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19-0725 Thursday “Daily Bugle”

19-0725 Thursday “Daily Bugle”

Thursday, 25 July 2019

TOP
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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[No items of interest today.] 

  1. Items Scheduled for Publication in Future Federal Register Editions 
  2. Commerce/BIS: (No new postings.)
  3. DoD/DSS Announces Free Webinar on ‘Doing Business with DCSA’ on 20 August 2019
  4. State/DDTC: (No new postings.)
  5. Treasury/OFAC Disrupts Corruption Network Stealing from Venezuela’s Food Distribution Program, CLAP
  6. UK Publishes Explanatory Memorandum Concerning the Export Control Order 2008 Amendment of 24 July 2019
  1. WorldECR: “OFAC Airs Thoughts on ‘Destabilising Activity’ of Iranian Airlines
  1. A. Illueca: “On Sanctions and Deregistration of Vessels: The Recent Practice of Panama”
  2. C. Todgham Cherniak: “Top 10 Canadian Export Controls and Economic Sanctions Developments in H1 2019”
  3. D. Tannebaum: “Sanctions Compliance: How to Raise Your Game to Meet OFAC’s High Expectations”
  1. ECTI Presents United States Export Control (ITAR/EAR/OFAC) Seminar in Amsterdam
  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 (23 July 2019), HTSUS (22 July 2019) 
  3. Weekly Highlights of the Daily Bugle Top Stories 

EXIMITEMS FROM TODAY’S FEDERAL REGISTER

[No items of interest noted today.]

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OGSOTHER GOVERNMENT SOURCES

OGS_a11. Items Scheduled for Publication in Future Federal Register Editions
(Source: Federal Register, 25 July 2019.)

 

* State; PROPOSED RULES; Consolidation of Exemptions in the International Traffic in Arms Regulations [Pub. Date: 26 Jul 2019.]
 
* State; NOTICES; List of Entities and Subentities Associated with Cuba (Cuba Restricted List) [Pub. Date: 26 Jul 2019.]

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OGS_a22
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Commerce/BIS (No new postings.)

(Source: Commerce/BIS)

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OGS_a33
.
DoD/DSS Announces Free Webinar on ‘Doing Business with DCSA’ on 20 August 2019
(Source: DoD/DSS, 25 july 2019.)
 
The DCSA Small Business Office will be hosting a webinar on August 20th from 1-3PM titled “Live with Liz: Getting you Prepared for DCSA 4th Quarter”. This FREE event is open to companies of all sizes. To register, click here.

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OGS_a44. 
State/DDTC: (No new postings.)
(Source: State/DDTC)

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OGS_a55.
Treasury/OFAC Disrupts Corruption Network Stealing from Venezuela’s Food Distribution Program, CLAP

(Source: Treasury/OFAC, 25 July 2019.) [Excerpts.]
 
Today, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned Colombian national Alex Nain Saab Moran (Saab), a profiteer orchestrating a vast corruption network that has enabled former President Nicolás Maduro (Maduro) and his regime to significantly profit from food imports and distribution in Venezuela. Saab has personally profited from overvalued contracts, including the Government’s food subsidy program titled the Local Committees for Supply and Production, or Los Comités Locales de Abastecimiento y Producción, commonly known as CLAP. Through a sophisticated network of shell companies, business partners, and family members, Saab laundered hundreds of millions of dollars in corruption proceeds around the world. Also targeted today are Maduro’s three stepsons, Walter, Yosser, and Yoswal, to whom Saab funneled money in exchange for access to contracts with the Government of Venezuela, including its food subsidy program.
 
“Alex Saab engaged with Maduro insiders to run a wide scale corruption network they callously used to exploit Venezuela’s starving population. Treasury is targeting those behind Maduro’s sophisticated corruption schemes, as well as the global network of shell companies that profit from the former regime’s military-controlled food distribution program,” said Treasury Secretary Steven Mnuchin. “The corruption network that operates the CLAP program has allowed Maduro and his family members to steal from the Venezuelan people. They use food as a form of social control, to reward political supporters and punish opponents, all the while pocketing hundreds of millions of dollars through a number of fraudulent schemes.” …

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OGS_a66.
UK Publishes Explanatory Memorandum Concerning the Export Control Order 2008 Amendment of 24 July 2019

(Source:
UK GOV, 25 July 2019.) [Excerpts.]
 
(1) Introduction
 
(1.1.) This explanatory memorandum has been prepared by the Department for International Trade and is laid before Parliament by Command of Her Majesty.
 
(2) Purpose of the instrument
 
(2.1) This instrument will introduce a new national export control that covers submersible vessels and related equipment, software and technology intended for export to Russia.
 
The Export Control (Amendment) (No. 2) Order 2019 (the “2019 Order”) adds to the Export Control Order 2008 at Schedule 3 (UK controlled dual-use goods, software and technology), a new entry PL9012 for “Submersible Vessels and related goods, software and technology”. This new control is being introduced to mitigate the national security risk presented by the uncontrolled export of this equipment to Russia given the Russian government’s underwater capabilities. The new control introduces the need for an export licence for certain equipment, meaning the government can assess on a case by case basis whether or not a proposed export will pose a threat to national security. … 

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NWSNEWS

NWS_a17

WorldECR: “OFAC Airs Thoughts on ‘Destabilizing Activity’ Of Iranian Airlines”
(Source: WorldECR, July 2019.) [Excerpts.]
 
The Office of Foreign Assets Control (‘OFAC’) of the US Department of the Treasury has published an advisory, which, it says, highlights the way that Iranian commercial airlines have been used by the regime in activities which destabilize the region – for example, ‘furthering the…agenda’ of the Iranian Revolutionary Guard Corp, and the Qods Force, and ‘flying fighters from their proxy militias across the region.’
 
Announcing the advisory, Sigal Mandelker, Under Secretary of the Treasury for Terrorism and Financial Intelligence said, ‘Lack of adequate compliance controls could expose those operating in the civil aviation industry to significant risks, including civil or criminal enforcement actions or economic sanctions.’ …

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COMMCOMMENTARY

COM_a18
.
A. Illueca: “On Sanctions and Deregistration of Vessels: The Recent Practice of Panama”
(Source:
Opinion Juris, 24 July 2019.) [Excerpts.]
 
* Author: Alonso Illueca, Esq., Bufete Illueca, alonso@illueca.com, + (507) 269 1333.
 
On July 12, 2019, Panama announced its decision to withdraw its flag from any vessel violating “sanctions and international legislation”. This decision resulted in the removal of 59 ships (mostly tankers) from Panama’s shipping fleet due to their link with the Islamic Republic of Iran (“Iran”) and the Syrian Arab Republic (“Syria”). While Panama has the right to withdraw its flag from any vessel, its practice as the State with the world’s largest shipping fleet remains relevant for other stakeholders in the maritime industry. In addition, Panama’s interpretation of the concept of “international sanctions”, its de-registration of vessels policy and its obligations under a bilateral treaty with the United States, may complicate the country’s international legal standing and its status as the leading flag of convenience within the shipping industry.
 
On July 12, 2019, Panama announced its decision to withdraw its flag from any vessel violating “sanctions and international legislation”. This decision resulted in the removal of 59 ships (mostly tankers) from Panama’s shipping fleet due to their link with the Islamic Republic of Iran (“Iran”) and the Syrian Arab Republic (“Syria”). While Panama has the right to withdraw its flag from any vessel, its practice as the State with the world’s largest shipping fleet remains relevant for other stakeholders in the maritime industry. In addition, Panama’s interpretation of the concept of “international sanctions”, its de-registration of vessels policy and its obligations under a bilateral treaty with the United States, may complicate the country’s international legal standing and its status as the leading flag of convenience within the shipping industry. …

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COM_a2
9

C. Todgham Cherniak: “Top 10 Canadian Export Controls and Economic Sanctions Developments in H1 2019”
(Source: Canada-U.S. Blog, 25 July 2019.) [Excerpts.]
 
* Author: Cyndee Todgham Cherniak, Esq., Lex Sage, cyndee@lexsage.com, +1 647 290 4249.
 
It has been a busy year in Canada for export controls and economic sanctions developments. As a result, we are posting an H1 2019 report. The top 10 developments in H1 2019 are:
 
1. Canada will implement the brokering rules on September 1, 2019. Bill C-47 “An Act to amend the Export and Import Permits Act and the Criminal Code (amendments permitting the accession to the Arms Trade Treaty and other amendments)” received royal assent on December 13, 2018. Section 20 of Bill C-47 (the officer’s liability provision) entered into force on December 13, 2019. Order in Council SI-2019-0041 sets September 1, 2019 as the date the other provisions enter into force.
 
2. Canada will become a State Party to the UN Arms Trade Treaty (ATT) on September 17, 2019. With Bill C-47 entering into force, Canada will be compliant with its obligations under the ATT. See Overview of the Arm’s Trade Trade Implementation Package.
 
3. Canada deposited its instrument of ratification of the ATT on June 19, 2019. See Canada presents it instruments of accession to the Arm’s Trade Treaty and Deposition of Canada’s instrument of accession to the Arm’s Trade Treaty.
 
4. On June 17, 2019, Canada published regulations to implement obligations in Bill C-47. Canada implemented the Brokering Control List, SOR/2019-220, which establishes the Brokering Control List and identifies goods controlled by Canada’s brokering rules. The Brokering Control List enters into force on September 1, 2019. …

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COM_a3
10

D. Tannebaum: “Sanctions Compliance: How to Raise Your Game to Meet OFAC’s High Expectations”
(Source: LinkedIn, 24 July 2019.)
 
* Author:  D. Tannebaum, Partner — Financial Crimes Unit, PWC

The fast-changing US sanctions landscape continues to create complex risk management hurdles. In May, the US Treasury’s Office of Foreign Assets Control (OFAC) issued its most prescriptive guidance on sanctions compliance. That clarity was much-needed for OFAC, historically an enforcement agency, has provided limited prescriptive guidance itself. OFAC has imposed penalties over $1-billion for sanctions violations just this year alone. But any relief companies felt proved to be short-lived.
 
In a seemingly technical update on June 21, OFAC significantly expanded the scope of sanctions reporting requirements. The new rules are sweeping. Previously, U.S. entities were required to file reports when a transaction was “blocked,” or put into frozen accounts due to a direct connection with persons on OFAC’s Specially Designated Nationals list. Now even “rejected” transactions have to be reported. The reporting requirement has broadened in two ways:
 
It applies to not just rejected fund transfers but any type of transaction, from wire transfers and checks to trade finance and goods and services.
It extends to all US persons or entities – not only US financial institutions
Why should you care?
 
The regulatory amendment is ambiguous. It does not provide details such as under which circumstances companies would be required to report rejected transactions. Taken at face value, companies would have to report them all, including, for example, transactions from foreign subsidiaries of US firms involving sanctioned countries or individuals.
 
Expect to see a significant increase in reporting-related violations: In many instances, these violations will be picked up through the banks’ reporting of rejected transactions, where OFAC could look for corresponding reporting from underlying companies and begin investigating.
 
OFAC is telling you what to do: The new rule would push companies to enhance their risk management frameworks to report all blocked and rejected transactions to OFAC. It comes very soon after OFAC issued its framework, outlining the essential components of robust sanctions compliance. According to OFAC, the root causes for common sanctions compliance deficiencies and violations include: the lack of a formal sanctions compliance program, misunderstanding OFAC requirements, technological issues related to sanctions screening software, failure to properly conduct customer due diligence and a decentralized sanctions compliance function
Sanctions have become a policy tool of choice. Companies should be diligent about reporting rejecting transactions as new sanctions programs continue to roll out. The Trump administration is relying heavily on sanctions to achieve its foreign policy objectives with broad embargoes affecting economic activity as well as narrowly-targeted ones on individuals. Sanctions interact with a complex array of US customs compliance and export controls regulations as well as evolving local watch-lists. Companies facing public enforcement actions could lose the ability to export to key markets, face heightened due diligence from financial institutions you work with and damaged reputations.
What should you do?
 
Make yourself heard: OFAC was accepting comments on this issue until July 22, and some companies used the opportunity to make a case for narrowing the rule’s scope. When new guidance comes out, seek clarity from OFAC. In parallel, increase staff and strengthen your risk management framework to comply.
 
Adopt a global sanctions policy standard: OFAC has an expansive view of its jurisdiction and it may be prudent to implement US standards globally as US sanctions come with the heftiest civil and criminal penalties. For example, though the EU last year implemented a “blocking statute” to prevent EU firms from complying with certain US sanctions on Iran, it is seen as ineffectual as EU firms have largely disengaged from Iran. Special purpose vehicles such as Europe-based clearing houses for transactions with Iran are mainly serving the political purpose of keeping Iran interested in the nuclear deal.
Monitor compliance from the center: Allocate more time and resources to trade compliance monitoring at the corporate risk and compliance level. After an issue is remediated, revamp the policies, procedures and controls around that area, and roll it out across the company’s global operations. Relying on country-level business units to manage trade transactions and related compliance requirements creates inefficiencies.
 
Explore automation of screening and alert processes: Consider how to improve screening procedures by automating data aggregation and generating high-quality alerts. Simultaneously, develop breach reporting procedures to speed up company responses to incidents to help minimize and protect the company brand.

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TEEX/IM TRAINING EVENTS & CONFERENCES

TE_a1 11. ECTI Presents United States Export Control (ITAR/EAR/OFAC) Seminar in Amsterdam 

(Source: Jill Kincaid;
jill@learnexportcompliance.com)
 
* What: United States Export Control (ITAR/EAR/OFAC) Seminar Series in Amsterdam, The Netherlands (for EU and other non-US Companies)
* When: ITAR Seminar: Sep 30-Oct 1, 2019; EAR/OFAC Seminar: Oct 2-3, 2019
* Where: Amsterdam, Hilton Amsterdam Hotel; Apollolaan 138, 1077 BG, Amsterdam, The Netherlands
* Sponsor: Export Compliance Training Institute (ECTI)
* ECTI Speaker Panel: Scott Gearity, Greg Creeser, Stephan Müller
* Register
here, or email
Jessica Lemon, 540-433-3977.

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TE_a212. 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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ENEDITOR’S NOTES

 

* Arthur Balfour
(Arthur James Balfour, 1st Earl of Balfour, 25 Jul 1848 – 19 Mar 1930; was a British statesman and Conservative Party politician who served as Prime Minister of the United Kingdom from 1902 to 1905.)
– “He has only half learned the art of reading who has not added to it the more refined art of skipping and skimming.”
 
* Eric Hoffer
(25 Jul 1898 – 21 May 1983; was an American moral and social philosopher. He worked as a longshoreman on the docks of San Francisco for 21 years before becoming an adjunct professor at the University of California, Berkeley. He was the author of ten books and was awarded the Presidential Medal of Freedom in February 1983. His first book, The True Believer, was widely recognized as a classic, receiving critical acclaim from both scholars and laymen, although Hoffer believed that The Ordeal of Change was his finest work.
– “Someone who thinks the world is always cheating him is right. He is missing that wonderful feeling of trust in someone or something.”

 

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EN_a314
. 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: 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.   

 

DOD NATIONAL INDUSTRIAL SECURITY PROGRAM OPERATING MANUAL (NISPOM): DoD 5220.22-M. Implemented by Dep’t of Defense.
  – 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: 23 July 2019: 84 FR 35307 – July 2019 Amendments to Global Terrorism Sanctions Regulations; Transnational Criminal Organizations Sanctions Regulations; and Hizballah Financial Sanctions Regulations [amendment of 31 CFR Parts 566, 590, and 594.] 

  

* 
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: 22 July 2019: Harmonized System Update (HSU) 1913  
  – HTS codes for AES are available here.
  – HTS codes that are not valid for AES are available here.

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EN_a0315
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  
here

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EPEDITORIAL POLICY

* 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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