26-0826: Wednesday's "Export/Import Daily Bugle"

(Source: 91 FR 55170, 26 Aug 2026)

(Source: 91 FR 54957, 26 Aug 2026)

(Source: Future Federal Register)

(Source: DHS/CBP/CSMS)

(Source: OTR Webinars) (All times Eastern)

(Source: OTR Webinars) (All times Eastern)

Questions: Email [email protected].

(Source: Commerce/BIS)

(Source: State/DDTC)

(Source: Treasury/OFAC, 26 Aug 2026)

     The Department of the Treasury's Office of Foreign Assets Control (OFAC) is issuing Counter Terrorism General License 36, "Authorizing the Wind Down of Transactions Involving Autistici Inventati."
     Additionally, OFAC is issuing Russia-related General License 104B, "Authorizing Transactions Related to Imports of Certain Diamonds Prohibited by Executive Order 14068."
     The SDN list has recently been updated. Visit this page to access the latest version of the SDN list. Visit this link for more information.

(Source: The White House)

(Source: Breaking Defense News, 26 Aug 2026) [Excerpts]

     The US Army has whittled down its nuclear microreactor vendor pool, divvying up to $2.2 billion to five companies to build out and test their prototypes for eventual use on military installations. . . .
     As of today, the service has tapped five companies to continue working on their respective microreactor designs with the goal of having them deliver more than 20 microreactors to Army installations and then be contractor owned and operated:

     Waksman explained that each of the five companies now has a unique Other Transaction Authority-based agreement for a share of that $2.2 billion pot that will be spent between fiscal 2027 and 2031.

. . . [Full article]

(Source: Customs & International Trade Law Blog, 26 Aug 2026) [Excerpts]

* Author: Jennifer Diaz, Esq., Diaz Trade Law LLP

     The Committee on Foreign Investment in the United States ("CFIUS" or the "Committee") has released its Annual Report to Congress for calendar year 2025 --- marking the Committee's 50th year of operation.
     The Report confirms that CFIUS remains an active and increasingly assertive gatekeeper for foreign investment in the United States, even as the Committee absorbed significant operational disruption in 2025 from lapses in federal appropriations that tolled statutory deadlines for more than 120 days over the course of the year.
     This alert distills the CY 2025 Report --- and the Committee's own year-over-year comparisons --- into the trends most relevant to companies and investors planning transactions that may fall within CFIUS jurisdiction.
     Two developments stand out. First, the President issued prohibition and forced-divestment orders of a U.S. business in two transactions in 2025, continuing a pattern (also seen in 2024) that had been dormant since 2020; this is CFIUS's most severe remedy, and its reappearance in back-to-back years is a meaningful signal for deals in sensitive sectors.
     Second, and directly relevant to parties that conclude a transaction does not warrant a voluntary filing, CFIUS's non-notified transaction program continued to convert unfiled deals into mandatory filing demands --- formally requiring nine parties to submit a declaration or notice in 2025 after Treasury investigated 90 potential non-notified transactions and opened 62 official inquiries.
     Below, we summarize the key figures from the CY 2025 Report to help clients calibrate risk, timing, and filing strategy: . . . [Full article]

(Source: Expeditors News, 25 Aug 2026) [Excerpts]

     In a press release published on August 24, 2026, the Office of Foreign Assets Control (OFAC) announced a new series of sanctions against Iran.
     The expanded sanctions programs apply to Iran's aviation, digital asset, gold, shipping, and technology economic sectors, the addition of dozens of new entities to OFAC's Specially Designated Nationals (SDN) list, and an indefinite suspension of multiple Iran-related general licenses.
     The suspended general licenses will be granted a "wind down" period until September 8, 2026, of transactions that were previously allowed. OFAC's press release and links to the specific determinations are HERE.

(Source: Sandler, Travis & Rosenberg Trade Report, 26 Aug 2026) [Excerpts]. Contact: [email protected], 1-305-894-1035

     In the Aug. 19, 2026, Customs Bulletin and Decisions, U.S. Customs and Border Protection is revoking a ruling regarding the country of origin of finished leather hides, effective with respect to goods entered or withdrawn from warehouse for consumption on or after Oct. 18.
     The items at issue are bovine leather imported as whole hides that are approximately 45 to 55 square feet each. The leather is mainly sourced from the U.S., Germany, Sweden, Australia, Great Britain, and Brazil. The hides sourced from Brazil are processed there from raw hide to wet-blue state and then shipped to Vietnam to undergo further processing into finished upholstery leather used in the manufacture of furniture. . . .
     However, CBP now finds that the processing in Vietnam is cosmetic in nature and akin to finishing operations, which prior rulings have held do not constitute a substantial transformation.
     CBP is issuing ruling HQ H355209 to revoke ruling NY N310029 and hold that the country of origin of the finished leather hides is Brazil. [Full article]

(Source: Washington Tariff & Trade Letter, 24 Aug 2026) [Excerpts of subscription publication]

     Federal prosecutors are gaining a more direct route to the information importers submit to U.S. Customs and Border Protection.
     The Justice Department's Trade Fraud Task Force, established with the Department of Homeland Security in August 2025, joins DOJ civil and criminal attorneys with CBP and Homeland Security Investigations. Its purpose is to improve information sharing and coordinate cases involving tariff evasion, transshipment, false country-of-origin claims, undervaluation and other customs violations.
     The task force does not give prosecutors new subpoena powers or automatically turn errors on customs forms into criminal cases. It does make it easier for CBP records and agency expertise to be used in False Claims Act investigations, criminal prosecutions and parallel enforcement proceedings.
     When DOJ announced the task force, officials specifically cited plans for closer coordination and information sharing with CBP and HSI. The agencies' July 2026 Resource Guide to Trade Fraud Enforcement further explains how customs violations may lead to administrative penalties, civil liability or criminal charges. . . .

[Full article]

(Source: The Export Practitioner, 24 Aug 2026) [Excerpts of paywall publication.]

     The U.S. Treasury Department has expanded its Iran sanctions program to cover five additional sectors of the Iranian economy and added more than 60 individuals, companies and vessels to its sanctions lists.
     The measures open an administration campaign called "Operation Economic Outcast." They affect exporters, importers, financial institutions, freight forwarders, shipowners, insurers, universities and other organizations with direct or indirect exposure to Iran.
     Treasury Secretary Scott Bessent presented the campaign in military terms, comparing its launch to the Allied invasion of Normandy and calling it an "economic onslaught" intended to "sever every economic lifeline" sustaining the Iranian government.
     His prepared remarks combined details of the sanctions program with repeated praise for President Donald Trump. Bessent said Trump had acted where previous presidents had hesitated and declared: "Under his leadership, America is no longer managing the Iranian threat. We are ending it." . . .
     Bessent said countries supporting Washington would "reap the rewards of our partnership," while those maintaining ties with Tehran should expect to share in its isolation.
     The language signaled that the administration intends to use access to U.S. markets and the dollar system as leverage over governments and companies outside the United States. Bessent said every country would receive a deadline to end specified Iran-related activity and warned that any entity facilitating Iranian money laundering "will be removed from the U.S. dollar system." . . .
     [Full article]

(Source: Sandler, Travis & Rosenberg Trade Report, 26 Aug 2026) [Excerpts]. Contact: [email protected], 1-305-894-1035

     Recent developments within the Department of Justice further highlight a strengthening, and increasingly institutionalized, federal focus on trade and customs enforcement efforts.
     In early 2025 the DOJ announced that its Criminal Division's enforcement priorities for prosecuting corporate and white-collar crimes would include "trade and customs fraudsters, including those who commit tariff evasion." The DOJ subsequently put teeth into that effort by launching a revitalized interagency Trade Fraud Task Force with "a nationwide mandate to investigate and prosecute trade fraud and related cases."
     The DOJ then announced in April 2026 (and formally established as of Aug. 24) the National Fraud Enforcement Division, which will consolidate and prioritize efforts to prosecute fraud involving public trust and financial integrity, health care, internal revenue, global trade and commerce, and corporate misconduct. An Aug. 13 DOJ memo said this division would have about 500 attorneys as of Aug. 24 and "will continue to rapidly grow for the next two years."
     With respect to trade, the memo said the Fraud Division "will lead the Department's coordinated criminal enforcement strategy, targeting trade and customs violations and supply chains polluted by forced labor." Prosecutors will focus on "systemic, high-impact noncompliance that threatens our economic and national security," including by "prioritizing the investigation and prosecution of illicit transshipment schemes, country-of-origin fraud, the undervaluation of imported goods designed to evade duties, sanctions evasion, and foreign forced labor schemes." . . .[Full article]

(Source: Volkov Law, 26 Aug 2026) [Excerpts]

* Principal Author: Michael Volkov, Volkov Law Group LLC

     BIS just settled with Container Manufacturing, an Ohio-based maker of tops for aluminum beverage cans, for $1 million over ten violations of U.S. export controls tied to Russia.
     On the surface, this looks like a modest regional manufacturer case involving unglamorous industrial spare parts. Underneath, it's one of the clearest illustrations I've seen this year of a principle every compliance officer needs to internalize: a restricted-party list screening that comes back clean does not end your due diligence obligation, and ignoring red flags that surface after that screening is itself a violation, independent of whatever the screening result showed.
     The Underlying Facts: Container Manufacturing had a business relationship going back to 2015 supplying spare and replacement parts for aluminum metalworking tools to the Russian subsidiary of a U.S.-based company.
     That relationship changed character in 2022, after Russia's invasion of Ukraine, when the U.S. parent sold its Russian subsidiary to a Russian buyer. Container Manufacturing kept shipping the same parts to the same operation under its new Russian ownership, including shipments in and after March 2023, right after those parts became subject to significantly stricter licensing requirements as part of the broader post-invasion controls regime.
     The parts themselves were classified as EAR99, generally the least restrictive classification under the Export Administration Regulations, and became newly controlled for Russia and Belarus destinations under specific Harmonized Tariff Schedule codes covering metalworking machine parts and certain gaskets and washers, once BIS added Russia and Belarus-specific licensing requirements in February and May of 2023. . . .
     Where This Case Gets Genuinely Instructive: The Red Flags.
     The more serious violations, from BIS's telling, came from what happened after the company's own bank raised concerns.
     Around December 2024, Container Manufacturing's bank declined to process wire payments connected to these exports, citing the Russia embargo directly. That is about as unambiguous a red flag as a company can receive, a financial institution refusing to move money specifically because of Russia sanctions exposure. Container Manufacturing did follow up:
     it contacted the bank and sought clarification from outside counsel. But according to BIS, the company never actually resolved the underlying red flag, and it kept dealing with the Russian company anyway.
     What happened next is the part of this case worth reading closely, because it shows exactly how sanctions evasion schemes get built around a cooperating counterparty's own inaction: . . . [Full article]

(Source: A.E. NicPhaidin)

20. List of Export/Import Job Openings

(Source: Editor)

(Source: Brainy Quotes)

(Source: History Channel)

1883 -- The volcano Krakatoa began its catastrophic eruption in Indonesia, one of the deadliest and most explosive volcanic events in recorded history. Over 36,000 deaths were attributed to the eruption and the tsunamis it created. Some broader estimates range as high as 100,000 when including longer-term effects like disease and starvation in the aftermath.

1920 -- The 19th Amendment to the U.S. Constitution was certified, on 26 August 1920, granting women the right to vote. This day is now commemorated annually as Women's Equality Day in the U.S.

24. 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.

25. 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.