26-0618: Thursday's "Export/Import Daily Bugle"

1. Today’s Federal Register (No relevant items.)

(Source: Today’s Federal Register)

2. Future Federal Register

(Source: Future Federal Register)

3. CBP Cargo Systems Messages

(Source: DHS/CBP/CSMS)

4. CBP Webinar July 20: “Intro to Biological Material Importation”

(Source: OTR Webinars, [email protected])

5. Commerce/BIS (Nothing new.)

(Source: Commerce/BIS)

6. DoD/DCSA Announcements (Nothing new.)

(Source: Defense Counterintelligence and Security Agency)

7. DoD/DSCA Posts Memo on Incorporating Guidance on Releasability Requirements Before AECA Congressional Notification

(Source: Defense Security Cooperation Agency, 18 Jun 2026)

DSCA has posted Policy Memo 26-60 Incorporation of Guidance on Releasability Requirements Prior to Arms Export Control Act Section 36(b) Congressional Notification. This policy memorandum adds guidance into the Security Assistance Management Manual (SAMM) Chapters 3 and 5 to provide increased clarity and transparency on releasability requirements that must be met prior to Arms Export Control Act (AECA) Section 36(b) Congressional Notification. This information is intended to support FMS program management planning. This memo:

8. OMB/OIRA BIS and DDTC Reviews (Nothing new.)

(Source: OMB Office of Information and Regulatory Affairs)

9. State/DDTC: Pay.gov and DECCS Registration May be Unavailable on June 20, 2026

(Source: State/DDTC, 18 Jun 2026)

Pay.gov will be unavailable on Saturday, June 20th, 2026, from 5:00 PM ET for up to 12 hours due to a cloud system upgrade. Users will be unable to submit Registration fee payments during this window.

For questions or concerns, contact Pay.gov Customer Support: 800-624-1373, Option 2

In conjunction with the Pay.gov upgrade, DDTC will also perform scheduled maintenance on the Defense Export Control and Compliance System (DECCS) Registration application on June 20, 2026, from 5:00–7:00 PM ET.

DECCS Registration will be unavailable during this period.

For questions about the DECCS maintenance, contact the Help Desk.

10. Treasury/OFAC Updates Cuba and Russia Designations; Amends Russia General Licenses and FAQs

(Source: Treasury/OFAC, 18 Jun 2026) [Excerpts]

OFAC actions: Cuba Designation; Russia-related Designations Removals and Designation Update; Issuance of Amended Russia-related General Licenses and Frequently Asked Questions. The following individuals have been added to OFAC’s SDN List: . . .

11. UK Export Control Joint Unit (No relevant items)

(Source: UK ECJU) [Excerpts]

12. US Trade Representative (No new items.)

(Source: USTR Press Office)

13. White House Executive Actions (No relevant items.)

(Source: The White House)

14. Diaz: “Navigating IEEPA Tariff Refunds: Legal and Compliance Considerations”

(Source: Customs & International Trade Law Blog, 18 Jun 2026) [Excerpts]

The recent Supreme Court decision invalidating tariffs imposed under the International Emergency Economic Powers Act (IEEPA) opened the door to tariff refunds for importers. However, amid the newly implemented administrative process for refunds and heightened enforcement scrutiny, importers must do more than simply file a claim.

Importers pursuing refunds of tariffs imposed under IEEPA must navigate a developing framework that blends judicial relief with a newly established administrative process. U.S. Customs and Border Protection (CBP) has implemented the Consolidated Administration and Processing of Entries (CAPE) as the primary mechanism for submitting refund claims following the Supreme Court’s decision and subsequent orders from the U.S. Court of International Trade (CIT).

While CAPE provides a pathway to recovery, it is limited in scope, phased in its application, and subject to ongoing legal and procedural uncertainty. Against this backdrop, importers must approach refund claims with a coordinated strategy that accounts for litigation posture, operational readiness, and heightened compliance expectations.

Requesting Refunds through CAPE. Following the Supreme Court decision and subsequent CIT orders, CBP developed the Consolidated Administration and Processing of Entries (CAPE) – the agency’s official process for handling IEEPA refund claims. . . . [Full article]

15. ECD: “US Fines Bosch for Illegal Exports to Huawei; DOJ Declines to Prosecute”

(Source: Export Compliance Daily, 18 Jun 2026) [Excerpts of subscription site.]

Bosch, a major German engineering and technology company, must pay about $36 million to the U.S. government after admitting to illegally sending export-controlled products and software to Huawei, violating license requirements under the foreign direct product (FDP) rule.

The company must pay about $36 million as part of a settlement agreement with the Bureau of Industry and Security, and BIS said it’s suspending about $3.6 million of that penalty as credit toward a $11,430,098 disgorgement from the DOJ. DOJ also said it’s crediting about $7.8 million of that disgorgement toward the BIS penalty, leading to a net penalty of $36,184,680.

DOJ said it declined to bring criminal charges against Bosch because it voluntarily disclosed the issues and cooperated with the agency. . . .

16. ECD: “UK Fines Firm $1.3M After Accusing It of Trying to Evade Sanctions on Russian Airline”

(Source: Export Compliance Daily, 18 Jun 2026) [Excerpts of subscription site.]

The U.K. this week issued its largest-ever sanctions penalty for a Russia-related violation, fining a travel software firm just over 1 million pounds, or about $1.3 million, for allegedly breaching sanctions against Russia’s Ural Airlines.

The U.K.’s Office of Financial Sanctions Implementation said Sabre Global Technologies, which operates an online travel marketplace, had a contract to provide services to Ural and tried to receive at least hundreds of thousands of dollars in payments from the airline after it was sanctioned in 2022.

OFSI said Sabre, a U.K.-registered company with offices in the U.S. and elsewhere, voluntarily disclosed the alleged breaches and reached a settlement agreement with the U.K.

The agency said the penalty represents the first fine issued by OFSI for a sanctions circumvention violation, “and comes as the UK steps up enforcement action on those seeking to evade our sanctions regime.” . . .

17. Expeditors News: “CBP Announces New Tools and Automation for ACE Account Management”

(Source: Expeditors News) [Excerpts]

In a Cargo Systems Messaging Service (CSMS) bulletin published on June 16, 2026, U.S. Customs and Border Protection (CBP) announced it had created new tools and automated processes to streamline account management for the Automated Commercial Environment (ACE) Portal.

CBP has automated the process of reactivating a trade owner’s account (TAO) when a reactivation request is sent from an email address associated with a TAO account in account. Inactive TAOs can send an email to ACE support with “reactivation” in the subject line and receive automatic confirmation and follow up instructions. Additionally, users can email ACE support with “Trade Account Owner Lookup” in the subject line and will provide a confirmation of who the TAO is for your account.

CBP is also deploying new webforms for managing ACE accounts including importer account applications and ACE portal account applications. These allow users to update TAO information and manage sub-account users to existing top accounts. CSMS #68966469 and links to the new webforms are HERE.

18. ST&R Trade Report: “CBP Encourages Small Businesses to Join CTPAT”

(Source: Sandler, Travis & Rosenberg Trade Report, 18 Jun 2026) [Excerpts]. Contact: [email protected], 1-305-894-1035

U.S. Customs and Border Protection recently highlighted how the Customs Trade Partnership Against Terrorism could benefit participating small businesses adjusting to the expected increase in customs enforcement activity under a recent executive order from the White House.

The EO directs CBP to take a number of actions to intensify customs enforcement, with a strong emphasis on importer accountability and vetting, foreign importer restrictions, disclosure obligations, and higher penalties.

The most immediate practical effect will likely be an increase in bonding, data submissions, and compliance requirements for importers of record, especially foreign IORs. However, none of the directed actions are immediate and instead are likely to be implemented via rulemaking, giving importers and others time to comment and adjust operations as needed.

CBP Executive Assistant Commissioner for Field Operations Diane Sabatino said CTPAT offers small businesses “a proven security framework,” suggesting that participation in this program could make it easier to comply with CBP’s anticipated measures. CTPAT currently includes CTPAT Security, in which partners take steps to ensure supply chain security, and CTPAT Trade Compliance, which allows importers to assume responsibility for monitoring their own compliance with trade laws and regulations. In return for meeting minimum security criteria across 12 categories, participants receive benefits that can reduce regulatory burdens and mitigate enforcement actions, including the following: . . . [Full article]

CBP is encouraging eligible small businesses to join CTPAT to leverage these advantages as the agency moves toward implementing the measures set forth in the EO.

19. Traders Union: “Justice Department Declines Prosecution of Bosch in China Export Control Case”

(Source: TradersUnion.com, 17 Jun 2026) [Excerpts]

As announced by the U.S. Department of Justice, the department declines to prosecute Robert Bosch GmbH under its Corporate Enforcement and Voluntary Self-Disclosure Policy, resolving an investigation into shipments of products and software to an Entity-listed company in China. The department says the matter marks the first time the National Security Division has issued a declination under that policy.

The decision follows Bosch’s prompt disclosure of the conduct to the National Security Division, full cooperation with investigators and remediation steps that the department says are timely and appropriate. Bosch agrees to disgorge $11,430,098 in profits from the transactions, with part of that amount credited toward a $36,184,680 fine paid in a parallel civil action by the Department of Commerce.

Assistant Attorney General for National Security John A. Eisenberg says the outcome shows the benefits for companies that quickly disclose potential violations and assist investigations. Assistant Secretary of Commerce for Export Enforcement David Peters says the settlement also reflects the Bureau of Industry and Security’s effort to pair strong enforcement with incentives for voluntary disclosures of past violations. . . . [Full article]

20. Baker/McKenzie: “OFAC Updates Venezuela General Licenses and Issues New Venezuela FAQs”

(Source: Global Sanctions and Export Controls Blog, 18 Jun 2026) [Excerpts]

On June 10, 2026, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued a suite of updated Venezuela-related general licenses (“GLs”) that slightly ease certain licensing conditions related to governing law and dispute resolution clauses in contracts involving the Government of Venezuela, Petróleos de Venezuela S.A. (“PdVSA”), CVG Compañía General de Minería de Venezuela CA (“Minerven”), or any entity in which PdVSA or Minerven owns, directly or indirectly, a 50% or greater interest.

These updated GLs replace and supersede a number of general licenses issued earlier in 2026, namely GLs 46B (now 46C), 47 (now 47A), 48A (now 48B), 50A (now 50B), 51A (now 51B), 52 (now 52A), and 54 (now 54A) (collectively, “Venezuela GLs”).

In parallel, OFAC published two new Frequently Asked Questions (“FAQs”) clarifying (i) the scope of the governing law of the contracts authorized under the Venezuela GLs and (ii) the extent to which aviation-related transactions involving Venezuela are authorized.

Below we outline the key changes and practical implications: . . . [Full article]

21. ECD: “US Action Against Anthropic Opens Door for Similar Future Controls, Analysts Say”

(Source: Export Compliance Daily, 18 Jun 2026) [Excerpts of subscription site]

Although the Trump administration’s recent export control directive against Anthropic applies only to certain advanced AI models deployed by that company, the saga has caused uncertainty about whether the U.S. could take similar steps against additional AI firms, according to export control policy experts with the Center for Strategic and International Studies.

A June 16 analysis by former Bureau of Industry and Security officials and CSIS experts Kate Koren and Kevin Kurland, along with Aalok Mehta, director of the CSIS Wadhwani AI Center, examines the authorities that BIS may be using to control access to Anthropic’s AI models and the implications for U.S. companies. . . .

The CSIS analysis said “confusion” over what authorities BIS had used to impose license requirements had been raising “uncertainty for all of U.S. industry,” calling into question what the agency could control in the future. Now that “export controls have been used to control model access, every company must consider the possibility of such controls being used again.” . . .

The authors said they expect the U.S. directive to push some of Anthropic’s customers to other AI labs in the short term. “In the long term, however, the uncertainty over durable access to any specific U.S. AI model is likely to drive potential foreign customers to consider options they deem more reliable, including use of small, open-weight models that can run on locally owned and operated hardware.”

22. ST&R Trade Report: “More Tissue Paper Products Could be Subject to AD Duties”

(Source: Sandler, Travis & Rosenberg Trade Report, 18 Jun 2026) [Excerpts]. Contact: [email protected], 1-305-894-1035

A circumvention inquiry filed June 4 could result in the imposition of antidumping duties on imports of tissue paper products from Vietnam that are produced using jumbo roll inputs from China.

The products covered by the AD order on tissue paper products from China are cut-to-length sheets of tissue paper with a basis weight not exceeding 29 grams per square meter. Subject merchandise may be bleached, dye-colored, surface-colored, glazed, surface-decorated or printed, sequined, crinkled, embossed, and/or die cut.

Covered tissue paper is in the form of cut-to-length sheets with a width equal to or greater than one-half inch. It may be flat or folded and may be packaged in a variety of ways, including banding, paper or film wrapping, plastic or film bags, and/or boxes for distribution to the ultimate consumer. Packages may contain tissue paper of a single color or style or multiple colors and/or styles. . . . [Full article]

23. Wasel & Wasel: “Anthropic’s Fable 5 Directive: Overnight Export Control Authority and Its Implications for the Commercial Space Industry”

(Source: Wasel & Wasel, 17 Jun 2026) [Excerpts]

On the evening of June 12, 2026, Anthropic received a directive from the United States government at 5:21 p.m. Eastern Time. The instruction was unambiguous: suspend all access to Fable 5 and Mythos 5 for any foreign national, whether residing inside or outside the United States, including Anthropic’s own employees who are non-U.S. citizens.

Within hours, both models went offline for every customer worldwide. No advance notice. No transitional period. No grandfathering of existing contracts. A commercial product generating active revenue was switched off overnight.

The government’s stated rationale was the discovery of a jailbreak technique capable of bypassing Fable 5’s safeguards and, in particular, those designed to prevent access to the advanced cybersecurity capabilities embedded in Mythos, the underlying frontier model. The directive cited national security authorities but provided no further specifics. . . .

Legal Architecture. The Export Administration Regulations (“EAR”) have for decades governed the transfer of dual-use technology which are items with both civilian and military applications. Under the EAR, the release of controlled technology or source code to a foreign national within the United States constitutes a deemed export to that person’s home country. This means that domestic access, not merely cross-border transfer, can trigger export control obligations. . . .

The commercial space industry operates under an analogous, and in some respects more demanding, regulatory framework. Space-related technologies sit at the intersection of the EAR and the International Traffic in Arms Regulations (“ITAR”). The U.S. Munitions List, against which ITAR is enforced, has historically encompassed satellites, launch vehicles, propulsion systems, guidance technologies, and related software. . . .

Takeaway. What June 12, 2026, demonstrated is that the U.S. government has both the legal authority and the operational willingness to issue a technology access suspension directive without advance notice, without detailed justification, and without a transitional framework.

Moreover, a commercial technology company has no practical mechanism to resist compliance before acting. Anthropic had no meaningful avenue to contest the directive before complying. Its customers had no recourse. Its foreign national employees could not continue working with the affected models. . . .

A satellite imagery company serving defense-adjacent customers in mixed-nationality jurisdictions. A launch service provider whose operations involve foreign nationals at mission control. An on-orbit servicing company whose telemetry systems constitute controlled technology. Any of these entities could, upon a government determination, find their operational licenses suspended, their services cut off, and their revenue interrupted with no more notice than Anthropic received. . . .

Commercial space companies would be wise to internalize that reality now, before a directive arrives at 5:21 in the afternoon with no advance notice and no specific explanation.

24. Skill Dynamics Presents a Webinar: “Technology Security & Foreign Disclosures (TSFD) with Defense Trade Solutions” on 25 June

(Source: Skill Dynamics, previously Content Enablers)

25. Export Compliance Solutions Presents: “Virtual ITAR/EAR Boot Camp” 13-14 October

(Source: Marie Nicolo)

26. List of Export/Import Job Openings

(Source: Editor)

RECENT:

FULL LIST:

27. Bartlett’s Unfamiliar Quotations

(Source: Brainy Quotes)

Auberon Herbert (Auberon Edward William Molyneux Herbert; 18 Jun 1838 – 5 Nov 1906; was a British writer, theorist, philosopher, and 19th century individualist. He promoted a classical liberal philosophy and took the ideas of Herbert Spencer a stage further by advocating voluntary-funded government that uses force only in defence of individual liberty and private property. He is known as the originator of voluntaryism.)

“The career of a politician mainly consists in making one part of the nation do what it does not want to do, in order to please and satisfy the other part of the nation.”

“If government half a century ago had provided us with all our dinners and breakfasts, it would be the practice of our orators today to assume the impossibility of our providing for ourselves.”

Robert Mondavi (Robert Gerald Mondavi; 18 June 1913 – 16 May 2008; was an American winemaker. His technical and marketing strategies brought worldwide recognition for the wines of the Napa Valley in California. From an early period, Mondavi promoted labeling wines varietally rather than generically, which became the standard for New World wines.)

“I’ve always wanted to improve on the idea of living well. In moderation, wine is good for you - mentally, physically, and spiritually.”

Paul McCartney (Sir James Paul McCartney; born 18 June 1942; is an English singer, songwriter, and musician who gained worldwide fame with the Beatles, for whom he played bass guitar and shared primary songwriting and lead vocal duties with John Lennon. His songwriting partnership with Lennon is the most successful in modern music history.)

“Why would I retire? Sit at home and watch TV? No thanks. I’d rather be out playing.”

“In the end, the love you take is equal to the love you make.”

“I’ve got to admit it’s getting better, a little better all the time.”

“If slaughterhouses had glass walls, everyone would be a vegetarian.”

“I don’t ever try to make a serious social comment.”

28. Today in History

(Source: History Channel)

29. Are Your Copies of Export/Import Regulations Current?

(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 are listed below.