19-0529 Wednesday “Daily Bugle”

19-0529 Wednesday “Daily Bugle”

Wednesday, 29 May 2019

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

inquiries and rates

  1. Commerce/BIS Seeks Comments on Form 0694-0125, BIS Program Evaluation 
  1. Items Scheduled for Publication in Future Federal Register Editions 
  2. Commerce/BIS: (No new postings.)
  3. DoD/DSCA Posts Policy Memo 19-30
  4. State/DDTC: (No new postings.)
  5. OMB/OIRA Reviews of Proposed Ex/Im Regulations: Implementation of New Commerce 232 Exclusion Process Portal
  6. OMB/OIRA Reviews of Proposed Ex/Im Regulations: Restricting the Temporary Sojourn of Aircraft and Vessels to Cuba
  7. Treasury/OFAC Releases 2018 Terrorist Assets Report
  1. American Shipper: “CBP Takes Steps to Reinvigorate Export Oversight”
  2. Bloomberg: “Hong Kong Rejects U.S. Warning on Ship Breaching Iran Sanctions”
  3. Bloomberg: “U.S. Warns Europe That Its Iran Workaround Could Face Sanctions”
  4. Reuters: “Huawei Challenges U.S. Defense Bill as Sanctions Fight Ramps Up”
  5. Swissinfo: “Authorities Intervene to Halt Exports of Nuclear Weapons Material”
  1. A. Halevy: “Artificial Intelligence and Export Control – What’s the Connection?”
  2. H. Bucher: “ITAR and EAR Compliance and Modern Product Development” (Part I of III)
  3. K.J. Wolf, T.J. McCarthy & S. Kimiagar: “Commerce Department Imposes Controls on Five Types of “Emerging Technologies” Agreed to by Multilateral Regime Allies”
  4. L. Catrain, A. Doussin & J. Charles: “Contacts New EU Sanctions Regime for Cyber-Attacks”
  5. M. Moore: “Trading with the Entity: Impact on Non-US Manufacturers from Huawei’s Addition to the Entity List (Part II of II)”
  6. Thompson Hine: “Trump Administration Further Tightens Economic Sanctions and Trade Restrictions on Venezuela”
  1. ECTI Presents “Export Control and IT Modernization – Issues and Considerations” Webinar on 25 Jun
  2. FCC Presents “The ABC of FMS”, 28 Nov 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 (24 May 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 (21 May 2019) 
  3. Weekly Highlights of the Daily Bugle Top Stories 


Commerce/BIS Seeks Comments on Form 0694-0125, BIS Program Evaluation
(Source: Federal Register, 29 May 2019.) [Excerpts.]
84 FR 24742 – 24743: Submission for OMB Review; Comment Request
* Agency: Bureau of Industry and Security.
* Title: BIS Program Evaluation.
Form Number(s): 0694-0125.
– OMB Control Number: 0694-0125.
– Type of Review: Regular submission.
– Estimated Total Annual Burden Hours: 500.
– Estimated Number of Respondents: 3,000.
– Estimated Time per Response: 10 minutes.
Needs and Uses: This collection of information is necessary to obtain feedback from seminar participants. This information helps BIS determine the effectiveness of its programs and identifies areas for improvement. The gathering of performance measures on the BIS seminar program is also essential in meeting the agency’s responsibilities under the Government Performance and Results Act (GPRA).
– Affected Public: Business or other for-profit organizations.
– Frequency: On Occasion.
– Respondent’s Obligation: Voluntary.
This information collection request may be viewed at
. 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 OIRA_Submission@omb.eop.gov.
Sheleen Dumas, Departmental Lead PRA Officer, Office of the Chief Information Officer, Commerce Department.

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

[No items of interest noted today.]  
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Commerce/BIS: (No new postings.)

(Source: Commerce/BIS)

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DoD/DSCA Posts Policy Memo 19-30

(Source: DoD/DSCA), 29 May 2019.)
This memorandum updates the SAMM with clerical and administrative changes. This memorandum does not contain contextual policy changes. DSCA will issue contextual changes to the SAMM under a separate policy memo/SAMM E-change. These administrative changes will be included in the online version of the SAMM here.
The SAMM changes identified in this memorandum are effective immediately. For questions, please contact Andrew Mayer, (703) 697-9480.

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OMB/OIRA Reviews of Proposed Ex/Im Regulations:
Implementation of New Commerce 232 Exclusion Process Portal

(Source: OMB/OIRA), 28 May 2019.)  
* TITLE: Implementation of New Commerce 232 Exclusion Process Portal
– STAGE: Interim Final Rule
– RECEIVED DATE: 28 May 2019
– RIN: 0694-AH55
– Status: Pending Review

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OMB/OIRA Reviews of Proposed Ex/Im Regulations:
Restricting the Temporary Sojourn of Aircraft and Vessels to Cuba

(Source: OMB/OIRA), 28 May 2019.)  
* TITLE: Restricting the Temporary Sojourn of Aircraft and Vessels to Cuba
– AGENCY: DOC-BIS        
– STAGE: Final Rule       
– RECEIVED DATE: 28 May 2019
– RIN: 0694-AH87
– Status: Pending Review

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Treasury/OFAC Releases 2018 Terrorist Assets Report

(Source: Treasury/OFAC, 29 May 2019.)   
The Office of Foreign Assets Control has released its 2018 Terrorist Assets Report.

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American Shipper: “CBP Takes Steps to Reinvigorate Export Oversight”

(Source: American Shipper, 29 May 2019.) [Excerpts.]
With COAC’s help, U.S. Customs and Border Protection seeks to devise an online strategy to better target illicit exports before they can leave the country.
Customs and Border Protection’s primary focus has long been on the health and safety, as well as revenue collection, of the nation’s voluminous imports. However, the increased national security controls placed on U.S. exports has the agency working to strengthen its outbound cargo oversight.
CBP serves as the front-line enforcement arm of several primary export control agencies, including the Commerce Department’s Bureau of Industry and Security, State Department’s Directorate of Defense Trade Controls and Treasury Department’s Office of Foreign Assets Control. …

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Bloomberg: “Hong Kong Rejects U.S. Warning on Ship Breaching Iran Sanctions”

(Source: Bloomberg, 29 May 2019.) [Excerpts.]
Hong Kong dismissed U.S. warnings that it could face penalties if it does business with an oil tanker headed for the city that allegedly violated sanctions on Iran.
The city’s government has “strictly” implemented United Nations Security Council sanctions, which don’t impose “any restrictions on the export of petroleum from Iran,” a spokesperson for Hong Kong’s Commerce and Economic Development Bureau said on Wednesday in response to a question about the U.S. warning.
“Certain countries may impose unilateral sanctions against certain places on the basis of their own considerations,” they said. “Those sanctions are outside the scope of the UN Security Council sanctions” implemented by Hong Kong. …

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Bloomberg: “U.S. Warns Europe That Its Iran Workaround Could Face Sanctions”

(Source: Bloomberg, 29 May 2019.) [Excerpts.]
The Trump administration escalated its battle with European allies over the fate of the Iran nuclear accord, threatening penalties against the financial body created by Germany, the U.K. and France to shield trade with the Islamic Republic from U.S. sanctions.
Sigal Mandelker, the Treasury Department’s undersecretary for terrorism and financial intelligence, signaled in a May 7 letter obtained by Bloomberg that Instex, the European vehicle to sustain trade with Tehran, and anyone associated with it could be barred from the U.S. financial system if it goes into effect.
“I urge you to carefully consider the potential sanctions exposure of Instex,” Mandelker wrote in the letter to Instex President Per Fischer. “Engaging in activities that run afoul of U.S. sanctions can result in severe consequences, including a loss of access to the U.S. financial system.” …

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Reuters: “Huawei Challenges U.S. Defense Bill as Sanctions Fight Ramps Up”

(Source: Reuters, 29 May 2019.) [Excerpts.]
China’s Huawei Technologies Co Ltd has filed a legal motion seeking to declare a U.S. defense law unconstitutional, in the telecom equipment maker’s latest bid to fight sanctions from Washington that threaten to push it out of global markets. …
Earlier this month, the U.S. Commerce Department put Huawei on a trade blacklist that bans companies from doing business with the Chinese firm, a move which immediately disrupted the global tech sector.
Huawei’s chief legal officer, Song Liuping, on Wednesday said the company was reviewing ways to fight the U.S. ban, which he said was affecting its more than 1,200 suppliers and threatened to affect its 3 billion customers in 170 countries. …

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Swissinfo: “Authorities Intervene to Halt Exports of Nuclear Weapons Material”

(Source: Swissinfo, 26 May 2019.) [Excerpts.]
Federal authorities are stepping up efforts to prevent the sale of Swiss machinery that could be used to develop nuclear weapons. The latest interventions concern direct sales to the US and France.
According to reports external link by the German-language newspaper NZZ am Sonntag, the federal export group halted the export of suspicious machinery to the US two times last year. Livia Willi, spokesperson for the State Secretariat for Economic Affairs (SECO), told the paper, “There was reason to believe that the goods would be used for the development of nuclear weapons”.

In the past six months, the US has ordered three laser markers worth a total of almost CHF 250,000 from Swiss companies. There have been other interventions as well including in October 2017, when Swiss authorities intervened to stop the export of machine spindles to France. … 

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A. Halevy: “Artificial Intelligence and Export Control – What’s the Connection?”

(Source: IHLS, 26 May 2019.)
* Author: Amiram Halevy, Independent Consultant, Amiram Halevy Consulting, info@i-hls.com. .
It has recently been published that Facebook’s development center in Israel is increasing its artificial intelligence (AI) capabilities. The company has established a team, called Data.AI, for developing AI tools that are intended to help build and improve software infrastructure and systems for data research on facebook. According to Facebook, these tools are intended to improve and optimize the work that Facebook’s international engineers and programmers handle. “If up until now most of Facebook’s efforts in the AI field has focused on advancing and improving the user’s experience, then now another dimension is being added by the Israeli team – the development of AI based capabilities towards the improvement of infrastructure and the capabilities of the internal interfaces of the company,” Facebook mentions.
Artificial Intelligence and Export Control
The Wassenaar Arrangement on Export Controls for dual-use goods and technologies supervises the export of technologies relating to AI, among other things. The purpose isn’t necessarily to supervise and control the possible applications of AI, but to control the export of AI tools and technologies allowing companies to develop such AI applications.
The many Israeli companies working in these fields should be aware of the need to check if the export of technology, whether it be traditional export or sellingtransferring the technologies abroad, requires certain permission from regulators.
For example, at the end of my service as a regulator for the Israeli Ministry of Economics, a multinational company that manufactures smartphones and has opened an R&D center in Israel, contacted me. The Israeli center developed facial recognition technologies that were to be implemented into the company’s smartphones. For the purpose of exporting the product of the development process back to the company’s home country, the company’s representatives asked to clarify if they had to have an export license.
When I visited the company’s Israeli branch, it turned out that the export of the previously mentioned technology does, in fact, need an export license as well as an “end user certificate” from the company’s parent company abroad.
The company asked for a license and they were granted one. There was no need for the company to ask for a license allowing them to sell the devices, the licensing was for the technology itself, that allows the company to integrate the facial recognition to their devices.
What is Artificial Intelligence?
Artificial intelligence, as an academic term, has been around since the mid 1900s. Its purpose back then, as well as today, was to make computers perform tasks that were considered exclusive to humans: tasks that require intelligence.
In its introduction, researchers worked on chess games and solving logical problems. Later on, development focused on the field of neural networks – the attempt to recreate how the human brain works and to utilize the efficiencies in the neural structure in order to solve complex logical challenges.
Artificial neural networks in software showed great promise and succeeded in solving some of the more complex problems that other algorithms couldn’t handle.
It is a mathematical computation model, built from several neurons arranged in layers, where any neuron can interact with several other neurons in the system. Each neuron is capable of performing basic logical calculations, which the data derived from each calculation is moved onto other neurons. In this manner, with the data moving forward through the layers, the system manages to convert the raw data into valuable data. The system then learns how to make more precise decisions.
Applications of Artificial Intelligence
It seems as though every technological field today utilizes AI applications. As time goes by, AI-based software is becoming more and more prevalent in our everyday lives in tasks such as searching for images, converting speech to text, translating audio messages, and more.
Support with Text Based Decision Making: Assisting businesses with data analysis or customer support. Companies that want to gather more precise insights regarding their customers stance on a new product or service launch; or organizations surveying the public about customer satisfaction towards a certain topic. IBM’s Project Debater, for example, is the first AI platform in the world that has succeeded in debating with a human regarding complex issues. This platform was developed in IBM’s research lab in Haifa. The platform has expanded the ability to support text-based decision making.
Automotive Fields: The start-up MOODIFY is trying to combine two separate fields – psychology and AI – in order to examine the psychological state of the driver and to improve safety while driving. The technology utilizes real time facial recognition as well as voice analysis and diagnosis of the driver’s vital signs in order to identify dangerous psychological states such as stress, anxiety, depression, and even “microsleep”. The solution – a personalized and quick spray of sophisticated aromas meant to relax the driver.
Military Fields: According to an article published on i-HLS.com, STM, a company that deals with security technologies and has developed the first Turkish “suicide” drones, will upgrade the aircraft with the help of AI. Today, drones possess high intelligence, the ability to operate as a swarm, and a high level of autonomy, all thanks to AI.

Facial Recognition: With the help of neural networks and AI, a computer can identify objects in such a way that the first neurons in the network know to identify straight lines. With the next layer of neurons identifying corners or simple templates. The following layer can identify the contours of different areas, and finally the last layer of neurons will know to identify if the image is a human face or not. 

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H. Bucher: “ITAR and EAR Compliance and Modern Product Development” (Part I of III)
(Source: Arena Solutions, May 2019.)
* Author: Heatherly Bucher, Director of Product Marketing, 1-866-937-1438, sales@arenasolutions.com.
As a high tech electronics manufacturer, you have your hands full developing and producing today’s complex products-a mix of sophisticated electrical, mechanical, and software elements. If you participate in the defense market, you may also be subject to strict federal regulations governing at least some of your product data and processes-either directly as an ITAR- or EAR-registered company or from your customers as part of flow-down requirements from their compliance needs.
And, as your products embody the most current technologies including IoT platforms, analytics, machine learning, and artificial intelligence, you might also need to update the very processes and tools you use to deliver products. Timely design decisions without multiple meetings? Transparent, accessible information on the latest revision sent to production? A clear, traceable set of requirements for the new product introduction coming up next month?
Complex products mean diverse teams-from engineering, program management, and scientific to quality assurance, operations, and supply chain. To succeed, you must deliver the right product at the right time for the right price to the customer. If your customer is part of the defense supply chain or a defense agency, all this product work must happen within the framework of strict federal compliance regulations. Products created for United States defense purposes are subject to the International Traffic in Arms Regulations (ITAR) and/or Export Administration Regulations (EAR), requiring manufacturers to adhere to a complex set of regulations to protect national security interests. Neither ignorance nor good intentions spare a company from serious consequences if it violates regulations. Recent non-compliance fines have ranged from $20,000 to $78 million and resulted in contract losses.
Before we look at your options for product lifecycle management (PLM), we need to review the basics of ITAR and EAR regulations as related to product development.
Understanding ITAR and EAR
At the most basic level, the regulations stipulate that any technical data deemed controlled by ITAR or EAR be under export control, meaning that technical data must not be exported at any point during design or production (or sustaining activities) unless covered under an export license. [FN/1]
In practical terms, this means that:
(1) ITAR- and EAR-regulated data must remain in the U.S. and be accessible only to U.S. citizens/U.S. green card holders.
(2) In-transit and at-rest data must be encrypted.
(3) Access to any platform containing regulated product data must be controlled and restricted to U.S. persons.
To summarize, companies must have tight control over all regulated technical data, including what’s referred to as controlled unclassified information (CUI). Depending on the circumstances, technical data can include file names, component descriptions, engineering drawings, specifications, test procedures, bills of materials, and more. As the registered manufacturer, you define what technical data in your product record is under export control based on your product, how the government classifies the product, and what particulars of the product are of interest to the U.S. government. All restricted data must be tightly controlled based on the terms above. This control includes standard policies and procedures for access, audit history, and incident reporting.
Furthermore, the access the regulations refer to includes any method of access:
– any operating system and any application, including during IT assistance and/or maintenance in systems where restricted data is stored. It specifies that all methods of sharing information require control (e.g., email, faxes, and physical deliveries).
Clearly, complying with these stringent regulations without sacrificing business agility can be an unwanted challenge for manufacturers of complex electronic devices.
Options for managing export controlled data
Compliance breeds caution. While this is understandable, it isn’t the desirable position to drive innovation or ensure market advantage. In the past, you might have found product record tool choices limited: desktop apps, spreadsheets, and local file servers; homegrown solutions; or heavier, outdated PLM systems. While any of these solutions can suffice for a period of time, none of these enable scaling your business, optimizing processes, and exceeding quality and market goals. And, most of them were not designed to (and cannot) adequately address the security and location-based restrictions federal regulations demand without cost and additional risk.
For any export controlled technical data, all records, access, and movement of data must meet federal regulations, as we’ve discussed. Manufacturers that assume a product record solution, tool, or platform meets regulatory requirements, without due diligence of validation, risk unpleasant customer audits or non-compliance incidents that endanger current or future contracts.
ITAR and EAR regulations impact every layer of tools and methods of storing and accessing controlled technical data: from physical and logical layers (e.g., hardware, OS systems, networks, protocols) and platforms and applications to product data structures, data classification, end-user controls, and access management. For each of these areas, the regulations stipulate specific requirements, and the responsible owner for each layer must ensure requirements are met, including policies and procedures, incident reporting, and maintenance activities.
Assumptions can be dangerous. Off-the-shelf business applications, such as word processing and spreadsheet software, are not designed to address these security and location-based restrictions. Your network may or may not already meet regulatory requirements for encryption and location-based access for identified users; most likely it does not unless you communicated these requirements to your IT team. And, for most manufacturers, to create the structures and processes in physical, logical, platform, and application layers diverts resources and time from the important work of making products.
Modern secure Cloud PLM – shared responsibility
In the commercial markets, manufacturers benefit from business-ready Cloud PLM solutions (like Arena, of course) that provide the product control and team collaboration needed in a flexible, scalable, and easy-to-implement platform. However, until recently, regulated defense suppliers have not been able to easily adopt a Cloud PLM for full product control across all product lines. Instead, they have settled for the inferior solutions we discussed earlier, all of which require responsibility burdens outside of the work of developing and delivering product to customers.
With the advent of regulatory maturity, plus the U.S. government’s own Cloud First, Cloud Smart [FN/2], and Gov cloud initiatives, and superior technology and platform advances, secure government-grade Cloud PLM is now a reality. Defense manufacturers can have a modern and empowering Cloud PLM, benefitting from a better shared-responsibility security model.
If your company participates in the defense industry, check out the Cloud PLM that will help address your ITAR and EAR regulatory needs, while empowering your teams with one source of product truth. Very soon, the same proven Arena PLM solution used by over 1,300 leading manufacturers will be available for our defense supply chain customers.  . . .
[FN/1] ITAR and EAR regulations are complex, and Arena Solutions is not offering any legal advice or counsel for any reader of this blog, nor should you take our statements as guidance to supersede your responsibilities to comply with these regulations.

[FN/2] https://cloud.cio.gov/

[Parts II and III to be posted tomorrow and Friday.]

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K.J. Wolf, T.J. McCarthy & S. Kimiagar: “Commerce Department Imposes Controls on Five Types of “Emerging Technologies” Agreed to by Multilateral Regime Allies”

(Source: Akin Gump Strauss Hauer & Feld LLP, 28 May 2019.)
* Authors: Kevin J. Wolf, Esq., kwolf@akingump.com, 1-202-887-4051; Thomas J. McCarthy, Esq., tmccarthy@akingump.com, 1-202-887-4047; and Sina Kimiagar, Esq., skimiagar@akingump.com, 1-202-887-4306; all of Akin Gump Strauss Hauer & Feld LLP.
The Department of Commerce’s Bureau of Industry and Security (BIS) has amended the Export Administration Regulations (EAR) to add controls over specific types of:
– Discrete microwave transistors used in wideband semiconductors.
– Software that ensures continuity of operation when electronics are exposed to an Electromagnetic Pulse (EMP) or Electrostatic Discharge (ESD).
– Post-quantum cryptographic algorithms (also known as quantum-safe or quantum-resistant algorithms).
– Underwater transducers designed to operate as hydrophones.
– Aircraft specially designed or modified to be air-launch platforms for space launch vehicles.
These are not the much-discussed possible unilateral (i.e., U.S.-only) controls over “emerging” and “foundational” technologies that could be proposed and implemented under the authority of section 4817 of the Export Control Reform Act of 2018 (ECRA). Rather, they are controls agreed to last year by our multilateral regime allies that meet the same standards for control as that provision – i.e., they are newly developed or developing items essential to the national security of the United States. BIS has not yet announced its plans for whether or which “emerging” or “foundational” technologies it will propose unilateral controls over pursuant to this ECRA section.
The Wassenaar Arrangement consists of 42 countries that have agreed to regulate the same lists of military and dual-use items to prevent destabilizing accumulations of such items or their use by terrorists. Representatives from each country meet several times a year, usually in Vienna, Austria, to discuss and decide upon the warranted new or amended controls. Final decisions are usually agreed to each December. BIS traditionally implements the agreed-upon controls in one final notice the following year. BIS has, however, decided to publish early the Wassenaar controls it deemed to be “recently developed or developing technologies” that are essential to the national security of the United States. The remaining changes agreed to in the Wassenaar Arrangement’s plenary meeting will be published later, according to the rule.
New and Revised Controls
Changes to the Commerce Control List (CCL) include the addition of, and revisions to, the following Export Control Classification Numbers (ECCNs):
3A001 – The rule adds new ECCN 3A001.b.3.f to control discrete microwave transistors rated for operation with a peak saturated power output greater than 5 W (37.0 dBm) at all frequencies exceeding 8.5 GHz up to and including 31.8 GHz (due to the increasing variety of dual-use applications for wideband semiconductors).
3D005 – The rule adds new ECCN 3D005 for software specially designed to restore normal operation of a microcomputer, microprocessor microcircuit, or microcomputer microcircuit within 1 ms after an Electromagnetic Pulse (EMP) or Electrostatic Discharge (ESD) disruption, without loss of continuation of operation.
5A002 – The rule amends the Technical Notes following ECCN 5A002.a.4 in order to control asymmetric algorithms with security based on post-quantum cryptography (e.g., “NewHope,” “Frodo,” “NTRUEncrypt,” “Kyber,” “Titanium,” “SIKE,” “McEliece,” “Niederreiter”).
6A001 – The rule adds Technical Note 2 to ECCN 6A002.a.2.a to clarify that underwater acoustic transducers designed to operate as passive receivers are hydrophones, and the rule amends 6A002.a.2.a.6 with certain technical parameters to control underwater transducers designed to operate as hydrophones (due to their utility in Anti-Submarine Warfare).
9A004 – The rule adds new ECCN 9A004.g to control aircraft specially designed or modified to be air-launch platforms for space launch vehicles (SLV) in recognition of the move towards air-launch platforms by some commercial satellite owners and space tourism companies.
The Emerging and Foundational Technologies Review Process
These changes are not the possible and much-discussed unilateral controls over “emerging” or “foundational” technologies that could be authorized under ECRA section 4817. Given the timing of their publication, they were almost certainly under consideration by the multilateral regime allies before ECRA became law. In addition, ECRA section 4817 requires any new controls issued under the authority of that provision to be published as a proposed rule for public review and comment before being implemented. BIS published the new changes in a final rule. Nonetheless, the new controls are, according to the rule, consistent with the ECRA standards for the types of emerging technologies to be controlled. In addition, consistent with a congressional preference expressed in ECRA, the new controls are multilateral, meaning that the United States and its regime allies impose or will soon impose the same controls.
BIS’s plans for publishing proposed unilateral controls over “emerging” and “foundational” technologies remain unknown. BIS and its interagency colleagues are apparently still reviewing public comments filed in response to its request for information about various types of emerging technologies and otherwise analyzing the issues. BIS has not published a request for information seeking public comments on which types of “foundational” technologies do and do not warrant controls.

Regardless of the background to the new controls, companies should review the new and revised CCL entries in ECCNs 3A001, 3D005, 5A002, 6A001, and 9A004 to identify whether they describe items relevant to their business or other activities, and control them accordingly. All should also stay tuned in 2019 for the remaining Wassenaar changes to be implemented and any proposed controls over emerging or foundational technologies or requests for information about them. 

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L. Catrain, A. Doussin & J. Charles: “Contacts New EU Sanctions Regime for Cyber-Attacks”

(Source: Hogan Lovells, 24 May 2019.)
* Authors: Lourdes Catrain, Esq., Lourdes.Catrain@hoganlovells.com; Aline Doussin, Esq., Aline.Doussin@hoganlovells.com; and Jérémie Charles, Esq., jeremie.charles@hoganlovells.com. All of Hogan Lovells.
On 17 May 2019, the EU adopted a new sanctions regime to deter and respond to cyber-attacks through the possible imposition of various restrictive measures (i.e., asset-freezing measures and travel bans) against the perpetrators of such attacks. The new sanctions regime is set out in Council Regulation 2019/796 and Council Decision 2019/797; its main features are summarized below.
The notion of cyber-attacks
The new sanctions regime targets cyber-attacks that constitute a threat to the EU or to the EU Member States.
, cyber-attacks comprise the following (unauthorized/unlawful) actions:
– Access to information systems;
– Information system interference; and/or
– Data interference/interception.
, cyber-attacks constitute a threat to the EU where, inter alia, they are carried out against its institutions, bodies, offices and agencies, its delegations to third countries or to international organisations, its common security and defence policy operations and missions, and its special representatives.
, cyber-attacks constitute a threat to the EU Member States where, inter alia, they affect information systems that relate to:
– Critical infrastructure essential for the maintenance of vital functions of society, or the health, safety, security, and economic or social well-being of people;
– Services necessary for the maintenance of essential social and/or economic activities, including in the sectors of energy, transport, banking, financial market infrastructures, drinking water supply and distribution, and digital infrastructure;
– Critical State functions, including in the areas of defence, governance and the functioning of institutions (e.g., public elections or the voting process), the functioning of economic and civil infrastructure, internal security, and external relations;
– The storage or processing of classified information; and/or
– Government emergency response teams.
The potential EU restrictive measures
The new sanctions regime allows the EU to impose asset-freezing measures and travel bans against the perpetrators of cyber-attacks.
, asset-freezing measures consist in:
– The freezing of all funds and economic resources of the perpetrators of cyber-attacks; and
– A prohibition to make funds and economic resources available to the perpetrators of cyber-attacks (except in the framework of exceptional and pre-determined circumstances).
, travel bans consist in preventing the perpetrators of cyber-attacks from entering into, or transiting through, the territories of the EU Member States (except in the framework of exceptional and pre-determined circumstances).
, the perpetrators of cyber-attacks include:
– Natural or legal persons, entities or bodies that are responsible for cyber-attacks or attempted cyber-attacks (as well as natural or legal persons, entities or bodies associated therewith);
– Natural or legal persons, entities or bodies that provide financial, technical or material support for or are otherwise involved in cyber-attacks or attempted cyber-attacks, including by planning, preparing, participating in, directing, assisting or encouraging such attacks, or facilitating them whether by action or omission (as well as natural or legal persons, entities or bodies associated therewith).
The Council of the EU will be responsible for establishing the list of perpetrators of cyber-attacks subject to asset-freezing measures and/or travel bans (the list will be annexed to Regulation 2019/796). As in the case of the other EU sanctions regimes, the new sanctions regime is directly applicable in all EU Member States who are responsible for adopting and enforcing the penalties for breaches of the applicable asset-freezing measures and/or travel bans. The UK has already adopted the necessary legislation to transpose the new sanctions regime into domestic law, which indicates that the UK intends to continue applying such regime after it leaves the EU.
Consequences for global businesses

The new sanctions regime adds a layer to the due diligence exercise that EU-based companies (and EU individuals in the EU and abroad) must routinely undertake in the framework of their global operations. In addition to making sure that they are not entering into a transaction prohibited or restricted under existing EU economic sanctions regimes (targeting e.g., specific sectors, activities and/or persons), they will now also have to verify that their activities are fully compliant with the restrictions applicable to perpetrators of cyber-attacks. 

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M. Moore: “Trading with the Entity: Impact on Non-US Manufacturers from Huawei’s Addition to the Entity List (Part II of II)”

(Source: Author)
* Author: Matthew Moore, Esq., Moore Compliance Law, P.C.; 256-924-2979;
The “Foreign-Produced
roduct” Rule (EAR Sections 734.3(a)(4) and 736.2(b)(3)):
In addition to the de minimis rule, the Non-U.S. Manufacturer must also consider the “foreign-produced
product” rule, in order to determine whether the non-U.S.-origin goods are subject to the EAR. There are some special rules for 9×515 and “600 series” foreign-produced direct products. But EAR Section 736.2(b)(3) provides the general rule, as follows:
“(3) General Prohibition Three-Reexport and export from abroad of the foreign-produced direct product of U.S. technology and software (Foreign-Produced Direct Product Reexports)-(i) Country scope of prohibition. You may not, without a license or license exception, reexport any item subject to the scope of this General Prohibition Three to a destination in Country Group D:1, E:1, or E:2 (See supplement no.1 to part 740 of the EAR). Additionally, you may not, without a license or license exception, reexport or export from abroad any ECCN 0A919 commodities subject to the scope of this General Prohibition Three to a destination in Country Group D:1, D:3, D:4, D:5, E:1, or E:2.
(ii) Product scope of foreign-made items subject to prohibition. This General Prohibition 3 applies if an item meets either the Conditions defining the direct product of technology or the Conditions defining the direct product of a plant in paragraph (b)(3)(ii)(A) of this section:
(A) Conditions defining direct product of technology. Foreign-made items are subject to this General Prohibition 3 if they meet both of the following conditions:
(1) They are the direct product of technology or software that requires a written assurance as a supporting document for a license, as defined in paragraph (o)(3)(i) of supplement no. 2 to part 748 of the EAR, or as a precondition for the use of License Exception TSR at §740.6 of the EAR, and
(2) They are subject to national security controls as designated on the applicable ECCN of the Commerce Control List at part 774 of the EAR.
(B) Conditions defining direct product of a plant. Foreign-made items are also subject to this General Prohibition 3 if they are the direct product of a complete plant or any major component of a plant if both of the following conditions are met:
(1) Such plant or component is the direct product of technology that requires a written assurance as a supporting document for a license or as a precondition for the use of License Exception TSR in §740.6 of the EAR, and
(2) Such foreign-made direct products of the plant or component are subject to national security controls as designated on the applicable ECCN of the Commerce Control List at part 774 of the EAR.”
In other words, the Non-U.S. Manufacturer’s export of the non-U.S. product to a D:1 country (which would include China and about 20 other countries) would be “subject to the EAR” if both: (1) the non-U.S.-made product is controlled for National Security (NS) reasons, and (2) the technology/software from which the non-U.S. product is made is controlled for NS reasons. Conversely, if the non-U.S. product is not going to a D:1 country or does not meet either of elements (1) or (2) above, then the non-U.S. Manufacturer’s export to Huawei would not be “subject to the EAR.”
If the non-U.S. product is subject to the EAR (under the “de minimis” or “foreign-made direct product” rules), the Entity List terms would normally apply-i.e., license required for all items, and a presumption of denial for all such license applications.
The Temporary General License (EAR Supplement No. 7 to Part 744):
If the Manufacturer determines that its sale of the non-U.S. product to Huawei is “subject to the EAR,” a sale to Huawei may yet be authorized under the Temporary General License, which BIS published as a final rule on May 22, 2019. See 84 FR 23468. The Temporary General License will be effective until 19 August 2019. During the effective period, the Temporary General License will effectively make it like Huawei is not on the Entity List, provided the subject export fits within one of the 4 scenarios. Those 4 scenarios are as follows:
“(1) Continued operation of existing networks and equipment: BIS authorizes engagement in transactions, subject to other provisions of the EAR, necessary to maintain and support existing and currently fully operational networks and equipment, including software updates and patches, subject to legally binding contracts and agreements executed between Huawei and third parties or the sixty-eight non-U.S. Huawei affiliates and third parties on or before May 16, 2019.
(2) Support to existing handsets: BIS authorizes engagement in transactions, subject to other provisions of the EAR, necessary to provide
service and support, including software updates or patches to existing Huawei handsets. This authorization is limited to models of Huawei handsets that were available to the public on or before May 16, 2019.
(3) Cybersecurity research and vulnerability disclosure: BIS authorizes, subject to other provisions of the EAR, the disclosure to Huawei, and/or the sixty-eight non-U.S. affiliates of information regarding security vulnerabilities in items owned, possessed or controlled by Huawei or any of the sixty-eight non-U.S. affiliates when related to the process of providing ongoing security research critical to maintaining the integrity and reliability of existing and currently fully operational networks and equipment.
(4) Engagement as necessary for
development of 5G standards by a duly recognized standards body: BIS authorizes, subject to other provisions of the EAR, engagement with Huawei and/or the sixty-eight non-U.S. affiliates as necessary for the
development of 5G standards as part of a duly recognized international standards body (e.g., IEEE – Institute of Electrical and Electronics Engineers; IETF – Internet Engineering Task Force; ISO – International Organization for Standards; ITU – International Telecommunications Union; ETSI- European Telecommunications Standards Institute; 3GPP – 3rd Generation Partnership Project; TIATelecommunications Industry Association; and GSMA, a.k.a., GSM Association, Global System for Mobile Communications).”
Note: Just because a transaction fits within one of these scenarios (and otherwise meets the requirements of the Temporary General License) does not mean the transaction can be consummated without a specific EAR export license. Again, if the transaction fits one of these scenarios, the effect is that it is like Huawei is not on the Entity List. But, even before Huawei was added to the Entity List, many transactions would still require a license-primarily based on country of
destination and the Part 742 CCL-based controls. So, all of those non-Entity-List controls still apply.
The Temporary General License also requires an exporter relying on the license to complete and retain (but not file) a certification statement that must specify how the export, reexport, or transfer (in-country) meets the scope of the Temporary General License.
In conclusion, a non-U.S. Manufacturer who wants to sell to Huawei must evaluate both the “de minimis” rule and the “foreign-made direct product” rule, to determine if its proposed transaction is “subject to the EAR.” If the Manufacturer’s transaction is subject to the EAR, the Manufacturer’s proposed sale to Huawei may yet be authorized under the Temporary General License. If, however, the transaction is subject to the EAR and not authorized by the Temporary General License, then the Entity List’s terms regarding Huawei will apply-i.e., a license is required for all items, and a presumption of denial for any license application.

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Thompson Hine: “Trump Administration Further Tightens Economic Sanctions and Trade Restrictions on Venezuela”

(Source: Trump and Trade Blog, 28 May 2019.)
During the month of May while President Donald Trump’s escalating trade war with China was garnering most of the headlines, the Trump administration also continued to apply economic pressure on Venezuela. In May, the Departments of Commerce, State and the Treasury further tightened sanctions and export restrictions on Venezuela.
On May 10, 2019, the Department of State announced that, pursuant to Executive Order 13850, the United States determined persons operating in the defense and security sector of the Venezuelan economy may be subject to economic sanctions. On the same date, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned two companies that operate in the oil sector of the Venezuelan economy, and also sanctioned two vessels, which transported oil from Venezuela to Cuba:  

  – Monsoon Navigation Corporation is based in Majuro, Marshall Islands, and is the registered owner of the vessel, Ocean Elegance.

  – Ocean Elegance is a crude oil tanker (IMO: 9038749) that delivered crude oil from Venezuela to Cuba from late 2018 through March 2019.
  – Serenity Maritime Limited is based in Monrovia, Liberia, and is the registered owner of the vessel, Leon Dias.
  – Leon Dias is a chemical and oil tanker (IMO: 9396385) that delivered crude oil from Venezuela to Cuba from late 2018 through March 2019.

As a result of this action, these entities and vessels have been placed on OFAC’s Specially Designated Nationals (SDN) List and all property and interests in property of these entities, and of any entities that are owned, directly or indirectly, 50 percent or more by the two entities, that are in the United States or in the possession or control of U.S. persons, are blocked and must be reported to OFAC. Also, OFAC’s regulations generally prohibit all dealings by U.S. persons with entities and persons placed on the SDN List.
On May 7, OFAC actually removed sanctions imposed on Manuel Ricardo Cristopher Figuera (Cristopher), who turned against the Maduro regime. Cristopher was the former director general of Venezuela’s National Intelligence Service, more commonly known as SEBIN. This action was viewed as an effort by the Trump administration to encourage other officials in the Maduro regime to oppose Nicolas Maduro Moros and recognize Juan Guaidó as the legitimate president of Venezuela.
On May 24, 2019, the Department of Commerce’s Bureau of Industry and Security (BIS) amended the Export Administration Regulations (EAR) to remove Venezuela from Country Group B (a country group offering more favorable treatment for certain exports) and place it into Country Group D:1 (which lists countries of national security concern). BIS also added Venezuela to Country Groups D:2-4, which cover countries of concern for nuclear, chemical and biological weapons, and missile technology purposes. BIS stated that this change reflects “current national security concerns related to Venezuela, e.g., the introduction of foreign military personnel and equipment into Venezuela, and to better protect U.S. national security.” The changes in this final rule also better align the Country Group designations for Venezuela with other EAR national security-related provisions that already apply to Venezuela, e.g., the military end-use and end-user controls that apply to certain items for export, reexport or transfer (in-country) and provisions that are specific to countries subject to U.S. arms embargoes. These changes will make exports and reexports to Venezuela under the EAR ineligible for certain license exceptions and increases the potential for the imposition of conditions on any export license granted for Venezuela entities or license denials.

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TE_a120. ECTI Presents “Export Control and IT Modernization – Issues and Considerations” Webinar on 25 Jun

(Source: Danielle Hatch, danielle@learnexportcompliance.com.)

* WhatExport Control and IT Modernization – Issues and Considerations
* When: June 25, 2019 1:00 p.m. (EDT)
* Where: Webinar
* Sponsor: Export Compliance Training Institute (ECTI)
* ECTI Speaker: Waqas Shahid & Kaitlyn Alessi
* Register: here or contact Danielle Hatch, 540-433-3977, danielle@learnexportcompliance.com.

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TE_a221. FCC Presents “The ABC of FMS”, 28 Nov in Bruchem, the Netherlands

This training course is specifically designed for compliance professionals and those in a similar role working for government agencies or companies (temporarily) obtaining U.S. export-controlled articles and technology procured through government-to-government Foreign Military Sales (FMS), and authorized by the Arms Export Control Act (AECA) (22 U.S.C. 2751, et. seq.).
The course will cover multiple topics relevant for organizations outside the U.S. working with U.S. export-controlled articles and technology procured through FMS, including: the U.S. regulatory framework, with a special focus on the AECA, key concepts and definitions, and practical compliance tips to ensure the proper handling of FMS-acquired articles and technology. Participants will receive a certification upon completion of the training.
* What: The ABC of Foreign Military Sales (FMS)
* When: Thursday, 28 Nov 2019
– Welcome and Registration: 9.00 am – 9.30 am
– Training hours: 9.30 am – 4.00 pm
* Where: Full Circle Compliance, Landgoed Groenhoven, Dorpsstraat 6, Bruchem, the Netherlands
* Information & Registration: here or contact FCC at events@fullcirclecompliance.eu or + 31 (0)23 – 844 – 9046
* This course can be followed in combination with “U.S. Export Controls: The International Traffic in Arms Regulations (ITAR) from a non-U.S. Perspective” (26 Nov 2019), and/or “U.S. Export Controls: The Export Administration Regulations (EAR) from a non-U.S. Perspective” (27 Nov 2019). Please, see the event page for our combo deals.

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* Gilbert K. Chesterton (29 May 1874 – 14 Jun 1936; was an English writer, poet, philosopher, dramatist, journalist, orator, lay theologian, biographer, and literary and art critic.)
  – “New roads; new ruts.”
  – “Let a man walk ten miles steadily on a hot summer’s day along a dusty English road, and he will soon discover why beer was invented.”

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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: 24 May 2019: 84 FR 24018-24021: Revisions to Country Group Designations for Venezuela and Conforming Changes for License Requirements; and 84 FR 24021: Addition of Certain Entities to the Entity List, Revision of an Entry on the Entity List, and Removal of an Entity From the Entity List [Correction to 14 May 2019 Entity List Amendment.]  
* 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: 29 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: 21 May 2019:
Harmonized System Update (HSU) 1908 

  – 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; and Assistant Editors, Alexander Witt and 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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