19-1113 Wednesday “Daily Bugle'”

19-1113 Wednesday “Daily Bugle”

Wednesday, 13 November 2019

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  1. Commerce/BIS Amends EAR by Adding 22 Entities, Modifies 1, and Removes 3 from Entity List
  2. USTR Grants Certain Product Exclusions from the Additional Duties on Goods of China
  1. Items Scheduled for Publication in Future Federal Register Editions
  2. Commerce/BIS: (No new postings.)
  3. State/DDTC: (No new postings.)
  1. Defense Connect: “US reports Strong Defence Export Sales for FY2019”
  2. FT: “Huawei to Pay Staff $286m Bonus for Helping Counter Sanctions”
  3. Reuters: “U.S. to Ease Firearm Export Rules Next Month”
  1. A.V. Capobianco, B.P. Curran & A. Dukic: “OFAC Issues General Licenses Authorizing Certain Transactions Involving the Government of Venezuela”
  2. G.R. Tuttle: “USTR Announces New Round of Section 301 Duty Exclusions for List 3”
  3. M. Bellan, W.Devaney & M. Batonga: “DOJ Guidelines Incentivize Companies to Self-Disclose and Cooperate in False Claims Act Cases”
  4. P. Burnson: “2020 Trade Update: More complexities in Compliance”
  1. Salvatore Di Misa Joins Full Circle Compliance
  1. ECTI Presents Navigating the Changing Foreign Investment Regulatory Environment Webinar: November 14, 2019
  1. Bartlett’s Unfamiliar Quotations
  2. Are Your Copies of Regulations Up to Date? Latest Amendments: DHS/Customs (5 Apr 2019), DOC/EAR (13 Nov 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 2019), DOS/ITAR (30 Aug 2019), DOT/FACR/OFAC (9 Sep 2019), HTSUS (3 Sep 2019) 
  3. Weekly Highlights of the Daily Bugle Top Stories 



1. Commerce/BIS Amends EAR by Adding 22 Entities, Modifies 1, and Removes 3 from Entity List

Federal Register, 13 Nov 2019.) [Excerpts
indicated by “….”]
84 FR 61538-61546:
Addition of Entities to the Entity List, Revision of an Entry on the Entity List, and Removal of Entities from the Entity List
* AGENCY: Bureau of Industry and Security, Commerce.
* ACTION: Final rule.
* SUMMARY: In this rule, the Bureau of Industry and Security (BIS) amends the Export Administration Regulations (EAR) by adding twenty-two entities, under a total of thirty-two entries, to the Entity List. …. This rule also modifies one existing entry on the Entity List under the destination of Pakistan. Finally, this rule removes three entities from the Entity List; one under the destination of Pakistan, one under the destination of Singapore and one under the destination of the U.A.E. ….
* DATES: This rule is effective November 13, 2019. ….

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2. USTR Grants Certain Product Exclusions from the Additional Duties on Goods of China

Federal Register, 13 Nov 2019.) [Excerpts
indicated by “….”]
84 FR 61674-61676: Notice of Product Exclusions: China’s Acts, Policies, and Practices Related to Technology Transfer, Intellectual Property, and Innovation
* AGENCY: Office of the United States Trade Representative.
* ACTION: Notice of product exclusions.
* SUMMARY: …. This notice announces the U.S. Trade Representative’s determination to grant certain exclusion requests, as specified in the Annex to this notice.
* DATES: The product exclusions announced in this notice will apply as of the September 24, 2018, effective date of the $200 billion action, to August 7, 2020.
* FOR FURTHER INFORMATION CONTACT: Assistant General Counsels Philip Butler or Megan Grimball, or Director of Industrial Goods Justin Hoffmann at (202) 395-5725. For specific questions on customs classification or implementation of the product exclusions identified in the annex to this notice, contact traderemedy@cbp.dhs.gov. ….

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. Items Scheduled
for Publication in Future Federal Register Editions

(Source: Federal Register)

* Commerce/BIS; NOTICES; Action Affecting Export Privilege: Rasheed Al Jijakli; Correction; Order Denying Export Privileges: Mojtaba Biria; Order: Ali Caby, a/k/a Alex Caby, Arash Caby, a/k/a Axel Caby, Arrowtronic, LLC [Pub. Date: 14 Nov 2019.]

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. Commerce/BIS: (No new postings.)


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State/DDTC: (No new postings.)

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(Source: Defense Connect, 13 Nov 2019.) [Excerpts.]
The US Defense Security Cooperation Agency (DSCA) has announced US$55.4 billion worth of sales for the 2019 fiscal year, marking continued growth for the global defence industry.  
This total increases the three-year rolling average to US$51 billion, demonstrating continued strength in the sales of US defence articles and services to allies and foreign partners.  . . .
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FT: “Huawei to Pay Staff $286m Bonus for Helping Counter Sanctions”

(Source: Financial Times, 12 Nov 2019.) [ Excerpts indicated by “….”]
Huawei will pay out Rmb2bn ($286 million) in bonuses and double almost all employees’ monthly salaries for October as a reward for helping the world’s largest telecoms equipment maker counter US sanctions imposed by the Trump administration. 
In May, the US barred the Chinese company from buying crucial semiconductors from suppliers including Qualcomm and banned it from using Google’s Android operating system in its smartphones, citing worries the group poses a national security risk.  
Washington views Huawei as a potential spy on behalf of the Chinese government, an allegation the company denies. ….

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Reuters: “U.S. to Ease Firearm Export Rules Next Month”
(Source: Reuters, 12 Nov 2019.) [Excerpts indicated by “….”]
U.S. firearms makers will be able to more easily export guns, including assault rifles and ammunition, as early as mid-December under rules set to be finalized by the Trump administration, people briefed on the matter said on Tuesday.
The proposed export changes could be enacted on or after Dec. 14, and would move oversight of commercial firearm exports to the Commerce Department from the State Department, the sources told Reuters.
Staff on several legislative committees were briefed on the rule changes on Tuesday ahead of a formal notification for lawmakers for Thursday, the people said, starting a 30-day clock before the rules can take effect. ….
The effort to streamline U.S. small arms export controls dates back to an Obama administration initiative begun in 2009 that was never translated into policy. ….

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COM_a19. A.V. Capobianco, B.P. Curran & A. Dukic: “OFAC Issues General Licenses Authorizing Certain Transactions Involving the Government of Venezuela”

Hogan Lovells, 8 Nov 2019.) [Excerpts indicated by “….”]
* Authors: Anthony V. Capobianco, Esq., anthony.capobianco@hoganlovells.com, +1 202-637-2568; Brian P. Curran, Esq., brian.curran@hoganlovells.com, +1 202-637-4886; and Aleksandar Dukic, Esq., aleksandar.dukic@hoganlovells.com, +1 202-637-546; all of Hogan Lovells.
On 5 November 2019, the Office of Foreign Assets Control (OFAC) issued two new general licenses authorizing certain transactions involving the Government of Venezuela (GOV) and certain individuals affiliated with the GOV, which is blocked pursuant to Executive Order 13884 (E.O. 13884). Specifically, OFAC issued General License No. 35 (GL 35) which authorizes U.S. persons to engage in certain administrative transactions with the GOV, provided that the activity is necessary and incident to the U.S. person’s day-to-day operations related to non-sanctioned activities and entities. In addition, OFAC issued amended General License No. 34A (GL 34A), which authorizes transactions with certain GOV persons.
With these general licenses, OFAC published new and amended Frequently Asked Questions (FAQs) concerning Venezuela-related Sanctions. An overview of the newly issued and amended general licenses and FAQs is set forth below.
You can view our previous publications concerning Venezuela-related Sanctions here.
General License No. 35
Before GL 35, was issued, U.S. persons were generally prohibited from engaging in transactions involving the GOV, and conducting business in Venezuela had become increasingly difficult for U.S. companies. However, GL 35 loosens certain restrictions on conducting business in Venezuela and authorizes particular transactions with the GOV that are otherwise prohibited by EO 13884, provided that these transactions are administrative in nature and are necessary and incident to day-to-day operations that are not otherwise prohibited under the sanctions. Such administrative transactions include paying for taxes, fees and import duties, public utility services, and purchasing and receiving permits, licenses, and certifications from the GOV.
This general license may be particularly beneficial for U.S. companies with continued business operations in Venezuela; however, it is important to note that GL 35 does not authorize any transactions or dealings with any blocked person other than those specifically described in the general license. …. 
Lastly, the use of GL 35 is subject to certain ongoing and mandatory reporting requirements. Specifically, …. 
General License No. 34A
GL 34A continues to authorize transactions involving individuals who meet the definition of the Government of Venezuela pursuant to E.O. 13884 for the following categories of authorized persons: (i) U.S. citizens; (ii) permanent resident aliens of the United States; (iii) individuals who have a valid U.S. immigrant or nonimmigrant visa, other than individuals in the United States as part of Venezuela’s mission to the United Nations; and (iv) former employees and contractors of the government of Venezuela. However, GL 34 was amended to specifically include the following new category of authorized persons: “current employees and contractors of the Government of Venezuela who provide health or education services in Venezuela, including at hospitals, schools, and universities.”
In addition, GL 34A authorizes transactions related to an authorized person’s receipt of a salary, pension, annuity or other employment-related payments of benefits from the GOV.  
Like GL 35, GL 34A is also subject to certain mandatory reporting requirements with OFAC.
New and Amended FAQs
In addition to the General Licenses above, OFAC published the following FAQs:

FAQ 805 addresses the types of activities authorized by GL 35, but warns that U.S. persons who rely on the authorizations set forth in GL 35 should remain cautious and exercise appropriate due diligence to ensure compliance with the terms of the authorization.

FAQ 680 was amended to reflect authorizations granted in GL 34A and provides additional clarity on the types of transactions that remain prohibited under E.O. 13884. …. 

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G.R. Tuttle: “USTR Announces New Round of Section 301 Duty Exclusions for List 3”

(Source: Author)
* Author: 
George R. Tuttle III, Esq., Law Offices of George R. Tuttle, 
PC, 1-415-986-8780, george.tuttle.iii@tuttlelaw.com
On November 7, 2019 the Office of the U.S. Trade Representative (USTR) released a notice granting 36 exclusion requests to the Section 301 duties levied on goods from China. See our updated EXCLUSION LIST, which includes all exclusions granted to date. The notice affects goods on List 3 and includes floor coverings, knitted fabrics, drive shafts and tension pole shower caddies. These exclusions apply from September 24, 2018 through August 7, 2020. The applicable HTS to apply to this round of exclusions is 9903.88.34.
CSMS #40564257
On Friday, November 8, 2019 Customs issued CSMS #40564257 on guidance for entering List 3 #200B products excluded in the October 28, 2019 Federal Register notice (84 FR 57802). The exclusion for products announced in the Federal Register notice is retroactive to September 24, 2018 and extends through August 7, 2020. CSMS #40564257 provides guidance for importers, brokers and filers on submitting entries and using HTS 9903.88.33 in lieu of the corresponding chapter 99 HTS number.
For List 1 $34 billion exclusions granted in December 2018 and set to expire in December 2019, comments to extend the expiration date are being accepted through November 30, 2019 (84 FR 58427 of 10/31/2019). The USTR will individually evaluate each exclusion comment and request for extension. Comments are to be submitted under USTR-2019-0019 at www.regulations.gov.
The List 4A Portal for Exclusion Process opened October 31, 2019 and closes on January 31, 2020 at 11:59pm. This exclusion process is for products covered by Annex A (84 FR 57145 of October 24, 2019). TheFederal Register notice sets out specific procedures for submitting requests.


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M. Bellan, W. Devaney & M. Batonga: “DOJ Guidelines Incentivize Companies to Self-Disclose and Cooperate in False Claims Act Cases”
(Source: Baker McKenzie, 11 Oct 2019.) [Excerpts indicated by “….”.  Footnotes omitted.]
* Authors: Maurice Bellan, Esq., maurice.bellan@bakermckenzie.com; William Devaney, Esq., william.devaney@bakermckenzie.com; and Marilyn Batonga, Esq., marilyn.batonga@bakermckenzie.com; all of Baker McKenzie.
The U.S. Department of Justice (“DOJ”) has issued Guidelines for Taking Disclosure, Cooperation, and Remediation into Account in False Claims Act Matters, which identify various factors that the Department will consider in issuing credit to companies that voluntarily disclose misconduct that could serve as the basis for False Claims Act (“FCA”) violations, or companies that otherwise cooperate in ensuing investigations. While the policy provides  companies incentives to make voluntary self-disclosures to obtain maximum credit, other forms of cooperation can also earn meaningful credit, and any credit awarded will vary depending on the circumstances in particular cases.
Types of Credit
Credit provided to a company can take the form of a reduction in civil penalties or impact the amount of the damages multiplier sought in the case. In any event, the maximum credit awarded may not exceed an amount that would result in the government receiving less than full compensation for the losses caused by the defendant’s misconduct. These losses can include not only the government’s damages, but also lost interest, the government’s costs in the investigation, and the relator share. …. 
How to Maximize Chances for a Credit
To maximize the chances that the disclosing party will receive credit in the resolution of an FCA matter, the disclosure must not only be voluntary but proactive and timely. …. The new guidelines contain a non-exhaustive list of the forms of cooperation that the DOJ will take into account when deciding whether to give cooperation credit and how much credit to give if it decides to do so, including:
* Identifying individuals substantially involved or responsible for the misconduct;
* Disclosing relevant facts and identifying opportunities for the government to obtain evidence ….;
* Preserving, collecting, and disclosing relevant documents ….;
* Identifying individuals who are aware of relevant information or conduct, including an entity’s operations, policies, and procedures;
* Making officers and employees who possess relevant information available for meetings, interviews or depositions;
* Disclosing facts relevant to the government’s investigation gathered during the company’s independent investigation;
* Providing facts relevant to potential misconduct by third-party entities and third-party individuals;
* Facilitating the review and evaluation of information if it requires proprietary technologies so that the information can be evaluated;
* Admitting liability or accepting responsibility for the relevant conduct; and
* Assisting in the determination or recovery of the losses caused by the company’s misconduct.
The Department will also consider whether the company took appropriate remedial measures in response to the FCA violation, including implementing or improving an effective compliance program or disciplining or replacing those responsible for the misconduct. …. 
The guidelines are consistent with recent efforts by the Department to exercise more control over FCA investigations and litigation. In January 2018, a leaked memo from Michael Granston, director of the DOJ’s Commercial Litigation Branch, Fraud Section, instructed Department attorneys to consider seeking dismissal of actions brought by whistleblowers when these FCA suits do not serve the federal government’s best interests. ….
Key Takeaways
* …. The new guidelines do not change the preexisting legal obligations of an entity or individual to report or cooperate with the federal government.  ….
* Disclosure is not the only method of cooperation that can earn credit. …. 
* DOJ acknowledges that self-disclosure of violations, while encouraged, can and does affect negotiations with other agencies. As credit for disclosure or other forms of cooperation, the DOJ may consider notifying other agencies of the cooperation so that it can be taken into consideration during administrative proceedings including those for suspension and debarment. …. 

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P. Burnson: “2020 Trade Update: More complexities in Compliance”
(Source: Logistics Management, 11 Nov 2019.) [Excerpts.]
* Author: P. Burson, Executive Editor, pburnson@peerlessmedia.com, Logistics Management.
Most countries impose legal control on the export of goods from their jurisdictions, while international trade agreements often include additional regulations. However, failing to observe new laws and sanctions can have severe consequences for importers as well.
When the Trump administration announced last month that it had secured a partial deal with Chinese negotiators to push pause on the escalating trade war, our nation’s leading retailers were among the first to praise the move.
“Retailers are encouraged by the progress made between the United States and China and are pleased that the administration has listened to the concerns of the business community as the trade war takes an increasing toll on the American economy,” says David French, senior vice president for government relations of The National Retail Federation.
French adds that the decision to delay planned tariff hikes is welcome, but incomplete news for shippers heading into the busy holiday shopping season. “Although this is a step in the right direction, the uncertainty continues,” French adds. “We urge both sides to stay at the negotiating table with the goal of lifting all tariffs and fundamentally resetting U.S.-China trade relations.”
Global logistics managers in automotive, electronics and agriculture sectors are also seeking regulatory compliance tips as both sides meet to finalize a tentative trade deal, while crafting the precise language of the preliminary phase.  ….
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Salvatore Di Misa Joins Full Circle Compliance
(Source: Editor.)
Full Circle Compliance weldomed Salvatore Di Misa as an FCC Associate on 10 Nov 2019. 
Salvatore holds a L.L.M in International Business Law obtained at the Tilburg University in July 2019 and a Master of Laws from the University of Palermo in 2017.  
Contact Salvatore at

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ECTI Presents Navigating the Changing Foreign Investment Regulatory Environment Webinar: November 14, 2019 
Danielle Hatch)
* What: Navigating the Changing Foreign Investment Regulatory Environment
* When: November 14, 2019; 1:00 p.m. (EST)
* Where: Webinar
* Sponsor: Export Compliance Training Institute (ECTI)
* ECTI Speakers: Randall Cook & Rosanne Giambalvo
* Register
here or Danielle Hatch, 540-433-3977.

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EN_a216. Are Your Copies of Regulations Up to Date?

(Source: Editor)

The official versions of the following regulations are published annually in the U.S. Code of Federal Regulations (C.F.R.), but are updated as amended in the Federal Register.  The latest amendments to applicable regulations are listed below.

: 19 CFR, Ch. 1, Pts. 0-199.  Implemented by Dep’t of Homeland Security, U.S. Customs & Border Protection.
  – Last Amendment: 5 Apr 2019:
5 Apr 2019: 84 FR 13499-13513: Civil Monetary Penalty Adjustments for Inflation

DOC EXPORT ADMINISTRATION REGULATIONS (EAR): 15 CFR Subtit. B, Ch. VII, Pts. 730-774. Implemented by Dep’t of Commerce, Bureau of Industry & Security.
  – Last Amendment: 13 Nov 2019: 84 FR 61674-61676Addition of Entities to the Entity List, Revision of an Entry on the Entity List, and Removal of Entities from the Entity List


: 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
  – The latest edition (4 Jul 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 
.  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 

: DoD 5220.22-M. Implemented by Dep’t of Defense.
  – Last Amendment: 18 May 2016: 

Change 2
: Implement an insider threat program; reporting requirements for Cleared Defense Contractors; alignment with Federal standards for classified information systems; incorporated and cancelled Supp. 1 to the NISPOM (Summary 

: 10 CFR Part 810; Implemented by Dep’t of Energy, National Nuclear Security Administration, under the 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.

; 10 CFR Part 110; Implemented by Dep’t of Energy, U.S. Nuclear Regulatory Commission, under the 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

: 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 45652-45654, 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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. Weekly Highlights of the Daily Bugle Top Stories
(Source: Editor)

Review last week’s top Ex/Im stories in “Weekly Highlights of Daily Bugle Top Stories” posted here.

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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 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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