19-0716 Tuesday “Daily Bugle'”

19-0716 Tuesday “Daily Bugle”

Tuesday, 16 July 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 

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  1. Commerce/BIS: “Pouran Azad, Sadr Emad-Vaez, of Los Altos Hills, CA and Ghareh Sabz Co. of Teheran, Iran, Denied Export Privileges for a Period of 10 Years”
  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 Targets Al-Qa’ida in Mali
  5. Dutch Government Releases New Report on 2018 Dutch Weapons Export Policy
  6. UK ECJU Amends Licensing Statistics and Data Reports
  7. UK ICC Announces Release of Incoterms 2020 in September 2019
  1. Deutsche Welle: “EU Penalizes Turkey over Cyprus Offshore Drilling”
  2. Netzpolitik.org: “EU States Unanimously Vote Against Stricter Export Controls for Surveillance Equipment”
  3. ST&R Trade Report: “No Section 232 Import Restrictions on Uranium”
  1. A. Kashefi, P. Bayz & A. Josselyn: “New Development: CFIUS’s Jurisdiction has Expanded to Cover Non-Controlling Investments in Certain Industries”
  2. S. Varma, B. Connor & S. Diamond: “U.S. Government Agencies Stress the Importance of Corporate Compliance Programs Through the Issuance of Guidance Documents”
  3. Stratfor: “U.S. Export Controls: What Has Changed?”
  1. ECTI Presents The New “Framework for OFAC Compliance Commitments: What You Need to Know”: 24 July 2019
  2. FCC Presents “Designing an ICP 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 (27 June 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 (5 June 2018), HTSUS (26 Jun 2019) 
  3. Weekly Highlights of the Daily Bugle Top Stories 


EXIM_a11Commerce/BIS: “Pouran Azad, Sadr Emad-Vaez, of Los Altos Hills, CA and Ghareh Sabz Co. of Teheran, Iran, Denied Export Privileges for a Period of 10 Years”

(Source: Commerce/BIS, 18 Jun 2018.) [Summary.]   
* Respondents: Pouran Aazad, a.k.a. Pouran Azad, a.k.a. Pourandokt Aazad, a.k.a. Pourandokt Azad, Sadr Emad-Vaez, a.k.a. Seid Sadredin Emad Vaez of Los Altos Hills, CA, and Ghareh Sabz Co., a.k.a. Ghare Sabz Co., a.k.a. GHS Technology of Teheran, Iran
* Charges: Conspiracy To Export an Item From the United 
States to Iran Without the Required U.S. Government Authorization
* Penalty: Denial of export privileges for a period of 10 years from the date of Sun’s conviction. 
* Date of Order: 8 Jul 2019. 

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OGS_a12. Items Scheduled for Publication in Future Federal Register Editions
(Source: Federal Register, 16 July 2019.)

* Treasury/OFAC; NOTICES; Blocking or Unblocking of Persons and Properties [Pub. Date: 17 July 2019.]
* U.S.-China Economic and Security Review Commission; NOTICES; Hearing [Pub. Date: 17 Juy 2019.]

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Commerce/BIS (No new postings.)

(Source: Commerce/BIS)

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OGS_a45Treasury/OFAC Targets Al-Qa’ida in Mali 

Treasury/OFAC, 16 July 2019.) [Excerpts.]
The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC), in concert with the Department of State, took action today targeting Jama’at Nusrat al-Islam wal-Muslimin (JNIM), a west African terrorist group designated in September 2018, by designating a JNIM leader as a Specially Designated Global Terrorist (SDGT) pursuant to Executive Order (E.O.) 13224, which targets terrorists and those providing support to terrorists or acts of terrorism.  Specifically, OFAC designated Bah Ag Moussa for acting for or on behalf of JNIM.  OFAC also designated Bah Ag Moussa for acting for or on behalf of JNIM leader, Iyad ag Ghali, who was designated pursuant to E.O. 13224 in February 2013. The Department of State today also designated Ali Maychou as an SDGT pursuant to E.O. 13224. …
As a result of today’s action, all property and interests in property of these persons, and of any entities that are owned, directly or indirectly, 50 percent or more by the designated persons, that are in the United States or in the possession or control of U.S. persons are blocked and must be reported to OFAC.  OFAC’s regulations generally prohibit all dealings by U.S. persons or within (or transiting) the United States that involve any property or interests in property of blocked or designated persons. …

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OGS_a78. UK ICC Announces Release of Incoterms 2020 in September 2019

ICS Global, 15 July 2019.) [Excerpts.]
The International Chamber of Commerce (ICC) has announced the release of Incoterms® 2020 in early September 2019. The ICC has stated:
Incoterms® 2020 reflects the ever-changing nature of today’s international trade system. Over the course of the drafting process of Incoterms® 2020, several revisions were made to make sure that the Incoterms® rules clearly and accurately reflect present-day trade practices. From early September 2019, users of the Incoterms® rules will be able to adapt, prepare and train their businesses for 1 January 2020, when Incoterms® 2020 will come into effect. …

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Deutsche Welle: “EU Penalizes Turkey over Cyprus Offshore Drilling”

Deutsche Welle, 15 July 2019.) [Excerpts.]
The European Union agreed political and financial sanctions against Turkey on Monday as a punishment for 
Ankara’s persistence in gas drilling operations off Cyprus, despite repeated warnings from the bloc.
The measures announced in a statement from EU foreign ministers meeting in Brussels late Monday include:
– suspending talks on an air transport agreement
– a review of European Investment Bank lending
– a reduction of financial assistance in 2020.
The ministers said additional “targeted measures” were being worked on to penalize Turkey, which began talks with the bloc to join the EU in 2005.
In recent weeks the bloc has become increasingly frustrated with Ankara’s refusal to heed warnings after what the EU viewed as 
“illegal” gas drilling in Cyprus’ exclusive economic zone.
Turkey does not recognize the government of the Republic of Cyprus. …

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Netzpolitik.org: “EU States Unanimously Vote Against Stricter Export Controls for Surveillance Equipment”

Netzpolitik.org, 16 July 2019.) [Excerpts.]
The EU wants to more closely control the trade of the European surveillance industry with autocratic regimes. After two years of tough negotiations, the member states have found a “compromise”: they are against anything that could limit the trade of spyware. Germany agreed as well. … 
On 28 May, the UN special rapporteur on the right to freedom of opinion and expression, David Kaye, appealed to the international community and 
demanded a moratorium on the sale of spying technology. Everywhere in the world, journalists, activists and opposition members are being monitored with state-of-the-art technology, trade is flourishing – and global regulation is at best in its infancy.
the same arguments, the EU Commission had already 
submitted a reform proposal in 2016 for the European control system. The items include hacking software, large data centres for data retention, IMSI catchers for monitoring demonstrations and equipment for telecommunications surveillance. …

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ST&R Trade Report: “No Section 232 Import Restrictions on Uranium”

Sandler, Travis & Rosenberg Trade Report, 16 July 2019.)
President Trump has declined to impose import restrictions on uranium despite a Department of Commerce determination that imports are threatening to impair national security.
In July 2018 the DOC initiated a Section 232 investigation of uranium ore, uranium concentrate, uranium hexafluoride, enriched uranium, and enriched uranium in fuel assemblies. In April 2019 the department determined that imports of these goods are threatening U.S. national security, noting that the U.S. currently imports about 93 percent of its commercial uranium (up from 85.8 percent in 2009) and that increased production by foreign state-owned enterprises have distorted global prices and made it more difficult for U.S. uranium mines to compete.
However, a July 12 presidential memorandum disagrees with the DOC’s determination, stating that while the report’s findings “raise significant concerns … a fuller analysis of national security considerations with respect to the entire nuclear fuel supply chain is necessary at this time.” To that end the memorandum establishes an interagency working group to develop recommendations for reviving and expanding domestic nuclear fuel production.
If the president had agreed with the DOC he would have had broad authority to adjust imports, including through the use of tariffs and quotas. The petitioner had requested (1) a quota that would reserve 25 percent of the U.S. market for U.S. uranium and (2) a Buy America policy for U.S. government agencies that utilize uranium.

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A. Kashefi, P. Bayz & A. Josselyn: “New Development: CFIUS’s Jurisdiction has Expanded to Cover Non-Controlling Investments in Certain Industries” 

* Authors: Aria Kashefi, Esq.,
akashefi@mofo.com, +1 650 813 5721, Panagiotis C. Bayz, Esq.,
akibayz@mofo.com, +1 202 887 8796, Amy S. Josselyn, Esq.,
ajosselyn@mofo.com, +1 202 572 6794, all of Morrison Foerster.
On August 13, 2018, the Foreign Investment Risk Review Modernization Act of 2018 (or FIRRMA for short) was signed into law, ushering in an unprecedented expansion in the jurisdiction of the Committee on Foreign Investment in the United States (or more commonly known as CFIUS). As our colleagues, Chuck Comey and Jim Ryan, mentioned in an earlier article, the enactment of FIRRMA capped months of escalation in the U.S./China trade relations. The expanded jurisdiction of CFIUS may result in financing transactions becoming subject to mandatory CFIUS declaration requirements prior to closing. Investors and companies alike should therefore take CFIUS considerations into account at the outset of any fundraising effort, even if the investment is not a controlling investment and the transaction is not expected to otherwise have any direct national security implications.
1. Non-Controlling Investments in “Critical Technologies” 
Prior to the enactment of FIRRMA, CFIUS only had jurisdiction to review transactions that could result (directly or indirectly) in “control” (broadly defined to include as little as 10% voting interest) in U.S. companies or U.S. assets by a foreign-owned or controlled person. The CFIUS review regime was also voluntary; there was no requirement to notify CFIUS of a transaction prior to closing, even if that transaction fell within CFIUS’s jurisdiction. With the enactment of FIRRMA, CFIUS’s jurisdiction was expanded to include, among other things, certain non-controlling investments in U.S. businesses involving critical infrastructure, critical technologies, or sensitive data pertaining to U.S. persons. This expanded jurisdiction is expected to be fully effective by February 2020 when CFIUS issues regulations implementing various FIRRMA provisions. …
2. Pilot Program Industries
A non-controlling investment by a foreign person in an Applicable U.S. Business is not, by itself, enough to trigger the mandatory CFIUS notification requirements. The critical technology produced by the Applicable U.S. Business must be one that is used in connection with the activities of the Applicable U.S. Business in one or more of the 27 specified industries (called “pilot program industries”), or that is specifically designed by the Applicable U.S. …
3. Access or Influence by the Foreign Investor
The third prong of the critical technologies pilot program jurisdiction involves the extent to which the investment will provide the foreign person access to information regarding critical technologies or influence over the activities of the Applicable U.S. Business. …
4. Declaration or Notice Requirement and Review Period
The parties to an investment subject to the critical technologies pilot program must submit either an abbreviated declaration or a full notice to CFIUS at least 45 days prior to closing. …
What does this development mean for investors and companies looking to raise funds?
Given the potentially significant penalties if a required filing is not made, investors and companies raising funds must carefully consider the relevant facts and the above legal developments (some of which are still in progress) at the outset of a financing transaction and, together with their legal advisors, develop a plan for navigating these issues.
1. Know Where You Stand; Be Prepared
For U.S. companies looking to raise money, it would be prudent to do a preliminary CFIUS risk assessment to determine, among other things, whether the technology produced by the company would be considered “critical technology” and whether it implicates one or more pilot program industries. …
2. Consider the Implications With Respect to Potential Investors
For a U.S. company that produces critical technology used in a pilot program industry, having foreign investors is not out of the question, and there may be any number of strategic reasons why having such investors may in fact provide a net benefit to the company. However, management should accept investments from foreign investors only after having considered whether additional regulatory compliance is needed. …
3. Consider the Rights Being Provided to Investors
Some of the investor rights that would trigger a CFIUS notification requirement are rights that are commonly provided to lead investors in a financing. …
4. Be Careful About Existing Investors, Too
Finally, the new CFIUS regulations discussed above could apply to a new investment by an existing investor as well, and not only to investments by new investors. …

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S. Varma, B. Connor & S. Diamond: “U.S. Government Agencies Stress the Importance of Corporate Compliance Programs Through the Issuance of Guidance Documents”

Thompson Hine, 15 July 2019.) [Excerpts.]
* Authors: Samir D. Varma, Esq.,
samir.varma@thompsonhine.com, +1 202 263 4136, Brent Connor, Esq.,
brent.connor@thompsonhine.com, +1 202 236 4188, Scott. E. Diamond,
scott.diamond@thompsonhine.com, +1 202 263 4197, all of Thompson Hine.
In May 2019, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) published the 
Framework for OFAC Compliance Commitments (“Framework”), which is intended to help organizations subject to U.S. jurisdiction, as well as foreign entities doing business in or with the United States, U.S. persons, or using U.S.-origin goods or services, to develop and implement an export control and economic sanctions compliance program (SCP). While acknowledging that each company’s SCP will vary depending upon a variety of company-specific and risk-based factors, OFAC has indicated that any program should include, at a minimum, the following compliance components: (1) management commitment; (2) risk assessment; (3) internal controls; (4) testing and auditing; and (5) training.
Although not mandated by law, OFAC has long acknowledged that the implementation of a structured SCP can be a mitigating factor in any enforcement proceeding when an export control or economic sanctions violation is discovered. And, while the existence of an SCP may not provide complete protection against any civil monetary fine, the Framework makes clear that companies that have an effective SCP at the time of an apparent violation would be viewed favorably, and could be a factor in any analysis as to whether a case is deemed “egregious.” …

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Stratfor: “U.S. Export Controls: What Has Changed?”

Stratfor Worldview Enterprise, 2 July 2019.) [Excerpts.]
Since the announcement of the Export Control Reform Initiative (ECRI) in 2011, the revisions have been slowly rolled out and implemented. Since the beginning of the three-phase ECRI rollout, exporters, agencies, and the system at large have experienced major changes. The changes have three overreaching themes: prioritization of business and commerce, unintended consequences, and enforcement and prosecution.
Prioritization of Business and Commerce
The ECRI developed in part from industry pressure to increase commerce and competitiveness of U.S. businesses in the international market. If other countries were selling restricted or prohibited items or selling items in countries with limited access to the U.S. market, then U.S. companies faced significant disadvantages compared to their international counterparts.
The changes moved items from International Traffic in Arms Regulations (ITAR) and the U.S. Munitions List (USML) to the Export Administration Regulations (EAR) and the Commerce Control List (CCL). This meant items controlled for military use, yet having a potential commercial use could be sold more easily, with fewer restrictions. The EAR, generally, places less burden on companies during the licensing process. Eighteen of 21 categories have already transitioned. …

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TE_a115. ECTI Presents The New “Framework for OFAC Compliance Commitments: What You Need to Know”: 24 July 2019

(Source: Danielle Hatch, 
* What: The New “Framework for OFAC Compliance Commitments”: What You Need to Know
* When: 24 July 2019 1:00 p.m. (EDT)
* Where: Webinar
* Sponsor: Export Compliance Training Institute (ECTI)
* ECTI Speaker: Timothy O’Toole
* Register here.
or Danielle Hatch, 540-433-3977, 

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TE_a216. FCC Presents “Designing an ICP for Export Controls & Sanctions”, 1 Oct in Bruchem, the Netherlands

This training course is designed for compliance officers, managers, and other professionals who aim to enhance their organization’s compliance efforts. The course will cover multiple topics and tackle various key questions, including but not limited to:
– Setting the Scene: ensuring compliance in the export control and sanctions arena
– What is expected from your organization? A closer look at the official frameworks and guidelines from U.S. and European government agencies
– Key elements of an ICP
– Best practice tips for enhancing your current compliance efforts  
– Internal controls samples (policies, procedures, instructions)
– Strategic benefits of having an ICP.
* What: Designing an Internal Compliance Program (ICP) 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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* Mary Baker Eddy (16 Jul 1821 – 3 Dec 1910; was an American writer and religious leader who established the Church of Christ, Scientist, as a Christian denomination and worldwide movement of spiritual healers. She wrote and published the movement’s textbook, 
Science and Health with Key to the Scriptures and 15 other books. She started several weekly and monthly magazines-the Christian Science Sentinel, The Christian Science Journal, and The Herald of Christian Science, and in 1908, at the age of 87, she founded The Christian Science Monitor, a global newspaper that has won seven Pulitzer Prizes.)
  – “Jealousy is the grave of affection.”
  – “Health is not a condition of matter, but of Mind.”

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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

: 15 CFR Subtit. B, Ch. VII, Pts. 730-774. Implemented by Dep’t of Commerce, Bureau of Industry & Security.

  – Last Amendment: 27 June 2019: 84 FR 30593-30595: Revisions to the Unverified List

* 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 (4 July 2019) of Bartlett’s Annotated FTR (“BAFTR”), by James E. Bartlett III, is available for downloading in Word format. The BAFTR is a 152-page Word document containing 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: 4 July 2019) of the ITAR with all amendments is contained in Bartlett’s Annotated ITAR (“BITAR”), by James E. Bartlett III. The BITAR is a 371-page Word document containing 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: 5 June 2019: 84 FR 25992 – June 2019 Amendments to the Cuban Assets Control Regulations [amendment of 31 CFR Part 515] 


, 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: 26 June 2019: Harmonized System Update (HSU) 1912

  – 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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