19-0827 Tuesday “Daily Bugle'”

19-0827 Tuesday “Daily Bugle”

Tuesday, 27 August 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. State/DDTC Corrects Cuba Restricted List 
  1. Items Scheduled for Publication in Future Federal Register Editions 
  2. Commerce/BIS: (No new postings.)
  3. State/DDTC: (No new postings.)
  4. UK ECJU Updates Exporting Country Guides
  1. Deutsche Welle: “European Rights Court Rules against Russia on Magnitsky Death”
  2. ST&R Trade Report: “Trump Hikes Tariffs on Chinese Goods Again, Threatens to Force U.S. Companies Out of China”
  1. C. Stagg: “D.C. Circuit Clarifies ITAR Criminal Intent Requirement”
  2. T.G. Ficaretta: “Selling Shotguns and Rifles to Nonresidents: Licensed Dealers Must Comply with State Law”
  1. Rob Monjay Moves from DDTC to Akin Gump
  2. Ted Murphy Moves to Sidley Austin
  1. ECS Presents “ITAR/EAR Boot Camp: Achieving Compliance” on 8-9 Oct in Savannah, GA
  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 (21 Aug 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 2019), DOT/FACR/OFAC (6 Aug 2019), HTSUS (13 Aug 2019) 
  3. Weekly Highlights of the Daily Bugle Top Stories 


EXIM_a11State/DDTC Corrects Cuba Restricted List

(Source: Federal Register, 27 Aug 2019.)
84 FR 44963: Updating the State Department’s List of Entities and Subentities Associated With Cuba (Cuba Restricted List)
In notice document 2019-15929 appearing on pages 36154-36156 in the issue of Friday, July 26, 2019, make the following corrections:
   1. On page 36156 in the first column, lines one and two, “Casa Editorial Verde Olivo Effective July 26, 2019” should not have been indented when published.
   2. On page 36156 in the first column, lines 26 and 27 “Editorial Capit[aacute]n San Luis Effective July 26, 2019” should have printed on its own a separate line.
   3. On page 36156 in the first column, line 37, “Ferreter[iacute]a TRASVAL” should have printed on its own a separate line.
   4. On page 36156 in the first column, lines 39 and 40, “Impresos de Seguridad” should have printed on its own a separate line.

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OGS_a12. Items Scheduled for Publication in Future Federal Register Editions
(Source: Federal Register, 27 August 2019.)

[No Items of Interest Noted.] 

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OGS_a45UK ECJU Updates Exporting Country Guides

UK ECJU, 27 Aug 2019.)
The UK Export Control Joint Unit (ECJU) within the Department of International Trade (TID) has published the following update on its website:

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Deutsche Welle: “European Rights Court Rules against Russia on Magnitsky Death”

Deutsche Welle, 27 Aug 2019.) [Excerpts.]
The European Court of Human Rights ruled Tuesday that Russia violated the rights of Sergei Magnitsky, an auditor who was charged with tax evasion while investigating state corruption. 
Magnitsky died in pre-trail detention in Moscow in 2009 after complaining of mistreatment and health problems. His death gained international attention and highlighted Russian human rights abuses, leading the United States and other countries to pass 
Magnitsky Acts” targeting Russians accused of rights abuses.

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ST&R Trade Report: “Trump Hikes Tariffs on Chinese Goods Again, Threatens to Force U.S. Companies Out of China”

President Trump announced Aug. 23 that he will further increase existing and pending tariffs on imports from China in response to Beijing’s move to raise its own tariffs on more than 5,000 additional goods from the U.S. The president also threatened to force U.S. companies to relocate operations out of China if bilateral trade relations worsen.
According to a statement from the Office of the U.S. Trade Representative, the additional 25 percent tariff currently in place on $250 billion worth of Chinese goods (lists 1 through 3) will be increased to 30 percent “effective October 1 following a notice and comment period.” USTR added that the additional tariff on another approximately $300 billion worth of imports from China, which is scheduled to be imposed in two stages on Sept. 1 (list 4A) and Dec. 15 (list 4B), “will now be 15 percent” instead of 10 percent. A 
Federal Register notice providing additional details is expected in the near future.
Also on Aug. 23 Trump declared in a Twitter post that “American companies are hereby ordered to immediately start looking for an alternative to China, including bringing … your companies HOME and making your products in the USA.” In a subsequent post he asserted that the International Emergency Economic Powers Act of 1977 gives him the authority to order U.S. companies to leave China.
However, Trump told reporters at a weekend summit of G-7 leaders in France that he has “no plan right now” to invoke this authority. Instead, a Bloomberg article quoted Treasury Secretary Steve Mnuchin as saying, the president is “ordering companies to start looking, because he wants to make sure to the extent we are in an extended trade war that companies don’t have these issues and move out of China.”

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 C. Stagg: “D.C. Circuit Clarifies ITAR Criminal Intent Requirement”

Stagg P.C., Aug 23 2019, Reprinted by permission.)
* Author: Christopher B. Stagg, Esq., 
chris@staggpc.com, +1 212 518 4854, of Stagg P.C.
On August 20, the U.S. Court of Appeals for the D.C. Circuit clarified the criminal intent requirement under the International Traffic in Arms Regulations’ (“ITAR”) willfulness standard. In 
United States v. Burden, No. 17-3018, 2019 U.S. App. LEXIS 24713 (D.C. Cir. Aug. 20, 2019), the appellate court expressed concern with a jury instruction that suggested any criminal intent, even if it were not relevant to the export control violation, would suffice for conviction. In other words, if a person intended to violate the import laws of another country, or some other law, then that intent could be transferred to find criminal intent under the ITAR.
The D.C. Circuit squarely rejected that premise: “The conduct that [the defendant] must know was unlawful is the 
actus reus of the crime with which he is charged.” 
Id. at *38-39. Thus, criminal intent under the ITAR requires “proof that defendants knew it was illegal to export the items they shipped without a license.” 
Id. at *34. Consequently, the D.C. Circuit vacated the original judgement and ordered a retrial. It also noted that the jury “instruction should make clear than an [ITAR] conviction requires that defendants knew of the unlawfulness of the charged unlicensed export of the items from the United States, and that a willfulness finding cannot draw on evidence that they knew the related, but legally and factually distinct, import of those into [another country] was illegal.” 
Id. at *39. 
The D.C. Circuit’s decision is similar to the explanation provided by Judge Easterbrook on behalf of the Seventh Circuit in 2009:
As the prosecutor sees things, an intent to violate one law is as good as the intent to violate any other. The United States’ appellate brief essentially invokes the doctrine of transferred intent (though it does not use that name or cite authority) . . . So far as we can tell, however, transferring intent from one genus of offense to another has never been permitted. Suppose [the defendant] had believed (wrongly) that the United States imposes an excise tax on exports of optical gear and had tried to avoid payment; an intent to evade a nonexistent tax would not transfer to an intent to export riflescopes without a license; the crimes are too different for one intent to suffice for the other. The crime that [the defendant] set out to commit was unrelated to unlicensed exports.
United States v. Pulungan, 569 F.3d 326, 330-31 (7th Cir. 2009).
Additionally, the D.C. Circuit weighed in as to whether the ITAR is a set of highly technical regulations warranting a heightened scienter requirement: that a criminal defendant knew of the specific regulation he or she is alleged to have willfully violated. The court followed a growing number of circuits that distinguish the ITAR from highly technical regulatory schemes, such as tax laws and currency structuring. Accordingly, ITAR criminal intent does not “require specific awareness of the Munitions List as such,” though once again it does require “proof that defendants knew it was illegal to export the items they shipped without a license.” 
Burden, at *34. 
It is important to remember that the impact of this recent decision may be limited because it directly affects only criminal cases that appear in the U.S. District Court for the District of Columbia. Other circuits and district courts are not required to follow the D.C. Circuit’s instructions, although they may be persuaded by it. Moreover, there is also a circuit split concerning how to approach criminal intent under the ITAR. 
United States v. Roth, 642 F. Supp. 2d 796, 799-803 (E.D. Tenn. 2009) (acknowledging and discussing circuit split). Nevertheless, the
Burden decision may provide criminal defendants with better legal authority to use when advocating what the jury instructions will state.

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COM_a29. T.G. Ficaretta: “Selling Shotguns and Rifles to Nonresidents: Licensed Dealers Must Comply with State Law”

FLS Bulletins
, 26 Aug 2019.)

* Author:  Teresa G. Ficaretta, Esq., teresa@ficarettalegal.com, +1 301 353 3558, of Ficaretta Legal Services LLC.

The Gun Control Act (“GCA”) specifically authorizes federal firearms licensees (“FFLs”) to sell rifles and shotguns to unlicensed purchasers who reside in a state other than the state where the dealer is located.  However, the statute specifically requires that the transactions comply with state law where the transaction takes place and the laws of the state where the buyer resides.  Sellers are generally knowledgeable about laws of the state where they are located, but may not be fluent in the laws of the buyer’s state.  This article addresses the hazards of selling long guns in violation of state law and highlights some of the types of state and local laws that apply to these sales.


From 1968-1986 the GCA allowed FFLs to sell rifles and shotguns to unlicensed purchasers who resided in states other than the state where the dealer was located only if (1) the transaction was a face-to-face, over-the-counter transaction; (2) the sale, delivery, and receipt fully complied with the legal conditions of sale in the seller’s state and the buyer’s state; and (3) the purchaser resided in a “contiguous state.”  The GCA was amended by the Firearms Owners Protection Act of 1986 to allow licensees to sell rifles and shotguns to residents of any state as long as the first two conditions above are satisfied.  The statute in question, 18 U.S.C. § 922(b)(3), further provides that FFLs shall be presumed, in the absence of evidence to the contrary, to have had actual knowledge of the state laws and published ordinances of both states.  

The term “published ordinance” is defined in the GCA as any published law of any political subdivision of a state which the Attorney General determines to be relevant to the enforcement of the GCA and which is contained on a list compiled by the Attorney General, published in the Federal Register, revised annually, and furnished to each FFL.  ATF revises and updates its publication State Laws and Published Ordinance-Firearms every 2-3 years and recently published its 33rd edition on the ATF website (https://www.atf.gov/firearms/state-laws-and-published-ordinances-firearms-33rd-edition) (last visited July 10, 2019).  This version is current through March, 2019.  The publication is broken down by state and includes provisions of each state code and local ordinances relevant to the sale, transfer, receipt, possession, and carrying of firearms.  

Importance of Compliance with State Law.  One of the principal purposes of the GCA was to assist the states in enforcing their laws.  The GCA accomplishes this purpose by channeling interstate and foreign commerce through FFLs and requiring FFLs to comply with state law in conducting firearms transactions.  Section 922(b)(3) furthers this purpose by allowing nonlicensees to purchase rifles and shotguns from FFLs in any state, but requires that the seller abide by state law relating to the sale, delivery, and receipt as if the transaction were occurring in the buyer’s state of residence.  

FFLs who sell rifles and shotguns to nonresidents in violation of section 922(b)(3) are running two risks, as follows:
  (1) If ATF determines that a particular transaction violated section 922(b)(3) and was a “willful” violation, ATF may revoke the seller’s license.  To be “willful” ATF must have evidence the seller had knowledge of the state law in question and acted with intent to violate that requirement with indifference or reckless disregard thereof.  If the state law requirement was included in ATF’s publication State Laws and Published Ordinances, the FFL will be presumed to have actual knowledge of the requirement.  Violations of section 922(b)(3) are one of the most frequently cited by ATF during annual compliance inspections.  
  (2) FFLs who knowingly violate a state or federal statute applicable to the sale or marketing of firearms may lose their immunity from civil liability under the Protection of Lawful Commerce in Arms Act, 15 U.S.C. §§ 7901-7903.  Sale of a rifle or shotgun in violation of 18 U.S.C. § 922(b)(3) would, if committed knowingly, appear to be a violation of federal law relating to sale of a firearm.  Such a violation could be used by plaintiffs in a civil liability action whether or not ATF cites it against an FFL during a compliance inspection.  

Legal Conditions of Sale.  As stated above, section 922(b)(3) requires FFLs selling rifles and shotguns to nonresidents to ensure that sale, delivery, and receipt fully comply with the legal conditions of sale in the seller’s state and the buyer’s state.  This means that the seller must make a reasonable effort to determine the relevant “legal conditions of sale” in the buyer’s state.  The starting point for this inquiry should be ATF’s compilation of state laws and local ordinances on the agency website.  These are the legal provisions the GCA presumes the FFL to know and those that ATF investigators will consult in determining the legality of a nonresident sale.  Reviewing these provisions can be a daunting task, as some of the state law summaries are over 50 pages long.  Questions about particular provisions of state law may be raised with state authorities (generally the state police) or the FFL’s local ATF office.  Licensees may also wish to consult with qualified counsel.  

Some of the more common “conditions of sale” include the following:
  (1) Age restrictions.  A number of states (e.g. Florida) recently raised the age for purchasing any firearm (including a rifle or shotgun) to 21.  
  (2) Waiting periods.  A number of states (e.g. Rhode Island) impose a waiting period before a firearm may be delivered to a purchaser.
  (3) Registration requirements.  States and local jurisdictions may impose registration requirements on firearms, including rifles and shotguns.  An example is the District of Columbia, which requires that all firearms be registered with the D.C. Metropolitan Police.  
  (4) Firearms owners identification cards.  States (e.g. Illinois) may impose a requirement that residents present a firearms identification card or other authorization before purchasing a firearm from an FFL.
  (The above list is for purposes of example only and should not be read as a complete list of state laws that are “legal conditions of sale” within the meaning of 18 U.S.C. § 922(b)(3)).

Conclusion.  FFLs who sell rifles and shotguns to nonresidents must make every effort to ensure the transaction complies with the state and local law where the premises are located and the laws where the buyer resides.  ATF’s State Laws and Published Ordinances should be consulted to determine the legal conditions of sale, and the FFL must sell the firearm in accordance with those conditions.  Licensees who fail to comply with all relevant state laws risk ATF citations and, in the event the firearm is misused, potential civil liability. 

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MS_a110. Rob Monjay Moves from DDTC to Akin Gump

(Source: Editor)
Robert J. Monjay, Esq., has left his position as Acting Division Chief for the Technology and Jurisdictional Analysis Division, Directorate of Defense Trade Controls, U.S. State Dep’t, to become Senior Counsel at Akin Gump Strauss Hauer & Feld LLP’s, Washington, DC, office. Contact Rob at +1 202 887 4557 or

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MS_a211. Ted Murphy Moves to Sidley Austin

(Source: Steve Lamar, 
Ted Murphy, Esq., formerly with the Baker McKenzie law firm, has joined Sidley Austin LLP, Washington, DC, as a partner in Sidley’s Global Arbitration, Trade, and Advocacy Practice. Contact Ted at +1-202-736-8016 or

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TE_a112. ECS Presents “ITAR/EAR Boot Camp: Achieving Compliance” on 8-9 Oct in Savannah, GA

(Source: ECS)
* What:  ECS ITAR/EAR Boot Camp:  Achieving Compliance
* When:  October 8-9, 2019
* Sponsor:  Export Compliance Solutions & Consulting (ECS)
* ECS Instructors:  Suzanne Palmer, Mal Zerden
* Register

 or by calling 866-238-4018 or email 

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TE_a213. 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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Lyndon B. Johnson (27 Aug 1908 – 22 Jan 1973; often referred to as LBJ, was an American politician who served as the 36th president of the United States from 1963 to 1969. Formerly the 37th vice president from 1961 to 1963, he assumed the presidency following the assassination of President John F. Kennedy.)

“What convinces is conviction. Believe in the argument you’re advancing. If you don’t you’re as good as dead. The other person will sense that something isn’t there, and no chain of reasoning, no matter how logical or elegant or brilliant, will win your case for you.”
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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: 21 August 2019: 84 FR 43493-43501: Addition of Certain Entities to the Entity List and Revision of Entries on the Entity List and 84 FR 43487-43493: Temporary General License: Extension of Validity, Clarifications to Authorized Transactions, and Changes to Certification Statement Requirements

* 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: 26 Aug 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: 6 August 2019: 84 FR 38545 – August 2019 Amendments to Iranian Financial Sanctions Regulations and Iranian Human Rights Abuses Sanctions Regulations [amendment of 31 CFR Parts 561 and 562.]  


, 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: 13 August 2019: Harmonized System Update 1914

  – 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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