19-0829 Thursday “Daily Bugle”

19-0829 Thursday “Daily Bugle”

Thursday, 29 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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[No items of interest today.]
  1. Items Scheduled for Publication in Future Federal Register Editions 
  2. Commerce/BIS: (No new postings.)
  3. State/DDTC Announces Open Meeting of DTAG
  1. Expeditors News: “China Announces Tariffs on Approximately $75 Billion Worth of Products Originating from the U.S.”
  2. ST&R Trade Report: “No Grace Period for Tariff Increase on Imports from China”
  1. A. Adamopoulos: “Sanctions proving ‘Extremely Challenging’ for Industry despite Transparency Tools”
  2. J. Leung, S. Fischer & A. Dafoe: “Export Controls in the Age of AI” (Part I of II)
  1. 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 (7 Aug 2019), HTSUS (13 Aug 2019) 
  3. Weekly Highlights of the Daily Bugle Top Stories 


[No Items of Interest.] 
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OGS_a11. Items Scheduled for Publication in Future Federal Register Editions
(Source: Federal Register, 29 August 2019.)


* Commerce/BIS: NOTICES; Agency Information Collection Activities; Proposals, Submissions, and Approvals [Pub. Date: 30 Aug 2019.]
* Commerce/BIS: NOTICES; Agency Information Collection Activities; Proposals, Submissions, and Approvals: Application for NATO International Bidding [Pub. Date: 30 Aug 2019.]
* DHS/CBP: NOTICES; Agency Information Collection Activities; Proposals, Submissions, and Approvals: Declaration of Owner and Declaration of Consignee When Entry is made by an Agent
* State/DDTC: RULES; Adjustment of Controls for Lower Performing Radar and Continued Temporary Modification of Category XI of the United States Munitions List [Pub. Date: 30 Aug 2019.]
* USTR: NOTICES; Proposed Modification of Action Pursuant to Section 301: China’s Acts, Policies, and Practices Related to Technology Transfer, Intellectual Property, and Innovation [Pub. Date: 3 Sep 2019.]

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Commerce/BIS (No new postings.)

(Source: Commerce/BIS)

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OGS_a33. State/DDTC Announces Open Meeting of DTAG

State/DDTC, 28 Aug 2019.)
The Defense Trade Advisory Group (DTAG) will meet in open session from 1:00 p.m. until 5:00 p.m. on Thursday, September 26, 2019 at 1777 F Street NW, Washington, DC 20006.

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Expeditors News: “China Announces Tariffs on Approximately $75 Billion Worth of Products Originating from the U.S.” 

Expeditors News, 28 Aug 2019.)
On August 23, 2019, China’s Ministry of Finance announced additional tariffs on goods of U.S. origin worth an approximate trade value of $75 Billion.
The additional tariffs will add additional tariffs in two rounds, going into effect on September 1, 2019, and December 15, 2019, respectively. The approximately 5,078 commodities on the two lists will be subject to additional tariffs of either 5 or 10 percent.
The original Chinese announcement may be found here:
Product List 1 will be entered into effect on September 1 may be found here:
Product List 2 will be entered into effect on December 15 may be found here:

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ST&R Trade Report: “No Grace Period for Tariff Increase on Imports from China” 

The Trump administration has indicated that another tariff increase on imports from China will be imposed with no flexibility for goods already in transit to the U.S.
The administration previously announced plans to impose a Section 301 additional tariff of 10 percent on $300 billion worth of Chinese goods in two stages, effective Sept. 1 (List 4A goods) and Dec. 15 (List 4B goods). China responded by pledging to levy additional tariffs of 5 or 10 percent on $75 billion worth of imports from the U.S. on the same dates.
The White House then said it would increase the additional tariff on List 4 goods from 10 percent to 15 percent. A notice from the Office of the U.S. Trade Representative now states that this higher tariff will be effective with respect to goods entered or withdrawn from warehouse for consumption on or after 12:01 a.m. EDT on the appropriate dates. As a result, this tariff will apply to subject goods even if they were already on their way to the U.S. prior to these effective dates.

USTR is also planning to increase the additional 25 percent tariff currently in place on $250 billion worth of Chinese goods (lists 1 through 3) to 30 percent effective Oct. 1 following a notice and comment period. However, USTR has yet to issue that notice.

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A. Adamopoulos: “Sanctions proving ‘Extremely Challenging’ for Industry despite Transparency Tools”

Lloyd’s List, 28 Aug 2019.)
* Author: Anastassios Adamopoulos,
anastassios.adamopoulos@informa.com, Anastassios is a news reporter at Lloyd’s List.
SANCTIONS monitoring can be “extremely challenging” for companies in the shipping industry but the technology available that makes operations more transparent and proactive measures can minimise potential damage, experts are warning. 
North P&I Club director Mark Church told Lloyd’s List that the increase in the number of sanctions and the marked escalation in enforcement primarily targeting the shipping sector over the past few years has increased the workload for P&I clubs, financial institutions and club members who must ensure they are not inadvertently breaching sanctions.
Arguably the most known and feared sanctions body is the US Treasury Department’s Office of Foreign Assets Control, responsible for enforcing sanctions, particularly as sanctions against Iran and Venezuela have ramped up.
“Today, there is more sanctions enforcement. And more sanctions. Starting with the Obama administration, the type of sanctions and complexity of sanctions by the US exponentially increased,” said a senior US-based lawyer knowledgeable in US sanctions on the shipping industry.
The lawyer admitted that one of the things that characterises OFAC regulations is that they are opaque as far as definitions are concerned.
But things are slightly more nuanced than simple definitions. The US Treasury Department is good at putting out information and facts it expects industry to take into account.
“Industry is definitely expected to be aware of all facts that government and [non-governmental organisations] have published about actors in the industry,” they said.
The lawyer stressed that despite the challenges, inadvertent sanctions violation would not get a company off the hook.
While sanctioned entities and individuals is fairly straightforward, things get more complicated when companies that are controlled or owned by sanctioned entities are not explicitly named by authorities.
But the greatest challenge, Mr Church argued, is monitoring activity to understand whether some kind of sanctioned cargo is being moved for example.
“The role of the P&I club traditionally has not been to police what our members are doing and we are not an enforcement agency, we are insurers,” he said.
P&I will advise members about how to best do ship-to-ship transfers, which are often used to move sanctioned cargo, and advises them to look at irregularities in Automated Identification System signals, which can indicate an attempt to conceal some kind of activity.
But despite the best due diligence efforts, companies may still fall foul of sanctions.
Lloyd’s List 
recently uncovered that European, UK and US P&I clubs were offering cover to vessels that were moving Iranian cargo, in violation of US sanctions. 
Mr Church explained that North has a compliance committee dedicated to ensuring the group is compliant with all sanctions and the kind of training employees should have and the measures the group should take.
He admitted that this is a costly endeavour but warned that a sanctions violation and the potential inability to trade in dollars and lose access to financing as a result would be disastrous.
“That is why everyone is aware that it is resource heavy, but it is important that there are resources there, as it is one of the few risks that is existential in the sense that if we get it wrong the impact would be catastrophic,” he said.
PB Tankers, an Italian shipping company that controlled seven vessels, 
went bankrupt earlier this year when OFAC sanctioned six of its vessels for violating US sanctions against Venezuela and Cuba.
OFAC later removed the vessels after claiming the company took steps to prevent future sanctions violations.
Technology and policy as a solution?
The US-based lawyer admitted that under today’s circumstances in the shipping industry, where the true ownership or interests behind a company are often far from clear, companies can never be fully certain that they are not dealing with sanctioned cargo or even businesses.
“What protects companies in the shipping industry from the fact that you may never get down to the actual source point of ownership, is their compliance regime,” they said.
This includes the measures in place to ensure compliance, how those are carried out and developed within the company’s policy.
“In the United States, if you get it wrong, no matter how much you tried, there is a very strong chance you will have to pay some money. But it would be far less than if you did not try,” they said.
They further argued that the availability of tools to access and analyse data has upped expectations that companies will be able to meet their legal obligations with regard to sanctions.
Mr Church does not believe this increased scrutiny will usher in a change in the opaque levels of ownership and structures of different firms.
What is changing however, is that vessels can be tracked a lot more easily using satellite technology, making illicit behaviour a lot more easy to detect, from the government, press and other stakeholders.
Five years ago, he argued, some owners perhaps may have thought they could get away with it.
“The real change is that if shipowners are not sure about the legality of what they are doing, somebody will be sure because someone is looking,” he said.

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7. J. Leung, S. Fischer & A. Dafoe: “Export Controls in the Age of AI” (Part I of II)

(Source: War on the Rocks, 28 Aug 2019.)
* Authors: Jade Leung, Head of Research and Partnerships at Centre for the Governance of AI at the University of Oxford, Sophie-Charlotte Fischer, PhD Candidate at ETH Zurich and Research Affiliate with the Centre for the Governance of AI, Allan Dafoe, Associate Professor at the University of Oxford and Director of the Centre for the Governance of AI.
What does technological leadership look like in an era of artificial intelligence? The United States, like other countries, is in the midst of grappling with this question against a backdrop of the rise of China and the growing realization that “business as usual” will no longer suffice for America to maintain its technological advantage. Washington has begun to take some important steps to translate this realization into action. In February, President Donald Trump launched the 
American AI Initiative in recognition that “American leadership in AI is of paramount importance to maintaining the economic and national security of the United States.” In a less constructive fashion, two months later Sen. Josh Hawley (R-Mo.) introduced the 
China Technology Transfer Control Act of 2019 that would “make it harder for American companies to export major emerging technologies to China.” Clearly, AI is on the agenda.
Unfortunately, Washington appears to be defaulting to traditional, 20th-century policy tools to address a 21st-century problem. Last November, the Department of Commerce published its 
advanced notice of proposed rulemaking to signal to the public that it is considering a regulatory change to the export of several emerging technologies, including AI. The notice establishes how the public can participate in the rulemaking process via the submission of comments. By the January deadline, 
245 public comments had been submitted to the Bureau of Industry and Security.
Export controls are a web of regulations that prohibit the transfer of certain commodities or information, motivated by national security concerns or trade objectives, or both. During the Cold War, the United States and its allies developed an 
American-led system of export controls to sustain the West’s advantage by denying or delaying the Soviet Union’s acquisition of militarily relevant goods and technologies. Today, 
who favor the proposed export controls hope that these measures can curb what they regard as China’s aggressive efforts to appropriate Western intellectual property, particularly in high-technology domains. Critics, on the other hand, warn that export controls risk 
intensifying the technology race between the United States and China and 
crippling the U.S. commercial AI industry.
Moreover, these opponents argue that new export controls on emerging technologies – designed to address national security issues – could 
broader trade tensions between the United States and China.
The pursuit of AI is becoming a key feature of
 great power rivalry, but this is crucially unlike previous periods of competition. For the United States, securing technological advantage on the world stage will require moving beyond traditional tools such as export controls. This is a time for new, globally-oriented policies. These should be focused on creating an innovative and open environment for research and development, as well as balancing the interests of multinational tech corporations, allied countries, and scientists. Critically, the United States must also bear in mind the stakes – the opportunity to realize the immense bounty of AI as a transformative general-purpose technology, and the risk of these gains being squandered by geopolitical competition. Washington should therefore be wary of stoking potential hostility – for instance, through the use of exclusionary policies such as export controls – and instead focus on aligning U.S. national strategy on AI with a vision to serve the common, global good.
Great Power Contestation in the Era of AI
America’s pursuit of technological advantage used to be more straightforward. Consider the 
strategy implicit at the beginning of the Cold War. In its mission to contain the Soviet Union, the U.S. government would actively support strategically relevant industries at home, creating loyal firms that were dependent on the state for investment and support. Simultaneously, the United States and its allies would devise mechanisms to prevent or delay the loss of technology to the adversary, using tools such as export controls to limit the movement of specific goods and technical information across its borders. These included, for example, 
radar equipment and aero-engines. This was achievable and effective at least for some time because American firms were the leading producers of these technologies, and the United States could reliably access them for military purposes.
Today, however, a state-led national technology strategy is inadequate. Cutting-edge developments in high-technology domains such as AI are spearheaded by 
powerful multinational technology companies with distinctly global interests and perspectives, rather than by the government. These companies are not dependent on government funding, but instead 
reinvest a substantial share of their internationally accrued revenues in research and development. They are focused on their 21st-century missions and on international markets, and are composed of 
influential employees who often share these internationalist values.
Meanwhile, the U.S. government has come to depend on these multinational companies to 
project the nation’s influence on the international stage and 
strengthen America’s industrial base. Thus, the successful pursuit of power now requires cooperating with private global tech companies. Further, for export control policies to work, they will need to be supported by both the U.S. public and America’s allies in order to gain the necessary political legitimacy and economic leverage. Notably, both the American people and the country’s allies are presently 
 convinced than those inside the Beltway of the threat from China.
Export controls made sense during the Cold War with the Soviet Union. However, the Cold War is over and the Soviet Union no longer exists. Today, the effectiveness of export control policies has been challenged by a shift towards global technology markets, as well as private sector leadership in the development of strategically important technologies. Export control policies risk interfering with the economic aims of global tech companies, obstructing the scientific aspirations of researchers, and offending allies by making the United States seem overly nationalistic and aggressive. To succeed, then, export controls will need to be well-motivated and carefully designed – a substantial challenge in today’s context.
Will Export Controls Aid U.S. Technological Leadership?
Export control policy must weigh the envisioned national security benefits against any unintended economic, scientific, and political costs. The primary aim is to deny rival countries or malicious actors access to strategically important technologies. Nations are consequently obliged to develop these technologies domestically, rather than shortcutting the technological development process by acquiring U.S. technologies.
Whether the national security benefit of restricting the diffusion of strategic technologies can be achieved depends on several features of both the technology and the international context in which it operates. First, export controls are most effective when the actor implementing them – a single country like the United States, or the members of an export control agreement like the 
Wassenaar Arrangement– has sufficient market leverage over the targeted product such that barring its export has a meaningful impact on the product’s availability on the international market. In the case of AI, however, there are few components over which the United States has a clear monopoly, or where allies who can produce the target components are willing to harmonize their export control systems with that of the United States. This limits the effectiveness of export controls in achieving a comprehensive restriction on the availability of AI technologies on the international market. A notable exception is in the 
equipment and expertise required for the design and production of microprocessors for AI systems, in which a small number of democratic countries, including the United States, still have an edge and thus could plausibly implement export controls effectively.
Part II of II will be published in the Daily Bugle of 30 August 2019.

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TE_a28. 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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John Locke (29 Aug 1632 – 28 Oct 1704; was an English philosopher and physician, widely regarded as one of the most influential of Enlightenment thinkers and commonly known as the “Father of Liberalism”. Considered one of the first of the British empiricists, following the tradition of Sir Francis Bacon, he is equally important to social contract theory. His work greatly affected the development of epistemology and political philosophy. His contributions to classical republicanism and liberal theory are reflected in the United States Declaration of Independence.)

“Government has no other end, but the preservation of property.”

Oliver Wendell Holmes, Sr. (29 Aug 1809 – 7 Oct 1894; was an American physician, poet, and polymath based in Boston. A member of the Fireside Poets, he was acclaimed by his peers as one of the best writers of the day. In addition to his work as an author and poet, Holmes also served as a physician, professor, lecturer and inventor and, although he never practiced it, he received formal training in law.  His son was Oliver Wendell Holmes, Jr., who served as an Associate Justice of the Supreme Court of the United States.)

“Don’t flatter yourselves that friendship authorizes you to say disagreeable things to your intimates. On the contrary, the nearer you come into relation with a person, the more necessary do tact and courtesy become.”

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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 August 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: 7 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 Aug 2019: Harmonized System Update (HSU) 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.

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