19-1002 Wednesday “Daily Bugle”

19-1002 Wednesday “Daily Bugle”

Wednesday, 2 October 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 

inquiries and rates

  1. CBP Decreases Quarterly IRS Interest Rates Used in Calculating Interest on Overdue Accounts and Refunds on Customs Duties] 
  1. Items Scheduled for Publication in Future Federal Register Editions 
  2. Commerce/BIS: (No new postings.) 
  3. State/DDTC: (No new postings.)
  4. Treasury/OFAC Announces Settlement Agreement with the General Electric Company
  5. International Trade Administration: “Privacy Shield and GDPR”
  1. WSJ: “U.S. Manufacturer H.B. Fuller Discloses Potential Sanctions Violation”
  2. EU Sanctions Blog: “Italian Judgements on the EU Blocking Regulation”
  3. Bulawayo24 News: “America Bans Buying of Zimbabwe Diamonds”
  1. T. Murphy: “Miscellaneous Tariff Bill — Opportunity for Tariff Relief” 
  2. G.R. Tuttle: “Sep 27, 2019 – Additional Products Excluded from Section 301 Duties (Tranche 1 & 2)” 
  1. ECTI Presents “Trade Compliance on a Budget – Issues and Considerations” Webinar: October 17, 2019 
  2. FCC Presents “U.S. Export Controls: ITAR from a non-U.S. Perspective,” 26 Nov 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 (30 Aug 2019), DOT/FACR/OFAC (9 Sep 2019), HTSUS (3 Sep 2019) 
  3. Weekly Highlights of the Daily Bugle Top Stories 


EXIM_a11. CBP Decreases Quarterly IRS Interest Rates Used in Calculating Interest on Overdue Accounts and Refunds on Customs Duties 

(Source: Federal Register, 2 Oct 2019.)

Agency: CBP/DHS

Action: General Notice

Summary: This notice advises the public that the quarterly Internal Revenue Service interest rates used to calculate interest on overdue accounts (underpayments) and refunds (overpayments) of customs duties will decrease from the previous quarter. For the calendar quarter beginning July 1, 2019, the interest rates for overpayments will be 4 percent for corporations and 5 percent for non-corporations, and the interest rate for underpayments will be 5 percent for both corporations and non-corporations. This notice is published for the convenience of the importing public and U.S. Customs and Border Protection personnel.

Dates: The rates announced in this notice are applicable as of July 1, 2019.

For Further Information, Contact: Bruce Ingalls, Revenue Division, Collection Refunds & Analysis Branch, 6650 Telecom Drive, Suite #100, Indianapolis, Indiana 46278; telephone (317) 298-1107.
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OGS_a12. Items Scheduled for Publication in Future Federal Register Editions

(Source: Federal Register, 2 Oct 2019.)
[No items of interest noted today.]
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OGS_a23. Commerce/BIS: (No new postings.)
(Source: Commerce, 2 Oct 2019.)

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(Source: State/DDTC, 2 Oct 2019.)

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(Source: Treasury/OFAC, 2 Oct 2019.)

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) today announced a $2,718,581 settlement with The General Electric Company (“GE”) of Boston, Massachusetts.  GE, on behalf of three GE subsidiaries – Getsco Technical Services Inc., Bentley Nevada, and GE Betz (collectively, the “GE Companies”) – has agreed to settle its potential civil liability for 289 alleged violations of the Cuban Assets Control Regulations, 31 C.F.R. part 515 (CACR).  

Specifically, between December 2010 and February 2014, the GE Companies appear to have violated § 515.201(b) of the CACR on 289 occasions by accepting payment from The Cobalt Refinery Company (“Cobalt”), an entity identified on the List of Specially Designated Nationals and Blocked Persons since June 1995, for goods and services provided to a Canadian customer of GE. 

OFAC determined that GE voluntarily disclosed the apparent violations, and that the apparent violations constitute a non-egregious case.

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(Source: Commerce/ITA: Tradeology, 1 Oct 2019.)
In April 2016, the European Union (EU) replaced its 1995 Data Protection Directive with the General Data Protection Regulation (GDPR). As companies in the EU and beyond review their data protection policies to ensure compliance with this law, many are asking how GDPR impacts the 3-year-old EU-U.S. Privacy Shield Framework.
Background on GDPR  
Effective May 2018, GDPR governs the commercial use of the personal data, requiring companies to follow certain data protection practices. The regulation applies to all EU-based companies, as well as companies outside the EU that receive EU personal data in offering goods and services or in monitoring EU individuals’ behavior. GDPR also governs the transfer of EU personal data to companies outside the EU.
GDPR has garnered a great deal of attention globally and has incentivized many companies to review and update their privacy and cross border data flow policies. The International Trade Administration at the U.S. Department of Commerce engages regularly with the U.S. business community to promote wider awareness of the GDPR’s new requirements. ITA’s Office of Digital Services Industries (ODSI) has also partnered with the U.S. Commercial Service team at the U.S. Mission to the European Union in outreach efforts.
For additional information about GDPR, click 
Relationship with Privacy Shield  
Privacy Shield is not a GDPR compliance mechanism, but rather a means that enables participating companies to meet the EU requirements for transferring personal data to third countries, as discussed in Chapter V of the
GDPR’s Article 45 explicitly provides for the continuity of prior European Commission (EC) adequacy determinations, like the adequacy decision regarding Privacy Shield adopted by the Commission in July 2016, under the 1995 Data Protection Directive. Accordingly, the EC’s adequacy determination for Privacy Shield remains valid under the GDPR.
Negotiators from both the U. S. Government and the European Commission accounted for the GDPR’s new substantive and procedural requirements as they developed the Privacy Shield Framework in 2016. Privacy Shield’s joint annual review, for example, was designed to satisfy the GDPR requirement for review of European Commission adequacy determinations once every four years. Privacy Shield’s annual review exceeds this requirement.
In addition, the Privacy Shield Framework created the Ombudsperson mechanism, which provides an unprecedented new channel for EU and Swiss individuals to seek an independent review regarding national security access to personal data transferred to the United States. This mechanism applies not only to data transferred pursuant to the Privacy Shield Framework, but also to other EU-approved data transfer mechanisms, such as Standard Contractual Clauses and Binding Corporate Rules, further enabling transatlantic commerce while protecting privacy.
To learn more about the Privacy Shield Frameworks, visit 
www.privacyshield.gov and check out our two-pager 


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WSJ: “U.S. Manufacturer H.B. Fuller Discloses Potential Sanctions Violation”

(Source: Wall Street Journal 
2 Oct 2019) [Excerpts.]

H.B. Fuller Co. , a U.S. manufacturer of adhesives, said it may have violated U.S. economic sanctions on Iran through the potential resale of its products by some customers of its subsidiaries.

The St. Paul, Minn., company in a regulatory filing said its hygiene products were possibly resold into Iran through customers of its subsidiaries based in Turkey, starting in 2011, and in India, from 2014.

H.B. Fuller, which makes adhesives used in electronics, furniture, construction and disposable baby diapers, said it made a self disclosure of the possible violation to the U.S. Treasury Department’s Office of Foreign Assets Control, which enforces U.S. economic sanctions, in January 2018. The company said it stopped sales to these customers in fiscal 2018, adding the company doesn’t currently conduct any business in Iran.

Still, this could result in a finding that U.S. sanctions were violated and possible penalties, the company said in its quarterly report filed with the Securities and Exchange Commission last week.  . . .

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(Source: EU Sanctions Blog, 2 Oct 2019

There are two judgments of the Italian courts applying the EU Blocking Regulation, Council Regulation (EC) 2271/96:

In the first case, an Italian company controlled by partners in Iran was notified by its bank that their banking services would be terminated due to concerns about US sanctions. The court ordered an injunction to prevent the bank from terminating its services, which it said would be a breach of Article 5 of the EU Blocking Statute, which prohibits compliance in the EU with some US sanctions on Iran.

In the second case, an Italian company had a supply contract with an Iranian company. Payment was made through a US-designated bank, and was subsequently frozen by the Italian entity’s bank. The Italian court found the US designation to be ineffective in the EU, and ordered release of the funds. 

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Bulawayo24 News: “America Bans Buying of Zimbabwe Diamonds”

(Source: Bulawayo24 News, 2 Oct 2019.)

The United States of America Customs and Border Protection (CBP) has issued five Withhold Release Orders (WROs) banning the importation of diamonds from Zimbabwe saying they are mined through forced labour.  In a statement on Tuesday CPB said this action was based on information obtained and reviewed by CBP that indicates that the products are produced, in whole or in part, using forced labour.
Part of the CBP statement:
“Under U.S. law, it is illegal to import goods into the U.S that are made wholly or in part by forced labor, which includes convict labor, indentured labor, and forced or indentured child labor. When sufficient information is available, CBP may detain goods believed to have been produced with forced labor by issuing a WRO. Importers have the opportunity to either re-export the detained shipments at any time or to submit information to CBP demonstrating that the goods are not in violation.  The Forced Labor Division within CBP’s Office of Trade leads agency enforcement efforts prohibiting the importation of goods made using forced labor. CBP receives allegations of forced labor from a variety of sources, including from the general public.  The following WROs are effective immediately.
– Garments produced by Hetian Taida Apparel Co., Ltd. in Xinjiang, China; produced with prison or forced labor.
– Disposable rubber gloves produced in Malaysia by WRP Asia Pacific Sdn. Bhd.; produced with forced labor.
– Gold mined in artisanal small mines (ASM) in eastern Democratic Republic of the Congo (DRC); mined from forced labor.
– Rough diamonds from the Marange Diamond Fields in Zimbabwe; mined from forced labor.
– Bone black manufactured in Brazil by Bonechar Carvão Ativado Do Brasil Ltda; produced with forced labor.
Investigations may be initiated a number of ways, including news reports and tips from either the public or trade community. CBP may also self-initiate an investigation into the use of forced labor in any given supply chain.

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T. Murphy: “Miscellaneous Tariff Bill — Opportunity for Tariff Relief”

(Source: Author)
* Author: Ted Murphy, Esq., 
1-202-736-8016, Sidley Austin, LLP
The Miscellaneous Tariff Bill (MTB) Petition Submission Portal is scheduled to open next Friday, October 11, 2019 at 8:45 am ET.  The portal will remain open for 60 days. 
This is an opportunity that all companies that import dutiable articles into the United States should evaluate, given the low cost/meaningful return nature of the opportunity (again, this opportunity only covers the Normal Trade Relations rate of duty; it will not impact special duties such as those imposed under Section 232, Section 301 or U.S. antidumping/countervailing duty law; although, the imposition of these other duties may strengthen your argument for having the NTR duty temporarily suspended through the MTB process).

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* Author: George R. Tuttle III, Esq.,  geo@tuttlelaw.com, 1-415-986-8780, Law Offices of George R. Tuttle, LLP 
On September 27, 2019, the USTR granted additional exclusions from Section 301 duties for Chinese-origin products that are identified in Section 301 Lists 1 and 2.
September 27th Exclusions for List 1
92 additional product exclusions were granted on Sept 27th for items identified on List 1 ($34 Billion). Importers, brokers and filers are instructed to use HTS 9903.88.19 when making entry of these excluded products. Some of the excluded items include gas treatment process modules, wheels, wood-working and glass-working machinery, DC and AC motors. (See our worksheet. )
September 27th Exclusions for List 2
111 additional product exclusions were granted on Sept 27th for items identified on List 2 ($16 Billion). For these exclusions, importers, brokers and filers are instructed to use HTS 9903.88.20 when making entry of these excluded products. Some of the excluded items include: tapes, gate posts, DC motors, surge protectors, and multimeters.
For a complete list of the 203 items and the applicable HTS numbers, click here
Claiming Refunds, Liquidation of Entries & Filing Extensions of Liquidation
List 1 exclusions were effective September 27, 2019 and are retroactive to July 6, 2018, the date the $34 billion list took effect. List 2 exclusions were effective September 27, 2019 and are retroactive to August 23, 2018. Each exclusion is valid for one year after the publication of the notice in the Federal Register.
To request a refund of Section 301 duties paid on previous imports of products granted duty exclusions by the USTR, importers may file a Post Summary Correction (PSC) if within the PSC filing time frame. If the entry is beyond the PSC filing time frame, importers may protest the liquidation.
Because entries of goods on List 1 and 2 now subject to exemptions are currently being liquidated, it is imperative that importers and brokers immediately file requests with CBP to extend the liquidation of entries of the goods under 19 CFR 1§ 59.12, so as to preserve the ability to file PSCs.
If the entry has been liquidated, it is too late to extend the liquidation, and importers and brokers will have to file protests to receive refunds for those HTS numbers granted exclusions. The protest filing time period is 180 days from the date of liquidation. 
In some extreme cases, the time period to file protests has started to run for goods liquidated in June, July, August and September of 2019.
Items on Lists 1, 2 and 3 are currently subject to a duty rate of 25% ad valorem, which is anticipated to increase to 30% ad valorem on October 15, 2019. The rate was originally set to increase on October 1, 2019 (84 FR 46213 of September 3, 2019).
On September 11, 2019 President Trump tweeted that United States have agreed to delay increasing tariffs on $250 billion worth of Chinese imports from Oct. 1 to Oct. 15, out of respect for the People’s Republic of China’s 70th Anniversary and “as a gesture of good will.”
The USTR has indicated that it will continue to issue exclusions on a periodic basis. To protect a future right to claim a refund, importers are advised to file a request to extend the liquidation of all entries of goods under 19 CFR 1§ 59.12, for which exemptions requests have been sought and are still pending or approved.
It is anticipated that an exclusion process will be available for HTS items on List 4A, which went into effect on September 1, 2019. If your business would like more information on filing an exclusion or is interested in filing an exclusion for products on List 4A, please contact our office.

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ECTI Presents Trade Compliance on a Budget – Issues and Considerations Webinar: October 17, 2019  
Danielle Hatch
* What: Trade Compliance on a Budget – Issues and Considerations
* When: October 17, 2019; 1:00 p.m. (EDT)
* Where: Webinar
* Sponsor: Export Compliance Training Institute (ECTI)
* ECTI Speakers: Roseanne Giambalvo & Randall Cook
* Register
Danielle Hatch
, 540-433-397.

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TE_a213. FCC Presents “U.S. Export Controls: ITAR from a Non-U.S. Perspective,” 26 Nov in Bruchem, the Netherlands

This intermediate-level training course is specifically designed for compliance professionals and those in a similar role who aim to stay up-to-date with the latest International Traffic in Arms Regulations (ITAR) requirements that apply to non-U.S. transactions. The course will cover multiple topics relevant for organizations outside the U.S. that are subject to the International Traffic in Arms Regulations, including but not limited to: the U.S. regulatory framework, key ITAR concepts and definitions, tips regarding classification and licensing, essential steps to ensure an ITAR compliant shipment, how to handle a (potential) non-compliance issue, recent enforcement trends, and the latest regulatory amendments, including the latest U.S. Export Control Reform developments. Participants will receive a certification upon completion of the training.

* What: U.S. Export Controls: The International Traffic in Arms Regulations (ITAR) from a non-U.S. Perspective
* When: Tuesday, 26 Nov 2019
 – Welcome and Registration: 9.00 am – 9.30 am
 – Training hours: 9.30 am – 4.30 pm
* Where: Full Circle Compliance, Landgoed Groenhoven, Dorpsstraat 6, Bruchem, the Netherlands
* Information & Registration: via the 
event page or contact FCC at 
events@fullcirclecompliance.eu or + 31 (0)23 – 844 – 9046
* This course can be followed in combination with “U.S. Export Controls: The Export Administration Regulations (EAR) from a non-U.S. Perspective” (27 Nov 2019), and/or “The ABC of Foreign Military Sales” (29 Nov 2019). Please see the event page for our combo pricing deals.

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* Mahatma Gandhi (Mohandas Karamchand Gandhi; 2 Oct 1869 – 30 Jan 1948; was an Indian lawyer, anti-colonial nationalist, and political ethicist, who employed nonviolent resistance to lead the successful campaign for India’s independence from British Rule, and in turn inspire movements for civil rights and freedom across the world. The honorific Mahātmā (Sanskrit: “high-souled” and “venerable”), first applied to him in 1914 in South Africa, is now used throughout the world.)
– “The best way to find yourself is to lose yourself in the service of others.”
– “Anger and intolerance are the enemies of correct understanding.”

* Groucho Marx (Julius Henry “Groucho” Marx; 2 Oct 1890 – 19 Aug 1977; was an American comedian, writer, stage, film, radio, and television star. A master of quick wit, he is widely considered one of America’s greatest comedians.)
– “The secret of life is honesty and fair dealing. If you can fake that, you’ve got it made.”

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EN_a315. 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: 30 Aug 2019: 84 FR 45652, Adjustment of Controls for Lower Performing Radar and Continued Temporary Modification of Category XI of the United States Munitions List.  
  – The only available fully updated copy (latest edition: 30 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: 9 Sep 2019:
 84 FR 47121-47123 – Cuban Assets Control Regulations


, 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: 4 Sep 2019: Harmonized System Update (HSU) 1915    

 – HTS codes for AES are available here.
 – HTS codes that are not valid for AES are available here.

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EN_a0316. 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 Editor, Alexander Witt. The Ex/Im Daily Update is emailed every business day to approximately 7,500 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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