19-0730 Tuesday “Daily Bugle'”

19-0730 Tuesday “Daily Bugle”

Tuesday, 30 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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[No items of interest today.]
  1. Items Scheduled for Publication in Future Federal Register Editions 
  2. Commerce/BIS: (No new postings.)
  3. State/DDTC: (No new postings.)
  4. Hong Kong TID Posts Lists of Officers Authorized to Sign Strategic Commodities Licenses
  1. Reuters: “U.S. Firms see Little Clarity on Huawei as U.S.-China Talks Resume”
  2. ST&R Trade Report: “Importer Drops Classification Lawsuit Because Win Would Have Yielded Tariff Increase”
  1. K. Brockmann: “Advances in 3D Printing Technology: Increasing Biological Weapon Proliferation Risks?”
  2. L. Ross & K. Zhou: “China’s Unreliable Entity List”
  1. Tony Dearth Joins Alpha Omega Consulting
  1. ECTI Presents United States Export Control (ITAR/EAR/OFAC) Seminar Training Focusing on Issues Relevant to Universities, Research Labs & Other Institutions of Higher Learning in Columbus, OH
  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 Jul 2019), HTSUS (22 Jul 2019) 
  3. Weekly Highlights of the Daily Bugle Top Stories 


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OGS_a11. Items Scheduled for Publication in Future Federal Register Editions
(Source: Federal Register, 30 July 2019.)


* President; Administrative Order; Lebanon; Continuation of National Emergency [Pub. Date: 31 July 2019.]

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Commerce/BIS (No new postings.)

(Source: Commerce/BIS)

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OGS_a44. Hong Kong TID Posts Lists of Officers Authorized to Sign Strategic Commodities Licenses

Hong Kong Trade and Industry Department, 30 July 2019.)
The Trade and Industry Department (TID) of Hong Kong has released the following document(s) on its website:

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Reuters: “U.S. Firms see Little Clarity on Huawei as U.S.-China Talks Resume”

Reuters, 30 July 2019.) [Excerpts.]
A month after President Donald Trump said he would allow U.S. companies to resume selling to blacklisted Chinese telecommunications giant Huawei, his administration has done little to clarify what sales will be permitted.
The lack of clarity on what U.S. firms can supply to the world’s top producer of telecommunications equipment as long as it’s on a so-called “entity list” is likely to cast a shadow over this week’s U.S.-China trade negotiations in Shanghai. …
But the department has yet to respond to any of a total of around 50 license requests from about 35 companies, sowing uncertainty in the industry and in Beijing.
“At this stage, there is mass confusion,” said William Reinsch, a former Commerce official, adding that the plan for case-by-case decisions “maximizes the uncertainty.” …

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ST&R Trade Report: “Importer Drops Classification Lawsuit Because Win Would Have Yielded Tariff Increase”

Sandler, Travis & Rosenberg Trade Report, 30 July 2019.)
The Court of International Trade has agreed to an importer’s request to dismiss a classification case because a ruling in the importer’s favor would have placed the goods at issue on a list of products subject to additional tariffs when imported from China.
The plaintiff filed this case in June 2015 after U.S. Customs and Border Protection classified various models of showerheads as other plastic hygienic or toilet articles under HTSUS 3924.90.5650 (3.4 percent duty). The plaintiff argued that the showerheads, which it imported from China, should be classified as mechanical appliances for spraying liquids under HTSUS 8424.89.0000 (1.8 percent duty) or as parts of such appliances under HTSUS 8424.90.9080 (duty-free).
However, goods from China classified under HTSUS 8424.89.90 became subject to a Section 301 additional 25 percent tariff as of Aug. 23, 2018, and goods from China classified under HTSUS 8424.90.90 became subject to a Section 301 additional 10 percent tariff as of Sept. 24, 2018 (which has since been increased to 25 percent).
These developments prompted the plaintiff to file a motion to voluntarily dismiss the case in April 2019. CBP opposed this motion, arguing that (a) the case is ready to resolve on the merits (although the plaintiff asserts that there are still some material facts that are disputed), (b) the plaintiff is not abandoning its classification claim and will likely file suit again once the Section 301 tariffs are eliminated, and (c) the federal government has spent more than three years litigating this case and filed a motion for summary judgment the day after the motion to dismiss was filed.
However, the CIT rejected these arguments and granted the request for dismissal. While the court recognized the effort and expense the government devoted to this case, it said at least some of that effort may be useful if the plaintiff does challenge the classification of these showerheads again in the future, which CBP thinks is likely given that the plaintiff has multiple protests involving other entries of these goods that have been administratively suspended.

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K. Brockmann: “Advances in 3D Printing Technology: Increasing Biological Weapon Proliferation Risks?”

SIPRI, 29 July 2019.) [Excerpts.]
* Author: Kolja Brockmann, MA, +46 76 628 63 49, Researcher in SIPRI’s Dual-Use and Arms Trade Control Programme.
The states parties to the Biological and Toxin Weapons Convention (
BWC) are gathering in Geneva from 29 July to 8 August 
for a series of Meetings of Experts. Among other topics, states are reviewing scientific and technological developments that impact the objectives of the treaty. Additive Manufacturing (AM), also referred to as 3D printing, is one of the technologies that is starting to receive attention, next to more well-known biotechnologies and genetic engineering techniques. Advances in AM have been met with concerns over its potential to facilitate the development, production, delivery and thus proliferation of biological weapons-and have highlighted the potential role of export controls in reducing these risks.
Concerns with this technology are therefore shared by the 
Australia Group (AG), a multilateral governance body that rarely interacts with the BWC. The AG’s relationship with the BWC 
has been controversial due to its exclusive membership and the alleged impact of export controls on the sharing of technology. Nevertheless, the AG has effectively set the standard for controls on the trade in relevant goods and key biotechnologies-with many non-members adopting the group’s control lists in their own export control systems. …
One technique that is 
currently receiving particular attention is
 bioprinting. In contrast to the inanimate materials used as feedstock by other AM techniques, bioprinting constructs objects made from biological materials such as living cells. Using bioinks involves the added complexity of their high sensitivity to environmental conditions, growth and differentiation factors, and the particularities of the construction of tissue. In bioprinting, the 
bioinks are deposited using, for example, small nozzles for extrusion or an inkjet to achieve precisely layered arrangements of cells and support structures. These materials then grow into functional tissue based on the cells’ biological processes.
What challenges does AM pose to non-proliferation and export controls?
AM promises to bring production to the end-user. It could 
decentralize production and thus reduce the need for the physical transportation of goods across borders. AM is also said to be ‘deskilling’ certain aspects of manufacturing, making it easier for producers with less knowledge and experience to produce more complex products. This characterization should however be used with caution and it is better to view AM as causing a shift in knowledge and skill requirements rather than their reduction. However, AM does threaten to provide a substitute for other, controlled production techniques and the associated equipment, thus potentially enabling the circumvention of the barriers imposed by export controls.
Perhaps more crucial than the new performance characteristics it enables is the increased digitization and automation of this production technology. As such, it further increases 
the importance of intangible transfers of technology

particularly the digital build files which encode both the characteristics of the object to be produced and the commands for the AM machine-which can easily be transferred for example via e-mail.
Compared to physical goods, digital transfers of 
technical data are harder to track and control. Moreover, the specialized audit capabilities to verify compliance with technology export controls are still very rare. States must therefore rely on intelligence and law enforcement information to detect illicit transfers and internal compliance mechanisms in companies are ever more important. …
Addressing AM in the Australia Group and the BWC
applications of AM relevant to the development, production and delivery of biological weapons are still relatively unknown. However, developments in bioprinting, as well as in the printing of drone components and laboratory equipment, continue at a rapid pace due to commercial and scientific interests-and an active DIY community. While relevant applications of AM currently still require considerable talent recruitment and process development efforts, particularly the digitized and automated nature of AM will likely mean that these barriers will be successively removed. Although 
the convergence of biotechnology and AM currently only produces moderate biological weapon proliferation risks, these are expected to increase. It is thus important to neither under- nor overestimate the immediate impact. 
Discussions in the AG on if and how to exert controls over the transfer of relevant goods and technologies area are therefore confronted by a difficult array of challenges. These include tracking advances in a rapidly evolving set of technologies and defining the associated risks. At the same time, export controls should not stifle developments for civilian applications of these technologies. Many of the challenges posed by AM extend beyond the biological and chemical weapons context and are relevant to 
missiles and the 
nuclear and conventional arms fields. Thus, they are of interest to all the export control regimes. Members of the regimes should therefore consider it as a topic for possible dialogue between the regimes, in particular regarding potential technical parameters for controls on AM machines and controlling intangible transfers of technical data that are used in AM.

At the same time, while export controls are currently a focus of regulatory discussions in the context of AM, meeting the challenges it creates in connection with biological weapons requires a more comprehensive approach. As such, discussions in both the BWC and the AG also need to pay attention to the role of research ethics and risk mitigation procedures in relevant research fields. This would include a stronger emphasis on raising awareness about possible weapons applications at relevant universities, research institutes and in DIY communities, as well as the development of stronger industry compliance and due diligence standards. States thus need to engage with all stakeholders and carefully monitor the nuanced risk picture currently faced to prevent AM from becoming an enabler of biological weapon proliferation.

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. L. Ross & K. Zhou: “China’s Unreliable Entity List”

WilmerHale, 29 July 2019.) [Excerpts.]
* Authors: Lester Ross, Esq.,
lester.ross@wilmerhale.com, +86 10 5901 6588, Kenneth Zhou, Esq.,
kenneth.zhou@wilmerhale.com, +1 202 459 8339, both of Wilmer Hale.
China’s Ministry of Commerce (MOFCOM) announced on May 31, 2019, that China will introduce an “Unreliable Entity List” regime under which foreign entities or individuals which boycott or cut off supplies to Chinese companies for noncommercial purposes, causing serious damage to Chinese companies, may be listed as “Unreliable Entities” subject to legal action.  
In a number of interviews in mid-June and early July, MOFCOM officials and spokespersons stated that the “Unreliable Entity List” regime is undergoing required internal review with detailed rules/measures soon to be promulgated.  
This new regime was announced after the US government added Huawei Technologies on its “Entity List.” The new regime is widely believed to be one of China’s countermeasures against foreign export control enforcement actions targeting Chinese companies, in particular US sanctions against Huawei. According to MOFCOM, four standards will be considered together when determining whether a foreign entity or individual should be listed as an “Unreliable Entity,” including (i) where there it is boycotting, cutting off supplies to Chinese companies or taken other specific discriminatory actions against Chinese companies; (ii) whether these actions are taken for noncommercial purposes, in violation of market rules or in breach of contractual obligations; (iii) whether these actions cause material damage to the legitimate interests of Chinese companies and relevant industrial sectors; and (iv) whether these actions constitute a threat or potential threat to China’s national security.  

The “Unreliable Entity List” regime will be established pursuant to the [Chinese] Foreign Trade Law, Anti-Monopoly Law and National Security Law. Such statutory authority includes:
Art. 7 of the Foreign Trade Law, which provides in general terms that if a foreign country or region adopts prohibitive, restrictive or similar measures on a discriminatory basis against China in trade, China may take corresponding counteractions against such country or region.  
The Anti-Monopoly Law focuses on penalizing monopoly conduct eliminating or reducing competition, including monopoly agreements, abuse of market dominance and monopoly through concentration of business undertakings. Art. 17 in particular prohibits abuse of market dominance by such means as refusal to trade or imposition of discriminatory conditions or prices.  
Art. 59 of the National Security Law provides that the State, in order to prevent and mitigate national security risks, shall establish a national security review and supervision system and conduct national security reviews on foreign investment, specific articles, key technologies, products and services relating to network information technologies, infrastructure construction products and other important transactions and activities that impact or may potentially impact national security. …
We note that both Art. 7 of the Foreign Trade Law and Art. 40 of the Foreign Investment Law are directed against foreign governments, not specific companies.  Therefore, a foreign company which complies with its own government’s rules to restrict trade or investment with China may be treated as an “unreliable entity.”
With respect to enforcement actions, even pending adoption of the detailed measures, foreign entities who are informally named as “Unreliable Entities” may face such market access sanctions as bans or restrictions on trade, investment, regulatory permits and licenses. Chinese business counterparts to foreign entities on the list will likely be ordered to cease business dealings with such foreign entities. …
While it is unclear at this point which Chinese government agency will take the lead in enforcing the new regime, we would expect that MOFCOM will play a leading role. MOFCOM established a new “Bureau of Industry, Security, Import and Export Control” (BISIEC) in 2015 that has been relatively quiescent until now. BISIEC’s roles and responsibilities are to some extent similar to those of the Bureau of Industry and Security (BIS) in the US Department of Commerce, which, among others, administers the BIS “Entity List.” … 
We understand that BISIEC has focused in part on export controls on “dual use” items (items that can be used for both civilian and military purposes) and also plays an important role in formulating China’s Export Control Law, which may restrict exports of Chinese origin products or technologies to specified foreign entities. Unlike the Export Control Law, the measures on the “Unreliable Entity List” are likely to take the form of administrative regulations rather than a statute.
The US and China have agreed to hold their 12th round of trade negotiations in Shanghai beginning July 30. Whether and how this new round of trade negotiations will affect the formulation of the “Unreliable Entity List” regime remains to be seen. However, China is likely to adopt the “Unreliable Entity List” regime regardless of the outcome of the negotiations.  

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MS_a19. Tony Dearth Joins Alpha Omega Consulting

(Source: Tony Dearth, 
Tony Dearth, formerly Chief of Staff, Directorate of Defense Trade Controls, U.S. Dep’t of State, and currently President, Dearth Consulting LLC, has joined Alpha Omega Consulting Group, LLC (
https://alphaocg.com/) as the Senior Policy Partner.  Contact Tony at 
Deartham@comcast.net or 1-703-587-7302.

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TE_a110. ECTI Presents United States Export Control (ITAR/EAR/OFAC) Seminar Training Focusing on Issues Relevant to Universities, Research Labs & Other Institutions of Higher Learning in Columbus, OH

(Source: Jill Kincaid; 
* What: University Export Controls (ITAR/EAR/OFAC) Seminar in Columbus, OH
* When: October 14-17, 2019
* Where: Columbus, OH: The Blackwell Inn on the campus of The Ohio State University
* Sponsors: Export Compliance Training Institute (ECTI), Descartes Visual Compliance, Amber Road/E2OPEN
* Speaker Panel: Scott Gearity, Marc Binder, with special presentations by Jim Bartlett (Full Circle Trade Law), Felice Laird (Export Strategies), Jessa Albertson, Dorata Grejner-Brzezinska, Stacy Rastauskas Bretherton, Emily Schriver, Elizabeth Wagner & Jennifer Yucel (Ohio State University), Mary Beran (Georgia Tech), Missy Peloso (Univ. of Penn.) and others

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TE_a211. 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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Emily Bronte (Emily Jane Brontë; 30 Jul 1818 – 19 Dec 1848; was an English novelist and poet who is best known for her only novel,
Wuthering Heights, now considered a classic of English literature. Emily was the third-eldest of the four surviving Brontë siblings, between the youngest Anne and her brother Branwell. She published under the pen name Ellis Bell.)

“A person who has not done one half his day’s work by ten o clock runs a chance of leaving the other half undone.”

Thorstein Veblen (30 Jul 1857 – 3 Aug 1929; was a Norwegian-American economist and sociologist.  In his best-known book,
The Theory of the Leisure Class (1899), Veblen coined the concept of conspicuous consumption and conspicuous leisure. Historians of economics regard Veblen as the founding father of the institutional economics school.)

“In point of substantial merit the law school belongs in the modern university no more than a school of fencing or dancing.”

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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: 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.] 


, 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 1913

  – 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.

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