States. The permit-free movement of other military goods and technology to the United States will remain intact.
The amended EIPA will prohibit unauthorized brokering by any Canadian company or individual whether in Canada or abroad. In practice, the broad application of these prohibitions means that unauthorized brokering will be a criminal offence, and that brokering obligations will be applicable both domestically and on an extraterritorial basis. The proposed Brokering Permit Regulations will establish the regulatory framework for the issuance of brokering permits. Applicants for brokering permits will be able to leverage the Export Controls On-Line (EXCOL) platform that is currently the dedicated website used for export permits. In addition, a General Brokering Permit has been proposed for use in conducting brokering activities in pre-defined low-risk circumstances and to select low-risk destinations.
Next Steps and Implementation
The industries and entities potentially affected by the EIPA amendments and proposed regulations include Canadian defence, security and aerospace industries, as well as companies that manufacture, export and/or broker military and dual-use goods and technologies, and those companies providing related technical and after-sale services.
The proposed regulations are open for comment for a 30-day period, until April 15, 2019. Comments will be reviewed and considered prior to finalization of the draft regulations. The finalized regulations are anticipated to be published in June, with an entry into force date some 30 days after that.
here to see the text of the Act and
here for the proposed regulations.

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O. Gonzalez: “Why Cats and Customs Brokers Hate Triennial Status Reports”

(Source: Author, 12 Apr 2019.)

Some laws are more nuisance than utilitarian. Take for example the legal requirement that customs brokers file triennial status reports with CBP.  CBP sets out those requirements online. These reports are sort of like glorified change-of-address forms, but so much less and so much more. The most that can be said in their defense is that they raise about a million dollars in filing fees (my rough estimate), a pittance when you consider their limited utility.  
CBP uses the triennial status reports to ask customs brokers to report violations of the conditions of their customs broker license. This strikes me as a lazy and harebrained method of entrusting customs brokers with enforcing the law. News flash: customs brokers are not law enforcement. A customs broker license doesn’t mean that the federal government deputized you. You certainly are not an agent or an employee of the federal government. You owe lots of duties to your customers and you must comply with reams of regulations and stacks of laws when executing those duties, but there is no legal requirement to turn yourself or your customers into federal enforcement authorities for possible violations. Also, what would the incentive be to report your license violations in triennial status reports? Unlike prior disclosures, CBP doesn’t promise mitigation. There is no carrot. Moreover, if you do turn yourself in, you risk losing your license, exactly the thing you’re trying to avoid. All stick. If you don’t turn yourself in, what are the chances that you’ll be caught? If you caught, how is that any worse that if you had turned yourself in at the beginning?
CBP ditches this honor system and becomes a pain-in-the-appendix stickler when it comes to forcing customs brokers to file triennial status reports on time. CBP is as inflexible as me doing hot yoga. Granted, filing the triennial status reports is not the most onerous task facing a customs broker, and filing timely forms is kind of what customs brokers are expected to do. Also, customs brokers get two chances under the regulations to file triennial status reports before their license is revoked. Still, missing the deadline is not surprising. It’s hard to remember something when it deceptively appears so trivial and when it pops up only every three years. I can’t think of anything else that comes in three-year increments. Not the Olympics (four years). Not cicadas (seventeen years). Not Halley’s Comet, which visits our corner of the solar system every seventy-five years. About the only other event that comes around every three years is Kattenstoet, the parade in Ypres, Belgium that “honors” cats. During the Middle Ages, the good people of Ypres threw cats from a belfry tower to the town square below to ward off witches. The history books do not say whether the ritual intimidated any witches into leaving town, but I am confident that the intent was felt and accommodated by all parties. CBP could, if it chose, similarly alert customs brokers that their licenses were in jeopardy for not filing triennial status reports before figuratively throwing them off of the belfry tower. It knows how to communicate with customs brokers when it wants to. Case in point. CBP just informed hundreds of people that it revoked their customs broker licenses for not filing their triennial status reports.
Revocation is serious. It means that you just lost your customs broker license. While revocation is “without prejudice” and you are allowed to submit a new license application, this is a viable option only if you’ve taken and passed the customs broker exam within the past three years. You can’t ask for reinstatement. It’s like trying to run back to the ledge after someone threw you off the belfry. Only Looney Tunes cartoons are capable of that feat.
Perhaps reasonable minds will prevail at CBP and triennial status reports will disappear and go the way of faxes. Oops. I forgot that CBP is enamored with and still depends largely on yesteryear’s technology, including faxes. (I should probably expect a sternly-worded telegraph from CBP in response to this article. Ha. I’ll have the last laugh. I never learned Morse Code). But we’re not there yet. In the meantime, dear customs brokers, don’t forget to file your triennial status reports on time. Otherwise, the good people of Ypres, Belgium may start throwing parades in your honor. Every three years. Splat!

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14. The FAQ of the Day:
Shipping Defense Articles to the U.S. Government Overseas
, 27 Apr 2018.)
Q: If I am shipping a defense article to the [U.S.] Government at either an Army Post Office (APO) or Fleet Post Office (FPO) overseas, is it considered an export, and if so, then what type of authorization is required?
A: DDTC considers shipments of USML-controlled defense articles and/or technical data to APO boxes to be an export and thus require an authorization to ship the subject defense articles/technical data. Regardless of method employed (aircraft, vessel, etc.), such exports require prior written approval from DDTC, except in cases where the applicant opts to use an eligible ITAR exemption.

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MS_a115. Monday List of Ex/Im Job Openings: 147 Openings Posted This Week, Including 15 New Openings 

(Source: Events & Jobs Editor) 

Published every Monday or first business day of the week. Please, send job openings in the following format to 


” New or amended listing this week


* Abbott; Abbott Park, IL; Customs and Trade Technician

* Adient; Plymouth, MI;
Director Americas Regional Compliance
; Requisition ID: R-03478
AeroVironment; Simi Valley, CA; Trade Compliance Specialist II; Requisition ID: 333;

Agility; Houston, TX; Ocean Export Team Leader;

* Airbus; Blagnac, France; Internship Compliance et Export control; Requisition ID: 1819-X12

* Airbus; Getafe, Spain; Export Control Officer; Requisition ID: 10447448 XX EN EXT 1
* Airbus; Munich, Germany;
Internship within Legal & Compliance: Data Protection Mapping
; Requisition ID: 10436096 NK EN EXT 4
* Ajilon; Bedford Park, IL; Import / Export Logistics Coordinator; Requisition ID: US_EN_7_849116_2650289

Allnex; Drogenbos, Belgium; Head of Trade Compliance EMEA;

AM General; Auburn Hills, MI; 
International Compliance Analyst
Amazon Web Services; Seattle, WA; Trade Compliance Manager, Export Controls & Classification; Requisition ID: 787194;

* Analog Devices, Inc.; Singapore; 
Asia Trade Compliance Manager
; Requisition ID: 12456
* Ansys; Pittsburgh, PA;
Paralegal – Compliance and Trade Compliance
; Requisition ID: 7535

* Autodesk; San
Rafael, CA (SF Bay Area) or Portland, OR; 
Export Compliance Officer
; Requisition ID: 19WD31812
* Axis Communications; Lund, Sweden;
Export Control Advisor – Operations
; Requisition ID: 2629

BAE Systems; Sterling Heights, MI; 
Senior Procurement Compliance Analyst
; Requisition ID: 43034BR

Beiersdorf; Hamburg, Germany; International Trade Expert;

Bell Flight; Fort Worth, TX; Trade Compliance Specialist; Requisition ID: 273691

* Bloomberg; London, United Kingdom; 
Trade Compliance Specialist
; Requisition ID: 71755

* Bosch USA; Owatonna, MN; Import/Export Compliance Analyst

* Bristol-Myers Squibb; New Brunswick, NJ; 
Director Global Customs & Trade
; Requisition ID: R1509390_EN

* CACI International Inc.; Arlington, VA; Director, Trade Compliance; Requisition ID: 219396
* CACI International Inc.; Chantilly, VA; Director, Trade Compliance; Requisition ID: 

* Carnegie Mellon University; Pittsburgh, PA; Export Compliance Manager;

* Danaher – Beckman Coulter Diagnostics; Brea, CA;
Global Export Compliance Manager
; Requisition ID: BEC014282

* Danaher – Leica Microsystems; Wetzlar, Germany; Trade Compliance Manager – EMEA (m/f/d); Requisition ID: LEI004901

* Dell; Bukit Mertajam, Malaysia; Analyst, Import/Export; Requisition ID: R60622

* Dell; Bukit Mertajam, Malaysia; Specialist, Import/Export; Requisition ID: R45267

EDCO; Eindhoven, the Netherlands; Customs & Trade Compliance Coordinator

* Elbit Systems of America; Merrimack, NH; 
Licenses & Agreements Officer
; Requisition ID 2019-6948
* Element; Edinburgh, United Kingdom; 
Group Compliance and Communications Assistant
; Requisition ID: 2019-3094

* Engenium; Orlando, FL;
Import/Export Compliance Specialist 

Erickson Inc.; Portland or Central Point, OR; 
Import Specialist

Susan Colletto
; Requisition ID 927130;

* Esri; Redlands, CA; Export Compliance Specialist;

 Expeditors; Krefeld, Germany; 
Clerk Import / Export
 Expeditors; Bedfont, United Kingdom; 
Customs Brokerage Clerk

Five Below; Philadelphia, PA; Custom Trade & Compliance Analyst;

* Flexport; Amsterdam, the Netherlands; Regional Compliance Manager;

* FLIR; Arlington, VA, Elkridge, MD, and Nashua, NH;
Senior Manager, Global Export Licensing (Commercial); Requisition ID: REQ12110

* FLIR; several locations, Canada; Global Trade Compliance (GTC) Country Manager; Requisition ID: REQ12085

* Fortive – Tektronix; Beaverton, OR; Chief Compliance Counsel;

* Fourstar Group USA; Milford, MA; 
Import Manager/Customs Compliance/Classification Specialist

GCP Applied Technologies; Cambridge, MA; 
Trade Compliance Manager

* General Atomics; San Diego, CA; 
Compliance Specialist
; Requisition ID: 22119BR

* General Atomics; San Diego, CA; 
Trade Compliance Classification Leader
; Requisition ID: 22671BR

* General Atomics; San Diego, CA; Import/Export Compliance Specialist; Requisition ID: 23069BR

* Gulfstream Aerospace; Savannah, GA;
Trade Compliance Project Manager Sr
; Requisition ID: 142611  

* Harley-Davidson; Milwaukee, WI; Logistics Lead – Trade Compliance; Requisition ID: 826  

Harris Corporation; Van Nuys, CA; Trade Compliance Senior Specialist; Richard Wellbrock; Requisition ID: ES20192103-30606

Harry Winston; New York, NY; Analyst, Logistics and Trade Compliance;

HBM; Marlboro, MA; Export Compliance Manager;

* Henderson Group Unlimited, Inc; State Dept, DDTC; Washington, DC; 
Defense Trade Control Compliance Analyst
* Henderson Group Unlimited, Inc; State Dept, DDTC; Washington, DC; 
Commodities Jurisdiction Analyst

* Henkel; Rocky Hill, CT;
Global Trade Manager
; Requisition ID: 190001EB

* Honeywell; multiple locations, United States; Export Compliance Manager (North America); Requisition ID: HRD45798;
* Honeywell; Prague, Czech Republic; Export Compliance Officer; Requisition ID: req179383;

* Honeywell International Inc.; Sunnyvale, CA or Lincolnshire, IL; Sr. Import/Export Analyst; HRD32371
* IGT; Reno, NV; Global Trade Analyst; Requisition ID: 1171

* Illumina; Great Abington, United Kingdom; 
Trade Compliance Manager
; Requisition ID: 16204-JOB 
* Illumina; San Diego, CA; 
Associate Director, Global Trade Compliance
; Requisition ID: 16094-JOB
* Illumina; Woodlands, Singapore; Manager, Trade Compliance; Requisition ID: 16361-JOB

 Infineon; El Segundo, CA; 
Manager, Export Control
; Requisition ID: 33841

* Infineon Technologies; Tijuana, Mexico; Import-Export Manager;

IPG Photonics; Oxford, MA; 
Global Director Trade Compliance 
* Irving Shipbuilding; Halifax, NS, Canada; Manager, Export Compliance; Requisition ID: 19000058
* Johnson & Johnson; Skillman, NJ; Trade Compliance Lead; Requisition ID: 0470190327

* Johnson Controls; Milwaukee, WI; Director, Global Trade Compliance; Requisition ID: WD30055791295;

Keeco Home; Hayward, CA; Director Customs and Compliance

* Kirkland’s; Brentwood, TN; 
Customs Compliance Program Manager
; Requisition ID: 2019-8158

Koch Chem Tech; Tulsa, OK; Import/Export Compliance Specialist; Requisition ID: 052017

* KPMG; Chicago, IL or New York, NY or Washington D.C.;
Export and Sanctions Compliance Manager
; Requisition ID: 41146

* Kubota; Grapevine, TX; 
Manager, Import & Export Compliance
; Requisition ID: 228

Leidos; Columbia, MD; International Trade Manager / Export Compliance; Req. ID: R-00005745;

* Leonardo DRS; Arlington, VA; Trade Compliance Import Manager; Requisition ID: 93515

* Leonardo DRS; Melbourne, FL; 
Senior Supply Chain Analyst – Small Business Compliance
; Requisition ID: 91669

* Lockheed Martin; Arlington, VA; International Licensing Analyst; Requisition ID: 468160BR;

* Lockheed Martin; Crystal City, VA; International Licensing Analyst Staff; Requisition ID: 465724BR

* Lockheed Martin; Orlando, FL; 
International Trade Compliance Specialist / International Licensing Analyst
; Requisition ID: 467458BR

* Lockheed Martin; Stratford, CT; International Trade Compliance Authorization Owner; Requisition ID: 479245BR

* Lockheed Martin Aeronautics; Palmdale, CA; Export Compliance Site Lead; Requisition ID: 477630BR

* Lutron Electronics Co; Lehigh Valley, PA; Trade Compliance Coordinator; Requisition ID: 4025;

* Masonite; Charlotte, NC;
Customs Compliance Specialist
; Requisition ID: 2019-16989

* Meggitt; Miami, FL; 
Trade Compliance Coordinator
; Requisition ID: 37514
* Meggitt; Rockmart, GA; 
Trade Compliance Coordinator
; Requisition ID: 37846

* Mercury Systems; multiple locations; Trade Compliance Specialist; Requisition ID: 19-203

Mohawk Global Trade Advisors; Chicago, IL; 
Vice President and General Manager of Consulting Division
; Contact: CSardella@mohawkglobal.com;  

 Newell Brands; Norwalk, CT; 
Manager of Trade Operations

* Northrop Grumman; Herndon, VA;
Principal International Trade Compliance Analyst Level 3 or 4
; Requisition ID: 19007160  

* Northrop Grumman; Rancho Bernardo, CA; Sr. Manager, International Trade Compliance; Contact: Fred Czarske at 310-332-7606, fred.czarske@ngc.com; Requisition ID: 19008010

* NXP Semiconductors; Eindhoven, The Netherlands; (Senior) Manager Customs Compliance; Requisition ID: R-10013630;

* Pacific Northwest National Laboratory; Richland, WA; Export Control Professional; 509-375-4496; Requisition ID: 309048

* Parexel; Kiev, Ukraine; Trade Compliance Specialist; Requisition ID: 51579BR

* PCC Forged Products – Wyman-Gordon; Houston, TX;
Division Trade Compliance Manager
; Requisition ID: 20961
* PerkinElmer; Shelton, CT or Boston, MA or Hopkinton, MA or Waltham, MA;
Senior Director Global Transportation and Logistics
; Requisition ID: JR-004907

* Philips; Best, the Netherlands;
Head of Trade Compliance
; Requisition ID: 308818

* Pinpoint Pharma; Lincolnshire,IL; Export Compliance Specialist; Requisition ID: 351;

* PwC; Houston, TX; Customs and International Trade Director; Requisition ID: 38150WD;

* Raytheon; El Segundo, CA; Global Trade Authorization Owner; Requisition ID: 137660BR
* Raytheon; El Segundo & Goleta, CA; Global Trade Licensing Analyst I; Requisition ID: 136372BR
* Raytheon; El Segundo, CA; Global Trade Licensing Analyst II; Requisition ID: 136372BR

* Raytheon; El Segundo, CA; Import Ctl&Compliance Advisor; Requisition ID:136269BR

* Raytheon; El Segundo, CA/McKinney, TX/Rosslyn, VA; Senior Analyst Global Trade Management; Requisition ID: 136411BR
* Raytheon; El Segundo, CA/McKinney, TX; Senior Manager, Global Trade Strategy; Requisition ID: 135692BR
* Raytheon; McKinney, TX: Senior Analyst Global Trade Licensing; Requisition ID: 136939BR

* Raytheon; Tuscon, AZ;
Manager Export-Import Control
; Requisition ID: 134614BR

* Raytheon; Tuscon, AZ;
Senior Export Licensing and Compliance Specialist
; Requisition ID: 135002BR;

* Richemont; Fort Worth, TX; Import/Export Manager; Requisition ID: 8837;

Rohde Schwarz; Munich, Germany; 
Spezialist Exportkontrolle (m/w) 

* Rolls-Royce; Derby, United Kingdom; Export Control Manager; Requisition ID: JR6042437

 SABIC; Houston TX; 
Senior Analyst, Trade Compliance
; Requisition ID: 8411BR

* Shell; Krakow, Poland; Trade Compliance Manager; Requisition ID: 100384BR;
* Siemens; München, Germany; Director (m/f) Compliance Audit – Export Controls and Customs (ECC); Requisition ID: 104465 

* Sierra Nevada Corporation; Arlington, VA; International Trade Compliance Analyst I; Requisition ID: R0007830

* Sierra Nevada Corporation; Arlington, VA;
International Trade Compliance Analyst II
; Requisition ID: R0007508
* Signify; Eindhoven or Amsterdam, the Netherlands;  
Legal Export Control Officer
; Requisition ID: 289784

* Solenis; Wilmington, DE; Global Trade Compliance Specialist II; Requisition ID: R0002807

* StanleyBlack&Decker; Southington, CT; 
Trade Compliance Specialist/Analyst
; Requisition ID: 58390BR

TE Connectivity; El Cajon, CA or Middletown, PA; Licensing Specialisttbaker@te.com; Requisition 40514 

* Teledyne Semiconductors; Saint-Egrève/Grenoble, France; Trade Compliance Manager; Requisition ID: 2019-8459;

* Teledyne Technologies; Mountain View, CA;
Trade Compliance Import Administrator
Janice Whitaker; Requisition ID: 2019-9078;  

* Textron Aviation; Wichita, KS; 
Trade Compliance Analyst
; Requisition ID: 269127

* Thales; Stuttgart, Germany;
Trade Compliance Spezialist (M/W/D)
; Requisition ID: R0054290

* ThermoFisher Scientific; Monza, Italy; Trade Compliance Specialist – Pharma; Requisition ID: 88807BR

* ThermoFisher Scientific; Loughborough, United Kingdom;
Global Trade Compliance Manager
; Requisition ID: 90337BR

* Trek Bicycle; Waterloo, WI;  
Trade Compliance Manager  

* U.S. Department of State; Washington D.C.; Compliance Specialist; Requisition ID: PM-2019-0011
* U.S. Department of State; Washington D.C.; Compliance Specialist; Requisition ID: PM-2019-0012
* U.S. Department of State/Directorate of Defense Trade Controls; Washington D.C.;  Attorney [Multiple positions]; legaljobs@state.gov.  

* U.S. Department of the Army – U.S. Army Security Assistance Command; Redstone Arsenal, AL; Security Assistance Policy Specialist; Requisition ID: 60590  
* United Technologies – Collins Aerospace; Danbury, CT;
Fall CO-OP, International Trade Compliance
; Requisition ID: 01295830

* United Technologies – Pratt & Whitney; East Hartford, CT; 
ITC Licensing Specialist
; Requisition ID: 01289652

University of California; San Francisco, CA; 
Export Control Officer
; Requisition ID: 51010;

* UPS; Münchenstein, Switzerland; Customs & Trade Compliance Coordinator; Requisition ID: 052228

* Velocity Electronics; Austin, TX; 
Director of Global Trade Compliance 
* Veridos GmbH; München, Germany; 
Ausfuhrbeauftragter (Export Control Officer m/w/d
; Requisition ID: 1677

* Vigilant GTS; Remote Position, U.S.; Global Trade Compliance Account Manager;

* VT iDirect; Herndon, VA;
Manager, Global Logistics
; Requisition ID: 2018R-3120-1;
* Walt Disney; Kissimmee, FL; Export Compliance Analyst; Requisition ID: 634260BR

* Walt Disney; Kissimmee, FL; Trade Compliance Analyst (Project Hire); Requisition ID: 654599BR

* Wealth Ocean; Newport Beach, CA; Marketing & International Trade Specialist;

* Xilinx; San Jose, CA;
Trade Compliance Specialist
; Requisition ID: 155901

* Xpand Group: Hong Kong, China; 
Compliance Analyst
; Requisition ID: G-REQ-00169936

* YETI Coolers; Austin, TX; Inbound Logistics and Trade Compliance Manager  

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


TE_a116. ECS Presents “Mastering ITAR/EAR Challenges” on 30 Apr-1 May in Nashville, TN

(Source: S. Palmer,
* What: Mastering ITAR/EAR Challenges; Nashville, TN
* When: April 30-May 1, 2019
* Sponsor: Export Compliance Solutions (ECS)
* ECS Speaker Panel:  Suzanne Palmer; Lisa Bencivenga; Timothy Mooney, Debi Davis, Matthew McGrath, Matt Doyle.
* Register 
here or by calling 866-238-4018 or email 
* * * * * * * * * * * * * * * * * * * *

TE_a217. FCC Presents “An Introduction to EU / Dutch Dual-Use and Military Export Controls”, 7 May in Bruchem, the Netherlands 

This 1-day training course is ideally suited for compliance professionals and those in a similar role who aim to gain a better understanding of EU and Dutch export control laws and regulations and industry’s best practices to ensure compliance.
  The course will cover multiple topics relevant for organizations subject to EU and Dutch dual-use and/or military export controls, including: the EU and Dutch regulatory framework; key concepts and definitions; practical tips regarding classification and licensing, and for ensuring a compliant shipment; identifying red flag situations and handling (potential) non-compliance issues; and the latest developments regarding Internal Compliance Program requirements in the EU an the Netherlands.
* Training Event: “An Introduction to EU / Dutch Dual-Use and Military Export Controls” (in Dutch)
* Date: Tuesday, 7 May 2019
* Location: Full Circle Compliance, Landgoed Groenhoven, Dorpsstraat 6, Bruchem, The Netherlands
* Times:
  – Registration and welcome: 9.00 am – 9.30 am
  – Training course hours: 9.30 am – 4.00 pm
* Level: Awareness / Beginner.
* Target Audience: Compliance professionals or those in a similar role in any industry affected by EU/Dutch export controls (
e.g., manufacturing, logistics, research & development, aerospace & defense, government, etc.).
* Instructors: Marco F.N. Crombach MSc (Senior Manager) & Vincent J.A. Goossen MA (Senior Associate). 
* Information & Registration: click
here or contact us at 
events@fullcirclecompliance.eu or 31 (0)23 – 844 – 9046.  

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


Henry IV of England (15 Apr 1367 – 20 Mar 1413; was King of England from 1399 to 1413, and asserted the claim of his grandfather, Edward III (himself a maternal grandson of Philip IV of France), to the Kingdom of France.)
  – “The shortest and surest way of arriving at real knowledge is to unlearn the lessons we have been taught, to mount the first principles, and take nobody’s word about them.”
Leonardo da Vinci (Leonardo di ser Piero da Vinci; 15 Apr 1452 – 2 May 1519; was an Italian polymath of the Renaissance whose areas of interest included invention, drawing, painting, sculpting, architecture, science, music, mathematics, engineering, literature, anatomy, geology, astronomy, botany, writing, history, and cartography. He has been variously called the father of palaeontology, ichnology, and architecture, and he is widely considered one of the greatest painters of all time. Sometimes credited with the inventions of the parachute, helicopter, and tank, he epitomised the Renaissance humanist ideal.)
 – “Iron rusts from disuse; water loses its purity from stagnation… even so does inaction sap the vigor of the mind.”
  – “I love those who can smile in trouble, who can gather strength from distress, and grow brave by reflection. ‘Tis the business of little minds to shrink, but they whose heart is firm, and whose conscience approves their conduct, will pursue their principles unto death.”
Monday is pun day:
* What do you call a beautiful pumpkin? Gourd-geous.
* Why did the male banana stare at the female banana?  Because she was appealing.
* I used to be afraid of hurdles, but I got over it.

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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: 5 Apr 2019:
84 FR 13499-13513: Civil Monetary Penalty Adjustments for Inflation

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: 11 Apr 2019: 84 FR 14608-14614: Revisions to the Unverified List (UVL) 
* 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: 14 Mar 2019: 84 FR 9239-9240: Bump-Stock-Type Devices 


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: 19 Mar 2019: 84 FR 9957-9959: Department of State 2019 Civil Monetary Penalties Inflationary Adjustment. 
  – The only available fully updated copy (latest edition: 19 Mar 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 Mar 2019: 84 FR: 9456-9458: List of Foreign Financial Institutions Subject to Correspondent Account or Payable-Through Account Sanctions (CAPTA List) 
* 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 Amendment: 2 Apr 2019:
Harmonized System Update (HSU) 1905
[contains 792 ABI records and 176 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, Vincent J.A. Goossen and Alexander Witt; and Events & Jobs Editor, Sven Goor. The Ex/Im Daily Update is emailed every business day to approximately 7,000 readers of changes to defense and high-tech trade laws and regulations. 
We check the following sources daily: Federal Register, Congressional Record, Commerce/AES, Commerce/BIS, DHS/CBP, DOE/NRC, DOJ/ATF, DoD/DSS, DoD/DTSA, FAR/DFARS, State/DDTC, Treasury/OFAC, White House, and similar websites of Australia, Canada, U.K., and other countries and international organizations.  Due to space limitations, we do not post Arms Sales notifications, Denied Party listings, or Customs AD/CVD items.

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

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

* SUBSCRIPTIONS: Subscriptions are free.  Subscribe by completing the request form on the Full Circle Compliance website

* BACK ISSUES: An archive of Daily Bugle publications from 2005 to present is available HERE.

* TO UNSUBSCRIBE: Use the Safe Unsubscribe link below.

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