26-1006: Tuesday's "Export/Import Daily Bugle"

1. Today's Federal Register (No items of interest.)

(Source: Today's Federal Register)

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

(Source: Future Federal Register)

3. CBP Cargo Systems Messages

(Source: DHS/CBP/CSMS) (No new items.)

4. CBP Events in October 2026

(Source: OTR Webinars)

     Editor's Note: As of this writing CBP has not updated its current web page, which lists CBP events scheduled for August and September, and states, "October webinars coming soon!"

5. CBP Reminder: Licensed Customs Brokers Must Complete Continuing Education by 31 Jan 2027

(Source: CBP Continuing Education, 1 Oct 2026)

     "Dear Licensed Customs Broker: To maintain your license, you are required to complete 20 hours of Continuing Education (CE) no later than January 31, 2027. Don't wait until the last minute. Failure to meet these requirements will result in the revocation of your customs broker's license.
     If you have not yet done so, start your CE training today. Visit the Customs Broker Triennial Status Report (TSR) and Continuing Education (CE) Requirements | U.S. Customs and Border Protection and Customs Broker Continuing Education | U.S. Customs and Border Protection webpages.
     CE Requirements: Individual brokers are required to complete 20 hours of CE credits to maintain their license for the current triennial.

     TSR Requirements: Filing the TSR requires that individual brokers with an active license: certify CE compliance, provide CBP with current contact information, and pay the triennial fee.

     CBP recommends that brokers file their TSR as soon as their CE credits are complete. The deadline to complete the 20 hours of CE credits is January 31, 2027."

6. Commerce/BIS (Nothing new.)

(Source: Commerce/BIS)

7. State/DDTC (Nothing new.)

(Source: State/DDTC)

8. Treasury/OFAC Updates SDN List, Amends Iran FAQs

(Source: Treasury/OFAC, 5 Oct 2026)

     The Department of the Treasury's Office of Foreign Assets Control (OFAC) is publishing an Iran-related Alert, "Notice to Foreign Financial Institutions Conducting Business with Iran."
     OFAC is publishing one amended Iran-related Frequently Asked Question (FAQ 156).
     OFAC recently updated the SDN list. Visit this page to access the latest version.

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

(Source: The White House)

10. Breaking Defense: "Boeing Nabs Potential $14.7 Billion PAC-3 Seeker Contract"

(Source: Breaking Defense News, 6 Oct 2026)

     Aerospace giant Boeing has been awarded an undefinitized contract worth up to $14.7 billion to boost production of seekers for the PAC-3 Missile Segment Enhancement (MSE) interceptor, a key system used by Western allies for air defense, the company said today.
     In a press release, Boeing revealed the contract was issued as a seven-year deal by Lockheed Martin, which manufactures the PAC-3. The PAC-3 MSE is a hit-to-kill interceptor launched by the Patriot air defense system to bat down threats like missiles and aircraft. . . .
     In its release, Boeing notes that the company began ramping up production and surging hiring earlier this year at its facilities in Huntsville, Ala., to support increased production. Historically, the missile's seeker has reportedly been a choke point for PAC-3 output.

11. Expeditors News: "CBP Issues WRO on Certain Palm Oil Product Manufacturers"

(Source: Expeditors News) [Excerpts]

     In a press release on September 29, 2026, U.S. Customs and Border Protection (CBP) announced the issuance of Withhold Release Order (WRO) on palm oil and palm oil derivative products produced by Mitra Aneka Rezeki (MAR) and Hardaya Inti Plantation (HIP) in Indonesia.
     The WRO was issued following a CBP investigation and review of information indicating that these manufacturers use forced labor to produce their goods. CBP will detain shipments of these products at all U.S. ports of entry, effective immediately.
     The WRO is HERE.

12. Sanctions.com: "BIS Reaches Conditional Settlement with Suspended $2 Million Penalty for Lambda Research Corporation"

(Source: Sanctions.com, 6 Oct 2026)

     The Bureau of Industry and Security reached a conditional settlement with Lambda Research Corporation that would impose a $2 million civil penalty for 66 violations of the Export Administration Regulations.
     Payment will be suspended for one year and then waived if the Massachusetts software company complies with the settlement and commits no further violations. Failure to meet the terms could activate the full penalty immediately.
     Most of the violations arose from automatic software updates, which BIS treated as individual exports. Lambda transmitted 47 updates to Huawei Technologies Japan K.K. and seven to Shenzhen SiCarrier Technologies Co. Ltd. without required licenses after the companies were placed on the Entity List.
     The conduct occurred from April 2021 through August 2025 and involved optical and illumination design software classified as EAR99. Lambda also admitted conduct underlying 11 charges of acting with knowledge of a violation involving Huawei Japan and one charge tied to an export involving an Unverified List party without obtaining the required statement.
     Lambda disclosed the conduct to BIS in 2025. During the period covered by the charges, it had no written export compliance procedures and no personnel trained or specifically assigned to export compliance. . . . [Continue]

13. ST&R Trade Report: "USMCA Review is Subject of USTR Inquiry"

(Source: Sandler, Travis & Rosenberg Trade Report, 6 Oct 2026) [Excerpts]. Contact: [email protected], 1-305-894-1035

     The Office of the U.S. Trade Representative is commencing a public consultation process in advance of the 2027 joint review of the U.S.-Mexico-Canada Agreement.
     The USMCA provides for its own termination as of July 1, 2036, unless each party confirms that it wishes to continue the agreement.
     Because the U.S. declined to do so earlier this year, there will now be annual joint reviews until an agreement to extend the USMCA is unanimous or the deal terminates.
     Ahead of the 2027 review, USTR is inviting public comments on the following no later than Jan. 12, 2027.

14. WTTL: "WTO Talks Falter as Reform Disputes Deepen"

(Source: Washington Tariff & Trade Letter, 2 Oct 2026) [Editor's summary of subscription publication]

     WTO members remain divided not only on trade issues but also on how negotiations should be conducted and agreements adopted. At the October 1 Trade Negotiations Committee meeting, Director-General Ngozi Okonjo-Iweala urged members to seek compromises as debates over agriculture, fisheries subsidies, development, and institutional reform continue.
     Agriculture remains the most contentious area. Members disagree on whether to focus on long-standing mandates, including public stockholding and a special safeguard mechanism for developing countries, or pursue a broader negotiating package. India advocates advancing its priority issues independently, while Australia argues against allowing progress in one area to become a prerequisite for movement elsewhere.
     Fisheries negotiations face added urgency. While the Agreement on Fisheries Subsidies entered into force in September 2025, members have yet to conclude additional disciplines on overfishing and overcapacity. Failure to reach agreement by September 2029 could jeopardize the agreement's continuation, creating pressure to accelerate text-based negotiations.
     A broader institutional dispute centers on plurilateral agreements. The European Union, Korea, and New Zealand support incorporating the Investment Facilitation for Development Agreement and e-commerce initiatives into the WTO framework. India and Pakistan question both the legal basis and governance implications of allowing subsets of members to advance agreements without full consensus.
     Reform discussions have also generated concerns among developing and least-developed members. Several delegations argue that overlapping meetings and limited resources prevent smaller missions from participating effectively in negotiations. Brazil, India, Indonesia, Bangladesh, and Pacific members have also emphasized that reform efforts should not detract from restoring a fully functioning two-tier dispute-settlement system.
     Although members have achieved some progress on development-related commitments, significant differences remain on agriculture, fisheries, institutional reform, and dispute settlement. The key test over the coming months will be whether consultations can be translated into formal negotiating texts while preserving broad participation and consensus-based decision making. . . .
     [Original article]

15. Diaz: "Commerce Restricts Polysilicon Stockpiling Ahead of December 4 Section 232 Tariffs: What Importers and Customs Brokers Need to Know"

(Source: Customs & International Trade Law Blog, 6 Oct 2026) [Excerpts]

* Author: Jennifer Diaz, Diaz Trade Law LLP

     On September 24, 2026, the Bureau of Industry and Security (BIS) published a temporary final rule at 91 FR 60505 establishing how the Department of Commerce will identify and restrict importers that stockpile polysilicon and polysilicon derivatives (Polysilicon Products) before the Section 232 minimum import prices and tariffs under Proclamation 11052 take effect on December 4, 2026.
     The rule caps weekly import volumes for new importers of record, creates a waiver process, and reminds customs brokers of their enforcement exposure. Importers of polysilicon, the covered HTSUS 3818 products, solar cells, and solar modules, along with the customs brokers that file their entries, are affected now.
     Key Takeaways:

16. Sidley Austin: "Update on Tariff Refund Litigation"

(Source: Author) [Editor's Summary]

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

     IEEPA Tariff Refunds. Earlier this year, the Supreme Court held that the International Emergency Economic Powers Act (IEEPA) does not authorize the President to impose tariffs. In response, U.S. Customs and Border Protection (CBP) created a streamlined refund process within ACE known as Consolidated Administration and Processing of Entries (CAPE).
     The Court of International Trade (CIT) later ordered the government to refund all IEEPA tariffs. The government has appealed the portion of that order requiring refunds on entries liquidated more than 90 days ago for importers that did not file their own CIT actions. Importers that filed individual lawsuits are expected to become eligible to request refunds through CAPE beginning October 6. Importers should continue monitoring developments because the appeal could affect both eligibility and timing of refunds.
     Section 122 Tariff Challenge. Following the end of IEEPA tariff collections on February 24, 2026, the government imposed a 10% tariff under Section 122 of the Trade Act of 1974. The measure remained in effect through July 24, 2026.
     In May, the CIT invalidated the tariff in a 2-1 decision. The government appealed, and the U.S. Court of Appeals for the Federal Circuit stayed the ruling pending review. The case is currently in the briefing stage. Importers that paid Section 122 duties should closely follow the litigation because a favorable ruling could create refund opportunities.
     Section 301 Forced-Labor Tariffs. On July 24, 2026, the government began collecting new Section 301 tariffs of 10% or 12.5% on imports from 60 economies based on forced-labor-related trade findings.
     The tariffs have been challenged at the CIT. Oral argument was held on September 30, 2026, and the court subsequently requested additional written submissions. Although the litigation remains in its early stages, importers should monitor the proceedings because they may ultimately provide another avenue for tariff refunds.
     [Original Article]

17. Volkov: "Updating Your Sanctions Compliance Guidance, Part 1: The 2019 Framework Is Still Your Foundation, But It's No Longer the Whole Picture"

(Source: Volkov Law, 6 Oct 2026) [Excerpts]

… If you built your sanctions compliance program around OFAC's 2019 Framework for Compliance Commitments and haven't revisited it since, you're not alone, and you're also overdue for an update. The 2019 Framework remains the foundational document for how OFAC evaluates a sanctions compliance program, and every one of its five pillars is still good law today.
     But federal sanctions enforcement has fundamentally changed shape since 2019. It's no longer just an OFAC conversation. The Department of Justice, the Department of Commerce's Bureau of Industry and Security, and OFAC now routinely coordinate through joint "Tri-Seal" compliance notes that layer substantial new expectations on top of the 2019 baseline.
     This is the first of a two-part series. Part 1 revisits what the 2019 Framework actually requires and why it remains your starting point. Part 2 covers the specific multi-agency updates you need to build on top of it. . . . [Continue]

18. FD Associates Presents: "Brokering Under the ITAR" Webinar, 3 November

(Source: Jenny Hahn, [email protected])

19. List of Export/Import Job Openings

(Source: Editor)

21. Bartlett's Unfamiliar Quotations

(Source: Brainy Quotes)

22. Today in History (Source: History Channel)

1926. Babe Ruth set a World Series record. On October 6, 1926, Yankee slugger Babe Ruth hit a record three homers against the St. Louis Cardinals in the fourth game of the World Series. The Yanks won the game 10-5, but despite Ruth's unprecedented performance, they lost the championship in the seventh game. In 1928, in the fourth game of another Yanks-Cards World Series, Ruth tied his own record, knocking three more pitches out of the same park. Since then, the record has been tied but never broken.

1927: The Jazz Singer premiere on October 6, 1027, ushering out Hollywood's silent era. While hailed as the first feature-length "talkie"---and earning blockbuster sums at the box office---the film had only about two minutes of synchronized dialogue; the rest used titles.

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

(Source: Editor)

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24. 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.