26-0724: Friday's "Export/Import Daily Bugle"

1. State Debars 14 Persons for Export Violations

(Source: 91 FR 46821, 24 Jul 2026) [Excerpts]

2. Future Federal Register

(Source: Future Federal Register)

3. CBP Cargo Systems Messages

(Source: DHS/CBP/CSMS)

4. CBP Events in August 2026

(Source: OTR Webinars)

5. Commerce/BIS (Nothing new.)

(Source: Commerce/BIS)

6. OMB/OIRA DDTC Reviews: Proposed Revisions to ITAR Parts 120, 121, and 126

(Source: OMB Office of Information and Regulatory Affairs)

7. State/DDTC: Problems with Outgoing DECCS Email Resolved

(Source: State/DDTC, 24 Jul 2026)

This issue has been resolved. All queued emails began this morning, July 24, 2026. Users may receive delayed emails as well as duplicates of those emails. Please review any delayed emails to determine if action is needed; if not, they may be disregarded. Contact the Help Desk at 202-663-2838 if help is needed.

8. Treasury/OFAC Posts General License and FAQs; Issuance of Amended Venezuela-related FAQs; Publishes Regulatory Amendments

(Source: Treasury/OFAC, 24 Jul 2026)

The Department of the Treasury's Office of Foreign Assets Control (OFAC) is issuing Russia-related General License 131H, "Authorizing Certain Transactions for the Negotiation of and Entry Into Contingent Contracts for the Sale of Lukoil International GmbH and Related Maintenance Activities."
     Additionally, OFAC is amending two associated, Russia-related Frequently Asked Questions, FAQs 1224 and 1225. OFAC is also amending Venezuela-related Frequently Asked Question FAQ 1239.
     The Department of the Treasury's Office of Foreign Assets Control (OFAC) is adopting a final rule to update website and contact information in certain parts of the Code of Federal Regulations (CFR).
     OFAC is amending one CFR part to update general licenses authorizing payments for legal services from funds originating outside the United States to replace the reporting requirement in the general license with a recordkeeping requirement and correcting typographical errors in two CFR parts. OFAC is also updating a part of 31 CFR chapter V to correct an erroneous cross-reference.
     OFAC has also updated the Specially Designated Nationals and Blocked Persons List.

9. White House Executive Actions (No items of interest.)

(Source: The White House)

10. Breaking Defense: "'Easier access': US export change for the UAE to boost Emirati drones, AI tech"

(Source: Breaking Defense News, 24 Jul 2026) [Excerpts]

BEIRUT — Washington's recent decision to significantly ease export controls for the UAE should give a boost to the Emirates' domestic production of high-tech drones and other military hardware, thanks to more available dual-use tech like computer chips, analysts told Breaking Defense.
     The US Commerce Department announced on July 10 that the Emiratis will be upgraded to the A:5 export country group, making the UAE the first Arab state — and the second Middle Eastern state after Israel — to be granted the coveted status.
     "They'll have much cleaner and easier access to dual-use technology and other technologies with defense implications," Michael Horowitz, a former senior Pentagon official who teaches at the University of Pennsylvania, told Breaking Defense. "While munitions are governed by the US munitions list, controlled by the State Department, the decision by the Commerce Department will make UAE access to American technology substantially easier." . . .
     The Commerce announcement also specifically cited the benefits for the UAE when it comes to AI. Vidal also said the new status will replace "case-by-case approvals of advanced chips sales for license-free access, for both the UAE government and G42, which will accelerate the country's AI ambitions." . . . [Full article]

11. Expeditors News: "USTR Announces Forced Labor Enforcement Section 301 Tariffs"

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

In a press release on July 23, 2026, the Office of the United States Trade Representative (USTR) announced the imposition of tariffs on 60 economies "for their failure to impose and effectively enforce a prohibition on the importation of goods produced with forced labor."

The following Section 301 duty rates will apply:

These duties will apply to covered goods that are entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. Eastern Time on July 24, 2026.
     Goods that were loaded onto a vessel at the port of loading and were in transit on their final mode of transportation before the effective date will be exempt from these duties, provided they are entered for consumption or withdrawn from a warehouse for consumption, before 12:01 a.m. Eastern Time on July 28, 2026. USTR's press release are HERE.

12. Global Trade: "Canada Slams New US Tariffs as Trade Agreement Violation"

(Source: Global Trade, 24 Jul 2026) [Excerpts]

Canada has characterized the Trump administration's fresh 50% tariffs as a direct breach of trade pacts. Starting Friday, the administration will enforce new duties of 10% and 12.5% on goods from 60 trade partners, coinciding with the expiration of a short-term global tariff.
     This follows a February Supreme Court decision that invalidated President Donald Trump's earlier reciprocal tariffs, which ranged from 10% to 50% and were enacted last year. In response, Trump had introduced a temporary 10% global tariff under Section 122 of the Trade Act of 1974, set to lapse at 12:01 a.m. ET on Friday. . . . [Full article]

13. Space News: "Office of Space Commerce to Move Ahead on Mission Authorization"

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

The Commerce Department is moving ahead with plans to implement a voluntary mission authorization system for novel space activities that are not regulated by other agencies.
     In a July 23 statement, the Office of Space Commerce, or OSC, said it was "taking the next step forward" on its plans to offer certification to companies proposing space activities not currently overseen by OSC, the Federal Aviation Administration or the Federal Communications Commission.
     "After months of effort working with partners and stakeholders in industry, the U.S. federal government and the White House, OSC is making the next giant leap on mission authorization," the office stated.
     The office rolled out its mission authorization proposal, called Space Commerce Certification, in March. Under that voluntary scheme, companies would submit information about their proposed activities to OSC, which would then coordinate an interagency review. The system would operate under a "presumption of approval," meaning that applications would be automatically granted in 120 days if the office took no action.
     OSC did not disclose what prompted the agency to move ahead with Space Commerce Certification. However, at a July 15 hearing of the House Science Committee's space subcommittee, Taylor Jordan, director of the office, said he was awaiting a White House decision on the proposal. . . .
     [Full article]

14. ST&R Trade Report: "Court Upholds FMC Ruling Against Carrier Detention Fees"

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

The Federal Maritime Commission reports that the U.S. Court of Appeals for the D.C. Circuit recently upheld the FMC's determination that detention fees levied on a trucker by an ocean common carrier during a three-day port closure were unreasonable.
     According to an FMC press release, this case concerned detention fees issued to a trucker for its late return of a shipping container and chassis when a port was closed over a holiday weekend and the trucker had no practical ability to return the equipment to the port before the closure. The FMC had thus concluded, by applying its interpretive rule on detention and demurrage, that these fees did not effectively incentivize freight fluidity. It also determined that none of the carrier's explanations justified the fees under the circumstances of the case and that the carrier had not provided sufficient evidence about its costs related to the late equipment return. . . . [Full article]

15. Sheppard Mullin: "Choosing Between U.S. and Chinese AI Models: The Export Control Risks on Both Sides"

(Source: Global Trade Law Blog, 23 Jul 2026) [Excerpts]

* Principal Author: Jordan Mallory, Sheppard, Mullin Richter & Hampton LLP

At the G7 summit in June, over a lunch attended by President Trump and the chief executives of Anthropic and OpenAI, President Macron warned that if the United States "from one day to the next can turn off the switch," it would damage not only the economies building on American AI, but also the American AI companies themselves.
     He was not speaking hypothetically.
     On June 12, the Commerce Department used export controls to order Anthropic to suspend access to its newest frontier AI models, Fable 5 and Mythos 5, just days after their release. The order came not as a rule or a published directive but as an unpublished letter requiring export licenses before the models could be made available to any foreign person worldwide, reportedly invoking the Export Control Reform Act and the EAR's military-intelligence end-use controls.
     A follow-up letter on June 26 carved out "certain trusted partners," and access to Fable returned on July 1 with additional safeguards, while Mythos remains limited to approved U.S. institutions. Nothing about the episode ever appeared in the Federal Register. For three weeks, the most capable AI models ever released were switched off for most of the planet, and the switch was flipped by a letter.
     Meanwhile, the Chinese labs keep shipping. On July 16, Moonshot AI released Kimi K3, which became the first Chinese model to top a major coding leaderboard ahead of both Fable 5 and GPT-5.6; Moonshot has promised to open source full model weights by July 27. That release follows Z.ai's GLM-5.2, released mid-June with open weights under an MIT license, which NIST's own AI evaluators judged "probably the most capable open-weight AI model" at its release. . . .

[Full article]

16. Sidley Austin: "New Section 301 Tariffs Went Into Effect This Morning (July 24, 2026)"

(Source: Author, 24 Jul 2026) [Excerpts]

* Author: Ted Murphy, Esq., [email protected]; Sidley & Austin LLP

As was widely expected, the Office of the United States Trade Representative (USTR) announced yesterday afternoon that new Section 301 tariffs will go into effect Friday, July 24, 2026 (the same day the 10% Section 122 tariffs the administration imposed after the U.S. Supreme Court struck down the IEEPA tariffs back in February expire; but that is just a coincidence . . . ). A copy of the USTR's press release is available here and an advance copy of the Federal Register notice is available here.
     These new tariffs are being imposed pursuant to a Section 301 investigation that sought to determine whether 60 countries have imposed, and effectively enforced, a legal prohibition on the importation of goods produced with forced labor (i.e., do these countries have a law like our 19 U.S.C. §1307 that is enforced as effectively as U.S. Customs and Border Protection does?).
     Back in June, the USTR determined that the 60 countries do not. Specifically, the USTR determined that some countries may have such a law, but they do not effectively enforce it; and other countries do not have such a law. In order to get these countries to change their actionable policies and practices, the USTR proposed imposing additional tariffs. . . .

Specifically, the USTR has determined that:

The USTR has also determined to exempt a number of articles from these tariffs. The exemptions are for articles determined to be: . . .
     The USTR also determined that a tariff-rate quota (TRQ) to allow a certain volume of textiles and apparel produced in Bangladesh, Cambodia, Indonesia and Malaysia to be imported into the United States free of this new Section 301 duty was appropriate. The TRQ is based on the country's importation of U.S. cotton.
     Given that these new tariffs go into effect tomorrow, we recommend that all companies review the attached notice, and the annexes in particular. We also recommend that you review the guidance U.S. Customs and Border Protection issued shortly after the notice was issued. [Full article]

17. Snell & Wilmer: "Importers Beware: Trade Fraud Task Force Surpasses $1 Billion in Enforcement Recoveries"

(Source: Snell & Wilmer advisory, 23 Jul 2026) [Excerpts]

* Principal author: Brett W. Johnson, Snell & Wilmer, LLP

On July 14, 2026, the U.S. Department of Justice (DOJ) announced that the Trade Fraud Task Force (TFTF), a joint initiative with the U.S. Department of Homeland Security (DHS) and the U.S. Customs and Border Protection (CBP), surpassed $1 billion in penalties less than one year after its launch.
     DOJ described the milestone as reflecting a "fundamental shift" in customs enforcement from administrative penalties toward civil and criminal accountability.
     As such, stakeholders in the global supply chain (at any tier) should consider this development and the significant governmental resources dedicated to international trade compliance to evaluate ongoing operations, potential updates to policies and procedures, and consideration of voluntary disclosures of past wrongdoing to mitigate past and future risks.
     These considerations are particularly significant as companies search for ways to reduce or mitigate growing tariff exposure and uncertainty. Legitimate tariff-mitigation strategies remain available.
     But strategies based on false country-of-origin declarations, sham manufacturing operations, unsupported classifications, undervaluation, or other inaccurate entry information can result in far more than a CBP penalty.
     They can lead to False Claims Act (FCA) liability, criminal prosecution, forfeiture, and debarment from federal contracting. . . . [Full article]

18. Steptoe: "Navigating US Border Searches of Electronic Devices: Practical Guidance for Chinese Companies and Employees"

(Source: Steptoe Alerts, 24 Jul 2026) [Excerpts]

* Principal Author: Wendy Wysong, Steptoe LLP

US Customs and Border Protection (CBP) has broad authority to search electronic devices at US borders, including land crossings, international airports, and seaports, without a warrant and, in many instances, without probable cause or even reasonable suspicion.
     This authority derives from the "border search exception" to the Fourth Amendment, which the Supreme Court has long recognized as permitting warrantless and sometimes suspicionless inspections of luggage and electronic devices at these locations. . . .
     Given the increase in electronic device searches at US borders, multinational companies should carefully assess the information stored on employees' devices when traveling to or from the United States.
     Even a single, poorly timed search of an executive's laptop, particularly one containing years of sensitive corporate data, can create significant legal and business risks. Companies should therefore take proactive steps to prepare for the possibility of device searches and seizures.
     This article provides an overview of the types of electronic device searches that business travelers may encounter at US borders and airports. It also offers practical guidance on responding to such searches and protecting sensitive information. . . . [Full article]

19. Troutman: "Carrots and Sticks: Aluminum Tariff Breaks and Tougher Defense Sourcing Rules"

(Source: Troutman Pepper Locke, 22 Jul 2026) [Excerpts]

* Author: Ryan Last, Troutman Pepper Locke LLP

Key Points

[Full article]

20. Volkov: "A Seat at the Table: Why Your CCO Should Report to the CEO"

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

* Principal Author: Michael Volkov, Volkov Law Group LLC

Every so often, corporate governance debates that we thought were settled come roaring back. The reporting line for the chief compliance officer is one of them. For years, the trend line pointed in the right direction — more companies elevating the CCO to report directly to the CEO, with independent access to the board. Lately, I am seeing troubling signs of backsliding, with companies quietly tucking the compliance function back under the general counsel. This is a mistake, and boards should recognize it as such.
     Let's go back to first principles. Where the CCO reports is not an org-chart technicality. It is the single clearest signal a company sends — to regulators, to employees, and to itself — about what compliance means inside the organization.
     Structure Is Strategy. A CCO who reports to the CEO sits at the leadership table. He or she hears business strategy as it is being formed, not after decisions are made. Compliance considerations get built into new market entries, acquisitions, product launches, and third-party relationships at the design stage — where risk mitigation is cheap — rather than bolted on afterward, where it is expensive and often ineffective.
     A CCO buried two or three layers down in the legal department hears about the deal when the documents arrive for review. By then, the strategic choices have been made, and compliance is reduced to a cleanup function. That is not a compliance program; that is a compliance afterthought. . . . [Full article]

21. List of Export/Import Job Openings

(Source: Editor)

23. Bartlett's Unfamiliar Quotations

(Source: Brainy Quotes)

* Simon Bolivar (Simón José Antonio de la Santísima Trinidad Bolívar y Palacios Ponte-Andrade y Blanco; 24 Jul 1783 – 17 Dec 1830; was a Venezuelan military and political leader who led what are currently the countries of Venezuela, Bolivia, Colombia, Ecuador, Peru, and Panama to independence from the Spanish Empire.)

- "Nothing is so dangerous as to permit the same citizen to remain in power for a long time."

* Alexander Dumas (born Dumas Davy de la Pailleterie; 24 Jul 1802 – 5 Dec 1870; was a French writer. Many of his historical novels of high adventure were originally published as serials, including The Count of Monte Cristo, and The Three Musketeers. His novels have been adapted since the early twentieth century into nearly 200 films.)

- "A person who doubts himself makes his failure certain by himself being the first person to be convinced of it."

- "It is almost as difficult to keep a first class person in a fourth class job, as it is to keep a fourth class person in a first class job."

- "It is rare that one can see in a little boy the promise of a man, but one can almost always see in a little girl the threat of a woman."

- "All generalizations are dangerous, even this one."

Friday Funnies:

Some incorrect myths:

24. Today in History (Source: History Channel)

1847: Brigham Young and Mormon pioneers arrived in the Salt Lake Valley, laying the foundation for Salt Lake City, Utah.

1911: American explorer Hiram Bingham brought international attention to the ancient Incan city of Machu Picchu in Peru.

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

(Source: Editor)

Don't miss an issue of the Daily Bugle if you change your email. Click here to manage your profile.

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.