26-0623: Tuesday's "Export/Import Daily Bugle"

FEDERAL REGISTER

OTHER U.S. GOVERNMENT SOURCES

NEWS

OPINION

TRAINING EVENTS & CONFERENCES

EX/IM MOVERS & SHAKERS

EDITOR'S NOTES

1. OFPP, DoD, GSA, and NASA Propose Amendment of FAR (48 CFR Parts 5, 24, 29, and 52)

(Source: 91 FR 37676, 23 Jun 2026) [Excerpts]

2. OFPP, DoD, GSA, and NASA Propose Amendment of FAR (48 CFR Parts 1, 2, 4, 33, 39, 40, 52, and 53)

(Source: 91 FR 37550, 23 Jun 2026) [Excerpts]

3. OFPP, DoD, GSA, and NASA Propose Amendment of FAR (48 CFR Parts 3 and 49)

(Source: 91 FR 37698, 23 Jun 2026) [Excerpts]

4. OFPP, DoD, GSA, and NASA Propose Amendment of FAR (48 CFR Parts 6, 7, 10, 18, 26, 37, and 41)

(Source: 91 FR 37636, 23 Jun 2026) [Excerpts]

5. Future Federal Register

(Source: Future Federal Register)

6. CBP Cargo Systems Messages

(Source: DHS/CBP/CSMS)

7. Commerce/BIS (Nothing new.)

(Source: Commerce/BIS)

8. DoD/DCSA Announcements (Nothing new.)

(Source: Defense Counterintelligence and Security Agency)

9. DoD/DSCA (Nothing new.)

(Source: Defense Security Cooperation Agency)

10. Justice Dept (Nothing new.)

(Source: U.S. Attorney’s Office)

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

(Source: OMB Office of Information and Regulatory Affairs)

12. State/DDTC (Nothing new.)

(Source: State/DDTC)

13. Treasury/OFAC Updates SDN and Blocked Persons List; Issues TCO-related General License; Publishes OFAC-OFSI Comparative Overview

(Source: Treasury/OFAC, 23 Jun 2026)

The United States Department of the Treasury's Office of Foreign Assets Control (OFAC) published a featured story detailing its enhanced partnership with the United Kingdom's Office of Financial Sanctions Implementation (OFSI).

OFAC and OFSI have published a joint guidance document to assist the private sector in understanding its obligations under both the U.S. and UK sanctions regimes, this guidance compares key aspects of both regimes and highlights key similarities and differences.

This comparison focuses specifically on topics such as sanctions lists, available licenses, and recordkeeping and reporting requirements. While this guidance provides a general overview of key concepts, you are encouraged to review the most relevant OFAC or OFSI guidance or regulations to address specific questions or concerns.

OFAC also is issuing TCO General License 2, "Authorizing the Wind Down of Transactions Involving CCU Commercial Bank Plc."

OFAC has updated its Specially Designated Nationals and Blocked Persons List. Visit this page for the latest version of the SDN list.

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

(Source: UK ECJU)

15. US Trade Representative (No new items.)

(Source: USTR Press Office)

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

(Source: The White House)

17. Breaking Defense: "Changes to US FMS Weapons Sales Practices Should Emerge Later This Year, Says Pentagon Official"

(Source: Breaking Defense News, 23 Jun 2026)

The Trump administration is making progress on its revamped version of the Foreign Military Sales (FMS) process, but a Pentagon official involved in the changes says not to expect major shifts in the near term.

"So we're on time and on target with regards to everything that was tasked to us within" the America First Arms Transfer Strategy, Michael Cadenazzi, the assistant secretary of Defense for Industrial Base Policy, told reporters last week after a Center for a New American Security event. "We have a series of initiatives that are tied to it, the sales catalog, and all those kind of things… and so we've delivered our portion of it." . . .

Some of those tasks included having Defense Secretary Pete Hegseth and Secretary of State Marco Rubio, along with Secretary of Commerce Howard Lutnick, draft a "sales catalog of prioritized platforms" that the US will encourage allies and partners to buy from, while a future "Promoting American Military Sales Task Force" will be stood up to work on an implementation plan.

"The hardest part is just to time phase it, because there's so many things hitting the enterprise all at once, and so we're seeing the impact of that here," Cadenazzi added. Some of those changes include creating a "single tracking system" for arms sales and identifying possible production challenges that require an intervention.

The overhaul of the entire process of selling weapons to allies and partners comes at a time when Trump administration officials have publicly assailed some of those countries, while some buyers voice concerns about long US production queues, and being notified of possible delays so the US can backfill weapons spent against Iran. . . .

18. ECD: "Bill to Restrict Exports of Chipmaking Tools Proposed as NDAA Amendment"

(Source: Export Compliance Daily, 23 Jun 2026) [Excerpts of subscription site.]

A bipartisan group of seven House members led by Rep. Michael Baumgartner, R-Wash., has proposed an amendment to the FY 2027 National Defense Authorization Act that would aim to increase allied export controls on chipmaking equipment.

The amendment is identical to the Match Act that the House Foreign Affairs Committee approved as a stand-alone bill in April. It is one of more than 1,100 amendments that lawmakers have submitted to the House Rules Committee. . . .

19. Expeditors News: "USTR Announces Section 301 Investigation of Germany's Pharmaceutical Pricing Practices"

(Source: Expeditors News, 23 Jun 2026) [Excerpts]

In a press release published on June 18, 2026, the Office of the U.S. Trade Representative (USTR) announced the initiation of a Section 301 investigation of Germany's pharmaceutical pricing practices to determine "whether persistent underpayment for innovative pharmaceutical products by Germany is unreasonable or discriminatory and burdens or restricts U.S. commerce.

According to USTR, the investigation follows months of discussions with Germany. USTR stated that is looking to reach a similar agreement with Germany to the one that United States and United Kingdom reached on April 2, 2026, on pharmaceutical pricing to expand "access to the most innovative drugs for the German people while ensuring fair reimbursement for the pharmaceuticals made by American workers."

USTR is accepting public comments on this investigation and must be submitted by August 10, 2026. A hearing will be held on the investigation on September 22, 2026.

USTR's press release and a link to the Federal Register Notice can be found HERE. Comments can be submitted on this investigation HERE.

20. ST&R Trade Report: "HTSUS Numbers Subject to Seafood Trade Monitoring Programs Updated"

(Source: Sandler, Travis & Rosenberg Trade Report, 23 Jun 2026) [Excerpts]. Contact: [email protected], 1-305-894-1035

According to a recent message from U.S. Customs and Border Protection, additional HTSUS codes are being added to the list of those flagged for permit and reporting requirements under one or more of the following trade monitoring programs: the Antarctic Marine Living Resources Program, the Seafood Import Monitoring Program, and the Tuna Tracking and Verification Program.

CBP said it will begin flagging the new or revised HTSUS codes on July 1. Entries using one of these codes will be subject to all permitting, reporting, and recordkeeping requirements associated with the trade monitoring program(s) for which it is listed. More information can be found here.

21. Baker/McKenzie: "OFAC Begins to Relax US Sanctions to Implement US-Iran MOU"

(Source: Global Sanctions and Export Controls Blog, 23 Jun 2026) [Excerpts]

On June 22, 2026, the US Treasury Department's Office of Foreign Assets Control ("OFAC") published a new general license (Iran General License X or "GL X") as the first step in implementing the US-Iran Memorandum of Understanding ("MOU") to end recent hostilities in the Middle East.

The MOU has not been formally or officially published by US Government agencies such as the State or Treasury Departments, but its text has widely been reported and confirmed in news articles such as this BBC report. . . .

The MOU sets out the measures the United States and Iran have agreed on, including a commitment to negotiate a final deal that could lead to the lifting of US unilateral and other categories of sanctions against Iran in exchange for an agreement on nuclear issues. . . . [Full article]

22. Braumiller: "Customs Enforcement Overhaul: What Importers and Brokers Need to Do Now"

(Source: Braumiller Group, 23 Jun 2026) [Excerpts]

On June 3, 2026, President Trump issued Executive Order 14411, "Strengthening Customs Enforcement," directing the Department of Homeland Security and U.S. Customs and Border Protection to tighten importer eligibility, increase disclosure obligations, and expand enforcement measures across the U.S. import system.

While many of the order's requirements will depend on forthcoming implementation guidance, the overall direction is already clear: CBP is moving toward a more heavily vetted, more transparent, and more financially accountable importer-of-record framework. Importers and customs brokers should begin preparing now, particularly where current operations depend on foreign importer-of-record structures, limited ownership disclosures, or compliance processes that may not withstand greater scrutiny.

Key Changes for Importers of Record. For all importers of record, the order directs DHS and CBP to revise importer eligibility requirements. Those revisions are expected to include minimum tangible domestic assets, higher bond requirements, and mandatory designation and reporting of the importer of record to CBP. Importers of record are also expected to provide expanded information to CBP, including anticipated import volumes, year organized, ownership and beneficial ownership information, business affiliations, and domestic asset disclosures.

The order also imposes a new "good standing" requirement. Good standing will be based on the importer's and its affiliates' customs compliance history, payment of customs liabilities, and other factors CBP considers relevant. An importer of record that is not in good standing will be barred from importing into the United States or engaging in activities directly related to importation, including appointing a customs broker to act as importer of record on its behalf. . . . [Full article]

23. ECD: "Nvidia CEO on US-Anthropic Saga: Justification for Export Controls Should Be 'Very Specific'"

(Source: Export Compliance Daily, 23 Jun 2026) [Excerpts of subscription site]

The U.S. should be "careful" not to overuse export controls on AI, especially after the export control directive it sent to Anthropic earlier this month, Nvidia CEO Jensen Huang said last week.

In an interview with the Associated Press, Huang acknowledged that protecting national security should be the U.S. government's highest priority, but he also said the U.S. should use export controls judiciously.

"Export control is a powerful tool that, if used precisely and specifically, could be quite effective," said Huang, who has lobbied the Trump administration to loosen export restrictions on Nvidia's advanced AI chips. The U.S. has "to be careful not to over-exercise export control so that it doesn't create unintended consequences to a lot of other things that we don't intend it to do." . . .

24. S&W: "New Customs Enforcement Order Gives Importers a Limited Window to Review Tariff-Driven Import Practices"

(Source: Snell & Wilmer Alert, 22 Jun 2026) [Excerpts]

On June 3, 2026, President Donald J. Trump issued an Executive Order titled "Strengthening Customs Enforcement," directing the Department of Homeland Security and U.S. Customs and Border Protection (CBP) to increase scrutiny of importers, expand reporting requirements, enhance audits, and impose stricter penalties for noncompliance. Companies that act as importers of record should evaluate global supply chains to ensure compliance and expediting processing in importing goods into the United States.

The Executive Order is not an isolated policy development. As new tariffs have been implemented, many importers and end-users have changed how they import merchandise in an attempt to mitigate tariff impacts. Some changes relate to updating Harmonized Tariff Schedule (HTS) classification or changing global supply chain manufacturers.

In these instances, importers are working to comply with U.S. customs law. But, there are other schemes that improperly reduce entered value, change HTS classifications or countries of origin without support, or shift liability to a foreign supplier or its domestic pass-through U.S. entity.

The Executive Order makes clear that CBP is aware of these practices. The relevant structures include delivered duty paid (DDP) terms, foreign suppliers as importers of record, nominal U.S. importer domestic entities, separate invoices for the same product, and unsupported HTS changes and country-of-origin changes.

The practical message is clear. Any company that materially changed its import practices after the imposition of new tariffs in 2025 should conduct a customs compliance review to ensure compliance or consider voluntary disclosure in an effort to avoid significant criminal and civil liabilities. . . . [Full article]

25. Volkov: "The Shadow AI Crisis — Your Employees Are Already Using AI, and You Don't Know How (Part 2 of 3)"

(Source: Volkov Law, 23 Jun 2026) [Excerpts]

If Part I of this series described the governance gap at the organizational level, Part II describes the crisis that is already unfolding inside your organization right now — whether you know it or not. Shadow AI is real, it is pervasive, and the statistics are alarming.

According to Gartner research across 500 companies, 68% of employees use unauthorized AI tools at work — a figure that jumped from 41% in 2023. Shadow AI tool usage increased 156% from 2023 to 2025. More than 80% of workers, including 90% of security professionals, use unapproved AI tools, according to cybersecurity research. And 71% of office workers admit to using AI tools without IT approval.

Read those numbers again. The majority of your workforce is almost certainly using AI tools your organization has not approved, evaluated, or even identified.

What Shadow AI Actually Means. Shadow AI is the use of artificial intelligence tools — chatbots, writing assistants, code generators, image creators, browser plug-ins, analytical platforms — without the knowledge or approval of IT, compliance, or legal teams. It is the employee who runs confidential contract language through ChatGPT to get a summary. The HR manager who uses an AI tool to draft performance reviews; the finance analyst who uploads earnings projections to get model commentary; the developer who uses an AI coding assistant that is not on the approved software list.

None of these employees are acting with malicious intent. They are trying to be more productive. They have discovered that AI tools genuinely help them work faster and better, and they are using them — regardless of whether their employer has a policy in place. The problem is what they are doing with your data in the process.

Approximately 54% of shadow AI tools have been used to upload sensitive company data, increasing the risk of data exposure and leaks. And approximately 76% of shadow AI tools fail to meet SOC 2 compliance standards. A significant percentage of generative AI users access tools through personal accounts, bypassing enterprise controls entirely. The average cost of a shadow AI data breach has reached $4.2 million. The financial exposure is not hypothetical. It is documented and growing. . . . [Full article]

26. Export Compliance Solutions Presents: "9th Annual ITAR/EAR Symposium" Seminar, 15-16 Sep 2026 in Annapolis

(Source: Marie Nicolo)

27. Chris Stagg Moves to Varick

(Source: Editor)

Christopher B. Stagg, formerly with State/DDTC and Holland & Knight, has moved to Varick PLLC in Washington, DC. Contact Chris at [email protected] or 202-935-2778.

28. List of Export/Import Job Openings

(Source: Editor)

RECENT:

FULL LIST:

29. Bartlett's Unfamiliar Quotations

(Source: Brainy Quotes)

Irvin S. Cobb (Irvin Shrewsbury Cobb; 23 June 1876 – 11 Mar 1944; was an American author, humorist, editor and columnist from Paducah, Kentucky, who relocated to New York in 1904, living there for the remainder of his life. He wrote for the New York World, Joseph Pulitzer's newspaper, as the highest paid staff reporter in the United States.)

"Middle age: when you begin to exchange your emotions for symptoms."

Edward VIII (Edward Albert Christian George Andrew Patrick, later Prince Edward, Duke of Windsor; 23 Jun 1894 – 28 May 1972; was King of the United Kingdom and the Dominions of the British Empire, and Emperor of India, from 20 January 1936 until his abdication on 11 December of that year.)

"The thing that impresses me most about America is the way parents obey their children."

David Ogilvy (David Mackenzie Ogilvy; 23 Jun 1911 – 21 Jul 1999; was a British advertising tycoon, founder of Ogilvy & Mather, and known as the "Father of Advertising". Trained at the Gallup research organization, he attributed the success of his campaigns to meticulous research into consumer habits.)

"The best ideas come as jokes. Make your thinking as funny as possible."

30. Do You Need to Update Your Daily Bugle Profile?

(Source: Editor)

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31. 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.