26-1008: Thursday's "Export/Import Daily Bugle"

1. CBP Seeks Comments on Proposal to Modify Electronic Filing Requirements for Entries of Goods Valued at $2,500 or Less
(Source: 91 FR 64532, 8 Oct 2026)

* AGENCY: U.S. Customs and Border Protection (CBP), Department of Homeland Security.

* ACTION: Notice of proposed rulemaking.

* SUMMARY: This document proposes to amend the U.S. Customs and Border Protection regulations to modify filing requirements for informal entries of goods valued at $2,500 or less and to establish a new electronic informal entry type for merchandise entering through the mail environment. This document also proposes other related changes such as requiring an additional data element for carriers pertaining to mail shipments and imposing bonding requirements for certain informal entries.

* DATES: Comment by 7 December 2026.

2. Labor/WHD: Minimum Wage for Federal Contracts to Increase on 6 Jan 2027
(Source: 91 FR 64404, 8 Oct 2026)

* AGENCY: Wage and Hour Division, Department of Labor.

* ACTION: Notice.

* SUMMARY: The Wage and Hour Division (WHD or Division) of the U.S. Department of Labor (the Department) is announcing the applicable minimum wage rate for workers performing work on or in connection with federal contracts covered by Executive Order 13658, Establishing a Minimum Wage for Contractors (the Executive Order or the order), beginning January 6, 2027.
     The rates announced in this notice apply to certain types of federal contracts entered into between January 1, 2015, and January 29, 2022, that were not renewed or extended (pursuant to an exercised option or otherwise) on or after January 30, 2022.
     Beginning on January 6, 2027, the Executive Order 13658 minimum wage rate that generally must be paid to workers performing work on or in connection with contracts covered by Executive Order 13658 will increase to $14.05 per hour, while the required minimum cash wage that generally must be paid to tipped employees performing work on or in connection with covered contracts will increase to $9.85 per hour.

* DATES: These new Executive Order 13658 rates take effect on 6 January 2027.

3. Treasury/OFAC Removes Names from SDN List
(Source: 91 FR 64465, 8 Oct 2026)

* AGENCY: Office of Foreign Assets Control, Treasury.

* ACTION: Notice.

* SUMMARY: The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) is publishing the names of one or more persons whose property and interests in property have been unblocked and who have been removed from the Specially Designated Nationals and Blocked Persons List (SDN List). OFAC is also publishing updates to the identifying information of one or more persons or property currently included on the SDN List whose property and interests in property remain blocked.

* DATES: See Supplementary Information for relevant dates.

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

5. CBP Cargo Systems Messages
(Source: DHS/CBP/CSMS)

6. CBP Events in October 2026
(Source: OTR Webinars)

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

7. Commerce/BIS (Nothing new.)
(Source: Commerce/BIS)

8. State/DDTC (Nothing new.)
(Source: State/DDTC)

9. Treasury/OFAC Issues Iran-related Designations; Iran-related General License; Amended Russia-related General License
(Source: Treasury/OFAC, 8 Oct 2026)

     Operation Economic Outcast Neutralizes Iranian Regime's Remaining Shadow Fleet Network
     The Department of the Treasury's Office of Foreign Assets Control (OFAC) is issuing Iran-related General License EE, "Authorizing the Wind Down of Transactions Involving Samudra Marine Services Private Limited."
     Additionally, OFAC is issuing Russia-related General License 13S, "Authorizing Certain Administrative Transactions Prohibited by Directive 4 under Executive Order 14024."
     Lastly, OFAC has made the following changes to its list of Specially Designated Nationals and Blocked Persons (SDN List): . . . [Full article]

10. White House Actions (No new items of interest.)
(Source: The White House)

11. Breaking Defense: “Gecko Robotics, Anduril Team Up for New Baltimore County Shipyard”
(Source: Breaking Defense, 8 Oct 2026) [Excerpts]

     Gecko Robotics will deploy its robotics and AI software at Anduril facilities, the company announced today, as Anduril prepares to launch its new Arsenal-2 shipyard in Baltimore County, MD, to manufacture submarine parts. . . .
     On Tuesday, Anduril and the White House announced that the company is establishing a new facility to manufacture parts like torpedo turbines for Virginia-class submarines as part of a $6.6 billion investment, with $3.7 billion from private capital and up to $2.9 billion from the Navy.
     Permitting for the new shipyard is expected to commence immediately, and construction will launch after it has received appropriate approval, Breaking Defense previously reported.
     Currently, Anduril is preparing for the facility to launch initial operations in 2030, and plans to expand production from basic submarine parts into more complex sections of the vessel, like the bow. . . . [Full article]

12. Compliance & Ethics Blog: “Selling Software to Huawei Earns Massachusetts Firm a $2 Million Fine”
(Source: Compliance & Ethics Blog, 7 Oct 2026) [Editor’s summary]

     Massachusetts-based Lambda Research Corporation has agreed to a $2 million settlement with the Bureau of Industry and Security (BIS) to resolve 55 violations of the Export Administration Regulations (EAR) involving software sales and support provided to Huawei Technologies Japan and Shenzhen SiCarrier Technologies, both of which are subject to BIS Entity List restrictions.
     According to an Oct. 2 BIS order, Lambda sold licenses for its optical and illumination design software and provided associated updates and support services to the two companies between 2021 and 2025 without obtaining the required BIS authorization. . . .
     The penalty will be suspended provided the company implements specified compliance enhancements. These include appointing two employees with export compliance responsibilities, requiring export control training, and conducting an internal audit of its compliance program within nine months.
     BIS criticized Lambda’s compliance culture, noting that the company lacked written export compliance procedures and had no personnel specifically responsible for export controls. . . . The case underscores BIS’s continued focus on export control enforcement, including against smaller firms lacking sophisticated compliance infrastructures. . . .[Full article]

13. Expeditors News: “Mexico Updates Electronic Value Manifest Enforcement Date”
(Source: Expeditors News, 7 Oct 2026) [Excerpts]

     On September 30, 2026, Mexico’s Tax Administration Service (SAT) published the “First Anticipated Version” of the Third Ruling of Modifications to the General Foreign Trade Rules for 2026 and its annex on the enforcement of the Electronic Value Manifest. The requirements will now be enforced in phases across different “customs regimes” established under Mexican customs law. Prior to this update, enforcement was scheduled to enter into force on October 1, 2026.
     The resolution becomes effective on the day following its publication in the Diario Oficial de la Federación. However, under General Rule 1.1.2, Anticipated Versions provide an enforceable benefit as soon as they are published through this mechanism.
     The Electronic Value Manifest must be transmitted for applicable foreign trade operations according to the following implementation schedule:

     For more information go HERE.

14. ST&R Trade Report: “Section 301 Tariffs on Imports from China Officially Continued”
(Source: Sandler, Travis & Rosenberg Trade Report, 8 Oct 2026) [Excerpts]. Contact: [email protected], 1-305-894-1035

     The Office of the U.S. Trade Representative has issued a formal notice of the continuation of the Section 301 tariffs currently in place on a broad range of products from China.
     These tariffs range from 7.5 percent to 25 percent and are assessed on about $370 billion worth of imports from China across four lists (lists 1-4A). There are 178 exclusions to these tariffs that are currently valid through Nov. 9.
     USTR states that, following a May 2026 notification of the possible termination of these tariffs, it received numerous requests to continue them from a range of domestic industries that benefit from them. As a result, the tariffs did not terminate on July 6 or Aug. 23 (their four-year anniversary dates) and remain in effect.
     USTR notes that these tariffs are “subject to possible further modifications, including any modifications resulting from the statutory four-year review” that the agency will now conduct.
     USTR will publish a separate notice describing the process for this review, which will include inviting comments on the effectiveness of the tariffs in achieving the objectives of the Section 301 investigation, other actions that could be taken, and the effects of such actions on the U.S. economy, including consumers.

15. Two Oceans Vibe: “Missed Email by UPS Worker Lands China Classified US F-35 Tech”
(Source: 2 Oceans Vibe, 8 Oct 2026) [Editor’s summary]

     A reported shipping error may have allowed parts from the U.S. military’s most advanced fighter jet, the F-35, to fall into Chinese hands. According to Bloomberg, the incident stemmed not from espionage or hacking, but from a missed compliance email.
     The email, sent by logistics firm DSV on behalf of Lockheed Martin, warned that the shipment was subject to U.S. International Traffic in Arms Regulations (ITAR) and could not transit certain countries.
     However, the message was reportedly overlooked by a UPS employee, possibly because it was transmitted through a different information system than the one the employee routinely monitored.
     The shipment included an F-35 cockpit canopy and a weapons bay door, both reportedly coated with radar-absorbing material. The components were being transported from Australia to the United States for inspection, repair, or disposal.
     Originally scheduled to travel through South Korea and Taiwan en route to San Francisco, the cargo was allegedly rerouted through Hong Kong after departing Australia behind schedule. Chinese authorities subsequently took possession of the parts and have reportedly retained them.
     The Pentagon and State Department are now investigating the incident. Pentagon officials briefed congressional staff from the House Foreign Affairs and Armed Services Committees on September 29, and officials say they are working with industry partners and government agencies to recover the components and strengthen safeguards against similar incidents.
     Officials differ on the significance of the breach. Australian Defence Minister Richard Marles said he understood the shipment contained no sensitive technology. U.S. officials, however, reportedly told Bloomberg that the components included classified radar-absorbing coatings. China’s Foreign Ministry has said it is unaware of the matter.

16. Burns, Clif: “Biodiesel Bound for Cuba Seized by US Claiming Export Violations”
(Source: Export Law blog, 7 Sep 2026) [Editor’s summary]

* Author: Clif Burns, Clark Hill LLP

     Homeland Security Investigations recently announced the seizure of 615,000 gallons of biodiesel worth $2.8 million at Port Everglades and Port Houston. The government alleges the fuel was destined for Cuba through ENETEC S.A., a Cuban fuel importer and wholesaler designated on the SDN List under Executive Order 14404.
     The case raises questions because the shipments were not concealed. The exporters openly identified Cuba as the destination and ENETEC as the ultimate consignee on export documents, suggesting they believed the transactions were lawful. Adding to the uncertainty, the Miami Herald reported that the exporters possessed a letter from OFAC authorizing the shipment.
     A key legal issue involves OFAC General License 1 under Executive Order 14404. The license authorizes transactions otherwise prohibited by the executive order if they are authorized or exempt under the Cuban Assets Control Regulations (CACR).
     While the license excludes transactions prohibited elsewhere in 31 CFR Chapter V, Executive Order 14404 was never implemented through a corresponding OFAC regulatory prohibition. As a result, ENETEC's designation appears to arise from the executive order itself rather than from Chapter V regulations.
     The analysis therefore turns to CACR §515.533 and BIS License Exception SCP. Section 515.533 authorizes exports to Cuba that are licensed or otherwise authorized by BIS. License Exception SCP permits exports of EAR99 items, including biodiesel, for use by Cuba's private sector in private-sector economic activities. Authorities have not alleged that the ultimate end users were government entities or that the shipments failed SCP requirements.
     HSI's public statements focus on ENETEC's role as ultimate consignee. However, an ultimate consignee is not necessarily the end user, particularly when the consignee is a wholesaler. The State Department's designation describes ENETEC as an entity engaged in the import and export of fuels and lubricants, suggesting a distribution function rather than final consumption.
     Consequently, the central question is whether the shipments were ultimately intended for authorized private-sector end users, not merely whether ENETEC appeared as the consignee. . . . [Full article]

17. Diaz: “Your Data Is Still Not Your Own at the Border: The Second Circuit’s Alisigwe Ruling and CBP’s 2026 Device Search Directive”
(Source: Customs & International Trade Law Blog, 8 Oct 2026) [Excerpts]

* Author: Jennifer Diaz, Diaz Trade Law LLP

     On September 17, 2026, the U.S. Court of Appeals for the Second Circuit held in United States v. Alisigwe that the government needs neither a warrant nor any level of suspicion to manually search a traveler’s cellphone at the border, and it rejected four district court decisions within the circuit that had required a warrant. The ruling follows CBP’s replacement of its 2018 electronic device search policy with Directive 3340-049B, effective January 1, 2026. Business travelers, in-house counsel, and companies whose employees carry client, pricing, or technical data through ports of entry in New York, Connecticut, and Vermont should revisit their travel practices now.
     Key Takeaways:

     [Full article]

18. Export Practitioner: “Senators call for action on Russia Sanctions”
(Source: The Export Practitioner, 8 Oct 2026) [Excerpts of paywall publication.]

     Sens. Jeanne Shaheen, D-N.H., and Roger Wicker, R-Miss., urged the Trump administration to use the newly enacted Lindsey O. Graham Sanctioning Russia and Iran Act of 2026 to cut off revenue and dual-use technology supporting Russia’s war against Ukraine.
     In an Oct. 6 letter to Secretary of State Marco Rubio and Treasury Secretary Scott Bessent, the senators called for expanded sanctions against Russia’s shadow fleet, oil-trading intermediaries and financial networks that facilitate sanctions evasion. They also sought secondary sanctions against suppliers of advanced machine tools and drone electronics, along with measures targeting Russia’s low-Earth-orbit satellite program.
     Shaheen, the Senate Foreign Relations Committee’s ranking member, and Wicker, the Senate Armed Services Committee chairman, said most provisions take effect 18 October. They urged Treasury to issue clear guidance on prohibitions against new U.S. investment in Russia and dealings in Russian sovereign debt.

19. ST&R Trade Report: “Defense Export Controls Would be Eased Under Proposed Rule”
(Source: Sandler, Travis & Rosenberg Trade Report, 8 Oct 2026) [Excerpts]. Contact: [email protected], 1-305-894-1035

     The State Department has issued a proposed rule that would amend the International Traffic in Arms Regulations to ensure that the U.S. Munitions List focuses ITAR controls on the most sensitive technologies.
     Among other things, this rule proposes the removal from the USML of items ranging from specific types of items to much broader sets of items described in catch-all controls (i.e., controls that refer to unspecified parts, components, accessories, or attachments if they are specially designed for an enumerated item).
     It also proposes to create a new exemption from the ITAR licensing requirements for the temporary export of a foreign defense article to its foreign manufacturer.
     The rule would also revise certain sections of the ITAR to (1) improve the clarity, consistency, and syntax of the regulatory text, (2) align with evolving technologies, and (3) update internal references within the USML. . . . [Full article]

20. Volkov: “Can a Company Survive C-Suite Misconduct?”
(Source: Volkov Law, 8 Oct 2026) [Excerpts]

* Principal Author: Michael Volkov, Volkov Law Group LLC

     A pharma CEO just found out the captain doesn’t always go down with the ship. Sometimes the ship stays afloat by handing him to DOJ.
     Veloxis Pharmaceuticals just paid over $46 million to resolve a kickback scheme involving its kidney transplant drug, lavish meals, resort stays, payments dressed up as consulting fees paid to doctors and pharmacies to drive prescription demand.
     Here’s the part that should stop you. The deferred prosecution agreement says the company’s own former CEO was directing this. That’s the kind of fact pattern that usually gets a company prosecuted, not offered a deal, but Veloxis got a deferred prosecution agreement anyway under DOJ’s corporate enforcement policy.
     Why? Because after the conduct came to light, the company disclosed, cooperated, and identified and fired the people responsible, including its own CEO.
     The lesson is clear. Even executive-level misconduct doesn’t actually doom the corporate entity if your response afterward is real. Disclosure, cooperation, and actually removing the people responsible is exactly the formula DOJ rewards. Don’t assume C-suite involvement means game over. What you do next is what actually decides the outcome.

21. ECS Presents 2-Day Virtual ITAR/EAR Boot Camp 13-14 October
(Source: Marie Nicolo, Export Compliance Solutions)

* What: ITAR/EAR Boot Camp

* Where: Virtual on your computer

* When: October 13-14, 2026

* Comments: This interactive webinar provides a step-by-step approach to understanding the ITAR and EAR. There will be many "tricks of the trade" shared, and exercises to highlight the nuances of a successful compliance program for both novices and seasoned professionals.

* Presenters: Suzanne Palmer & Lisa Bencivenga

* Register: HERE, email HERE, or call (866) 238-4018.

22. List of Export/Import Job Openings
(Source: Editor)

RECENT:

FULL LIST (Includes above entries.):

Bartlett's Annotated ITAR ("BITAR") (1 Oct 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.

24. Bartlett's Unfamiliar Quotations
(Source: Brainy Quotes)

25. Today in History
(Source: History Channel)

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27. Are Your Copies of 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.