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  • Home
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  • 26-0831: Monday's "Export/Import Daily Bugle"

26-0831: Monday's "Export/Import Daily Bugle"

Jim Bartlett
Jim Bartlett

Aug 31, 2026

•

22 min read

MONDAY, 31 AUGUST 2026

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TABLE OF CONTENTS

FEDERAL REGISTER

  1. President's Executive Order Prohibits Transactions Involving Foreign Bulk-Power Electric Equipment Tied to a Covered Foreign Entity

  2. State Seeks Comments on ITAR Form DSP-85, Application for Permanent/Temporary Export or Temporary Import of Classified Defense Articles and Classified Technical Data"

  3. State Rescinds Determination of Syria as a State Sponsor of Terrorism

  4. Future Federal Register

OTHER U.S. GOVERNMENT SOURCES

  1. CBP Cargo Systems Messages

  2. CBP Events in September

  3. Commerce/BIS

  4. DSCA Updates SAMM's Foreign Military Training Report

  5. State/DDTC

  6. White House Executive Actions

NEWS

  1. Diaz: "What Happened This Month in International Trade"

  2. Expeditors News: "CBP Announces Webinar on Combating Unfair Trade"

  3. Hoodline: "South Florida Man Convicted in $900K Plot to Smuggle Aircraft Parts to Russia"

  4. ST&R Trade Report: "Legislative Update: Tariffs, Classification"

  5. WTTL: "Canada Revises Retaliatory Tariffs as U.S. Trade Dispute Deepens"

OPINION

  1. Breaking Defense: "The Fight Over the FY27 Defense Budget is On -- Here are Key Issues for Congress to Resolve"

  2. Pillsbury: "State Department Eases Export Controls on Survivability-Enhanced Aircraft--Key Takeaways"

  3. ST&R Trade Report: "CBP to Require Advance Electronic Rail Export Manifests"

  4. Troutman: "Currents of Control: What the New Executive Order on Bulk-Power System Equipment Means for Your Business"

  5. Volkov: "DOJ's New Fraud Division Memo: A Roadmap to Where Enforcement Is Actually Headed"

EX/IM MOVERS & SHAKERS

  1. Jeremy Huffman Moves to K&L Gates

  2. List of Export/Import Job Openings

EDITOR'S NOTES

  1. Do You Have Access to the Latest and Greatest ITAR and FTR?

  2. Today in History

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

  4. Bartlett's Unfamiliar Quotations

  5. Are your copies of regulations current?

ITEMS FROM THE FEDERAL REGISTER

1. President's Executive Order Prohibits Transactions Involving Foreign Bulk-Power Electric Equipment Tied to a Covered Foreign Entity

(Source: 91 FR 55995, 31 Aug 2026) [Excerpts]

  • AGENCY: Executive Office of the President

  • ACTION: Executive Order 14421 of August 26, 2026: "Declaring a National Emergency To Secure the United States Bulk-Power System"

  • SUMMARY: Section 2 prohibits acquiring, importing, transferring, or installing foreign-produced bulk-power system electric equipment when the transaction involves a foreign country or national's interest, was initiated after the order's date, and the Secretary of Energy---coordinating with OMB and consulting War, Commerce, Homeland Security, and DNI---determines both that: (1) the equipment (or associated components, software, firmware, or services) is designed, made, or supplied by entities owned, controlled, or directed by a Covered Foreign Entity; and (2) the transaction poses undue risk of sabotage, subversion, unauthorized access, or supply disruption; undue risk of catastrophic harm to U.S. critical infrastructure or economic security; or otherwise unacceptable national security risk.

         Once these determinations are made, the Secretary (with the same consulting agencies, minus OMB) may impose conditions on equipment already acquired or installed before the order---requiring it to be identified, isolated, monitored, secured, disconnected, replaced, or removed.

2. State Seeks Comments on ITAR Form DSP-85, Application for Permanent/Temporary Export or Temporary Import of Classified Defense Articles and Classified Technical Data"

(Source: 91 FR 55966, 31 Aug 2026) [Excerpts]

  • AGENCY: State Department

  • ACTION: Notice: "30-Day Notice of Proposed Information Collection: Application for Permanent/Temporary Export or Temporary Import of Classified Defense Articles and Classified Technical Data"

  • SUMMARY: Under Part 123 of the International Traffic in Arms Regulations (ITAR), any person who intends to permanently export, temporarily export, or temporarily import classified defense articles, including classified technical data must first obtain Directorate of Defense Trade Controls authorization.

         The "Application for Permanent/Temporary Export or Temporary Import of Classified Defense Articles and Classified Technical Data" (Form DSP-85) is used to obtain permission for the permanent export, temporary export, or temporary import of classified defense articles, including classified technical data, covered by the U.S. Munitions List (USML).
         This form is an application that, when completed and approved by the Bureau of Political Military Affairs, Directorate of Defense Trade Controls (PM/DDTC), Department of State, constitutes the official record and authorization for all classified commercial defense trade transactions, pursuant to the Arms Export Control Act and the ITAR. The purpose of this Notice is to allow 30 days for public comment.

  • DATE: Comment by September 30, 2026.

3. State Rescinds Determination of Syria as a State Sponsor of Terrorism

(Source: 91 FR 55965, 31 Aug 2026)

  • AGENCY: State Department

  • ACTION: Notice: "Rescission of the State Sponsor of Terrorism Determination Regarding Syria"

  • TEXT: "In accordance with sections 1754 (c) and 1768(c) of the National Defense Authorization Act for Fiscal Year 2019 (50 U.S.C. 4813(c) and 4826(c)), I hereby rescind the Determination of December 29, 1979, regarding Syria, effective August 24, 2026. This action is based upon the considerations contained in the memorandum accompanying the Presidential Report of July 8, 2026, regarding Syria.

         This rescission shall also satisfy the provisions of section 620A(c) of the Foreign Assistance Act of 1961 (22 U.S.C. 2371(c)), and section 40(f) of the Arms Export Control Act (22 U.S.C. 2780(f), and, to the extent applicable, section 6(j) of the Export Administration Act of 1979 (50 U.S.C. App. 2405(j)), and as continued in effect by Executive Order 13222 of August 17, 2001)." By Secretary of State.

  • DATE: August 24, 2026.

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

(Source: Future Federal Register)

OTHER U.S. GOVERNMENT SOURCES:

5. CBP Cargo Systems Messages

(Source: DHS/CBP/CSMS)

  • CSMS # 69711865 - Copper Additional Smelt and Cast Country Detail Error Code Update

  • CSMS # 69710138 - Resolved - Recent Error ASF A44

  • CSMS # 69709869 - Information: Quota Bulletin 26-230 Further Ensuring Affordable Beef Tranche 1

  • CSMS # 69684363 - U.S. Customs and Border Protection publishes Final Rule to require Automated Commercial Environment (ACE) Electronic Export Manifest (EEM) for the Rail Mode of Transportation - Final Rule - 19 CFR Parts 103, 113, 123, and 192

  • CSMS # 69680973 - Registration Now Open: U.S. Customs and Border Protection September 2026 Trade Enforcement Webinars

6. CBP Events in 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. DSCA Updates SAMM's Foreign Military Training Report

(Source: Defense Security Cooperation Agency)

     DSCA posts Policy Memo 26-73 Updates to Chapter 10 Foreign Military Training Report Requirements and Responsibilities.

     This memorandum updates the Security Assistance Management Manual (SAMM), Chapter 10, Section C10.21.2. Foreign Military Training Report (FMTR) to clarify roles, responsibilities, and data requirements for data providers. This memo updates:

  • C10.21.2. Foreign Military Training Report and adds subsections.

  • Table C10.T19. Foreign Military Training Report Applicable Programs

9. State/DDTC (Nothing new.)

(Source: State/DDTC)

10. White House Executive Actions: (No items of interest.)

(Source: The White House)

NEWS

11. Diaz: "What Happened This Month in International Trade"

(Source: Customs & International Trade Law Blog, 31 Aug 2026) [Excerpts]

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

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

Administration:

  • President Trump issued a proclamation imposing section 232 tariffs on certain imported unmanned aircraft systems (UAS), stating that the United States' dependence on foreign-manufactured drones and critical drone components threatens to impair national security.

  • The White House's Office of Trade and Manufacturing Policy published a report discussing transshipment. ...

  • President Trump issued an Executive Order creating a new national-security framework that can block certain foreign-produced electrical-grid equipment from being imported, purchased, transferred, or installed in the United States.

Canada Tariffs:

  • Canada announced that it is imposing tariffs of 15%, 25% or 50% on U.S. goods in a response to new 50% Section 338 tariffs on Canadian goods. The tariff changes match the 338 action dollar for dollar, and cover 6% of U.S. exports to Canada.

Customs and Border Protection (CBP)

  • CBP filed an update with the CIT in the IEEPA refunds case. Over $132 billion in potential and certified refunds have been accepted for processing via CAPE. 272,029 CAPE declarations have been submitted, of which 191,494 passed the file validation. 22,170 refunds, totaling approximately $1.7 billion have not been transmitted to Treasury because ACH information has not been provided.

  • CBP extended the Jones Act Waiver for 90 days -- to November 15, 2026. CBP also implemented a new requirement that companies considering transportation on a foreign-flagged vessel must first send a written request to the Defense Department, the Maritime Administration, and CBP.

  • CBP's Office of Field Operations (OFO) released its 2026-2030 Strategy, outlining what transformations are required to advance OFO's four Core Mission Areas: Secure Lawful Travel, National Security and Contingency Operations, Secure and Compliant Trade and Agriculture and Biological Threat Security.

  • CBP published a federal register notice on August 19, 2026 announcing that, beginning September 18, 2026, it will immediately void importer of record numbers when the information on CBP Form 5106 is inaccurate or incomplete.

  • CBP has delayed the launch of the Consolidated Administration and Processing of Entries (CAPE) refund tool Phase 3. . . .

Courts

  • A group of 25 states led by Oregon, Arizona and California filed a lawsuit at the CIT challenging the Section 301 forced labor tariffs as a violation of the Administrative Procedure Act, alleging that USTR's investigation was rushed and failed to address comments.

  • On August 10, 2026, the Department of Justice filed its opening brief in the consolidated Federal Circuit appeal challenging the Court of International Trade's universal injunctions governing IEEPA duty refunds. . . .

  • The Court of International Trade upheld the Trump Administration's decision to eliminate the de minimis exemption, concluding that IEEPA provides the President with the authority to do so. In reaching its decision, the court rejected the plaintiffs' contention that IEEPA's authorities are confined to common-law property rights.

Department of Justice

  • Everlight Electronics of Taiwan agreed to pay the United States $5.15 million to resolve allegations that they violated the False Claims Act, common law, and the Tariff Act by knowingly failing to pay duties owed on LEDs imported from China.

Office of Foreign Assets Control (OFAC)

  • OFAC announced a $60,764 settlement with Rice Lake Weighing Systems, Inc., a Wisconsin-based manufacturer, to settle potential civil liability for eight apparent violations of OFAC sanctions on Iran.

U.S. Department of Treasury

  • On August 11, 2026, the Department of Treasury's Financial Crimes Enforcement Network (FinCEN) issued a final rule permanently removing the requirement for U.S. companies and U.S. persons to report beneficial ownership information (BOI) under the Corporate Transparency Act (CTA).

U.S. Food and Drug Administration (FDA)

  • The FDA announced that the application window for the Voluntary Qualified Importer Program (VQIP) portal for fiscal year 2027 benefits will close on September 1, 2026.

  • On August 10, 2026, the FDA proposed a rule that would convert its voluntary Generally Recognized as Safe (GRAS) notification program into a mandatory one. Comments are due December 9, 2026.

International

  • China issued a coordinated set of export-control measures on Aug. 5 targeting U.S. entities and certain U.S.-bound goods. . . .

12. Expeditors News: "CBP Announces Webinar on Combating Unfair Trade"

(Source: Expeditors News 28 Aug 2026) [Excerpts]

     In a Cargo Systems Messaging Service (CSMS) bulletin published on August 17, 2026, U.S. Customs and Border Protection (CBP) announced a webinar in partnership with the U.S. Department of Commerce titled "Combating Unfair Trade."
     This webinar will be hosted on Monday September 21, 2026, at 2:00 p.m. Eastern Standard Time and is "designed to help the trade community understand new antidumping and countervailing duty (AD/CVD) orders and empower the public with the knowledge to effectively report suspected AD/CVD violations and file Enforce and Protect Act allegations with CBP."
     Registration is open to the public and advanced registration is required to attend. CSMS #69536147 and a link for registration are HERE.

13. Hoodline: "South Florida Man Convicted in $900K Plot to Smuggle Aircraft Parts to Russia"

(Source: Hoodline News, 30 Aug 2026) [Excerpts]

     A federal jury has convicted a 62-year-old South Florida man and Russian national on all 12 counts he faced for conspiring to illegally ship nearly $1 million worth of U.S. aircraft parts to Russia and its flagship carrier, Aeroflot.
     Alexander Mamonov, a former Aeroflot employee who relocated from Russia to South Florida, now faces sentencing on November 20 before U.S. District Judge Kathleen M. Williams in the Southern District of Florida.
     The case follows the U.S. Department of Commerce's broader tightening of export restrictions after Russia's 2022 invasion of Ukraine.

14. ST&R Trade Report: "Legislative Update: Tariffs, Classification"

(Source: Sandler, Travis & Rosenberg Trade Report, 31 Aug 2026) [Excerpts]. Contact: [email protected], 1-305-894-1035

Tariffs. H.R. 10175 (introduced Aug. 27 by Rep. Hinson, R-Iowa) would repeal section 338 of the Tariff Act of 1930 and nullify certain presidential proclamations imposing a tariff or other duty pursuant to that law.

Classification. H.R. 10147 (introduced Aug. 24 by Reps. Miller, R-W.V., and Sewell, D-Ala.) would amend the Harmonized Tariff Schedule of the U.S. to establish a new subheading in chapter 39 for silicone prosthetics for women who are breast cancer survivors and a new subheading in chapter 90 for mastectomy bras.

15. WTTL: "Canada Revises Retaliatory Tariffs as U.S. Trade Dispute Deepens"

(Source: Washington Tariff & Trade Letter, 28 Aug 2026) [Excerpts of subscription publication]

     The United States and Canada moved deeper into a trade confrontation this week, with Ottawa announcing---and then revising---counter-tariffs on C$27.6 billion in American goods as the Trump administration considered additional penalties and maintained pressure on key Canadian industries.
     The developments from August 24 through August 28 mixed substantive trade actions with limited signs that negotiations might eventually resume. Canada finalized counter-tariffs scheduled for September 8, announced C$7.5 billion in assistance for affected workers and businesses, and adjusted its product list following industry objections. Washington, meanwhile, defended its new duties and reportedly considered further escalation.
     The dispute follows the August 22 implementation of additional 50 percent U.S. tariffs on roughly US$20 billion---C$27.6 billion---of Canadian goods. The Trump administration imposed the duties through three presidential proclamations under Section 338 of the Tariff Act of 1930, targeting products connected to alleged Canadian discrimination involving American motor vehicles, dairy products and alcoholic beverages.
     The tariffs apply to covered goods even when they qualify as originating under the United States-Mexico-Canada Agreement. The White House's Section 338 fact sheet outlines the administration's rationale and product treatment.
     Canada Announces Dollar-for-Dollar Response: . . .

[Full article]

OPINION

16. Breaking Defense: "The Fight Over the FY27 Defense Budget is On -- Here are Key Issues for Congress to Resolve"

(Source: Breaking Defense, 31 Aug 2026) [Excerpts]

     When Congress returns to Capitol Hill in September, lawmakers will face a massive to-do list on defense issues, including a stopgap bill to keep the government open through the midterm election, a supplemental funding plan to cover the Iran war, and the fiscal 2027 defense budget.
     The Pentagon is betting big on a $1.15 trillion discretionary budget request with a further $350 billion coming from the reconciliation process --- together adding up to a historic $1.5 trillion defense budget. But whether the Republican-led Congress can find the political will to pass the full $1.5 trillion sum is very much up in the air, with both chambers in various states of progress.
     The House has yet to pass its version of the FY27 defense appropriations bill, having moved the bill through committee in June. But the Senate is even further behind, with Republican and Democrat leaders of the Senate Appropriations Committee still at a stalemate on how to balance defense and nondefense spending. As a result, Senate appropriators have not yet released the text of the FY27 defense spending bill.
     That situation has had a trickle down effect on passing the National Defense Authorization Act. The House passed the NDAA in July, but Senate Democrats have prevented the upper chamber from bringing its version of the bill to the floor, with members citing the war in Iran and questions about the defense topline as key reasons for blocking the bill. . . .
     Other moving pieces include:

  • The White House's supplemental spending request, which included $67 billion in defense funds meant to replenish US stockpiles and backfill money spent on operations. Neither the House nor the Senate have carved out a path forward for securing this funding.

  • A continuing resolution that would keep funding at FY26 levels when funding expires on Oct. 1. The House and Senate have each passed separate CR bills that extend until early December, and will have to agree on a final version before the Sept. 30 deadline or risk a government shutdown. . . .

[Full article]

17. Pillsbury: "State Department Eases Export Controls on Survivability-Enhanced Aircraft--Key Takeaways"

(Source: Global Trade Blog, 31 Aug 2026) [Excerpts]

  • Principal Author: Stephan E. Becker, Pillsbury Winthrop Shaw Pittman LLP

     On August 28, 2026, DDTC published an IFR easing export controls on certain survivability-enhanced aircraft under the ITAR. This action substantially relaxes ITAR controls on aircraft that have been modified to incorporate aircraft survivability equipment (ASE), and to exclude from ITAR authorization requirements certain reexports and temporary imports of ASE.
     This rule intends to both reduce unnecessary compliance burdens on international partners using secured ASE to protect dignitaries and commercial passengers, and remove the competitive disadvantage for U.S. manufacturers relative to foreign manufacturers whose products are not subject to ITAR jurisdiction.
     The rule will become effective on October 13, 2026, and DDTC is requesting public comments on the rule on or before September 28, 2026.

     Revisions to USML Category VIII(a)(8). The rule revises USML Category VIII(a)(8) to exclude survivability-enhanced aircraft (i.e., manned civil aircraft modified solely to incorporate secured ASE) from the USML. ASE itself is a defense article described in USML Category XI(a)(4) (which describes electronic warfare systems and equipment).

     Previously, any civil aircraft modified to incorporate ASE had been ITAR-controlled, including when the ASE was not physically present in the aircraft because such aircraft are specially designed to incorporate a defense article for the purpose of performing an electronic warfare function.

     New Definitions. To concisely implement the exclusion in USML Category VIII(a)(8), DDTC also added new defined terms in ITAR § 121.0:

  • ASE: Aircraft Survivability Equipment.

  • Secured ASE: Directed infrared countermeasures (DIRCM) systems or infrared/ultraviolet missile warning systems necessary for DIRCM operation, that are incorporated into an aircraft and employ anti-tamper measures to deter, delay and detect unauthorized access to, or exploitation of, critical system components and software.

  • Survivability-enhanced aircraft: A manned aircraft that (1) prior to modification, was a civil aircraft in production described only in ECCN 9A991.b with an FAA or equivalent NATO/major non-NATO ally type certificate; (2) has been modified to incorporate secured ASE; (3) would not otherwise be described in USML Category VIII(a)(8); and (4) is not described in any other USML paragraph.

     New Entries in § 120.54(a). The IFR creates two new activities that are carved out of the definition of export, reexport, retransfer or temporary import. Specifically:

  • New § 120.54(a)(8): Temporarily bringing secured ASE into the United States, provided neither the ASE nor the aircraft in which it is incorporated is transferred to another foreign person while in the United States.

  • New § 120.54(a)(9)*: Taking secured ASE previously exported from the United States pursuant to an ITAR license from one foreign country to another while incorporated into a survivability-enhanced aircraft.

     What Remains Controlled. ASE itself (e.g., prior to being integrated into an aircraft) remains described on the USML in Category XI(a)(4). Defense services directly related to ASE, including assisting a foreign person in modifying an aircraft to incorporate ASE, servicing ASE, and transferring technical data related to ASE, remain controlled. Retransfer of ASE to a foreign person while outside the United States also remains controlled.

18. ST&R Trade Report: "CBP to Require Advance Electronic Rail Export Manifests"

(Source: Sandler, Travis & Rosenberg Trade Report, 31 Aug 2026) [Excerpts]. Contact: [email protected], 1-305-894-1035

     U.S. Customs and Border Protection has issued a final rule that, effective Oct. 26, will require the advance submission of electronic manifests in the Automated Commercial Environment's Electronic Export Manifest system for all rail cargo exports.
     Currently, CBP regulations require a U.S. principal party in interest, the USPPI's agent, or the authorized filing agent of a foreign PPI to transmit electronic export information through ACE. However, EEI is generally only required on shipments that exceed $2,500 per Schedule B number and is generally not required for shipments to Canada.
     Asserting that these limitations inhibit its enforcement efforts, CBP states that this rule "closes the gap" by creating "an integrated pre-departure electronic export manifest which includes receiving advance information for risk assessment purposes from the source most likely to have correct information about the cargo," thereby aligning with existing rail cargo import regulations.
     Specifically, this rule mandates the transmission of EEM data, in addition to required EEI data, for all rail cargo prior to departing the U.S. for Canada or Mexico. The data elements are largely the same mandatory, conditional, and optional data elements included in the rail EEM test CBP has been conducting since 2015.
     Most will have to be submitted two hours before departure of the train from the U.S. port of export, but the rule adds an initial filing of seven data elements to be presented no later than 24 hours prior to such departure: (1) bill of lading number, total cargo numbers and quantities, total cargo weight, precise cargo description, shipper name and address, consignee name and address, and employer identification number, importer record number, or CBP-assigned number, and (2) Automated Export System internal transaction number or Foreign Trade Regulations exemption/exclusion code (conditional).
     The outbound carrier will be responsible for . . .

In addition,. . . [Full article]

19. Troutman: "Currents of Control: What the New Executive Order on Bulk-Power System Equipment Means for Your Business"

(Source: Troutman Pepper Locke, 31 Aug 2026) [Excerpts]

  • Author: Ryan Last, Troutman Pepper Locke LLP

Key Points:

  • Executive Order 14420, signed August 26, 2026, authorizes DOE to prohibit transactions involving foreign-produced bulk-power system electric equipment linked to Covered Foreign Entities, including Chinese companies, when DOE determines the transaction poses an unacceptable national security risk.

  • The Order applies to high-voltage infrastructure operating at or above 69 kV and covers not only physical equipment --- including transformers, inverters, generators, and BESS --- but also associated software, firmware, and remote-access capabilities.

  • DOE has 120 days to publish implementing regulations that will define Covered Foreign Entities, establish licensing procedures, and create pre-qualified vendor lists; until those rules are published, no individual transactions are formally prohibited.

  • Prohibition authority extends retroactively to already-installed equipment, and DOE may require disconnection or removal of existing Covered Equipment after weighing effects on reliability and continuity of service.

  • Companies should immediately conduct supply chain audits, review EPC and financing contracts for change-in-law and force majeure provisions, and participate in the DOE rulemaking to shape Covered Foreign Entity definitions and licensing criteria.

[Full article]

20. Volkov: "DOJ's New Fraud Division Memo: A Roadmap to Where Enforcement Is Actually Headed"

(Source: Volkov Law, 30 Aug 2026) [Excerpts]

  • Principal Author: Michael Volkov, Volkov Law Group LLC

     The Justice Department rarely hands compliance officers a document that spells out its enforcement priorities this directly, but that's essentially what Assistant Attorney General Colin McDonald did this week in a memo to staff of the newly formed National Fraud Enforcement Division. . . .
     A New Division, Built for Scale and Speed. The National Fraud Enforcement Division is being staffed up to roughly 500 attorneys and support personnel this month, with resources reallocated from other parts of the Department to build it out. McDonald described the design philosophy in explicit terms: a division built to be "lean, flat and agile," with reduced bureaucratic layers so that career prosecutors, deployed alongside U.S. Attorneys' Offices around the country, can move directly from investigation to charging decisions.
     That structural choice matters. A flatter, faster-moving enforcement division with dedicated privilege review teams, data science capability, and automated litigation support is built specifically to shorten the time between identifying a fraud pattern and bringing a case.
     This division is distinct from, but will work closely with, the Department's White Collar and Corporate Enforcement Section, the group recently renamed from what had been the Fraud Section. That renaming, paired with the creation of this new division, reflects a deliberate structural separation: one team focused on traditional corporate and white-collar prosecution, and a separate, larger, resource-heavy division built specifically around fraud detection and enforcement at scale, spanning far more territory than corporate misconduct alone.
     Where the Division Will Actually Focus. The scope described in the memo is broad by design, covering public trust, healthcare, tax administration, global trade and commerce, and corporate misconduct. Within healthcare, the memo specifically calls out marketing practices for unsafe products and services that deceive consumers, a signal that healthcare fraud enforcement is not limited to billing and reimbursement schemes but extends to how products and services are marketed to the public in the first place. . . .

[Full article]

EX/IM MOVERS & SHAKERS

21. Jeremy Huffman Moves to K&L Gates

(Source: Editor)

Jeremy Huffman leaves Northrop Grumman Corporation to join K&L Gates LLP as a partner in its Washington, DC office International Trade, Investment Controls, and National Security practice. Contact Jeremy at 202-778-9218 or [email protected].

22. List of Export/Import Job Openings

(Source: Editor)

Submit job openings HERE.

To view job description, click Job ID.

Submit job openings HERE.

(To view job description, click Job ID or Title.)

RECENT:

  • GE Aerospace. Job location: Evendale, OH; Lynn, MA; Norwalk, CT. Title: Lead Specialist, International Trade Compliance. Job ID:R5039226

  • KBR. Job location: Arlington, VA. Title: Counsel, Global Trade Compliance. 

  • Northrop Grumman. Job location: 9 locations Title: Principal International Trade Compliance Analyst – Level 2 or 3. Job ID: R10243563

  • Rapiscan Systems. Job location: Andover, MA. Title: Senior Export Specialist. Job ID: 37435. Contact: Jon Logins, 978-584-6450

  • Teledyne. Job location:  UK - Chelmsford (TDY). Title: Customs Compliance Analyst (EAR/ITAR). Job ID: REQ35221

  • Torres Trade Law. Job location: Dallas, TX. Title: International Trade & National Security Associate. Job ID: 154. Contact: Olga Torres, 214.295.8473

  • US Office of Naval Research. Job location: Naval Research Laboratory, Wash, DC. Title: Export Control Program Manager

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

  • 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

  • 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: 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

  • GE Aerospace. Job location: Evendale, OH; Lynn, MA; Norwalk, CT. Title: Lead Specialist, International Trade Compliance. Job ID:R5039226

  • 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

  • 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

  • KBR. Job location: Arlington, VA. Title: Counsel, Global Trade Compliance. 

  • 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

  • Northrop Grumman. Job location: 9 locations Title: Principal International Trade Compliance Analyst – Level 2 or 3. Job ID: R10243563

  • 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

  • Rapiscan Systems. Job location: Andover, MA. Title: Senior Export Specialist. Job ID: 37435. Contact: Jon Logins, 978-584-6450

  • 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

  • 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 location:  UK - Chelmsford (TDY). Title: Customs Compliance Analyst (EAR/ITAR). Job ID: REQ35221

  • 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

  • Torres Trade Law. Job location: Dallas, TX. Title: International Trade & National Security Associate. Job ID: 154. Contact: Olga Torres, 214.295.8473

  • Tower Semiconductor. Job location: Newport Beach, CA. Title: In-House Legal Counsel. Job ID: 9452. Contact: Alyssa Olaosebikan, 949-435-8549

  • Unical Aviation. Job location: Glendale, AZ. Title: Senior Export Control Manager. Job ID: 2026-0778. Contact: Rebecca Whiteley, 626-949-3325

  • US Office of Naval Research. Job location: Naval Research Laboratory, Wash, DC. Title: Export Control Program Manager

  • 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

23. Do You Have Access to the Latest and Greatest ITAR and FTR?

Bartlett's Annotated ITAR ("BITAR") (28 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 the latest ITAR amendments and over a thousand footnotes showing 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.

BITAR Advertisement _1 Sep 2024_.pdf

Compare the BITAR with the Government's free version

Download this PDF by clicking the button below.

411.65 KB • File

You'll see why all export professionals must use the BITAR and BAFTR.

Subscribe today!

24. Today in History

(Source: History Channel)

1798: America's first bank robbery took place at the Bank of Pennsylvania, an inside job that netted the enormous sum of $162,821 ($4.4 Million today's value). In a bonehead move, the culprit, Isaac Davis, began depositing the missing money in the very bank he had robbed. Davis struck a deal with the governor for a full pardon in exchange for confession and restitution, and never served a day in prison.

1997: Princess Diana died in a car crash. Shortly after midnight on August 31, 1997, Diana, Princess of Wales---affectionately known as Lady Di or "the People's Princess"---died in a car crash in Paris. She was 36 year old at the time of her death. Her boyfriend, the Egyptian-born socialite Dodi Fayed, and the driver of the car, Henri Paul, died as well.

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. Bartlett's Unfamiliar Quotations

(Source: Brainy Quotes)

27. Are Your Copies of Export/Import Regulations Current?

(Source: Editor)

The official versions of the following regulations are published annually in the U.S. Code of Federal Regulations (C.F.R.) but are updated as amended in the Federal Register. The latest amendments are listed below.

DHS CUSTOMS REGULATIONS

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.

DOC EXPORT ADMINISTRATION REGULATIONS (EAR)

15 CFR Subtitle B, Ch. VII, Pts. 730-774.

24 Aug 2026 15 CFR Part 744 (91 FR 54658, 24 Aug 2026) and (91 FR 54657, 24 Aug 2026):

EAR Part 744 was amended to remove Chinese and Turkish entities.

DOC FOREIGN TRADE REGULATIONS (FTR)

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 NATIONAL INDUSTRIAL SECURITY PROGRAM OPERATING MANUAL (NISPOM)

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.

DOJ ATF ARMS IMPORT REGULATIONS

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.

DOS INTERNATIONAL TRAFFIC IN ARMS REGULATIONS (ITAR)

22 C.F.R. Chapter I, Subchapter M, Parts 120-130

28 Aug 2026 (91 FR 55461) and (91 FR 55457): Amendment to Part 121 Cat XI to extend temporary modification of USML Cat XI(b) and to § 120.54 and 121.1 to Remove Certain Civil Aircraft from the USML (effective Oct. 13, 2026).

 (The latest Bartlett's Annotated ITAR ("BITAR") is 28 Aug 2026.)

DOT FOREIGN ASSETS CONTROL REGULATIONS

(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.

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