TABLE OF CONTENTS
FEDERAL REGISTER
Commerce/BIS Corrects Typographical Error EAR Part 774
State Amends ITAR 121 § Cat XI to Extend Temporary Modification of USML Category XI(b)
State Amends ITAR § 120.54 and 121.1 to Remove Certain Civil Aircraft from the USML and to Exclude from the ITAR Certain Activities that Would Otherwise Meet the Definition of Reexport; Requests Comments
Future Federal Register
OTHER U.S. GOVERNMENT SOURCES
CBP Cargo Systems Messages
CBP OTR Events in August-September 2026
Commerce/BIS
State/DDTC
Treasury/OFAC Updates List of Specially Designated Nationals (SDN) and Blocked Persons
UK Export Control Joint Unit Strategic Export Controls: Licensing Statistics (1 Jan to 31 Mar 2026)
White House: "President Establishes a Commission to Design the United States Space Academy"
NEWS
Expeditors News: "CBP to Verify Form 5106 Information, Penalize Inaccuracies"
Space News: "SpaceX to Develop Starship Launch Site in Louisiana"
ST&R Trade Report: "Import Duties on Beef Lowered for Three Months"
ST&R Trade Report: "CBP Expands Jurisdiction in Waters Off Southern Borders"
Tech Times: "BIS Investigates Apex Logistics over Nvidia Servers: First Freight Forwarder Targeted
OPINION
Baker/McKenzie: "US Rescinds Syria's State Sponsor of Terrorism Designation and Delists Hay'at Tahrir al-Sham"
Breaking Defense: "How the Commerce Department Plans to Win More Foreign Defense Sales"
Diaz: "Getting Off the SDN List: A Practical Guide to OFAC's Administrative Reconsideration Process"
Husch Blackwell: "Executive Order and Forthcoming Rules Will Restrict U.S. Imports and Installations of Foreign Bulk-Power System Equipment"
KPMG: "U.S. State Department Removes Certain Survivability-Enhanced Aircraft from U.S. Munitions List Controls"
Volkov: "Veloxis Pharmaceuticals' $46 Million Kickback Settlement: A CEP Case Study Worth Studying Closely"
EX/IM MOVERS & SHAKERS
List of Export/Import Job Openings
EDITOR'S NOTES
Do You Have Access to the Latest and Greatest ITAR and FTR?
Bartlett's Unfamiliar Quotations
Today in History
Do You Need to Update Your Daily Bugle Profile?
Are your copies of regulations current?
ITEMS FROM THE FEDERAL REGISTER
1. Commerce/BIS Corrects Typographical Error EAR Part 774
(Source: 91 FR 55457, 28 Aug 2026)
AGENCY: Commerce, Bureau of Industry & Security
ACTION: Correction of former Federal Register
CORRECTION: In rule Document 2026-16628, appearing on pages 52501 through 52508, in the issue of Friday, August 14, 2026, make the following correction: Supplement No. 1 to Part 774 [Corrected]
On page 52507, in Supplement No.1 to Part 774, in the third column, on the 14th line from the top, "List of Items Controlled[MISSING◻" should read "List of Items Controlled".
2. State Amends ITAR 121 § Cat XI to Extend Temporary Modification of USML Category XI(b)
(Source: 91 FR 55461, 28 Aug 2026)
AGENCY: State Department
ACTION: Final rule; Extension of Temporary Modification of Category XI(b) of the U.S. Munitions List, International Traffic in Arms Regulations:
SUMMARY: The Department of State extends a previous temporary modification of Category XI(b) of the United States Munitions List (USML).
DATE: This rule is effective August 30, 2026, except for amendatory instruction 3, which is effective August 30, 2028.
SUPPLEMENTARY INFORMATION: On July 1, 2014, the Department published a final rule revising Category XI of the USML, 79 FR 37536, effective December 30, 2014. That final rule, consistent with the two prior proposed rules for USML Category XI (78 FR 45018, July 25, 2013, and 77 FR 70958, November 28, 2012), revised paragraph (b) of Category XI to clarify the extent of control and maintain the existing scope of control on items described in paragraph (b) and the directly related software described in paragraph (d). The Department later determined that exporters may read the revised control language to exclude certain intelligence-analytics software that has been and remains controlled on the USML. The Department extends the temporary modification of USML Category XI(b) for two years, to August 30, 2028, while the Department, with its interagency partners, continues to review the U.S. Munitions List as mandated by the Arms Export Control Act, 22 USC 2778(f) and every three years as mandated by section 1345 of the National Defense Authorization Act FY24.
For reasons stated in the preamble, the Department of State amends 22 CFR part 121 as follows: [List here.]
[Editor's Note: A new edition of Bartlett's Annotated ITAR containing the above amendments will be released on the effective date, 30 August. Subscribe now.]
3. State Amends ITAR § 120.54 and 121.1 to Remove Certain Civil Aircraft from the USML and to Exclude from the ITAR Certain Activities that Would Otherwise Meet the Definition of Reexport; Requests Comments
(Source: 91 FR 55457, 28 Aug 2026)
AGENCY: Department of State.
ACTION: Interim final rule; request for comments.
SUMMARY: The Department of State (the Department) amends the International Traffic in Arms Regulations (ITAR) to remove from the U.S. Munitions List (USML) certain aircraft that have been modified to incorporate aircraft survivability equipment (ASE) and to exclude from the ITAR certain activities that would otherwise meet the definition of reexport.
DATES: Effective date: This rule is effective Oct. 12, 2026. Comment due date: Comments by Sept. 27, 2026.
SUPPLEMENTARY INFORMATION: For reasons stated in the preamble, the Department of State amends 22 CFR parts 120 and 121 of the United States Munitions List, as follows: [See full version for amended sections.]
The Department also requests comments focused on the following questions:
How much would practitioners benefit from the Department defining the terms for the eligible types of ASE?
Are there commodities, services, or technical data closely related to these revisions that warrant ITAR control, but are currently either not described on the USML, or not described with sufficient clarity? If so, please provide examples and a concise explanation.
Are there commodities, services, or technical data closely related to these revisions that do not warrant ITAR control? If so, please provide examples and a concise explanation.
Are there specific functions, performance levels, or characteristics related to these revisions that could better:
a. Distinguish between the commodities that do, and do not, warrant ITAR control; or
b. Align with the constructions or language used elsewhere in the ITAR?
Can any of these revisions be more clearly or concisely stated?
[Editor's Note: A new edition of Bartlett's Annotated ITAR containing the above amendments will be released on the effective date, 30 August. Subscribe now.]
4. Future Federal Register
(Source: Future Federal Register)
State Department; Notices; Agency Information Collection Activities; Proposals, Submissions, and Approvals: Application for Permanent/Temporary Export or Temporary Import of Classified Defense Articles and Classified Technical Data. Scheduled Pub. Date: 31 Aug 2026. Permalink. (This is an ICR renewal notice tied to DDTC's classified defense article/technical-data export-import application --- no substantive rule change, just an information-collection approval request.)
State Department; Determination: State Sponsor of Terrorism Regarding Syria; Recission. Scheduled Pub. Date:31 Aug 2026. Permalink
State Department; Specially Designated Global Terrorist: Revocation of the Designation of Al-Nusrah Front, also known as Hay'at Tahrir al-Sham. Scheduled Pub. Date: 31 Aug 2026. Permalink
OTHER U.S. GOVERNMENT SOURCES:
5. CBP Cargo Systems Messages
(Source: DHS/CBP/CSMS)
CSMS # 69680973 - Registration Now Open: U.S. Customs and Border Protection September 2026 Trade Enforcement Webinars
CSMS # 69668727 - ACE Production Standard Invasive Maintenance from 10:00 p.m. ET Saturday, August 29, 2026 to 4:00 a.m. ET Sunday, August 30, 2026
CSMS # 69647683 - REMINDER: ACE User Satisfaction Survey -- Your Input Matters!
CSMS # 69668138 - Updated Guidance: Entry Summary Order of Reporting for Multiple HTS when 98 or 99 HTS are Required
6. CBP OTR Events in August-September 2026
(Source: OTR Webinars)
Combating Unfair Trade: Understanding New AD/CVD Orders and Reporting Evasion to CBP --- Monday, September 21, 2026 at 2:00 p.m. EDT
Seats of Cane, Osier, Bamboo --- Tuesday, September 22, 2026 at 11:00 a.m. EDT
Trade Violations Reporting (TVR) Q4 --- Tuesday, September 22, 2026 at 1:00 p.m. EDT
Surfactants - Global Specialty Chemicals --- Thursday, September 24, 2026 at 11:00 a.m. EDT
Enforce and Protect Act (EAPA) Q4 --- Thursday, September 24, 2026 at 1:00 p.m. EDT
Sound and Visual Signaling Devices of Heading 8531 --- Friday, September 25, 2026 at 11:00 a.m. EDT
Happy Trailers to You: Trailers of 8716 --- Monday, September 28, 2026 at 1:30 p.m. EDT
Misc. Edible Preparations of Heading 2106: Part I --- Tuesday, September 29, 2026 at 1:30 p.m. EDT
Misc. Edible Preparations of Heading 2106: Part II --- Wednesday, September 30, 2026 at 1:30 p.m. EDT
7. Commerce/BIS (Nothing new.)
(Source: Commerce/BIS)
8. State/DDTC (Nothing new.)
(Source: State/DDTC)
9. Treasury/OFAC Updates List of Specially Designated Nationals (SDN) and Blocked Persons
(Source: Treasury/OFAC, 28 Aug 2026)
The SDN list has recently been updated. Visit this page to access the latest version of the SDN list. Check this page periodically as it may also be updated if a new list-related format or product is offered. Visit this link for more information on today's update.
10. UK Export Control Joint Unit Strategic Export Controls: Licensing Statistics (1 Jan to 31 Mar 2026)
(Source: UK ECJU, 28 Aug 2026)
The strategic export controls licensing statistics provide data on decisions made on licence applications to the Export Control Joint Unit (ECJU) of the Department for Business, Innovation, Science and Trade (BIST) through the Shared Primary Information Resource Environment (SPIRE) and Licensing for International Trade and Enterprise (LITE) licensing systems. These statistics are currently Official Statistics in Development.
11. White House: "President Establishes a Commission to Design the United States Space Academy"
(Source: The White House, 28 Aug 2026) [Excerpts]
[Editor's Summary]: This executive order titled "Establishing the United States Space Academy" (Aug. 28, 2026) (as yet unnumbered) establishes the Presidential Commission on the United States Space Academy, chaired by the NASA Administrator, with the Assistant to the President for Science and Technology and the Assistant to the President for Economic Policy as Vice Chairs, and NASA's Deputy Administrator as Executive Director. Additional members include the Secretary of War, White House Chief of Staff, OMB Director, National Security Advisor, Secretary of the Air Force, and other invited federal officials.
The Commission will advise on creating a NASA-led federal academy combining technical education with leadership development to build a corps of leaders for the space domain.
Within 120 days, it must report recommendations on governance structure (including a NASA-based option), curriculum, graduate service obligations, applicant prerequisites, site selection, actions possible under existing authority, needed legislation, coordination with existing federal education programs, and an implementation timeline.
NEWS
12. Expeditors News: "CBP to Verify Form 5106 Information, Penalize Inaccuracies"
(Source: Expeditors News, 27 Aug 2026) [Excerpts]
In a Federal Register Notice (FRN) published on August 18, 2026, U.S. Customs and Border Protection (CBP) announced they would begin to verify the accuracy of the information provided on CBP Form 5106 for new and existing Importers of Record (IORs).
Beginning on September 18, 2026, CBP will review information provided on Form 5106 to ensure that "all information, including the physical addresses, email addresses, phone numbers, Internal Revenue Service (IRS) Employer Identification (EIN), and any Social Security Number (SSN) provided on the CBP Form 5106 are accurate and complete, and that each one belongs directly to the IOR."
If CBP determines that an IOR, or customs broker acting on behalf of an IOR, has failed to provide accurate or incomplete information, CBP may immediately void the IOR number and potentially take "other enforcement actions, as appropriate."
When an IOR number is voided, CBP will issue a written notice to the IOR using the most recent email address on file. If applicable, CBP will also copy the customs broker that last filed an entry on behalf of the IOR. The notice will include information on how to request the reestablishment of the IOR number. FRN 2026-16911 is HERE.
13. Space News: "SpaceX to Develop Starship Launch Site in Louisiana"
(Source: Space News, 28 Aug 2026) [Excerpts of subscription publication]
SpaceX announced plans Aug. 25 to build a massive new spaceport for its Starship launch vehicle in Louisiana as the company starts to wind down Falcon 9 launches.
SpaceX and the Louisiana state government unveiled plans for "Starbase Louisiana," a launch site the company will build in Vermilion Parish, located on the Gulf Coast south of Lafayette. The facility will be built on about 125,000 acres (50,600 hectares) of land in an area called Pecan Island.
State officials said SpaceX would spend $100 billion to develop Starbase Louisiana, which will ultimately include 10 Starship launch pads and related infrastructure. Construction is scheduled to begin in 2027, with first launches there no earlier than 2029.
14. ST&R Trade Report: "Import Duties on Beef Lowered for Three Months"
(Source: Sandler, Travis & Rosenberg Trade Report 28 Aug 2026) [Excerpts]. Contact: [email protected], 1-305-894-1035
President Trump issued Aug. 26 a proclamation temporarily lowering import duties on lean beef trimmings combined with U.S. beef to produce ground beef.
The U.S. maintains a tariff-rate quota on imports of certain beef products that allows a set volume of covered goods into the U.S. at a lower duty rate, with any additional amounts subject to a higher rate.
According to a White House fact sheet, the proclamation will expand the in-quota amount under this TRQ by a total of 300,000 metric tons. This increase will be administered in three month-long tranches of 100,000 mt each that will be open in September, October, and November. It will apply to lean beef trimmings classifiable under HTSUS 0201.30.5091, 0201.30.5097, 0202.30.5091, and 0202.30.5097.
The proclamation further directs the Department of Agriculture and the Office of the U.S. Trade Representative to monitor whether the additional imports are being sold at a price 25 percent below the market price for lean beef trimmings. If not, the president will have the option to eliminate what remains of the increased in-quota quantity to "prevent a windfall to foreign producers."
The proclamation said these actions are being taken after a determination that the domestic supply of beef products, including ground beef, "will be inadequate to meet domestic demand at reasonable prices because of natural disasters, disease, or major national market disruptions."
15. ST&R Trade Report: "CBP Expands Jurisdiction in Waters Off Southern Borders"
(Source: Sandler, Travis & Rosenberg Trade Report 28 Aug 2026) [Excerpts]. Contact: [email protected], 1-305-894-1035
U.S. Customs and Border Protection has issued a notice that, effective Aug. 25, established four customs enforcement areas that expand CBP's enforcement jurisdiction from 12 to 24 nautical miles in designated waters adjacent to South Florida, Southern California, Puerto Rico, and the Gulf Coast of Texas.
A CBP press release explains that smuggling organizations have "exploited the outer edge of traditional customs waters by positioning vessels beyond the 12 nautical mile boundary, transferring illicit cargo at sea, and coordinating landings along remote shorelines."
In response, consistent with a June 2026 executive order directing CBP to bolster enforcement of customs laws, the new designations "provide more consistent customs enforcement authority across these waters and support the investigation and prosecution of maritime smugglers."
Among other things, customs officers and agents are now able to board vessels within the CEAs to examine manifests and other documents and papers and to examine, inspect, and search vessels and cargo on board.
They also may pursue and seize or arrest and otherwise enforce upon any vessel, merchandise, or person in the CEA in accordance with applicable U.S. laws and regulations in the same manner they are authorized to do at any place in the U.S.
CBP acknowledges that such enforcement activity may in some cases result in "limited operational impacts," including delay, to vessel owners, operators, passengers, and cargo interests.
16. Tech Times: "BIS Investigates Apex Logistics over Nvidia Servers: First Freight Forwarder Targeted"
(Source: Tech Times, 28 Aug 2026) [Excerpts]
The Commerce Department's Bureau of Industry and Security is examining whether Singapore-based Apex Logistics --- a wholly owned subsidiary of Swiss shipping giant Kuehne+Nagel --- transported Nvidia AI server hardware to China in violation of US export restrictions, in what would mark the first-ever enforcement action against a transportation company for participating in the illegal semiconductor trade.
US probe corroborated by multiple sources: Two former Apex employees allegedly applied false shipping codes to 47 shipments that designated the controlled hardware as exempt from US export restrictions --- a filing that, if proven deliberate, carries both civil and criminal exposure for the company and the individuals involved.
Apex Acknowledged the Investigation; Parent Says It Has Not Been Contacted: Apex said it is "fully cooperating and committed to compliance with all applicable regulations" and acknowledged awareness of US concern over "a small number of shipments that Apex handled in 2024 and which may have involved materials and equipment which were ultimately forwarded to prohibited locations." . . .
[Full article]
OPINION
17. Baker/McKenzie: "US Rescinds Syria's State Sponsor of Terrorism Designation and Delists Hay'at Tahrir al-Sham"
(Source: Global Sanctions and Export Controls Blog, 27 Aug 2026) [Excerpts]
Principal Author: Paul Amberg (Spain), philippe Reich; Baker Mckenzie
On August 24, 2026, the US Department of State rescinded Syria's designation as a State Sponsor of Terrorism ("SST") and revoked the designation of al-Nusrah Front, also known as Hay'at Tahrir al-Sham ("HTS"), as a Specially Designated Global Terrorist ("SDGT").
Concurrently, the US Department of the Treasury's Office of Foreign Assets Control ("OFAC") removed HTS from the Specially Designated Nationals and Blocked Persons List ("SDN List"), revoked Syria General License 25 ("GL 25"), and updated its Syria-related guidance. The OFAC notice is available here.
As we previously covered, President Trump notified Congress on July 8, 2026 of his administration's intent to rescind Syria's SST designation, which triggered a 45-day waiting period before the rescission could take effect. Once the waiting period ended, Secretary of State Marco Rubio authorized the formal rescission. According to the State Department, rescinding Syria's SST designation and HTS's SDGT designation "eliminates the final major barriers for private sector investment in Syria."
Effect of the SST Rescission and the HTS Delisting: As a result of the rescission, Syria is no longer subject to the prohibitions under the Terrorism List Governments Sanctions Regulations (31 CFR Part 596) or 22 USC 7205(a)(1), which had restricted, among other things, US financial transactions with SST-designated governments.
Following revocation of the SDGT designation, HTS is no longer blocked pursuant to the Global Terrorism Sanctions Regulations, 31 CFR Part 594. Treasury has confirmed in its press release that US persons do not require authorization from OFAC to engage in transactions or activities with HTS, provided those activities do not involve blocked persons or otherwise prohibited activities. . . . .
Concurrent Counterterrorism Designations: . . .
[Full article]
18. Breaking Defense: "How the Commerce Department Plans to Win More Foreign Defense Sales"
(Source: Breaking Defense, 14 Aug 2026) [Excerpts]
In an exclusive preview of America's new arms sale policies, a key Commerce official says the department is ready to "help US companies" in foreign markets. . . .
Working with interagency partners and under the leadership of Commerce Secretary Howard Lutnick and Under Secretary of Commerce for International Trade William Kimmitt, the Advocacy Center has developed four concrete priorities:
Reform Defense Advocacy Policy: . . .
Educate and Empower US Government Stakeholders: . . .
Prioritize Advocacy at the Highest Levels: . . .
Strengthen Industry Outreach and Engagement: . . .
19. Diaz: "Getting Off the SDN List: A Practical Guide to OFAC's Administrative Reconsideration Process"
(Source: Customs & International Trade Law Blog, 28 Aug 2026) [Excerpts]
Author: Jennifer Diaz, Esq., Diaz Trade Law LLP
Landing on the Office of Foreign Assets Control's (OFAC) Specially Designated Nationals and Blocked Persons List (SDN List) is one of the most consequential things that can happen to a company or individual doing business in or with the United States. Assets are frozen, U.S. persons are barred from dealing with you, and banking relationships evaporate almost overnight.
The good news is that SDN designations are not necessarily permanent. OFAC maintains a formal process -- administrative reconsideration -- for petitioning to have a person, entity, or piece of property removed from an OFAC-administered sanctions list. This article walks through how that process works, what to expect at each stage, and where clients most often stumble.
Step One: Confirm You're Using the Right Process: . . .
Step Two: Submit a Petition Through OFAC's Reconsideration Portal: . . .
Step Three: The Reinvestigation --- and Why Timing Varies Widely: . . .
Step Four: The Determination: . . .
Reapplying After a Denial: . . .
A Word of Caution: Candor Is Not Optional: OFAC has been explicit that it may deny petitions containing inconsistent, misleading, or false information. More significantly, knowingly and willfully making materially false, fictitious, or fraudulent statements to OFAC --- or concealing a material fact in a submission --- can carry criminal penalties, separate and apart from a denied petition.
[Full article]
20. Husch Blackwell: "Executive Order and Forthcoming Rules Will Restrict U.S. Imports and Installations of Foreign Bulk-Power System Equipment"
(Source: HB International Trade Insights, 27 Aug 2026) [Excerpts]
Primary Author: Grant D. Leach, Husch Blackwell LLP
On Wednesday, August 26, 2026, President Donald Trump issued an Executive Order titled "Declaring a National Emergency to Secure the United States Bulk-Power System."
The Order establishes broad powers which will allow the U.S. Secretary of Energy to prohibit the importation or installation of foreign-produced bulk-power system electric equipment in the United States if the Secretary determines that the equipment presents undue or unacceptable risk to the U.S. power grid or to U.S. national security.
It is currently unclear how these new powers will operate, but the Order does require the Secretary to publish implementing rules or regulations within the next 120 days.
The White House also published a Fact Sheet to accompany the Order.
Types of Equipment Potentially Subject to the Order: . . .
Equipment Determination Requirement: . . .
Treatment of Existing Equipment: . . .
Possibility of Pre-Qualification and Mitigation Measures: . . .
[Full article]
21. KPMG: "U.S. State Department Removes Certain Survivability-Enhanced Aircraft from U.S. Munitions List Controls"
(Source: KPMG, 27 Aug 2026) [Excerpts]
The Department of State today released an interim final rule amending the International Traffic in Arms Regulations (ITAR) to remove from the U.S. Munitions List (USML) certain civil aircraft that have been modified to incorporate aircraft survivability equipment (ASE).
The rule also excludes from certain ITAR authorization requirements specified reexports and temporary imports of ASE incorporated into those aircraft.
The rule:
Revises USML Category VIII(a)(8) to exclude certain "survivability-enhanced aircraft" from USML coverage
Adds definitions for "ASE," "secured ASE," "survivability-enhanced aircraft," and "USML"
Defines secured ASE to include certain directed infrared countermeasure (DIRCM) systems and related missile warning systems that incorporate specified anti-tamper protections
Excludes certain manned civil aircraft modified to incorporate secured ASE from ITAR control, provided they meet the new definition of survivability-enhanced aircraft
Adds a new exclusion from the definition of export-related activities for certain temporary imports into the United States of secured ASE incorporated into survivability-enhanced aircraft
Adds a new exclusion for certain movements of secured ASE between foreign countries while incorporated into survivability-enhanced aircraft, provided the ASE was previously exported from the United States under an ITAR license
Retains USML control over ASE itself, as well as technical data and defense services directly related to ASE
Clarifies that assistance involving the modification, maintenance, repair, or operation of ASE, or aircraft modifications directly related to ASE integration, may continue to constitute controlled defense services under the ITAR
Requests public comments on the rule and poses specific questions regarding the scope, clarity, and treatment of ASE-related controls
The interim final rule is effective 45 days after publication in the Federal Register. Comments must be submitted within 30 days after the publication date of August 28, 2026.
22. Volkov: "Veloxis Pharmaceuticals' $46 Million Kickback Settlement: A CEP Case Study Worth Studying Closely"
(Source: Volkov Law, 27 Aug 2026) [Excerpts]
Principal Author: Michael Volkov, Volkov Law Group LLC
Veloxis Pharmaceuticals, the maker of the kidney transplant immunosuppression drug Envarsus XR, has agreed to pay more than $46 million and submit to years of enhanced compliance oversight to resolve civil and criminal allegations that the company ran a sustained kickback scheme to drive prescriptions of its drug.
This case is worth a close read for compliance officers well beyond the pharmaceutical industry, because it's one of the clearer real-world applications we've seen of DOJ's Corporate Enforcement and Voluntary Self-Disclosure Policy, and it shows exactly what that policy can offer a company willing to cooperate, even when the underlying conduct reached the CEO's office.
The Scheme: According to the deferred prosecution agreement DOJ filed, Veloxis ran an aggressive marketing campaign from January 2016 through June 2023 built around paying kickbacks to the physicians who could drive prescriptions of Envarsus.
Surgeons, nephrologists, nurse practitioners, pharmacists, and hospital administrators received lavish meals, alcohol, expensive trips, resort stays, gifts, and payments structured as consulting fees, all designed to influence prescribing decisions for Medicare and Medicaid patients. Separately, from July 2017 through April 2023, Veloxis paid per-patient and per-month kickbacks directly to pharmacies to induce them to stock and dispense the drug.
What makes this case particularly serious from an enforcement perspective is where the conduct originated. According to the DPA, the company's former chief executive officer, along with its former president of sales and former vice president of market access, directed and oversaw significant portions of these payment schemes.
This wasn't a rogue regional sales team operating outside leadership's knowledge. The DPA describes conduct orchestrated at the highest levels of the organization, which is exactly the kind of fact pattern that typically pushes DOJ toward the harshest available resolution, criminal prosecution of the corporate entity itself.
Veloxis also concealed the conduct through its own books and records, falsifying expense reports and mischaracterizing kickback payments as legitimate consulting fees. And the company failed to report required payments to CMS under the Open Payments Program, commonly known as the Sunshine Act, the federal transparency regime requiring drug and device manufacturers to publicly disclose payments made to physicians and teaching hospitals.
Why Veloxis Avoided Prosecution Despite Executive-Level Misconduct: . . . [Full article]
EX/IM MOVERS & SHAKERS
23. List of Export/Import Job Openings
(Source: Editor)
Submit job openings HERE.
(To view job description, click Job ID or Title.)
RECENT:
Anduril Industries. Job location: Many US sites. Title: Export Compliance, Senior Analyst, Job ID: 5188755007
Northrop Grumman. Job location: 9 locations Title: Principal International Trade Compliance Analyst. Job ID: R10240096
Northrop Grumman. Job locations: Linthicum, MD and 5 other locations. Title: Manager 3 - Global Trade. Job ID: R10238060
Rieter AG. Job location: Winterthur, Switzerland. Title: Head of Trade Compliance. Contact: Jasmin Bauer
SpaceX, Job location: Palo Alto, CA. Title: Counsel, Global Trade Compliance
FULL LIST:
Alcon Research. Job location: Fort Worth, TX. Title: International Trade Counsel Global Trade Compliance. Job ID: R-2026-46235
Amazon LEO. Job location: Bellvue, WA. Title: Sr. Export Compliance Manager. Job ID: 10469204
Amazon Services. Job location: Arlington, VA. Title: Senior Export Compliance Manager, Global Trade Services.
Analog Devices. Job locations: Germany, Munich, Otl-Aicher-Strasse. Title: Sr. Trade Compliance and Audit Officer. Job ID: LI-RW1
Anduril Industries. Job location: US sites. Title: Senior International Trade Compliance Engineer. Job ID: 5217656007
Abrams Airborne Manufacturing. Job location: on-site. Title: Export Compliance Officer, Job ID: 1. Contact Cindy Valencia, 1-520-887-1727
Altimeter Solutions. Job location: Londonderry, NH. Title: Remote Export Compliance Coordinator. Job ID: JP6978
Anduril Industries. Job location: Costa Mesa, CA. Title: Director of Air Maneuver Dominance & Maritime, International Trade Compliance. Job ID: 5100621007
Arotech. Job location: Ann Arbor, MI (Hybrid). Title: Director of Trade Compliance. Job ID: 2026-072101. Contact: Erin Heine, 734-761-5836
Arrow. Job location: Denver, CO. Title: Director, Global Trade Compliance Counsel
AV. Job location: Simi Valley, CA (+ other locations). Title: Trade Compliance Officer. Job ID: 8195. Contact: Cherie Labick
AV. Job location: Simi Valley, CA. Title: Export Controls Officer. Job ID: 8215. Contact: Cherie Labick
Axiom Law. Job location: U.S. Remote. Title: Export Trade Compliance Counsel
BAE Systems. Job location: McLean, VA, or Rockville, MD. Title: Import Export Analyst. Job ID: 125516BR. Contact: Jordan Reisman, 301-944-4700
BAE Systems. Job location: Greenlawn, NY; Fort Wayne, IN; Wayne, NJ; Reston, VA (Hybrid). Title: Senior International Trade Analyst. Job ID: 125393BR. Contact Robert Wojcik, 412-377-3351
Barnes & Thornburg. Job location: Washington, D.C. Title: International Trade Associate.
Castelion, Job location: Washington, DC. Title: Senior Counsel, Trade & Export Compliance
Castelion, Job location: Torrence, CA. Title: Senior Counsel, Trade & Export Compliance
Continental Electronics. Job location: Richardson, TX. Title: Trade Compliance Analyst. Job ID: 36830. Contact: Maria Jabara, 310-658-7787
Elanco. Job location: Indianapolis, IN. Title: Senior Counsel, Global Trade
Eli Lilly. Job location: Indianapolis, IN. Title: Associate Director - Trade Sanctions Compliance. Job ID: R-108914. Contact: Bailey Patten, 864-875-1659
Expeditors; Job location: Noorderlaan, Antwerpen, Belgium. Title: Customs Brokerage Agent
Expeditors. Job location: Brisbane, CA. Grapevine, TX. Title: Customs Brokerage Agent
Export Compliance Solutions & Consulting. Job location: Remote, USA. Title: Sales Representative/Software Sales; Contact Suzanne Palmer
FedEx. Job location: Queensland, AU. Title: Customs Broker. Job ID: P25-249616-2
General Atomics Aeronautical Systems. Job location: San Diego (Poway) CA (hybrid). Title: Senior Director, International Trade Compliance. Job ID: 54950BR. Contact Arthur Shulman
General Atomics. Job location: San Diego CA (hybrid) or another U.S. location including Wash DC; Huntsville, AL; Tupelo, MS; Denver, CO. Title: Senior Trade Compliance Integrator. Job ID: 52696BR; Contact James Van Eenenaam
General Dynamics. Job location: Scranton, PA. Title: Regulations Compliance Specialist II. Job ID: 2026-35876
Hermes. Job location: Manhattan, NYC. Title: Customs / Import-Export Coordinator (Temporary or Full-time)
Hillspire. Job locations: Arlington, VA; Washington, DC; New York, NY; Long Beach, CA; Los Angeles, CA; San Francisco, CA. Title: Export Control Jurisdiction and Classification Manager. Job ID: 1762. Contact: Tracy Gronewold
Hillspire. Job locations: Arlington, VA and New York, NY. Title: Trade Compliance Counsel. Job ID: 1761. Contact: Tracy Gronewold
Home Depot. Job location: Atlanta, GA. Title: Corporate Counsel, Supply Chain and International
Honeywell Aerospace. Job location: Charlotte, NC. Title: Trade Compliance General Counsel. Job ID: 147681
Honeywell Aerospace. Job location: Charlotte, NC. Title: Senior Trade Compliance Investigator. Job ID: 150642
Horizon3 AI. Job location: U.S> Remote. Title: Senior Legal, Privacy & Export Compliance
Immigration & Customs Enforcement (ICE). Job Location: Birmingham, AL. Title: General Attorney, Immigration and Customs
Immigration & Customs Enforcement (ICE). Job Location: Washington, DC. Title: General Attorney, Criminal/Customs
L3Harris. Job location: Ottawa, Canada. Title: Trade Compliance Senior Specialist. Job ID: 38357
Lockheed Martin. Job location: Syracuse & Owego, NY. Title: International Trade Compliance, Senior Staff. Job ID: 733880BR. Contact: Rebecca Edwards, 203-540-7922
Mastronardi Produce. Job Location: Livonia, MI; Title: Customs Manager (Certified Customs Specialist); Job ID: CUSTO011196. Contact Tiziana Mastronardi, 519-796-7710
McCarter & English. Job locations: Newark, NJ; Stamford, CT; New York, NY. Title: Trade Specialist. Job ID: 001. Contact: Christine Lydon
Mercedes-Benz. Job location: US Remote/Hybrid. Title: Senior Counsel, Export Compliance (Contractor). Job ID: Legal (4031)
Northrop Grumman. Job location: 9 locations Title: Principal International Trade Compliance Analyst. Job ID: R10240096
Northrop Grumman. Job location: Falls Church, VA or Linthicum, MD. Title: Corporate Counsel II - Export/Import. Job ID: R10243093
Northrop Grumman. Job location: Linthicum, MD; San Diego, CA; Rolling Meadows, IL; Charlottesville, VA; or Woodland Hills, CA. Title: Manager 3 - Global Trade. Job ID: R10238060
PCC Airfoils. Job Location: On-site; Title: Facility Trade Compliance Officer, Job ID: 13286
Peraton. Job location: Reston, VA (& local remote). Title: Manager, Trade Compliance. Job ID: 169785. Contact: Julia Mason
Planet. Job location: DC Metro Area; Denver; San Francisco; Remote. Title: Technical Program Manager, Trade Compliance. Job ID: 8014103. Contact Ashley McNally.
Planet Labs. Job location: San Francisco, CA. Title: Senior Analyst, International Trade Compliance. Job ID: 8069677. Contact: Albert Zuniga
Planet Labs. Job location: San Francisco, CA. Title: Analyst, International Trade Compliance. Job ID: 8077154. Contact: Albert Zuniga
Radiant. Job Location: Renton, WA. Title: International Operations Specialist Lead
Rapiscan Systems. Job location: Billerica, MA. Title: Trade Compliance Manager. Job ID: 37117. Contact: Jon Logins, 978-584-6450
Regeneron. Job location: East Greenbush, NY. Title: Senior Trade Analyst, Customs Brokerage. Job ID: R46522
Rieter AG. Job location: Winterthur, Switzerland. Title: Head of Trade Compliance. Contact: Jasmin Bauer
Rocket Lab Corp. Job location: Long Beach, CA. Title: Senior Legal Counsel
Safran Nacelles Services Americas. Job location: Plainfield, IN (or remote). Title: Import & Export Control Specialist. Job ID: 2026-181128. Contact: Kendall Hatcher, 214-882-3886
Safran Power Units Dallas. Job location: Grand Prairie, TX (or remote). Title: Trade Compliance Manager. Job ID: 170562. Contact: Meagan Montelongo, 858-276-8242
Salesforce. Job location: Wash DC. Title: Export Control Manager & ITAR Compliance Official. Job ID: JR346062. Contact: Amber Graves
SpaceX, Job location: Hawthorne, CA. Title: Counsel, Global Trade Compliance
SpaceX, Job location: Palo Alto, CA. Title: Counsel, Global Trade Compliance
STENA. Job location: Baltimore, MD. Title: MRO Customer Program Manager
Teledyne. Job locations: Elkridge, MD; Billerica, MA; Goleta, CA; Hudson, NH. Title: Export Licensing Specialist (EAR/ITAR). Job ID: REQ36249
Teledyne. Job location: Garland, TX; Billerica, MA; Elkridge, MD. Title: Trade Compliance Director, Aerospace & Electronics Segment. Job ID: REQ33489.
TikTok. Job location: Wash DC. Title: Global Head of Export Control & Trade Compliance
Tower Semiconductor. Job location: Newport Beach, CA. Title: In-House Legal Counsel. Job ID: 9452. Contact: Alyssa Olaosebikan, 949-435-8549
Trane Technologies. Job location: Davidson, NC; San Diego, CA. Title: Trade Compliance Specialist
Unical Aviation. Job location: Glendale, AZ. Title: Senior Export Control Manager. Job ID: 2026-0778. Contact: Rebecca Whiteley, 626-949-3325
Wurth Industry USA. Job locations: Greenwood, IN; Brooklyn Park, MN; Roanoke, VA; or Bondurant, IA. Title: Logistics Specialist. Job ID: LOGIS006301. Contact: Stephanie Johnston, 612-505-1605
Wurth Industry USA. Job locations: Greenwood, IN; Brooklyn Park, MN; Roanoke, VA; Bondurant, IA. Title: Export Compliance Specialist. Job ID: EXPOR006254. Contact: Stephanie Johnston, 612-505-1605
Zygo. Job location: Location of Employment: Middlefield, CT. Title: Trade Compliance Specialist. Job ID: 70100. Contact: James Scroggins, 860-652-2971
EDITOR'S NOTES
#. Do You Have Access to the Latest and Greatest ITAR and FTR?
Bartlett's Annotated ITAR ("BITAR") (28 Aug 2026, available effective date of 30 Aug 2026) and Bartlett's Annotated FTR ("BAFTR") (6 July 2026) are Word documents to download to your laptop to keep you updated on the latest amendments to the International Traffic in Arms Regulations (22 CFR 120-130) and the Foreign Trade Regulations (15 CFR Part 30).
The new version of the BITAR contains today’s ITAR amendments. It will be available on 30 August, the effective date of the first amendment. They contain over a thousand footnotes of errors in the official text, section histories, key cases, practice tips, Consent Agreements, glossaries, and extensive Tables of Contents. You download the updated edition when the regs are amended, so you'll always have the latest regulations.
But if the official on-line version of the ITAR is free, why subscribe to the BITAR?"
Answer: Compare the BITAR with the Government's free version.
You'll see why all export professionals must use the BITAR and BAFTR.
25. Bartlett's Unfamiliar Quotations
(Source: Brainy Quotes)
Johann Wolfgang von Goethe (28 Aug 1749 -- 22 Mar 1832; was a German writer and statesman. His works include four novels, epic and lyric poetry, prose and verse dramas, memoirs, an autobiography, literary and aesthetic criticism, and treatises on botany, anatomy, and color. In addition, numerous literary and scientific fragments, more than 10,000 letters, and nearly 3,000 drawings by him have survived. He is considered the greatest German literary figure of the modern era.)
"There is nothing in which people more betray their character than in what they laugh at."
"He is happiest, be he king or peasant, who finds peace in his home."
"Let everyone sweep in front of his own door, and the whole world will be clean."
"What is not started today is never finished tomorrow."
"Many people take no care of their money till they come nearly to the end of it, and others do just the same with their time."
"Boldness has genius, power, and magic in it."
Leo Tolstoy (Count Lev Nikolayevich Tolstoy; 28 Aug 1828 -- 20 Nov 1910), usually referred to in English as Leo Tolstoy, was a Russian writer. He is regarded as one of the greatest and most influential authors of all time. His body of writing (fiction + nonfiction + letters + diaries) was large enough to fill 90 volumes in the standard Russian collected edition. His most famous novels were War and Peace, Anna Karenina, and Resurrection.)
"Everyone thinks of changing the world, but no one thinks of changing himself."
"If you want to be happy, be."
"The strongest of all warriors are these two --- Time and Patience."
Friday Funnies:
There is a town in Michigan named Hell, that freezes over every winter. It is 338 miles from Paradise, MI.
New Your City's Central Park is nearly twice the size of the whole country of Monaco.
I recently bought a toilet brush. Long story short -- I'm going back to toilet paper.
Someone unexpected may come into your life from nowhere, making your heart race, and changing your life forever. We call those people cops.
When one door closes and another one opens, you're probably in jail.
26. Today in History
(Source: History Channel)
1963: Martin Luther King Jr. delivers "I Have a Dream" speech at the March on Washington. On the steps of the Lincoln Memorial in Washington, D.C., where Martin Luther King Jr. delivered his "I Have a Dream" speech to about 250,000 people attending the March on Washington.
27. 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.
28. 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.
19 CFR, Ch. 1, Pts. 0-199.
28 Apr 2026 (91 FR 22713): CBP Extends 19 CFR part 12 Import restrictions on Archaeological and Ethnological Material from Afghanistan.
15 CFR Subtitle B, Ch. VII, Pts. 730-774.
24 Aug 2026 15 CFR Part 744 (91 FR 55457)
EAR Part 744 to correct typographical error.
15 CFR Part 30
11 June 2026 (91 FR 35383): Amendment to Correct Errors
(The latest Bartlett's Annotated FTR ("BAFTR") is 6 Jul 2026.)
DoD 5220.22-M, 32 CFR Part 117
19 Aug 2021 (86 FR 46597): Extended compliance date for reporting and approval of foreign travel under SEAD‑3 for contractors.
27 CFR Part 447: Importation of Arms, Ammunition, and Implements of War
6 May 2026 (91 FR 24352, 34348, 24362, 24364): Revised four sections in 27 CFR § 447 and 479, to refer to Commerce regulations and court cases.
22 C.F.R. Chapter I, Subchapter M, Parts 120-130
28 Aug 2026 (91 FR 55461) and (91 FR 55457): Amendment § 120.54 and 121.1 to Remove Certain Civil Aircraft from the USML
(The latest Bartlett's Annotated ITAR ("BITAR") is 28 Aug 2026 (to be released 30 Aug 2026.)
(OFAC FACR): 31 CFR, Parts 500-599, Embargoes, Sanctions, Executive Orders
21 Mar 2025 (90 FR 13286): Increased record keeping requirements from 5 to 10 years.