TABLE OF CONTENTS
FEDERAL REGISTER
Commerce/BIS Seeks Comments on Five-Year Records Retention Requirement for Export Transactions and Boycott Actions
Treasury/OFAC Amends Cuba Sanctions Regulations
Treasury/OFAC Amends Cuba Asset Control Regulations
Treasury/OFAC Amends Iranian Transactions and Sanctions Regulations
Treasury/OFAC Publishes Iran-Related Web General Licenses X and X1
Treasury/OFAC Publishes Russian Harmful Foreign Activities Sanctions Regulations Web General Licenses
Treasury/OFAC Publishes Transnational Criminal Organizations Sanctions Regulations Web General License 2
Treasury/OFAC Publishes Venezuela Sanctions Regulations Web General License 5W
Treasury/OFAC Publishes Venezuela Sanctions Regulations Web General License 5W
Treasury/OFAC Publishes Venezuela Sanctions Regulations Web General Licenses 46D, 47B, 48C, 50C, 51C, 52B, 54B, and 61A
Treasury/OFAC Publishes Venezuela Sanctions Regulations Web General Licenses 52, 53, 54, 55, 56, 57, and 58
Treasury/OFAC Removes Duplicative Penalties Information and Reorganizing Certain Parts
Future Federal Register (No items of interest.)
OTHER GOVERNMENT SOURCES
CBP Cargo Systems Messages
Commerce/BIS (Nothing new.)
DSCA Posts Concurrent Modification Process for Legacy Case Closure
State/DDTC to Remove Syria from ITAR Section 126.1 and to Review the USML and Related Definitions and License Exemptions
Treasury/OFAC Updates SDN List, Counter Terrorism and Transnational Criminal Organizations Designations; Removes Certain Belarus, Counter Narcotics, and Libya Designations
UK Export Control Joint Unit Posts Guidance on How to Apply for an Export Certificate
US Trade Representative: “Ambassador Greer Issues Statement Following the Ministerial Meeting of the Global Forum on Steel Excess Capacity”
White House Actions (No new items of Ex/Im interest.)
NEWS
Breaking Defense: “US Withdraws Last Troops Out of Iraq”
Expeditors News: “CBP Issues Guidance on Canadian Products Excluded from Importation into the U.S.”
ST&R Trade Report: “Customs Broker Continuing Education Hours Must be Completed by Jan. 31”
U.S. News: “US Removes Syria From Arms Export Ban as Trump Administration Draws Closer to New Syrian Government”
OPINION
Baker McKenzie: “UK Introduces Further Sectoral Sanctions Against Iran”
Breaking Defense: “What Boeing’s F/A-XX Win Means for Boeing, and What Challenges Come Next”
ST&R Trade Report: “Two Minutes in Trade - USTR Announces the US-China Board of Trade”
Tuttle Law: “75 Chinese Products Being Considered for Favorable Import Status”
Volkov: “Can DOJ Make an Indictment Disappear?”
TRAINING EVENTS & CONFERENCES
FD Associates Presents: “ITAR FUNdamentals” Livestream Webinar, 6-9 October 2026
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 Seeks Comments on Five-Year Records Retention Requirement for Export Transactions and Boycott Actions
(Source: 91 FR 61821, 30 Sep 2026)
AGENCY: Commerce/Industry and Security Bureau
ACTION: Comment Request; Five-Year Records Retention Requirement for Export Transactions and Boycott Actions
SUMMARY: This collection is necessary under Sections 760 and 762.6(a) of the Export Administration Regulations (EAR). The five-year retention requirement corresponds with the statute of limitations for violations and is necessary to preserve potential evidence for investigations. All parties involved in the export, reexport, transshipment or diversion of items subject to the EAR and the U.S. party involved in the export transaction involving a reportable boycott request are required to maintain records of these activities for a period of five years.
DATE: Public comments were previously requested via the Federal Register on June 24, 2026, during a 60-day comment period. This notice allows for an additional 30 days for public comments.
2. Treasury/OFAC Amends Cuba Sanctions Regulations
(Source: 91 FR 61748, 30 Sep 2026)
AGENCY: Office of Foreign Assets Control, Treasury.
ACTION: Final rule
SUMMARY: OFAC is issuing the Cuba Sanctions Regulations, 31 CFR part 516 (the “Regulations”), to implement E.O. 14404. OFAC is adding regulations to implement a May 1, 2026 Cuba-related Executive order. OFAC intends to supplement these regulations with a more comprehensive set of regulations, which may include additional interpretive guidance and definitions, general licenses, and other regulatory provisions.
DATE: This rule is effective September 30, 2026.
3. Treasury/OFAC Amends Cuba Asset Control Regulations
(Source: 91 FR 61741, 30 Sep 2026)
AGENCY: Office of Foreign Assets Control, Treasury
ACTION: Final rule
SUMMARY: OFA) is amending the Cuban Assets Control Regulations to implement portions of the President's foreign policy toward Cuba, including as directed by National Security Presidential Memorandum-5, “Reissuance of and Amendments to National Security Presidential Memorandum 5 on Strengthening the Policy of the United States Toward Cuba” (2025 NSPM-5).
This rule adds a prohibition on indirect financial transactions with entities or sub-entities on the Cuba Restricted List; amends other authorizations related to financial transactions, including removing an authorization for “U-Turn” transactions; and amends authorizations related to travel and related transactions, including removing authorizations for group people-to-people travel and professional meetings in Cuba.
DATE: This rule is effective September 30, 2026.
4. Treasury/OFAC Amends Iranian Transactions and Sanctions Regulations
(Source: 91 FR 61759, 30 Sep 2026)
AGENCY: Office of Foreign Assets Control, Treasury.
ACTION: Final rule
SUMMARY: OFAC is adopting a final rule amending the Iranian Transactions and Sanctions Regulations to implement certain provisions of a January 10, 2020 Iran-related Executive order. This amendment also revises an existing definition and an existing exemption, and incorporates two exemptions from the January 10, 2020 Iran-related Executive order.
DATE: This rule is effective September 30, 2026.
5. Treasury/OFAC Publishes Iran-Related Web General Licenses X and X1
(Source: 91 FR 61758, 30 Sep 2026)
AGENCY: Office of Foreign Assets Control (OFAC), Treasury.
ACTION: Publication of web general licenses.
SUMMARY: OFAC is publishing two Iran-related general licenses (GLs): GL X and GL X1. These GLs were previously made available on OFAC's website. GL X was revoked and superseded by GL X1. GL X1 has expired.
DATES: GL X was issued on June 21, 2026. See Supplementary Information for additional relevant dates.
6. Treasury/OFAC Publishes Russian Harmful Foreign Activities Sanctions Regulations Web General Licenses 131E, 131F, and 131G
(Source: 91 FR 61762, 30 Sep 2026)
AGENCY: Office of Foreign Assets Control (OFAC), Treasury.
ACTION: Publication of web general licenses.
SUMMARY: OFAC is publishing three general licenses (GLs) issued pursuant to the Russian Harmful Foreign Activities Sanctions Regulations: GLs 131E, 131F, and 131G, each of which was previously made available on OFAC's website.
DATES: GL 131E was issued on April 29, 2026. See Supplementary Information for additional relevant dates.
7. Treasury/OFAC Publishes Transnational Criminal Organizations Sanctions Regulations Web General License 2
(Source: 91 FR 61763, 30 Sep 2026)
AGENCY: Office of Foreign Assets Control (OFAC), Treasury.
ACTION: Publication of a web general license.
SUMMARY: OFAC is publishing a general license (GL) issued pursuant to the Transnational Criminal Organizations Sanctions Regulations: GL 2. This GL was previously made available on OFAC's website.
DATES: GL 2 was issued on June 23, 2026. See Supplementary Information for additional relevant dates.
8. Treasury/OFAC Publishes Venezuela Sanctions Regulations Web General License 5W
(Source: 91 FR 61771, 30 Sep 2026)
AGENCY: Office of Foreign Assets Control (OFAC), Treasury.
ACTION: Publication of a web general license.
SUMMARY: OFAC is publishing a general license (GL) issued pursuant to the Venezuela Sanctions Regulations: GL 5W, which was previously made available on OFAC's website.
DATES: GL 5W was issued on May 4, 2026. See Supplementary Information for additional relevant dates.
9. Treasury/OFAC Publishes Venezuela Sanctions Regulations Web General License 5W
(Source: 91 FR 61775, 30 Sep 2026)
AGENCY: Office of Foreign Assets Control, Treasury.
ACTION: Publication of web general licenses.
SUMMARY: The Department of the Treasury's Office of Foreign Assets Control (OFAC) is publishing seven general licenses (GLs) issued pursuant to the Venezuela Sanctions Regulations: GLs 46C, 47A, 48B, 50B, 51B, 52A, and 54A, each of which was previously made available on OFAC's website.
DATES: GL 46C was issued on June 10, 2026. See Supplementary Information for additional relevant dates.
10. Treasury/OFAC Publishes Venezuela Sanctions Regulations Web General Licenses 46D, 47B, 48C, 50C, 51C, 52B, 54B, and 61A
(Source: 91 FR 61764, 30 Sep 2026)
AGENCY: Office of Foreign Assets Control (OFAC), Treasury.
ACTION: Publication of web general licenses.
SUMMARY: The Department of the Treasury's Office of Foreign Assets Control (OFAC) is publishing eight general licenses (GLs) issued pursuant to the Venezuela Sanctions Regulations: GLs 46D, 47B, 48C, 50C, 51C, 52B, 54B, and 61A, each of which was previously made available on OFAC's website.
DATES: GL 46D was issued on August 27, 2026. See Supplementary Information for additional relevant dates.
11. Treasury/OFAC Publishes Venezuela Sanctions Regulations Web General Licenses 52, 53, 54, 55, 56, 57, and 58
(Source: 91 FR 61771, 30 Sep 2026)
AGENCY: Office of Foreign Assets Control (OFAC), Treasury.
ACTION: Publication of web general licenses.
SUMMARY: The Department of the Treasury's Office of Foreign Assets Control (OFAC) is publishing seven general licenses (GLs) issued pursuant to the Venezuela Sanctions Regulations: GLs 52, 53, 54, 55, 56, 57, and 58, each of which was previously made available on OFAC's website.
DATES: GL 52 was issued on March 18, 2026. See Supplementary Information for additional relevant dates.
12. Treasury/OFAC Removes Duplicative Penalties Information and Reorganizing Certain Parts
(Source: 91 FR 61727, 30 Sep 2026)
AGENCY: Office of Foreign Assets Control (OFAC), Treasury.
ACTION: Final rule.
SUMMARY: OFAC is removing duplicative regulatory provisions in 31 CFR Parts 510, 525, 526, 528, 535, 536, 539, 544, 546, 547, 548, 549, 551, 552, 553, 555, 558, 560, 561, 562, 566, 569, 570, 576, 578, 579, 582, 583, 584, 586, 587, 588, 589, 590, 591, and 594, and adding a provision to those parts directing readers to the Sanctions Penalties Regulations where the information is located. OFAC is also moving to an expanded subpart at the beginning of each part information regarding delegations of authority, recordkeeping and reporting requirements, and the Paperwork Reduction Act within multiple parts of the Office of Foreign Assets Control chapter of the CFR.
DATES: This rule is effective September 30, 2026.
13. Future Federal Register (No items of interest.)
(Source: Future Federal Register)
U.S. Customs and Border Protection; Notices; Certain Immigration-Related Fees Required by the One Big Beautiful Bill Act: Fiscal Year 2027 Adjustments for Inflation. Scheduled Pub. Date: 1 Oct 2026. Permalink
U.S. Customs and Border Protection; Notices; Agency Information Collection Activities; Proposals, Submissions, and Approvals: Entry. Scheduled Pub. Date: 1 Oct 2026. Permalink
U.S. Customs and Border Protection; Notices; Agency Information Collection Activities; Proposals, Submissions, and Approvals: Entry Summary. Scheduled Pub. Date: 1 Oct 2026. Permalink
State Department; Rules; International Traffic in Arms Regulations: Syria Country Policy Revision. Scheduled Pub. Date: 1 Oct 2026. Permalink
State Department; Proposed Rules; International Traffic in Arms: Review of the U.S. Munitions List and Related Definitions and License Exemptions. Scheduled Pub. Date: 1 Oct 2026. Permalink
OTHER U.S. GOVERNMENT SOURCES
14. CBP Cargo Systems Messages
(Source: DHS/CBP/CSMS)
15. Commerce/BIS (Nothing new.)
(Source: Commerce/BIS)
16. DSCA Posts Concurrent Modification Process for Legacy Case Closure
DSCA has posted Policy Memo 26-55 Concurrent Modification Process for Legacy Case Closure. This memorandum provides an update to the Security Assistance Management Manual (SAMM) and establishes guidance on Concurrent Modifications in support of legacy case closure activities consistent with DSCA 25-97. This policy standardizes execution across Implementing Agencies (IAs) by clarifying legacy case closure Concurrent Modification procedures and authorizing minimal-dollar value lines on Basic cases.
This memo:
Adds C16.4.7. Using Concurrent Modification Process to Consolidate Cases (and subsections)
Adds terms Legacy Foreign Military Sales (FMS) Case and Sister Foreign Military Sales (FMS) Case to the ESAMM Glossary
17. State/DDTC to Remove Syria from ITAR Section 126.1 and to Review the USML and Related Definitions and License Exemptions
(Source: State/DDTC, 30 Sep 2026)
Removal of Syria from Section 126.1: On September 30, 2026, the Department placed on public inspection in the Federal Register a final rule, effective October 1, 2026, revising the International Traffic in Arms Regulations (ITAR) to remove Syria from the list of countries in ITAR § 126.1.
Review of the U.S. Munitions List and Related Definitions and License Exemptions: On September 30, 2026, the Department placed on public inspection in the Federal Register a rule that proposes to remove certain items from the U.S. Munitions List (USML).
The rule also proposes changes to improve the transparency and clarity of the ITAR. This rule is in furtherance of the President’s April 9, 2025, Executive Order 14268, “Reforming Foreign Defense Sales to Improve Speed and Accountability,” which directed the Department to review the USML to ensure that it focused on our most sensitive and sophisticated technologies.
The Department assesses that the items proposed for removal no longer provide a critical military or intelligence advantage. This rule includes a proposal to narrow the USML’s broadest control paragraph, which describes items specially designed for military submarines, to narrow every catch-all control on the USML, and to remove certain other items. Additionally, the rule proposes an exemption for the temporary export of a foreign defense article to its manufacturer for certain activities.
The Department is seeking public comments on this rule for 60 days. Interested parties may submit comments by November 30, 2026, using one of the methods described in the proposed rule.
18. Treasury/OFAC Updates SDN List, Counter Terrorism and Transnational Criminal Organizations Designations; Removes Certain Belarus, Counter Narcotics, and Libya Designations
(Source: Treasury/OFAC, 30 Sep 2026)
The SDN list has recently been updated. Please 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. Please visit this link for more information on today's update.
19. UK Export Control Joint Unit Post Guidance on How to Apply for an Export Certificate
(Source: UK ECJU, 30 Sep 2026)
Guidance: Applying for an export certificate”. How to apply for an export certificate, including a Certificate of Free Sale, Certificate of Manufacture and Certificate of Good Manufacturing Practice.
Contents:
20. US Trade Representative: “Ambassador Greer Issues Statement Following the Ministerial Meeting of the Global Forum on Steel Excess Capacity”
(Source: USTR Press Office, 30 Sep 2026)
Today, Ambassador Jamieson Greer chaired the Ministerial Meeting of the Global Forum on Steel Excess Capacity, which reached consensus on a comprehensive framework for joint action (“the Milwaukee Framework”). Ambassador Greer highlighted the effective actions taken by the Trump Administration to address global steel excess capacity and its impacts, including on U.S. manufacturers and workers, and invited like-minded partners to take similar steps to more fully address excess capacity and the global market distortions it causes. …
Read the Milwaukee Framework here. Read the Global Forum on Steel Excess Capacity's Ministerial statement here.
21. White House Actions (No new items of Ex/Im interest.)
(Source: The White House)
NEWS
22. Breaking Defense: “US Withdraws Last Troops Out of Iraq”
(Source: Breaking Defense, 30 Sep 2026) [Excerpts]
The United States announced it has now withdrawn its remaining military forces from Iraq, marking the end to operations that began more than two decades ago.
The last of US forces and equipment departed from Erbil Air Base, completing the withdrawal agreed to by Washington and Baghdad in 2024, US Central Command (CENTCOM) announced today in a statement.
“The primary responsibility for addressing Iraq’s remaining security challenges, including ISIS remnants and Iran-aligned militias that undermine Iraqi sovereignty and regional stability, now rests with the Government of Iraq,” Chief Pentagon Spokesman Sean Parnell said in a separate statement.
“The United States remains committed to counterterrorism and will continue to work with Iraq and our partners to ensure ISIS can never reconstitute from Iraqi territory,” he added. … [Continue]
23. Expeditors News: “CBP Issues Guidance on Canadian Products Excluded from Importation into the U.S.”
(Source: Expeditors News, 29 Sep 2026)
On September 28, 2026, U.S. Customs and Border Protection (CBP) published a bulletin via its Cargo Systems Messaging Service (CSMS) providing implementation guidance for Presidential Proclamations 11061, 11062, and 11063, which identify certain Canadian-origin products as to be "excluded from importation" into the U.S.
According to the bulletin, as of 12:01 a.m. Eastern Time on September 29, 2026, any entry that contains products covered by the three proclamations "will be unconditionally rejected" by CBP.
Products entered into a Customs bonded warehouse or admitted prior to the exclusions taking effect "may be withdrawn for consumption and will be subject to the 50 percent ad valorem duty under Presidential Proclamations 11046, 11047, and 11048, as applicable."
The CSMS bulletin also provides guidance on the scope of alcoholic beverages subject to the exclusion and outlines new reject messaging added to the Automated Commercial Environment (ACE) to support the enforcement of the exclusion.
CSMS # 70050970, which includes annexes listing covered products, is HERE.
24. ST&R Trade Report: “Customs Broker Continuing Education Hours Must be Completed by Jan. 31”
(Source: Sandler, Travis & Rosenberg Trade Report, 30 Sep 2026) [Excerpts]. Contact: [email protected], 1-305-894-1035
U.S. Customs and Border Protection has issued a notice reminding customs brokers that they must complete 20 hours of continuing education no later than Jan. 31, 2027. CBP is urging brokers not to wait for that deadline to certify CE credits or file their triennial status report.
Continuing Education Requirements. Under a June 2023 final rule CBP is requiring individual customs broker license holders to complete at least 36 CE credits per triennial period, which works out to an hour per month. However, because brokers were not able to begin completing qualified CE courses until Jan. 1, 2025, CBP is only requiring 20 credits for the triennial period ending Jan. 31, 2027.
In addition, brokers who obtain their licenses in 2024, 2025, or 2026 do not need to obtain CE credits until the 2027-2030 triennial period. …
According to CBP, accredited training will have the CE logo visible, and accredited providers and eligible activities can be found here. Brokers must retain proof of CE completion (certificates, course codes, course names, dates, educators’ names, and/or transcripts) for at least three years for audit purposes.
CBP states that a percentage of brokers will be chosen to show their records once each triennial reporting period has ended and that for the current period the audited brokers will be selected and notified after March 2027. [Full article]
25. U.S. News: “US Removes Syria From Arms Export Ban as Trump Administration Draws Closer to New Syrian Government”
(Source: U.S. News & World Report, 30 Sep 2026) [Excerpts
The Trump administration is removing Syria from a list of countries that are not allowed to purchase or import U.S. weaponry, a step that is part of a monthslong process of easing sanctions on the new government in Damascus and its leaders.
In an advance notice published Wednesday in the Federal Register (formal notice to be published tomorrow), the State Department said it was amending its International Traffic in Arms Regulations, or ITAR, so that Syria no longer was among the nations subject to a policy of denial for licenses and other approvals needed for the sale of U.S. weapons and munitions.
The change effective Thursday means that arms sales requests from Syria will now be considered on a case-by-case basis. The State Department has also announced plans to reopen the U.S. Embassy in Damascus. It has been closed for 14 years.
With Syria’s removal from the ITAR blacklist, only seven countries remain subject to the policy of denial for licenses for U.S. arms exports: Belarus, China, Cuba, Iran, Myanmar, North Korea and Venezuela. … [Continue]
OPINION
26. Baker McKenzie: “UK Introduces Further Sectoral Sanctions Against Iran”
(Source: Global Sanctions and Export Controls Blog, 30 Sep 2026) [Excerpts]
* Principal Author: Ben Smith (UK); Baker McKenzie
On 29 September 2026, a range of new and expanded UK sanctions targeting Iran entered into force, following the publication on 8 September 2026 of the Iran (Sanctions) (Amendment) Regulations 2026 (the “Regulations“).
The Regulations amend both the Iran (Sanctions) Regulations 2023, which principally address human rights abuses and hostile activity by Iran, and the Iran (Sanctions) (Nuclear) (EU Exit) Regulations 2019, which seek to restrict Iran’s ability to develop nuclear weapons and implement certain UN obligations. Certain of these measures are in line with those previously lifted in 2016 pursuant to the Iran nuclear deal.
As explained below, this is further to Iran sanctions developments globally, including recent action taken by the US, EU and UAE. …
[Continue]
27. Breaking Defense: “What Boeing’s F/A-XX Win Means for Boeing, and What Challenges Come Next”
(Source: Breaking Defense News, 29 Sep 2026) [Excerpts]
Boeing has emerged the champion to build the Navy’s sixth-generation strike fighter — beating out competitor Northrop Grumman to produce the aircraft that will replace the service’s aging F/A-18 Super Hornet and EA-18G Growler fighter jets.
But while the more than $20 billion win gives Boeing a stranglehold on America’s sixth-generation fighter fleets, the challenge now is making sure the company can execute, according to analysts who spoke to Breaking Defense ahead of the contract decision.
To be sure, today’s win cements a major turnaround for Boeing’s defense arm. After years of struggling with major aircraft programs, including executing on the KC-46 tanker and T-7 trainer, Boeing’s March 2025 award of the Air Force’s F-47 fighter marked an earlier turning point for the company. …
Stacie Pettyjohn, a senior fellow and director of the defense program at the Center for a New American Security, voiced similar sentiments, saying that winning F/A-XX represents “a complete pendulum swing for Boeing, going from thinking that they’re going to be closing their fighter lines to having both of the big contracts for sixth-generation fighters.”
However, analysts warned, there are potential challenges ahead as Boeing attempts to execute a series of major production efforts.
“The first question that comes to mind is how quickly they can produce a workable F/A-XX, which is really a question of how much it’s based on the F-47 that they’ve already developed,” Jeremiah Gertler, a senior advisor at AeroDynamic Advisory and former military aviation analyst for the Congressional Research Service, told Breaking Defense. … [Continue]
28. ST&R Trade Report: “Two Minutes in Trade - USTR Announces the US-China Board of Trade”
(Source: Sandler, Travis & Rosenberg Trade Report, 29 Sep 2026) [Excerpts]. Contact: [email protected], 1-305-894-1035
$60 Billion in possibilities—$0 Billion in tariff cuts. USTR announced the formation of the US-China Board of Trade. Listen for more on Two Minutes In Trade.
Listen to ST&R Trade Report HERE.
29. Tuttle Law: “75 Chinese Products Being Considered for Favorable Import Status”
(Source: Author).
* Author: George Tuttle, Law Offices Of George R. Tuttle, PC, 415-986-8780
On September 27, the Office of the U.S. Trade Representative (USTR) provided a list of more than 75 Chinese products for import into the U.S. that are being considered for more favorable status.
“As a direct result of the strong relationship between President Trump and President Xi, the United States and China, under the auspices of the new Board of Trade, have recommended $30 billion of trade in non-sensitive goods on each side that could benefit from more favorable tariff treatment in the future,” U.S. Trade Representative Jamieson Greer said in a statement.
Certain U.S. exports to China are also under review for more favorable consideration. The result would be approximately $30 billion in imports for each country being given favorable import status.
Information about the working procedures of the U.S.-China Board of Trade, can be found here with further clarification of the terms of reference the 30-for-30 framework available here.
Listings for the products being considered for favorable trade status by the board of trade can be accessed below:
China Imports to the U.S.
30. Volkov: “Can DOJ Make an Indictment Disappear?”
(Source: Volkov Law. 29 Sep 2026) [Excerpts]
* Principal Author: Michael Volkov, Volkov Law Group LLC
For anyone hoping a friendlier DOJ can make their old charges disappear, a federal judge just reminded us that vanishing requires his or her permission.
Big development out of Brooklyn federal court. DOJ tried to drop the remaining bribery and obstruction charges against executives tied to Indian billionaire Gautam Adani. The judge said no.
Judge Nicholas Garaufis ruled that Deputy AG Trent McCotter’s justification for dismissal didn’t include the actual facts needed to support it, just conclusions. McCotter argued weak U.S. jurisdictional ties. Garaufis said essentially: show me the facts, not just the argument.
He’d already rejected an earlier diplomatic strain argument too, noting some conduct happened right here in the U.S. There’s real context here. Reporting suggests DOJ’s posture shifted after Adani’s team hired a lawyer personally connected to the president.
None of that decided the legal question, but it’s exactly why a court might scrutinize DOJ’s reasoning more closely instead of rubber-stamping it.
Here’s why this matters beyond one case: a change in DOJ’s political priorities doesn’t automatically make an indictment disappear. Courts still have to sign off. Don’t assume that a friendlier enforcement climate erases charges already on the books.
TRAINING EVENTS & CONFERENCES
31. FD Associates Presents: “ITAR FUNdamentals” Livestream Webinar, 6-9 October 2026
(Source: Jenny Hahn, [email protected])
* What: “ITAR FUNdamentals” Workshop Webinar
* Where: At Your Computer
* When: 6 October (Tuesday) - 9 October (Friday), 2026 — 9am to 1pm Eastern
* Summary: This workshop is delivered over four 1/2-day sessions. It is a hands-on workshop for beginners or companies newly exposed to the ITAR. It is also a useful refresher for anyone needing to get up to speed with the latest changes to the ITAR of State Department requirements for licensing defense articles or defense services.
* Presenters: Jenny Hahn, President; John Herzo, Senior Compliance Associate; Odyssey Gray, Senior Associate - FC Associates
* Sponsor: FD Associates, Inc.
* Register: HERE. The fourth participant from the same company is free. For more information call 703-847-5801 or email HERE.
EX/IM MOVERS & SHAKERS
Submit job openings HERE.
(To view job description, click Job ID or Title.)
32. List of Export/Import Job Openings
(Source: Editor)
RECENT:
Anduril Industries. Job location: Sydney, Australia (will consider U.S. Person relocation). Title: International Trade and Compliance Leader, APAC. Job ID: 5246828007
Caterpillar. Job locations: Washington, DC; Irving, TX; Peoria, IL. Title: Senior Corporate Counsel, Compliance - Customs. Job ID: R0000365977
ConocoPhillips. Job location: Houston, TX. Title: Analyst, Trade Compliance. Job ID: REQ-006574
ConocoPhillips. Job location: Houston, TX. Title: Senior Counsel, Import and Trade Compliance. Job ID: REQ-006578
IDD Aerospace. Job location: Redmond, WA. Title: Trade Compliance Specialist. Job ID: 8626. Contact: Anne Singh, 1-425-628-5983
Lockheed Martin. Job locations: Syracuse, NY; Owego, NY. Title: International Trade Compliance, Senior Staff. Job ID: 733880BR. Contact: Rebecca Edwards, 1-203-540-7922
Mercedes-Benz. Job location: Atlanta, GA. Title: Senior Counsel, Export Compliance. Job ID: LI-ST1
TE Connectivity. Job location: Hybrid in Wayne, PA, or Greensboro, NC. Title: Senior Manager, Global Trade Services - Automotive. Job ID: 158441
US National Institute of Standards and Technology. Job location: Gaithersburg, MD. Title: Export Control Manager
FULL LIST (Includes above entries.):
Alcon Research. Job location: Fort Worth, TX. Title: International Trade Counsel - Global Trade Compliance. Job ID: R-2026-46235
Altimeter Solutions. Job location: Londonderry, NH. Title: Remote Export Compliance Coordinator. Job ID: JP6978
Amazon Global Logistics. Job location: U.S. Remote. Title: Customs Compliance Specialist. Job ID: 10538268
Anduril Industries. Job location: Sydney, Australia (will consider U.S. Person relocation). Title: International Trade and Compliance Leader, APAC. Job ID: 5246828007
Anduril Industries. Job locations: Costa Mesa, CA; Washington, DC. Title: Director of 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, 1-734-761-5836
Arrow. Job location: Denver, CO. Title: Director, Global Trade Compliance Counsel
AV. Job locations: 10 U.S. 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
Barnes & Thornburg. Job location: Washington, DC. Title: International Trade Associate
Castelion. Job location: Torrance, CA. Title: Senior Counsel, Trade & Export Compliance
Caterpillar. Job locations: Washington, DC; Irving, TX; Peoria, IL. Title: Senior Corporate Counsel, Compliance - Customs. Job ID: R0000365977
Caterpillar. Job location: Jakarta, Indonesia. Title: Trade Compliance Analyst. Job ID: R0000395158
Caterpillar. Job location: Singapore. Title: Manager Regional Trade Compliance
Caterpillar. Job location: Fort Worth, TX. Title: Trade Risk & Compliance Professional. Job ID: R0000384556
ConocoPhillips. Job location: Houston, TX. Title: Analyst, Trade Compliance. Job ID: REQ-006574
ConocoPhillips. Job location: Houston, TX. Title: Senior Counsel, Import and Trade Compliance. Job ID: REQ-006578
Continental Electronics. Job location: Richardson, TX. Title: Trade Compliance Analyst. Job ID: 36830. Contact: Maria Jabara, 1-310-658-7787
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, 1-864-875-1659
Entegris. Job location: Chaska, MN. Title: Senior Trade Compliance Specialist. Job ID: REQ-13241
Expeditors. Job location: Noorderlaan, Antwerpen, Belgium. Title: Customs Brokerage Agent
Expeditors. Job locations: Brisbane, CA; Grapevine, TX. Title: Customs Brokerage Agent
Export Compliance Solutions & Consulting. Job location: U.S. Remote. Title: Sales Representative-Software Sales. Contact: Suzanne Palmer
GE Aerospace. Job locations: Evendale, OH; Lynn, MA; Norwalk, CT. Title: Lead Specialist, International Trade Compliance. Job ID: R5039226
General Atomics. Job locations: San Diego, CA (hybrid) or another U.S. location including Washington, DC; Huntsville, AL; Tupelo, MS; Denver, CO. Title: Senior Trade Compliance Integrator. Job ID: 52696BR. Contact: James Van Eenenaam
General Atomics Aeronautical Systems. Job location: San Diego (Poway), CA (hybrid). Title: Senior Director, International Trade Compliance. Job ID: 54950BR. Contact: Arthur Shulman
General Dynamics. Job location: Scranton, PA. Title: Regulations Compliance Specialist II. Job ID: 2026-35876
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
Honeywell Aerospace. Job location: Charlotte, NC. Title: Trade Compliance General Counsel. Job ID: 147681
Horizon3 AI. Job location: U.S. Remote. Title: Senior Legal, Privacy & Export Compliance
IDD Aerospace. Job location: Redmond, WA. Title: Trade Compliance Specialist. Job ID: 8626. Contact: Anne Singh, 1-425-628-5983
Immigration & Customs Enforcement (ICE). Job location: Birmingham, AL. Title: General Attorney, Immigration and Customs
Leonid. Job locations: Rancho Cordova, CA; North Canton, OH; Plainfield, IL. Title: Trade Compliance Program Manager
Leonid. Job location: Hybrid (Toulouse, Occitanie, France). Title: Export Controls Investigations Specialist
Lockheed Martin. Job locations: Syracuse, NY; Owego, NY. Title: International Trade Compliance, Senior Staff. Job ID: 733880BR. Contact: Rebecca Edwards, 1-203-540-7922
Lockheed Martin. Job location: Hybrid. Title: Operations Team Lead - Senior Staff - U.S. Export - Level 5
Mastronardi Produce. Job location: Livonia, MI. Title: Customs Manager (Certified Customs Specialist). Job ID: CUSTO011196. Contact: Tiziana Mastronardi, 1-519-796-7710
McCarter & English. Job locations: Newark, NJ; Stamford, CT; New York, NY. Title: Trade Specialist. Job ID: 001. Contact: Christine Lydon
Medtronic. Job location: Washington, DC. Title: Principal Legal Counsel, Global Trade Legal & Compliance (Import)
Mercedes-Benz. Job location: Atlanta, GA. Title: Senior Counsel, Export Compliance. Job ID: LI-ST1
Mercedes-Benz. Job location: U.S. Remote/Hybrid. Title: Senior Counsel, Export Compliance (Contractor). Job ID: Legal (4031)
Northrop Grumman. Job locations: 9 locations. Title: Principal International Trade Compliance Analyst. Job ID: R10240096
Northrop Grumman. Job locations: 9 locations. Title: Principal International Trade Compliance Analyst - Level 2 or 3. Job ID: R10243563
PCC Airfoils. Job location: Douglas, GA. 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 locations: DC Metro Area; Denver, CO; San Francisco, CA; 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
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, 1-978-584-6450
Rieter AG. Job location: Winterthur, Switzerland. Title: Head of Trade Compliance. Contact: Jasmin Bauer
Sidley Austin. Job location: Washington, DC. Title: International Trade Analyst. Job ID: LI-KG1
SpaceX. Job location: Washington, DC. Title: Counsel, Global Trade Compliance
SpaceX. Job location: Hawthorne, CA. Title: Counsel, Global Trade Compliance
SpaceX. Job location: Starbase, TX. Title: Counsel, Global Trade Compliance
TE Connectivity. Job location: Hybrid in Wayne, PA, or Greensboro, NC. Title: Senior Manager, Global Trade Services - Automotive. Job ID: 158441
Teledyne. Job location: Chelmsford, UK (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 locations: Garland, TX; Billerica, MA; Elkridge, MD. Title: Trade Compliance Director, Aerospace & Electronics Segment. Job ID: REQ33489
TikTok. Job location: Washington, 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, 1-214-295-8473
Tower Semiconductor. Job location: Newport Beach, CA. Title: Export and Trade Compliance Director. Job ID: 9597. Contact: Alyssa Olaosebikan, 1-949-435-8549
Unical Aviation. Job location: Glendale, AZ. Title: Senior Export Control Manager. Job ID: 2026-0778. Contact: Rebecca Whiteley, 1-626-949-3325
U.S. Department of Commerce. Job location: Washington, DC. Title: Director, Office of Antiboycott Compliance (GS-15)
U.S. Customs & Border Protection. Job location: Seattle, WA. Title: General Attorney, Office of Chief Counsel
US National Institute of Standards and Technology. Job location: Gaithersburg, MD. Title: Export Control Manager
Zygo. Job location: Middlefield, CT. Title: Trade Compliance Specialist. Job ID: 70100. Contact: James Scroggins, 1-860-652-2971
EDITOR'S NOTES
33. Do You Have Access to the Latest and Greatest ITAR and FTR?
Bartlett's Annotated ITAR ("BITAR") (18 Sept 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).
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.
34. Bartlett's Unfamiliar Quotations
(Source: Brainy Quotes)
Rumi (Jalāl ad-Dīn Muhammad Rūmī; 30 Sep 1207 – 17 Dec 1273; was a poet, faqih, Islamic scholar, theologian, and Sufi mystic originally from Greater Khorasan in Greater Iran. His poems have been widely translated into many languages. His "Masnavi" composed in Konya, is considered one of the greatest poems of the Persian language.)
"Listen! Clam up your mouth and be silent like an oyster shell, for that tongue of yours is the enemy of the soul, my friend."
“Don't grieve. Anything you lose comes round in another form.”
“May this marriage be full of laughter, our every day in paradise.”
Elie Wiesel (born Eliezer Wiesel; 30 Sep 1928 – 2 Jul 2016; was a Romanian-born American writer, professor, political activist, Nobel laureate, and Holocaust survivor. He authored 57 books, written mostly in French and English, including Night, a work based on his experiences as a Jewish prisoner in the Auschwitz and Buchenwald concentration camps.)
“Indifference, to me, is the epitome of evil.”
“I do not recall a Jewish home without a book on the table.”
“Human beings should be held accountable. Leave God alone. He has enough problems.”
35. Today in History
(Source: History Channel)
1947: World Series broadcast on TV for first time on September 30. The New York Yankees beat the Brooklyn Dodgers, 5-3, in Game 1 of the World Series. It was the second "Subway Series" between and Yankees and Dodgers and first World Series to involve a Black player. Jackie Robinson of the Dodgers broke Major League Baseball's color barrier six months earlier.
1954: USS Nautilus—world’s first nuclear submarine—is commissioned. The Nautilus was constructed under the direction of U.S. Navy Captain Hyman G. Rickover, a brilliant Russian-born engineer who joined the U.S. atomic program in 1946. In 1947, he was put in charge of the navy’s nuclear-propulsion program and began work on an atomic submarine. Regarded as a fanatic by his detractors, Rickover succeeded in developing and delivering the world’s first nuclear submarine years ahead of schedule. Commissioned on September 30, 1954, it first ran under nuclear power on the morning of January 17, 1955. The USS Nautilus was decommissioned on 3 March 1980 after approximately 25 years of service.
36. 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.
37. 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 54658, 24 Aug 2026) and (91 FR 54657, 24 Aug 2026):
EAR Part 744 was amended to remove Chinese and Turkish entities.
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
Sep. 23, 2026 (91 FR 60299): Corrections to § 125.4 Exemptions of general applicability and § 126.1 Prohibited exports, imports, and sales to or from certain countries.
(The latest edition of Bartlett's Annotated ITAR ("BITAR") is 23 Sep 2026)
(OFAC FACR): 31 CFR, Parts 500-599, Embargoes, Sanctions, Executive Orders
“Title 31 was last amended 9/30/2026, amending numerous OFAC sanctions regulations, including: 31 CFR Parts 510, 525, 526, 528, 535, 536, 539, 544, 546, 547, 548, 549, 551, 552, 553, 555, 558, 560, 561, 562, 566, 569, 570, 576, 578, 579, 582, 583, 584, 586, 587, 588, 589, 590, 591, and 594.