26-0625: Thursday's "Export/Import Daily Bugle"

1. President's Executive Order Establishes National Quantum Strategy

(Source: 91 FR 38487, 25 Jun 2026)

2. President's Executive Order Establishes Policy to Transition Government Systems to Post-Quantum Cryptography (PQC) Standards

(Source: 91 FR 38483, 25 Jun 2026)

3. OFPP, OMB, DoD, GSA, and NASA Seek Comments on Revolutionary Federal Acquisition Regulation Overhaul Parts 1, 2, 4, 33, 39, 40, and 53

(Source: 91 FR 38438, 25 Jun 2026)

4. OFPP, OMB, DoD, GSA, and NASA Seek Comments on Revolutionary Federal Acquisition Regulation Overhaul Parts 6, 7, 10, 18, 26, 37, and 41

(Source: 91 FR 38440, 26 Jun 2026)

5. Future Federal Register (No items of interest.)

(Source: Future Federal Register)

6. CBP: "US, Australia sign Customs Mutual Assistance Agreement"

(Source: DHS/CBP Newsroom, 26 Jun 2026)

U.S. Customs and Border Protection, on behalf of the United States, signed a Customs Mutual Assistance Agreement with Australia on June 25, 2026, in Brussels, Belgium. The CMAA is a bilateral agreement that enables both countries to prevent, detect, and investigate customs-related crimes, support judicial proceedings, enhance cooperation, and facilitate legitimate trade and travel through more efficient enforcement actions. . . .

Once entered into force, the CMAA will allow the United States and Australia to exchange information and provide mutual assistance on customs offenses, thus strengthening the collaboration between the two countries. This agreement reflects the United States' commitment to its relationship and collaboration with Australia on a wide range of issues, including securing the countries' borders against terrorists, combating drug traffickers, and disrupting the operations of transnational criminal organizations.

CMAAs also allow for the sharing of information that is used to assist governments in judicial proceedings involving suspected violations of customs laws. They provide the legal framework for the exchange of information and evidence to assist countries in the enforcement of customs laws, including duty evasion, trafficking, proliferation, money-laundering, and terrorism-related activities. CBP and U.S. Immigration and Customs Enforcement are the implementing agencies for the United States.

7. Commerce/BIS (Nothing new.)

(Source: Commerce/BIS)

8. OMB/OIRA BIS & DDTC Reviews: "Revision of the Countervailing Duty Adverse Facts Available Hierarchy Regulation"; Revision of ITAR/USML Categories IV and XV

(Source: OMB Office of Information and Regulatory Affairs)

9. Senate: "Senators Kennedy and Kim Introduce Bipartisan Bill to Strengthen Penalties for Illegal Exports of Sensitive U.S. Technology"

(Source: Sen. Kennedy Press Office, 25 Jun 2026) [Excerpts]

Sen. John Kennedy (R-La.), a member of the Senate Banking Committee, joined Sen. Andy Kim (D-N.J.) in introducing the Export Control Reform Act of 2018 (ECRA) Penalty Increase Act, bipartisan legislation to strengthen penalties for individuals and companies that violate U.S. export control laws.

The bill would increase civil penalties for unlawfully exporting, re-exporting or transferring sensitive American technology to foreign adversaries and other bad actors. The legislation would help ensure that penalties are strong enough to deter violations involving technology that could threaten U.S. national security. . . .

As the strategic importance and the commercial value of American technology have grown, ECRA's civil penalty structure has not kept pace. The ECRA Penalty Increase Act would modernize those penalties so violations carry real consequences.

The ECRA Penalty Increase Act would:

The full text of the ECRA Penalty Increase Act is HERE.

10. State/DDTC (Nothing new.)

(Source: State/DDTC)

11. UK Export Control Joint Unit: "Changes to UK Armed Forces Export Declarations and Export of Personal Household Items"

(Source: UK ECJU, 24 Jun 2026)

The following notice has force of law by virtue of regulation 14(1) of The Customs (Export) (EU Exit) Regulations 2019

The electronic form specified for the purposes of regulation 14(1)(a) is an export declaration that meets the software requirements for the Customs Declaration Service (CDS), unless one of the following exceptions apply.

For the purposes of regulation 14(1)(b), declarations must be submitted using CDS unless one of the following exceptions apply: . . . [Full notice]

12. ECD: "Lawsuit: US Can't Block Anthropic Models With Export Controls That 'Don't Exist'"

(Source: Export Compliance Daily, 25 Jun 2026) [Excerpts of subscription site.]

An AI technology company is suing the U.S. for what it said was the government's illegal use of export controls against Anthropic, arguing that the move exceeded the bounds of the Export Control Reform Act and could set a dangerous precedent for restrictions over other AI models.

Legion LegalTech, a company that builds AI drafting and case-management tools for lawyers, said the U.S. order "exceeds every source of statutory authority on which it could conceivably rest," including ECRA and the International Emergency Economic Powers Act.

It also said the order was an arbitrary and capricious agency action, asking the U.S. District Court for the District of Columbia to vacate the directive and restore Anthropic customers' access to the company's models.

The June 23 lawsuit, filed against President Donald Trump, Commerce Secretary Howard Luntuck and Bureau of Industry and Security Undersecretary Jeffrey Kessler, is the first official legal challenge against the is-informed letter BIS sent to Anthropic on June 12, which forced the company to suspend access to its Fable 5 and Mythos 5 AI models.

Although BIS specifically told Anthropic it needed an export license only for foreign nationals to access the models, the company said the only way it was able to comply with the order was to close access to those models entirely.

In its lawsuit, Legion said the U.S. called Anthropic on June 12th and gave the company 90 minutes to comply with the order based on an unspecified "national security threat." It said the U.S. gave Anthropic "no further detail concerning the asserted threat." . . . [More]

13. Expeditors News: "CBP Announces Next Phase of CAPE IEEPA Refunds"

(Source: Expeditors News, 24 Jun 2026) [Excerpts]

In a Cargo Systems Messaging Service (CSMS) bulletin published on June 23, 2026, U.S. Customs and Border Protection (CBP) provided updated guidance on new functionality for the Consolidated Administration and Processing of Entries (CAPE) tool in the Automated Commercial Environment (ACE). This functionality, available as of June 29, 2026, allows CAPE to process refunds of International Emergency Economic Powers Act (IEEPA) duties.

With this functionality, CAPE will accept entry types 01, 02, and 06 that have been flagged for reconciliation and for which the entry type 09 reconciliation entry has not been filed. Consistent with CAPE Phase 1, accepted reconciliation-flagged entries will be limited to unliquidated entries and entries within 80 days of liquidation.

Once entries flagged for reconciliation are accepted on a CAPE declaration, the trade may file the reconciliation entry. The CAPE process removes the IEEPA duties from the flagged entries before the reconciliation entry is filed, separating the IEEPA duty refund from the calculations on the reconciliation entry. . . .

If the reconciliation filing deadline is close to expiring, such as less than 30 days, the trade will need to prioritize filing the reconciliation entry. Entries flagged for reconciliation with a reconciliation entry already on file will be included in a future phase of CAPE development. CSMS # 69035485 is HERE.

14. Space News: "Small Satellite Operators Confront Bottleneck to Space Access"

(Source: Space News Archives, 25 Jun 2026) [Excerpts of subscription publication]

For years, small satellite manufacturers have built their business plans around the idea that SpaceX could launch their payload to space. Through its Falcon 9 Transporter and Bandwagon rideshare missions, SpaceX offered frequent, reliable and inexpensive transportation to sun-synchronous and mid-inclination orbits.

But now worry is setting in. At least nine SpaceX partners and customers tell SpaceNews that SpaceX is not accepting Transporter reservations beyond late 2028 or early 2029, and the manifest for the next couple of years is nearly full. Some customers said they expect that SpaceX will extend Falcon 9 rideshares if its super heavy-lift Starship rocket does not come online as quickly as company leaders anticipate. . . .

While secondary payloads can fly with many launch providers, none offer transportation as frequently or inexpensively as SpaceX rideshares, creating uncertainty at a time when manufacturers are producing satellites at a rate faster than launch capability is becoming available. . . .

15. ST&R Trade Report: "Defense Export Regulations to be Revised to Ease Reporting Burden"

(Source: Sandler, Travis & Rosenberg Trade Report, 25 Jun 2026) [Excerpts]. Contact: [email protected], 1-305-894-1035

The State Department's Directorate of Defense Trade Controls is accepting comments through Aug. 14 on a proposed rule that it says would revise the International Traffic in Arms Regulations to modernize, streamline, and standardize reporting on certain political contributions and fees or commissions.

In accordance with the Arms Export Control Act, DDTC requires adequate and timely reporting on political contributions, gifts, commissions and fees paid, or offered or agreed to be paid, (1) in connection with the sale or export of certain defense articles, defense services, and design and construction services, or (2) to or for the armed forces of a foreign country or international organization.

DDTC states that it is now proposing to:

DDTC states that this rule supports the policy directed in Executive Order 14268 to reduce rules and regulations involved in the development, execution, and monitoring of foreign defense sales and arms transfer cases.

16. Braumiller: "Contracts and Purchase Orders in Mexico – Their Role in Demonstrating Customs Compliance and the Substance of Foreign Trade Transactions"

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

Mexico's customs and foreign trade legal framework has evolved toward a stricter and more controlled compliance model. Historically, importers were primarily required to maintain documentation supporting the information declared in the customs entry (pedimento), including invoices, transportation documents, certificates of origin, evidence of compliance with non-tariff regulations and restrictions, and technical and commercial identification of the goods, among other records. Importers were also required to maintain supporting documentation as part of their compliance records.

Recent amendments to Mexico's customs legislation has expanded these obligations to require importers to include additional information and documentation to the electronic file, the electronic value manifest (Manifestación de Valor) and also to share specific documents with the Mexican Customs broker.

In general, the new legal framework requires importers to maintain documentary evidence capable of demonstrating materiality of the operation, including that the transaction exists, is real, verifiable, and has been effectively carried out as declared. . . .

[More]

17. ECD: "Export Controls Against Anthropic Said to Be 'Humongous Own Goal' on US AI Industry"

(Source: Export Compliance Daily, 25 Jun 2026) [Excerpts of subscription site]

The U.S.' export control directive aimed at Anthropic seems legally dubious and undermines American technology competitiveness against China, technology policy analysts and industry officials said this week. The order should be replaced with a normal rulemaking process that doesn't translate into an effective government "kill switch" for certain AI models, they added.

The U.S. reportedly imposed the restrictions against Anthropic's Fable 5 and Mythos 5 due to concerns of a national security threat posed by a jailbreak of at least one of the AI models. But Alex Stamos, chief product officer at Corridor, an AI coding company, said the U.S. order only damages the American AI industry, adding that the administration didn't appear to take into account that foreign AI models have similar capabilities. That includes Chinese AI models, Stamos said, which remain unrestricted. . . .

Kevin Bankston, senior adviser on AI governance for the Center for Democracy & Technology, said the directive was "made hastily based on unclear evidence of a cybersecurity threat with little to no due process." It also was issued "without any apparent clear plan for how long" the restrictions would last or what Anthropic would need to do to lift the controls, he said during the press call. . . .

Shutting down Anthropic's models "while offering no corresponding constraint on foreign or other domestic competitors" only shifts "customers, revenues and influence" to companies outside the U.S., including in China, said Michelle Maldonado, associate director for AI policy with the Information Technology & Innovation Foundation. . . .

Eric Gastfriend, co-founder of Americans for Responsible Innovation, an AI policy nonprofit, said his organization believes the U.S. should be able to restrict or even revoke access to an AI model if there's a threat to national security. But he also said those restrictions must be grounded in evidence, and they should be applied equally across all companies. . . .

18. Sheppard: "Revolutionary FAR Overhaul Update: Rulemaking Phase Begins with the Issuance of Four Proposed Rules"

(Source: Global Trade Law Blog, 25 Jun 2026) [Excerpts]

On June 23, 2026, the Revolutionary FAR Overhaul ("RFO") officially entered the rulemaking phase of the overhaul process with the release of four separate proposed rules (the "Proposed Rules"). Collectively, the Proposed Rules cover 20 parts of the FAR (including Part 52, which contains related clauses and will be updated on an ongoing basis throughout the process). The Proposed Rules are available here: FAR Case 2026-001, FAR Case 2026-002, FAR Case 2026-005, and FAR Case 2026-007. Comments for all four Proposed Rules are due by July 23, 2026. . . .

The first phase of the RFO process involved revising all 53 FAR parts via "model deviations" drafted by the FAR Council. Once the model deviations were published on the acquisition.gov website (note, not formally published in the Federal Register), all executive agencies had 30 days to implement the model deviations by issuing agency class deviations.

The agency deviations adopted the model deviations, making them applicable by agency. Our analysis of the deviations is available in our FAR Overhaul Tracker. Once adopted by agencies, the language in the deviations became effective as a temporary stopgap while the FAR Council considered feedback (nearly 1,600 comments) and began the process of drafting proposed rules.

Where Are We Now? With the June 23, 2026 publication in the Federal Register, we've now entered Phase 2 of the overhaul process – the official rulemaking phase – where the FAR Council will eventually publish all FAR Parts as proposed rules, solicit feedback from industry, and then (we suppose) issue final rules.

The FAR Council will release a series of 12 proposed rules in total, covering the entire FAR. As described in more detail below, each proposed rule will cover several FAR Parts. To its credit the FAR Council has published a useful resource, organized by proposed rule (i.e., FAR Case) that highlights major changes incorporated into the proposed rules based on feedback the FAR Council received in response to each FAR Part deviation. This resource will be updated continuously as the rulemaking continues.

The First Four Proposed Rules. So, what do these first four Proposed Rules cover? We're glad you asked! Below we provide a high-level overview of what is covered in each Proposed Rule, and here's a handy table: [More]

19. ST&R Trade Report: "Importers May be Able to Avoid Section 301 Tariffs on Forced Labor Policies"

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

The Office of the U.S. Trade Representative has proposed additional tariffs of 10-12.5 percent on imports from 60 economies following Section 301 investigations into the measures they have taken to prohibit imports of goods produced with forced labor. These additional tariffs would be imposed on all products except those listed in annex A to this notice.

These exceptions include (1) all articles and parts currently subject to section 232 tariffs, (2) raw materials that, if subject to the proposed tariffs, could lead to the unavailability of domestic supply, (3) products that could cause economy-wide disruptions if subject to the proposed tariffs, (4) certain products that cannot be grown or produced in sufficient quantities in the U.S. or obtained from other sources, (5) informational materials (e.g., books), donations, and accompanied baggage, and (6) articles for which additional tariffs may not contribute substantially to the elimination of the investigated acts, policies, and practices.

STR has identified two other potential exceptions to the anticipated tariffs:

Companies meeting either of these additional criteria, or any of those listed by USTR, should therefore submit by the July 6 deadline comments seeking exemptions from the forced labor tariffs. They may also wish to participate in a public hearing scheduled for July 7.

20. Volkov: "5 Keys to Effective Trade Compliance (Part 1)"

(Source: Volkov Law, 25 Jun 2026) [Excerpts]

What separates effective trade compliance programs from ineffective ones? It starts at the top. Good, bad, or ugly, it all trickles down from the top. Here are the five keys to an effective trade compliance program. The first two are building blocks for leadership and due diligence.

[Listen to "5 Keys to Effective Trade Compliance (Part 1) -- Corruption Crime & Compliance" podcast HERE.]

21. ACI Presents: ACI's "EAR Compliance & Licensing Masterclass + ITAR Week" (Virtual Series, 13 - 31 July)

(Source: Shannon Kao, ACI)

22. List of Export/Import Job Openings

(Source: Editor)

23. Bartlett's Unfamiliar Quotations

(Source: Brainy Quotes)

Antoni Gaudi (Antoni Gaudí i Cornet; 25 Jun 1852 – 10 Jun 1926; was a Spanish architect known as the greatest exponent of Catalan Modernism. Gaudí's works have a highly individualized, one-of-a-kind style. Most are located in Barcelona, including his main work, the church of the Sagrada Família.)

George Orwell (Eric Arthur Blair; 25 Jun 1903 – 21 Jan 1950), known by his pen name George Orwell, was an English novelist, essayist, journalist, and critic. His work is characterized by lucid prose, biting social criticism, opposition to totalitarianism, and outspoken support of democratic socialism. Orwell is best known for the allegorical novella Animal Farm and the dystopian novel Nineteen Eighty-Four.)

Earl Shorris (25 Jun 1936 – 27 May 2012; was an American author and social critic. Shorris was a child prodigy, attending the University of Chicago on scholarship at age 13. Shorris published extensively on Mexico and Mexican history, and was awarded the National Humanities Medal. His many books include Power Sits at Another Table and Other Observations on the Business of Power.)

24. Today in History

(Source: History Channel)

1876: Battle of the Little Bighorn, commonly referred to as Custer's Last Stand. Native American forces led by Sitting Bull and Crazy Horse defeated the U.S. 7th Cavalry, a force of 700 men commanded by Lieutenant Colonel George Armstrong Custer suffered a major defeat. Custer was killed, as were two of his brothers, his nephew, and his brother-in-law. The total U.S. casualty count included 268 dead and 55 severely wounded (six died later from their wounds). Only 30 to 60 Native Americans were killed.

1950: Korean War begins. The Korean War (25 June 1950 – 27 July 1953) was an armed conflict fought on the Korean Peninsula between North Korea (Democratic People's Republic of Korea; DPRK) and South Korea (Republic of Korea; ROK) and their allies. North Korea was supported by China and the Soviet Union, while South Korea was supported by the United Nations led by the United States under the auspices of the United Nations Command. It ended with an armistice (ceasefire) on July 27, 1953, not a peace treaty. Korea remains divided today; North Korea (communist), and South Korea (democratic).

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

(Source: Editor)

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26. 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.