26-0624: Wednesday'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. Commerce/BIS Seeks Comments on 5-Year Records Retention Requirement for Export Transactions and Boycott Actions

(Source: 91 FR 37947, 24 Jun 2026) [Excerpts]

2. Commerce/BIS Seeks Comments on Report of Requests for Restrictive Trade Practice or Boycott

(Source: 91 FR 37948, 24 Jun 2026) [Excerpts]

3. Commerce/BIS Seeks Comments on Technology Letter of Explanation

(Source: 91 FR 37947, 24 Jun 2026) [Excerpts]

4. Commerce/BIS Seeks Comments on Voluntary Self-Disclosure of Antiboycott Violations

(Source: 91 FR 37946, 24 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. State/DDTC (Nothing new.)

(Source: State/DDTC)

9. Treasury/OFAC: Russia-related Designations Removals from SDN List

(Source: Treasury/OFAC, 24 Jun 2026)

The following deletions have been made to OFAC's SDN List: [See list HERE.]

10. Diaz: "CBP Issues Two New WROs Against Jordan Garment Factories: What Importers Need to Know"

(Source: Customs & International Trade Law Blog, 24 Jun 2026) [Excerpts]

Here is a recap of the latest customs and international trade law news:

CBP just issued two Withhold Release Orders against garment factories in Jordan, a U.S. free trade agreement partner. If you diversified out of China, thinking that solved your forced-labor exposure, this action is your wake-up call. Duty-free status is not a compliance shield. For apparel and textile importers, the window to build a defensible admissibility package is now, before a detention notice arrives.

On June 23, 2026, U.S. Customs and Border Protection (CBP) issued two Withhold Release Orders (WROs) against garments produced by Needle Craft Ltd. and Casual Wear Apparel LLC — two garment-manufacturing factories in Jordan. Effective immediately, CBP will detain all garments produced by these two factories at every U.S. port of entry. These are the fifth and sixth WROs of fiscal year 2026, and they push CBP's active enforcement docket to 58 WROs and eight Findings under 19 U.S.C. § 1307.

If you read only one sentence of this post, read this one: the country you moved your sourcing to -- to escape China-related forced-labor risk -- is not safe by virtue of being a U.S. trade-preference partner. Jordan Apparel enters the United States duty-free under the U.S.–Jordan Free Trade Agreement and the Qualifying Industrial Zone (QIZ) framework. That preferential status did nothing to slow this enforcement action — and it will not slow the next one.

The Challenge: Enforcement Has Gone Global, and Diversification Created New Exposure: . . . [More]

11. ECD: "Trump's New Quantum Order Directs US to Coordinate Export, Investment Restrictions with Allies"

(Source: Export Compliance Daily, 24 Jun 2026) [Excerpts of subscription site.]

12. Expeditors News: "CBP Issues WRO on Certain Copper and Garment Manufacturers"

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

In a pair of press releases, U.S. Customs and Border Protection (CBP) announced the issuance of Withhold Release Orders (WROs) against copper and copper products manufactured in Serbia by Serbia Zijin Copper D.O.O. (Serbia Zijin), and against garments produced in Jordan by Needle Craft Ltd. and Casual Wear Apparel LLC.

All three WROs were issued as a result of CBP investigations and reviews of information indicating that these manufacturers use forced labor to produce their goods. CBP will detain shipments of these products at all U.S. ports of entry, effective immediately.

The WRO issued on Serbia Zijin are HERE. The WRO issued on Needle Craft Ltd. and Casual Wear Apparel LLC are HERE. CBP's Withhold Release Orders Dashboard are HERE.

13. Space News: "Boeing Wins $2 Billion Military Satellite Contract"

(Source: Space News, 24 Jun 2026) [Excerpts of subscription publication]

Boeing won a contract worth up to $2 billion to build two next-generation military communications satellites for the U.S. Space Force. The contract announced Tuesday covers the design, development, production and testing of two satellites for the Mobile User Objective System, or MUOS, the military's primary narrowband communications constellation operating in geostationary orbit.

Often described as a cellphone network in space, the system allows users equipped with relatively small terminals to communicate far beyond the reach of terrestrial networks.

Lockheed Martin built the five MUOS satellites currently operating, and competed with Boeing for this contract. . . . [More]

14. ST&R Trade Report: "Importers Have July 10 Deadline to Seek New or Continued China Tariff Exclusions"

(Source: Sandler, Travis & Rosenberg Trade Report, 24 Jun 2026) [Excerpts]. Contact: [email protected], 1-305-894-1035

Importers have until July 10 to submit comments that could yield new or continued reductions in tariffs on imports from China.

The Office of the U.S. Trade Representative opened June 2 a comment period on which non-sensitive products should be eligible for reductions in non-MFN (e.g., Section 301 and Section 232) tariffs when traded between the U.S. and China. USTR is also seeking input on the design of the U.S.-China Board of Trade, which is intended to manage bilateral trade in such goods and related tariff modifications.

Importers already benefiting from any of the relatively few remaining exclusions from the longstanding Section 301 tariffs on imports from China should use this opportunity to seek to make those exclusions permanent. . . . [More]

15. Baker/McKenzie: "Canada Expands Russia Sanctions at G7 Summit"

(Source: Global Sanctions and Export Controls Blog, 24 Jun 2026) [Excerpts]

At the 2026 G7 Leaders' Summit, Prime Minister Carney announced a further expansion of its sanctions regime under the Special Economic Measures (Russia) Regulations (Regulations), effective June 12, 2026. The measures form part of Canada's continuing effort to constrain Russia's military operations and to condemn recent attacks on Kyiv. The amendments list new individuals, entities and vessels in Russia's shadow fleet and repeal obligations held by the Minister of Foreign Affairs in relation to delisting applications.

Expansion of Designations: Individuals, Entities, and Shadow Fleet Actors. The amendments list seven individuals to Part 1 of Schedule 1 and over 30 entities in Part 2 of Schedule 1, targeting Russia's energy revenues, defense-industrial actors, disinformation actors, and shipping participants in Russia's shadow fleet. . . .

The Regulations impose a dealings prohibition against the individuals listed in Schedule 1, effectively freezing any assets they hold in Canada. Specifically, the Regulations prohibit any person in Canada and any Canadian outside Canada from:

Individuals listed are also rendered inadmissible to Canada under the Immigration and Refugee Protection Act. . . . [More]

16. Diaz: "Navigating IEEPA Tariff Refunds: Legal and Compliance Considerations"

(Source: Customs & International Trade Law Blog, 23 Jun 2026) [Excerpts]

The recent Supreme Court decision invalidating tariffs imposed under the International Emergency Economic Powers Act (IEEPA) has 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: . . . [More]

17. ECD: "UK, US Looking to Use Emerging Tech to Reduce Sanctions Implementation 'Burden'"

(Source: Export Compliance Daily, 24 Jun 2026) [Excerpts of subscription site]

The U.S. and U.K. are both hoping to make more use of emerging technologies, including AI, as they implement sanctions, review license applications and receive requests for guidance from industry.

The Office of Foreign Assets Control and the Office of Financial Sanctions Implementation said in a joint note and guidance document released July 23 that they have continued over the last year to work together closely to harmonize and modernize their sanctions regimes. Both said they're looking to make use of new technologies to "reduce the burden of sanctions while meeting increased demands," which may include modernizing systems for applying for licenses, disclosing violations, submitting reports or seeking guidance. . . .

OFAC and OFSI for years have maintained a partnership to share sanctions information and coordinate on enforcement and licensing, which has recently included swapping officials as part of an employee embed program. The two agencies said they last met in January for a weeklong "strategic dialogue" in London, where they discussed how to use their respective authorities to "meet foreign policy and national security demands, such as tightening or lifting sanctions, adopting new technology, and highlighting enforcement efforts." [More]

18. Sheppard: "JCPOA Again? What the New U.S.–Iran MOU Does (and Doesn't) Mean for Sanctions"

(Source: Global Trade Law Blog, 22 Jun 2026) [Excerpts]

This week delivered the kind of headline that had international trade compliance practitioners' heads swimming: a 14-point Memorandum of Understanding ("MOU") between the United States and Iran, aimed at ending hostilities, reopening the Strait of Hormuz, and setting a 60-day clock for negotiating a final deal on Iran's nuclear program and broader sanctions relief.

The signing itself had some flair: President Trump put pen to paper on June 17 at the Palace of Versailles, mid-dinner with French President Macron on the margins of the G7 summit, while President Pezeshkian signed separately and electronically from Tehran. Versailles has hosted history-making documents before; but this one comes with rather more modest aims.

CNN released the official 14-point text on Wednesday. Of those fourteen points, the one that has our practice's keen attention is Point 10, which provides:

"The United States of America undertakes that immediately upon the signing of this MOU and until the termination of sanctions, the U.S. Department of Treasury will issue waivers for the export of Iranian crude oil, petroleum products and derivatives, and all associated services, including banking transactions, insurances, transportation, etc."

That is a lot of relief (on paper)! Not just oil exports, but the banking, insurance, and transportation activity that moves those exports. Point 11 adds that frozen or restricted Iranian funds and assets are to be unfrozen and licensed accordingly. Meanwhile, Point 7 goes further still (I mean, all the way, at least in theory) committing the U.S. to eventually terminating "all unilateral U.S. sanctions, primary and secondary" (!) However, the commitment is tempered somewhat by the caveat that it will be done only "in an agreed-upon schedule as part of the final deal." In other words: someday, not today.

Still, OFAC did not wait long to put the proposal into action. On June 22 — five days after the Versailles signing — Treasury issued General License X ("GL X"), effective immediately and running through August 21, 2026. Point 10's promise of "waivers for the export of Iranian crude oil, petroleum products and derivatives, and all associated services" now has its first implementing instrument. . . . [More]

19. S&W: "Sanctioned by the United States? Mexican Individuals and Companies May Have Options"

(Source: Snell & Wilmer Advisories, 24 Jun 2026) [Excerpts]

U.S. sanctions can have immediate and wide-ranging effects on Mexican individuals and companies, including frozen funds, restricted bank accounts, delayed or rejected wire transfers, loss of access to U.S. dollar transactions, visa problems, terminated commercial relationships, increased scrutiny from business partners, and reputational harm.

OFAC designations often function as global risk events because banks and companies outside the United States may stop doing business with designated parties, especially where cross-border accounts, U.S. dollar payments, travel, or multinational relationships are involved.

A sanctions designation is not necessarily permanent and may be challenged through administrative or judicial processes, including OFAC reconsideration requests, correction of inaccurate information, evidence of changed circumstances, remediation measures, or litigation in U.S. federal court where appropriate.

Responses to a sanctions designation should be strategic because rushed or inconsistent communications with OFAC, banks, counterparties, or other agencies may undermine delisting or litigation options.

Overall, sanctioned Mexican individuals and companies are advised to assess the designation carefully and pursue a coordinated strategy to reduce operational, financial, legal, and reputational harm. [More]

20. Torres: "Old Rule, New Risk: OFAC's 50% Rule and the Growing Importance of Control"

(Source: Torres Insights, 23 Jun 2026) [Excerpts]

When the Office of Foreign Assets Control ("OFAC") sanctions a person or entity by adding that person or entity to OFAC's Specially Designated Nationals and Blocked Persons List, or SDN List, their property, funds, and business interests in the United States are generally frozen, or "blocked," and U.S. persons and businesses are prohibited from doing business with them unless OFAC authorizes the transaction.

Under OFAC's 50% Rule, an entity can also be treated as blocked even if its own name does not appear on the SDN List. The rule applies when one or more blocked individuals or entities, either directly or indirectly, own 50 percent or more of another entity.

For example, if a single blocked person owns 50 percent or more of Company A, Company A is also treated as blocked.

The same rule applies when multiple blocked persons collectively own 50 percent or more of an entity, meaning ownership may be aggregated (even if designated under different sanctions programs).

In either case, the entity is blocked by operation of law, and U.S. persons generally cannot conduct business with it without OFAC authorization. In 2023, Microsoft paid OFAC roughly $2 million after it and certain subsidiaries provided software or services to sanctioned jurisdictions and blocked persons. Microsoft's screening systems failed to identify entities that were not named on the SDN List but were owned 50 percent or more by SDNs.

The rule exists because sanctioned individuals and entities do not always conduct business in their own names. A blocked person may operate through a subsidiary, affiliate, holding company, shared ownership arrangement, or other legal structure involving non-blocked individuals. OFAC established the 50% Rule in 2014 to prevent blocked parties from circumventing sanctions through these indirect business activities.

There are a few important considerations with this rule: . . . [More]

21. Volkov: "The Third-Party AI Blind Spot — The Risk Your Compliance Program Is Not Addressing" (Part 3 of 3)

(Source: Volkov Law, 24 Jun 2026) [Excerpts]

If you read Parts I and II of this series and concluded that the AI governance problem is primarily an internal one — about what your employees do with AI inside your organization — you have only identified half the exposure.

The other half lives outside your walls. It lives in your vendors, your service providers, your agents, your supply chain. And for the vast majority of organizations, it is completely unaddressed. This is the third-party AI blind spot, and it may be the most dangerous AI risk that compliance programs are ignoring today.

The Governance Reality. As organizations race to scale AI, many have relied upon traditional vendor risk management policies to vet third-party AI vendors and tools. However, implementation of third-party AI tools presents distinctive risks that require tailored due diligence, auditing, contracting, and governance.

Because businesses are accountable for outputs generated by third-party AI tools and for vendors' processing of prompts and other business data, boards and management should ensure legal, IT and procurement teams apply a principled, risk-based approach to vendor management that addresses AI-specific considerations. . . . [More]

22. Skill Dynamics Presents a NEW Webinar: "CAPE in Practice: IEEPA Refunds, Importer Visibility & the New Refund Workflow" on 14 July

(Source: Skill Dynamics, previously Content Enablers)

23. List of Export/Import Job Openings

(Source: Editor)

RECENT:

FULL LIST:

24. Bartlett's Unfamiliar Quotations

(Source: Brainy Quotes)

Henry Ward Beecher (24 Jun 1813 – 8 Mar 1887; was an American Congregationalist clergyman, social reformer, and speaker, known for his support of the abolition of slavery.)

Ambrose Bierce (24 Jun 1842 – circa 1914; was an American short story writer, journalist, poet, and American Civil War veteran. Bierce was regarded as one of the most influential journalists in the United States. His book, The Devil's Dictionary was named as one of "The 100 Greatest Masterpieces of American Literature" by the American Revolution Bicentennial Administration.)

Juan Fangio (Juan Manuel Fangio; 24 Jun 1911 – 17 Jul 1995) was an Argentine racing driver. He won five Formula One World Drivers' Championship titles and—at the time of his retirement—held the record for most wins (24), pole positions (29), fastest laps (23), and podium finishes (35), among others.)

25. Today in History

(Source: History Channel)

1948: Soviets blockade West Berlin. The Berlin Blockade was an attempt in 1948 by the Soviet Union to limit the ability of the United States, Great Britain and France to travel to their respective sectors of the city of Berlin, which lay entirely inside Russian-occupied East Germany. The Soviets blocked all rail, road and canal access to the western zones of Berlin. Suddenly, some 2.5 million civilians had no access to food, medicine, fuel, electricity and other basic goods. Western powers began an airlift that lasted nearly a year and delivered vital supplies and relief to West Berlin.

1997: U.S. Air Force reports on Roswell UFO incident. On June 24, 1997, U.S. Air Force officials release a 231-page report dismissing long-standing claims of an alien spacecraft crash in Roswell, New Mexico, almost 50 years earlier. The town of Roswell became a magnet for UFO believers due to the strange events of early July 1947, when ranch foreman W.W. Brazel found a strange, shiny material scattered over some of his land. He turned the material over to the sheriff, who passed it on to authorities at the nearby Air Force base. On July 8, Air Force officials announced they had recovered the wreckage of a "flying disk." A local newspaper put the story on its front page, launching Roswell into the spotlight of the public's UFO fascination.

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

(Source: Editor)

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27. 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.