19-0430 Tuesday “Daily Bugle'”

19-0430 Tuesday “Daily Bugle”

Tuesday, 30 April 2019

  1. Treasury/OFAC Request Comments for Remittance Forwarding Services and Travel and Carrier Services to Cuba
  1. Items Scheduled for Publication in Future Federal Register Editions 
  2. Commerce/BIS: (No new postings.)
  3. DHS/CBP Updates AE CATAIR (Consolidated Express Filings) and Updated ACE Error Dictionary
  4. State/DDTC: (No new postings.)
  1. Bloomberg: “China Could Win from Tech Cold War”
  2. CGTN: “China Says It’s Considering Joining Arms Trade Treaty”
  3. Emirates Business: “FANR Develops Automated Import, Export Control System”
  4. Jane’s 360: “Airbus Takes Hit over German Export Controls”
  1. M. A. Castille, M. Levy & A. C. Schten: “What You Don’t Know Can Hurt You: US Export Controls and Trade Sanctions Laws”
  2. M. Volkov: “Episode 87 – Review of Recent Compliance Benchmarking, Surveys and Studies”
  1. ECS Presents “2nd Annual ECS ITAR/EAR Symposium and Boot Camp” on 17-19 Sep in Annapolis, MD
  2. FCC Presents “Designing an Internal Compliance Program for Export Controls & Sanctions”, 1 Oct 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 Apr 2018), DOT/FACR/OFAC (29 Apr 2018), HTSUS (18 Apr 2019) 
  3. Weekly Highlights of the Daily Bugle Top Stories 


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

FR 84: 18341-18342: Proposed Collection; Comment Request for Remittance Forwarding Services and Travel and Carrier Services to Cuba
* AGENCY: Office of Foreign Assets Control, Treasury.
* ACTION: Notice and request for comments.
* SUMMARY: The Department of the Treasury, as part of its continuing effort to reduce paperwork and respondent burden, invites the general public and other Federal agencies to comment on proposed and/or continuing information collections, as required by the Paperwork Reduction Act of 1995. Currently, the Office of Foreign Assets Control (OFAC) within the Department of the Treasury is soliciting comments concerning OFAC’s information collection requirements for persons using remittance forwarding, travel, or carrier service providers for remittances or travel to Cuba, which are contained within the Cuban Assets Control Regulations.
* DATES: Written comments must be submitted on or before July 1, 2019 to be assured of consideration.
* ADDRESSES: You may submit comments by any of the following methods: Federal eRulemaking Portal:
. Follow the instructions on the website for submitting comments. Refer to Docket Number OFAC-2019-0002 and the Office of Management and Budget (OMB) control numbers 1505-0167 and 1505-0168. …
   Current Actions: OFAC requires that persons subject to U.S. jurisdiction providing remittance forwarding services or travel or carrier services authorized pursuant to 31 CFR 515.572 retain for at least five years from the date of the transaction a certification from each customer indicating the section of 31 CFR part 515 or, if relevant, the number of the specific license, that authorizes the customer to send the remittance to Cuba or that authorizes the customer to travel to Cuba, respectively. In addition, the service provider must maintain on file the names and addresses of individual remitters or travelers, the number and amount of each remittance, and that name and address of each recipient, as applicable.
– Type of Review: Extension of currently approved collections.
– Affected Public: Individuals, households, businesses, non-governmental organizations, and banking institutions. The likely respondents and record-keepers affected by this collection of information are persons using U.S. remittance forwarding services and U.S. travel and carrier services. …
   Approved: April 24, 2019.
Andrea Gacki, Director, Office of Foreign Assets Control.
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OGS_a12. Items Scheduled for Publication in Future Federal Register Editions
(Source: Federal Register)


* Commerce/BIS; NOTICES; Meetings: Materials Processing Equipment Technical Advisory Committee
[Pub. Date: 5 May 2019.]

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DHS/CBP, 29 Apr 2019.)
An updated AE CATAIR chapter with the Consolidated Express Filing Indicator has been posted on CBP.GOV at the following location under the tab titled “Chapters: Drafts for Future Capabilities”: Click here.
Additionally, an updated ACE Error Dictionary has been posted on CBP.GOV at the following location under the tab titled: “Supporting Documents”: Click here.
The updated ACE error dictionary includes new error codes that will be relevant once the Consolidated Express Filing Indicator is deployed to CERTIFICATION and PRODUCTION environments. In addition, clarification was added to error code S06 (BOND DESIG TYP CODE NOT VALID FOR BOND TYP) related to bond validations.

An additional CSMS will be sent out when CERTIFICATION and PRODUCTION deployment dates are finalized for the Consolidated Express Filing Indicator. 

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(Source: Bloomberg, 30 Apr 2019.) [Excerpts.]
By driving Chinese researchers back home, new export controls are more likely to hurt than help the U.S.
China’s growing technological prowess in areas such as artificial intelligence is making Washington very nervous. U.S. efforts to fight back, though, could make the problem worse. …
If new export controls are enforced in their harshest form, the calculus for many Chinese scientists and engineers may change. Their job possibilities in the U.S. will be limited. A potentially cumbersome visa process could discourage many American companies and universities from even interviewing qualified Chinese candidates. …

This would drain the U.S. of some of its best talent; institutions such as the Massachusetts Institute of Technology rely on foreign students and academics for a significant part of their research capability. It’ll also limit the ability and willingness of U.S. companies and universities to learn from Chinese counterparts: The Commerce Department’s latest “unverified list” – essentially a red flag that requires U.S. companies to do more diligence and provide additional information about a listed company or person, while imposing license requirements – includes mostly Chinese academic institutions, research centers and tech companies. …

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CGTN, 30 Apr 2019.) [Excerpts.]
China is considering joining the Arms Trade Treaty (ATT), said Chinese Foreign Ministry Spokesperson Geng Shuang on Tuesday, adding that the country supports the ATT’s goals.
Foreign Ministry spokesperson Geng Shuang made the comments after U.S. President Donald Trump announced on April 26 that the United States was withdrawing from the ATT, which regulates international trade in conventional arms and seeks to prevent and eradicate illicit trade and diversion of conventional arms by establishing international standards governing arms transfers.  
China said Tuesday it hopes that relevant countries can do more to strengthen the mechanism of international arms control and safeguard international and regional peace and stability. …

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(Source: Emirates Business, 28 Apr 2019.)
The Federal Authority for Nuclear Regulation (FANR), the nuclear regulator in the UAE, has developed the nation’s first automated import and export control system for nuclear related items.
Fully integrated with the Abu Dhabi General Administration of Customs, FANR’s NuTech Portal system has reduced approval time for the clearing of shipments from Abu Dhabi Customs by 80 percent, and achieved a customer happiness rating of 100 percent.
The new portal strengthens the control of import, export, re-export, transit and transhipment of nuclear related dual-use items regulated by FANR. The portal is the result of FANR’s continuous efforts to prevent the diversion, misuse and illicit trafficking in nuclear equipment and technology, in line with international nuclear non-proliferation regime.
Christer Viktorsson, Director-General of FANR, said, “Import and export control form a key part of our safeguards system and the NuTech Portal not only strengthens our existing control regime, but enhances its efficiency and improves its user experience.”

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Jane’s 360: “Airbus Takes Hit over German Export Controls”
(Source: Jane’s 360, 30 Apr 2019.) [Excerpts.]
Airbus has recorded a EUR190 million (USD212.1 million) charge relating to the company’s delivery of equipment to Saudi Arabia for a long-running border security contract, it was revealed during the company’s first-quarter results released on 30 April.
The charge came as a result of increased export controls by Germany, which has involved the banning of transfers of military equipment to Saudi Arabia from Germany. The ban came as a result of the war in Yemen, as well as criticisms over human rights violations and the murder of journalist Jamal Kashoggi in Istanbul in October 2018. In March the ban was extended until at least 30 September. …

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10. M. A. Castille, M. Levy & A. C. Schten: “What You Don’t Know Can Hurt You: US Export Controls and Trade Sanctions Laws”
(Source: Financial Director, 30 Apr 2019.)
* Authors: M. Angela Castille, Esq., angella.castille@FaegreBD.com, +1 202 589 2849; Matthew R. Levy, Esq., matthew.levy@FaegreBD.com, +1 317 237 1114; and Allison C. Schten, Esq., allison.schten@FaegreBD.com, +1 317 237 1094. All of Faegre Baker Daniels.
Failing to ensure that your business is compliant with US export controls and trade sanctions can result in severe consequences. These laws have become some of the most dynamic tools by which the US government implements its global policy. They have extraterritorial reach and can extend to transactions outside of the US involving both Americans and non-Americans.
US trade sanctions target more than 20 jurisdictions, including complete embargoes on Cuba, Iran, North Korea, Syria and Crimea. In addition, the US Treasury Department’s Office of Foreign Assets Control (OFAC) maintains several screening lists, including a list of persons and entities known as Specially Designated Nationals (SDN List) whose assets are blocked and with whom transactions are generally prohibited (SDNs).
“Primary sanctions” restrict the activities of US businesses with respect to the embargoed jurisdictions and SDNs, while “secondary sanctions” are intended to restrict similar activities by non-US companies (including non-US subsidiaries of US companies). Secondary sanctions may include loss of access to the US financial system, denial of export licenses or approvals, loss of US government procurement contracts, denial of US visas and/or designation as an SDN. In 2018, OFAC enforcement actions resulted in civil penalties totaling $71.5m, and already in 2019, over $1.3bn. OFAC is also empowered to assess criminal penalties, including additional fines and prison time.
By contrast, US export controls apply to the exportation of commodities, technology, software and services subject to US law. The item to be exported, not the identity of the exporter, is the critical factor. Even products manufactured outside of the U.S. can be subject to US export control laws if they contain more than a “de minimis” amount of US content or controlled technology.
In May 2018, the US withdrew from the Joint Comprehensive Plan of Action (JCPOA), triggering a return to the pre-2016 sanctions regime. As a result, general licenses were revoked and secondary sanctions were reimposed on non-US. companies for their Iran-related activities.
Global bank Standard Chartered, for example, recently reached a $657m settlement with OFAC after being assessed a $1.1bn base penalty because its Dubai branch processed dollar-denominated transactions through its New York branch on behalf of Iranian customers. Similarly, Italian bank UniCredit reached a $611m settlement with OFAC after being assessed a $1.3bn base penalty because it opened an account on behalf of the Italian government for handling blocked funds from Bank Sepah, an Iranian bank on the SDN List.
Iran remains a main target of US sanctions, and both US and non-US companies can become caught in the crossfire. Though non-US companies may bristle at the thought of being subject to US law, the gravity of the US economy may nonetheless pull them in. OFAC essentially takes a “with us or against us” approach to most activity with Iran, and it has already imposed or threatened to impose secondary sanctions on a number of non-US companies.
In April 2018, OFAC designated several Russian officials, oligarchs and entities they own as SDNs. On January 27, 2019, OFAC lifted sanctions against three of those entities after they provided evidence that Oleg Deripaska had divested his majority ownership in them: RUSAL, En+ Group and JSC EuroSibEnergo.
Although those entities were removed from the SDN List, Deripaska himself was not. Pursuant to OFAC’s “50% Rule,” any entity that is owned 50% or more, directly or indirectly, by an SDN remains blocked. This means companies which are majority-owned by Deripaska or other Russian SDNs remain off-limits to US businesses.
US sanctions on Russia generally did not apply to non-US companies until the Countering America’s Adversaries Through Sanctions Act (CAATSA) was signed into law in August 2017. CAATSA requires the president to designate as SDNs any non-U.S. companies which knowingly facilitate transactions with Russian SDNs.
In addition, secondary sanctions can be imposed on non-US. companies involved in the crude oil and financial services industries in Russia or those acquiring Russian state-owned assets. This significant development pulls non-US companies into the Russian sanctions program and can result in punitive measures if the company does business both in Russia and the US.
North Korea
Although North Korea has been and remains embargoed with respect to transactions by US persons, OFAC has recently become more aggressive in sanctioning non-US entities for their business activities with North Korea. This is in part a consequence of the adoption of CAATSA.
OFAC has recently designated as SDNs shipping, oil and other transportation companies based in China, Hong Kong and Singapore known to facilitate trade with North Korea. OFAC has also targeted financial intermediaries based in these countries that knowingly finance North Korean transactions, including several Chinese banks.
Non-US businesses that conduct any business with North Korea risk becoming SDNs themselves. Even if they don’t transact with North Korea, non-US companies should screen their financial institutions against the SDN List. Knowingly conducting business with North Korea or a bank designated as an SDN due to its North Korean activity could cause the non-US company to be designated as an SDN itself.
Export controls
The Export Control Reform Act of 2018 (ECRA) was signed into law in August 2018 as part of the National Defense Authorization Act of 2019 (NDAA). ECRA created an interagency review process to identify “emerging and foundational technologies” that will become subject to US export controls.
To date, what constitutes “emerging and foundational technologies” has not been specifically identified. However, while seeking public comment, the US Commerce Department did specify the following categories of technology as potentially containing “emerging and foundational technologies”:
– Biotechnology
– Artificial intelligence
– Position, navigation and timing technology
– Microprocessor technology
– Advanced computing technology
– Data analytics technology
– Quantum information and sensing technology
– Additive manufacturing
– Robotics
– Brain-computer interfaces
– Advanced materials
– Advanced surveillance technologies
Emerging and foundational technologies” in these industries are likely to be added to the Commerce Control List and will require licenses to be exported, re-exported or transferred in country to destinations like China and other countries subject to US embargo.
Compliance tips
Penalties can be severe for violations of trade sanctions and/or US export controls. To reduce the risk of a violation, US. and non-US businesses should undertake the following:
(1) For non-US companies, assess your company’s ties to the US:
     (1) Are you owned or controlled by a US person?
     (2) Do you transact with US persons or trade in US products, software or technology?
     (3) Does your company maintain any accounts with US financial institutions or route transactions through the US financial system?
     (4) Does your company use US. dollars to pay for transactions involving companies or persons in countries subject to US embargoes?
     (5)Do you have any US citizens or permanent residents in positions of management or supervision or will US citizens or permanent residents be involved in a transaction prohibited by US law?
(2) Check counterparties, their owners and all financial institutions involved in a transaction against the Consolidated US Screening List (CSL), located here. The CSL combines the SDN List as well as several other prohibited parties lists maintained by OFAC and the US Commerce and State Departments. Also, confirm whether you do business in any of the jurisdictions subject to US embargo.

(3) Stay apprised of any updates on “emerging and foundational technologies,” especially if you operate in one of the sectors identified by the US Commerce Department. Those technologies will likely become the subject of new export control restrictions, meaning US companies may have new licensing requirements and non-US companies may have more difficulty acquiring those technologies from the US or acquiring US businesses in those industries.

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(Source: Volkov Law Group Blog, 28 Apr 2019. Reprinted by permission.)

* Author: Michael Volkov, Esq., Volkov Law Group, mvolkov@volkovlaw.com, 240-505-1992.
With the growth of the compliance profession and the importance of compliance functions as part of corporate governance, there has been a significant increase in the quantity and quality of compliance studies and surveys. It takes time to keep up with all the compliance information being developed and released.

In this episode, Michael Volkov reviews two recent compliance studies.


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TE_a112. ECS Presents “2nd Annual ECS ITAR/EAR Symposium and Boot Camp” on 17-19 Sep in Annapolis, MD

* What: The 2nd Annual ECS ITAR/EAR Symposium and Boot Camp; Annapolis, MD
* When: 17-19 September 2019
* Where:
Chart House 
* Sponsor: Export Compliance Solutions & Consulting (ECS)
* ECS Speaker Panel: Suzanne Palmer, Mal Zerden, Lisa Bencivenga, Timothy Mooney, Matthew McGrath, Matt Doyle
* Register 
 or by calling 866-238-4018 or e-mail

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FCC Presents “Designing an Internal Compliance Program for Export Controls & Sanctions”, 1 Oct in Bruchem, the Netherlands

* What: Designing an Internal Compliance Program for Export Controls & Sanctions”
* Date: Tuesday, 1 Oct 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 – 4.30 pm
* Level: Intermediate
* Target Audience:  the course provides valuable insights for both compliance professionals, employees and (senior / middle) management working in any industry subject to U.S. and/or EU (member state) export control laws and sanctions regulations.
* Instructors: Drs. Ghislaine C.Y. Gillessen RA and Marco M. Crombach MSc.

* Information & Registration: click here or contact us at events@fullcirclecompliance.eu or 31 (0)23 – 844 – 9046.  

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* Simon Kuznets (Simon Smith Kuznets; 30 Apr 1901 – 8 Jul 1985; was an American economist and statistician who received the 1971 Nobel Memorial Prize in Economic Sciences “for his empirically founded interpretation of economic growth which has led to new and deepened insight into the economic and social structure and process of development.”)
  – “Memorable occasions should be brief, and so should be the expressions of appreciation.”
* Hosea Ballou (30 Apr 1771 – 7 Jun 1852; was an American Universalist clergyman and theological writer.)
  – “Education commences at the mother’s knee, and every word spoken within hearsay of little children tends toward the formation of character.”

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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 Apr 2019: 84 FR 16398-16402: International Traffic in Arms Regulations: Transfers Made by or for a Department or Agency of the U.S. Government   
  – The only available fully updated copy (latest edition: 19 Apr 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: 19 Apr 2019: 84 FR 17950-17958: Foreign Interference in U.S. Elections Sanctions Regulations [amendment of 31 CFR Part 579 to implement EO 13848]  
* 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: 18 Apr 2019: Harmonized System Update (HSU) 1906

  – 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, 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.

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