26-1013: Tuesday's "Export/Import Daily Bugle"

1. Treasury/OFAC Determination in re Automotive and Rail Sectors of the Iranian Economy
(Source: 91 FR 64758, 13 Oct 2026)

     Determination Pursuant to Section 1(a)(i) of Executive Order 13902: Automotive and Rail Sectors of the Iranian Economy, Section 1(a)(i) of Executive Order (E.O.) 13902 of January 10, 2020 (“Imposing Sanctions With Respect to Additional Sectors of Iran”) imposes economic sanctions on any person determined by the Secretary of the Treasury, in consultation with the Secretary of State, to operate in such sectors of the Iranian economy as may be determined by the Secretary of the Treasury, in consultation with the Secretary of State.
     To further address the unusual and extraordinary threat to the national security, foreign policy, and economy of the United States described in E.O. 13902, and in consultation with the Department of State and pursuant to 31 CFR 560.802, I hereby determine that section 1(a)(i) of E.O. 13902 shall apply to the automotive and rail sectors of the Iranian economy.
     Any person determined to operate in these sectors shall be subject to sanctions pursuant to section 1(a)(i). Signed: Bradley T. Smith, Director, Office of Foreign Assets Control

2. Treasury/OFAC Publishes Venezuela Sanctions Regulations: GL 60
(Source: 31 CFR Part 591, 13 Oct 2026)

     (a) Except as provided in paragraph (b) of this general license, all transactions related to earthquake relief efforts in Venezuela that would otherwise be prohibited by the Venezuela Sanctions Regulations, 31 CFR part 591 (VSR), are authorized through 12:01 a.m. eastern daylight time, October 23, 2026.

3. Future Federal Register (Two items)
(Source: Future Federal Register)

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

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

Editor’s Note: As of today, CBP has not updated this webpage, which still 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: Defense Directorate of Trade Controls)

9. Treasury/OFAC Issues Russia-related General License
(Source: Treasury/OFAC, 9 Oct 2026)

     The Department of the Treasury's Office of Foreign Assets Control (OFAC) is issuing Russia-related General License 135, "Authorizing Transactions Related to the Sale, Delivery, Offloading, and Importation of Diesel Fuel of Russian Federation Origin."
     For more information on this specific action, please visit our Recent Actions page.

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

11. Breaking Defense: “Polish Defense Minister Calls for US Industry to Establish European Facilities”
(Source: Breaking Defense News, 13 Oct 2026) [Excerpts]

     WARSAW — Poland’s national defense minister is calling on Europe to develop an “enduring, predictable” alliance with the US, encompassing information exchange, military capabilities and defense industry collaboration.
     “I believe that within the ‘NATO 3.0’ strategy, it is worth emphasizing a strategy for the defense industry,” Władysław Kosiniak-Kamysz told the Warsaw Security Conference on Monday. “Relocating production lines and maintenance facilities to Europe, for instance, for Patriot missiles and systems, is crucial for the independence of both the United States and Europe.” . . .
     [Full article]

12. EurAsian Times: “India Shuts Down F-35 Talk With One Blunt Line. Says U.S. Crew Won’t Even Let Us Near the Stealth Fighter”
(Source: EurAsian Times, 12 Oct 2026) [Excerpts]

     India’s air force chief said on Saturday that the U.S. has made no formal offer to sell India F-35 stealth fighters, and added that American personnel have not even allowed Indian officers near the stealth aircraft.
     Air Chief Marshal Amar Preet Singh made the comments at a press conference marking the end of the multinational Exercise Tarang Shakti-2026 in Jodhpur, while seated alongside U.S. Pacific Air Forces commander Gen. Kevin Schneider. “Your people don’t even let us go near the aircraft, and you are talking about selling it to us,” Singh said.
     Six U.S. Air Force F-35As, accompanied by more than 200 personnel, participated in Tarang Shakti. This was the first time the American stealth fighters had drilled against Indian jets on Indian soil.
     Singh also said the Indian government has not yet decided whether the air force should evaluate Russia’s offer of the Su-57. “Once the decision is conveyed to us (by the government), we will evaluate how well it meets our requirements,” he said. . . . [Full article]

13. Expeditors News: “Development and Deployment Schedule”
(Source: Expeditors News, 12 Oct 2026) [Excerpts]

     In an update to the U.S. Customs and Border Protection (CBP) website on October 9, 2026, the agency published the latest Automated Commercial Environment (ACE) Development and Deployment Schedule.
     Notable ACE projects currently in development include:

     The schedule also identifies projects that were removed due to recent deployment and provides projected deployment dates for enhancements that are actively being developed. The updated ACE Development and Deployment Schedule can be found HERE.

14. Shapiro: “There’s Hope for Non-Lawsuit Files! Court Decision Could Open Additional Avenue for IEEPA Refunds for Fully Liquidated Entries”
(Source: Shap Flash, 9 Oct 2026) [Excerpts]

     On October 8, 2026, the U.S. Court of International Trade (CIT) issued a potentially significant decision in the ongoing IEEPA tariff refund litigation. The Court certified a class action that could eventually allow importers who have not filed individual lawsuits to recover IEEPA duties paid on entries that are now finally liquidated.
     While this is an encouraging development, it is important to emphasize that no additional refund eligibility has been officially established, and no new refund procedures have been announced by U.S. Customs and Border Protection (CBP).
     What Happened? As many importers are aware, CBP has been processing IEEPA duty refunds through its Consolidated Administration and Processing of Entries (CAPE) system. However, eligibility has been limited based on entry liquidation status and other criteria.
     Most recently, CAPE Phase 3 was intended to be launched on October 6, 2026, allowing certain importers who previously filed lawsuits with the CIT to pursue refunds on finally liquidated entries that were otherwise ineligible under earlier phases.
     The October 8 decision could potentially expand refund opportunities beyond those importers who filed individual lawsuits.
     Specifically, the Court certified a class action consisting of importers of record who paid IEEPA duties between February 1, 2025, and February 19, 2026, excluding importers who have separately filed their own lawsuits seeking recovery of those duties.
     If the decision stands and additional refund relief is ordered, it could eventually provide another avenue for eligible importers to recover IEEPA duties on finally liquidated entries without having filed an individual lawsuit.
     How does this affect me? . . . [Full article]

15. Street Insider: “Super Micro Contractor Pleads Guilty in Scheme to Divert AI Servers with Nvidia Chips to China”
(Source: StreetInsider.com, 9 Oct 2026) [Excerpts]

     …New York, (Reuters) - A contractor linked to Super Micro Computer has pleaded guilty in a scheme to illegally export computer servers containing advanced Nvidia AI chips to China, a federal court filing showed on Friday.
     Ting-Wei "Willy" Sun pleaded guilty to four counts, including conspiracy to violate US export controls, smuggle goods from the US, defraud the country and obstruct justice. He entered the plea on Thursday in U.S. District Court in Manhattan.
     The United States and China are competing for dominance in AI, with both investing billions of dollars in a technology seen as critical to economic growth, national security and military capabilities.
     In March, prosecutors charged Sun and two others associated with Super Micro, including a co-founder of the AI-server maker, with conspiring to divert about $2.5 billion worth of US AI technology to China in violation of export laws.
     The scheme began around October 2023, with Sun and others conspiring to export servers from a US manufacturer, widely believed to be Super Micro, to China without the required licenses, according to the indictment. . . .
     The indictment described Sun as a broker and “fixer” who facilitated orders and took steps to conceal the scheme. He helped stage "dummy" servers in December 2025 and made false statements to a US Department of Commerce officer during an inspection of supposedly stored servers, which had already been diverted to China, according to the indictment.
     Washington has restricted sales of advanced AI chips to China, citing national security concerns. The indictment said Nvidia's B200, H100 and H200 graphics processing units, and servers containing them, were subject to the restrictions.
     [Full article]

16. ST&R Trade Report: “Agricultural Trade News: Potatoes, Poultry, Cut Flowers, EU, Indonesia”
(Source: Sandler, Travis & Rosenberg Trade Report, 12 Oct 2026) [Excerpts]. Contact: [email protected], 1-305-894-1035

     Potatoes: U.S. Customs and Border Protection has issued a notification that the entry requirements for potatoes originating in Prince Edward Island, Canada, changed effective Oct. 5, as follows. . . .
     Poultry: Effective Sept. 18, 2026, APHIS imposed the following restrictions on the importation of avian commodities from Suriname due to highly-pathogenic avian influenza: . . .
     Cut Flowers: APHIS has issued a final rule that, effective Nov. 9, will remove the designation of chrysanthemum white rust as a quarantine pest and remove CWR-specific import restrictions on cut flowers. Specifically, APHIS has determined that . . .
     European Union: The USDA’s Foreign Agricultural Service reports that on June 2, June 29, and Sept. 23 the European Commission authorized four genetically-engineered crops (three soybean, one maize) and renewed the authorization of three GE crops (two maize, one soybean) for food and animal feed. . . .
     Indonesia: According to FAS, Indonesia’s Halal Product Assurance Agency will require pre-shipment inspections for all halal products and those that must be labeled non-halal (e.g., pork and alcoholic beverages), effective for shipments with a bill of lading date after Oct. 17, 2026. . . .
     [Full article]

17. Akin: “USTR Seeks Business Input on EU Carbon Border Adjustment Mechanism”
(Source: Akin Alerts, 13 Oct 2026) [Excerpts]

• Principal Author: Alan Yanovich, Akin Gump Strauss Hauer & Feld LLP

     Key Points:

     • The USTR is seeking comments from stakeholders on the current and potential effects of the EU’s CBAM on U.S. producers, workers, exports and overall U.S.-EU trade.
     • USTR is specifically requesting information on costs, regulatory burdens, EU market access, competitive effects and the possible impact of proposals to extend CBAM to additional downstream products.
     • USTR also asks “whether and what enforcement action may be appropriate” to remedy negative effects of CBAM.
     • The consultation provides U.S. businesses with an opportunity to place company- and sector-specific concerns before the U.S. government as it considers further engagement with the EU.
     • Comments are due on 9 November 2026.

     [Full article]

18. Baker McKenzie: “DOJ’s New Fraud Division Corporate Enforcement Directive”
(Source: Global Sanctions and Export Controls Blog, 12 Oct 2026) [Excerpts]

• Principal Author:  Geoff Martin, Baker Mckenzie

     Baker McKenzie has recently published a client alert regarding the US Department of Justice’s New Fraud Division Corporate Enforcement Directive issued on October 1, 2026. Corporate fraud schemes involving tariff evasion, importation of goods or services, or forced labor, are one of the four priority areas the Directive sets for Fraud Division prosecutors.
     The alert discusses the Division’s new Corporate Enforcement Section, the factors prosecutors must weigh heavily in corporate cases, and the Division’s use of whistleblower reporting and data analytics to find misconduct. Read the full client alert here

19. DLA Piper: “State/DDTC proposes ITAR Revisions--Top Points”
(Source: DLA Piper Insights, 9 Oct 2026) [Editor’s summary]

• Principal Author: Jana del-Cerro, DLA Piper LLC

     On September 30, 2026, the U.S. Department of State’s Directorate of Defense Trade Controls (DDTC) placed on public inspection a proposed rule that would make substantial revisions to the International Traffic in Arms Regulations (ITAR) and the U.S. Munitions List (USML). Comments are due by November 30, 2026.
     The proposal would remove certain items from USML control, including smooth-bore canister launchers (Category II), most radar altimeters (Category VIII), specified optical sight components (Category X), and selected military submersible parts and equipment (Category XX). Many de-controlled items could transition to the Export Administration Regulations (EAR) under Commerce Department jurisdiction.
     DDTC also proposes a new ITAR license exemption for temporary exports of unclassified foreign defense articles returned to their original manufacturers or authorized service providers for repair or servicing.
     The agency is further seeking to clarify that launching a defense article into or beyond Earth orbit is not, by itself, a controlled export.
     A notable aspect of the proposal is the revision of the ITAR “specially designed” definition. Two new release provisions would exclude certain items that become associated with defense articles only through later use and would remove many common commercial commodities, such as tires, gauges, switches, fuses, hinges, and passenger seats, from control.
     The rule would also clarify demilitarization standards, emphasizing that an item remains a defense article unless all controlled characteristics have been permanently removed. Additional revisions would update core definitions and clarify when development and production phases begin and end.
     Companies should review affected classifications, assess potential EAR transitions, evaluate servicing workflows, update compliance procedures, and consider submitting comments before the November 30 deadline. . . .
     [Full article]

20. Gadget Review: “A Rerouted Package, An Unread Email, Now F-35 Parts Are In Chinese Hands”
(Source: Gadget Review, 9 Oct 2026) [Excerpts]

     Key Takeaways

     • A missed UPS warning email allowed F-35 stealth components to reach Chinese custody.
     • Rerouting through Hong Kong exposed radar-absorbing canopy and weapons-bay door to Chinese authorities.
     • Pentagon and State Department investigations remain open, with parts still unaccounted for.

     A scheduling fix meant to recover lost transit time may have delivered physical components from one of the most advanced stealth fighters ever built directly into Chinese custody. That is the core of a Bloomberg report published October 7, 2026, based on a person briefed on the incident who was not authorized to speak publicly.
     The available reporting describes the case as a logistics and export-control failure, not a confirmed espionage operation. That framing is precisely what makes it matter: a routine commercial shipping decision, compounded by a missed warning, reportedly produced a serious national-security consequence.
     One Missed Email, One Rerouted Flight. The shipment originated with the Royal Australian Air Force and contained a cockpit canopy and a weapons-bay door from an F-35A Lightning II, both coated with radar-absorbing material. The parts were headed from Australia to San Francisco for inspection, possible repair, or disposal, routed through South Korea and Taiwan.
     The shipment left Australia late. A UPS employee reportedly rerouted it through Hong Kong to accelerate delivery. That employee reportedly never saw a warning email from freight forwarder DSV, acting on behalf of Lockheed Martin. The message flagged the parts as subject to U.S. International Traffic in Arms Regulations (ITAR).
     According to Bloomberg’s source, that warning appears to have arrived in a different UPS information system from the one the employee was actively monitoring. . . . These infrastructure vulnerabilities in commercial logistics networks mirror those exploited in other high-profile national-security incidents.
     Chinese authorities reportedly took possession of the components after they transited Hong Kong. [Full article]

21. Sidley Austin: “A New (Viable?) Option for IEEPA Tariff Refunds”
(Source: Author, 11 Oct 2026) [Editor’s summary.]

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

     There has been an important development in the ongoing IEEPA tariff refund litigation. On October 8, 2026, the United States Court of International Trade certified a class in Freestyle World, Inc. v. United States comprising importers of record that paid duties imposed by the challenged tariff orders between February 1, 2025, and February 19, 2026.
     Entities that have separately commenced actions seeking recovery of IEEPA duties are excluded. The certification order does not direct payment of refunds to class members.
     Although certification establishes a potential collective mechanism for recovery, material procedural uncertainties remain. The government may seek appellate review, with attendant delays and the possibility that certification will be reversed. Importers should therefore evaluate applicable limitations periods and potential tolling rather than presume that participation in the certified class conclusively preserves their claims.
     Individual litigation may provide a more direct avenue to recovery, particularly for finally liquidated entries. The court observed that U.S. Customs and Border Protection’s Consolidated Administration and Processing of Entries program accepts certain finally liquidated entries subject to orders in individual actions but excludes comparable entries belonging to nonplaintiff importers.
     The relative costs of individual and collective proceedings also require assessment. Importers should compare the terms of individual representation with any compensation ultimately sought by class counsel; neither approach should be presumed categorically more economical.
     For importers that have already commenced separate actions, certification does not alter their exclusion from the class. Other importers should assess the amounts at issue, liquidation status, available administrative remedies, litigation costs, and filing deadlines.
     Certification is a significant procedural development, but neither assures immediate recovery nor obviates individualized consideration of claim preservation. . . .
     [Full article]

22. ST&R Trade Report: “$2 Million Penalty for Export Violations”
(Source: Sandler, Travis & Rosenberg Trade Report, 13 Oct 2026) [Excerpts]. Contact: [email protected], 1-305-894-1035

     The Bureau of Industry and Security has issued an order imposing a $2 million civil penalty against a U.S. company [Lambda Research Corporation] to settle charges that it committed 66 violations of the Export Administration Regulations.
     The company was charged with

     • selling, exporting, transmitting, or servicing design software designated as EAR99 to or for parties on the Entity List without the requisite BIS license or other authorization,
     • thereafter entering into agreements to service and update that software, and
     • exporting a license for software designated as EAR99 to an entity on the Unverified List without obtaining a UVL statement.

     BIS will suspend the penalty for a year and waive it thereafter provided the company takes a number of specified measures,
     including . . . [Full article]

23. Troutman: “Getting Duties Back: Where Recovery Stands Under IEEPA, Section 122, and Section 301 Forced Labor Tariffs”
(Source: Troutman Pepper Locke, 12 Oct 2026) [Excerpts]

• Author: Ryan Last, Troutman Pepper Locke LLP

     Key Points

     • In its Freestyle World ruling on October 8, 2026, the Court of International Trade certified a class of importers that paid IEEPA duties and have not sued.
     • Certification following CIT’s Freestyle decision is not a refund order, so class members receive refunds only if the court enters a class-wide injunction and Customs and Border Protection processes their entries.
     • Importers that have filed their own actions to recover IEEPA duties are excluded from the Freestyle class.
     • Section 301 forced-labor tariffs remain in effect while the CIT weighs In re Section 301 Forced Labor Cases.
     • Importers suing in the Court of International Trade to recover IEEPA duties must file within two years under 28 U.S.C. § 2636(i), and the Freestyle certification order does not address whether the class action pauses that deadline for class members.

     Three different tariff programs. Three different statutes. Three different stages of litigation. Since 2025, U.S. importers have paid extraordinary duties under three programs: the International Emergency Economic Powers Act (IEEPA), Section 122 of the Trade Act of 1974 (Section 122), and Section 301 of the Trade Act of 1974 (Section 301) based on forced labor issues.
     Each program is now before the courts. The U.S. Supreme Court has held the IEEPA tariffs unlawful, the U.S. Court of International Trade’s (CIT) ruling against the Section 122 tariffs is stayed on appeal, and the Section 301 challenge awaits a first decision.
     The question for importers is the same in every case, whether duties already paid can be recovered, but the answer differs for each program. . . . [Full article]

24. Export Compliance Solutions Presents: “ITAR Exemptions Webinar”
(Source: Marie Nicolo)

     • What: ITAR Exemptions Webinar
     • Where: Virtual on your Computer
     • When: 20 October (Tues) 2026
     • Comments: Enhance your export compliance program – Save months of possible processing time! Don’t waste limited resources on getting unnecessary licenses. Find out all the most common ITAR exemptions and when and how you should use them.
     • Presenters: Suzanne Palmer & Lisa Bencivenga
     • Register: HERE, email: [email protected], or call (866) 238-4018.

25. FD Associates Presents: “Brokering Under the ITAR” Webinar, 3 Nov 2026
(Source: Jenny Hahn, [email protected])

     • What: “Brokering Under the ITAR” webinar
     • Where: At Your Computer
     • When: 3 November 2026 (Tuesday), 11am – 12:30pm Eastern
     • Summary: This webinar is for companies and individuals that are considering acting on behalf of others involving US and foreign defense articles and items on the US Munitions Import List. Brokering Under the ITAR captures actions (import and export or transfer). Often misunderstood or not contemplated, Brokering is an important part of the ITAR that companies must understand.
     • Presenter: John Herzo, Senior Compliance Associate, FD Associates
     • Sponsor: FD Associates, Inc
     • Register: HERE. For more information call 703-847-5801 or email HERE.

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

RECENT:

FULL LIST (Includes above entries.):

27. Jim Bartlett: New ITAR in Effect Today!
(Source: Editor)

     Changes to the ITAR went into effect today as a result of the August 28, 2026, Federal Register (91 FR 55457) amendments that took effect today. ITAR sections 120.54, Activities That are Not Exports, Reexports, Retransfers, or Temporary Imports, and 121.0, United States Munitions List Description and Definitions have new text.
     A new edition of the Bartlett’s Annotated ITAR (the BITAR) is available for download today containing the ITAR amendments that became effective today.  I also added the new § 120.0 definitions to the Index. The BITAR is available for download by subscribers HERE.

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

     • Margaret Thatcher (Margaret Hilda Thatcher, née Roberts; 13 Oct 1925 – 8 Apr 2013; was a British stateswoman who served as prime minister of the United Kingdom from 1979 to 1990. She was the longest-serving British prime minister of the 20th century and the first woman to hold that office. A Soviet journalist dubbed her "The Iron Lady", a nickname that became associated with her uncompromising politics and leadership style.
          - “I am extraordinarily patient, provided I get my own way in the end.”

     • Benjamin Harris Brewster (October 13, 1816 – April 4, 1888) was an attorney and politician from New Jersey, who served as United States Attorney General from 1881 to 1885.
          - "A lawyer starts life giving $500 worth of law for $5 and ends giving $5 worth for $500."

     • Edward Blake (Dominick Edward Blake PC KC; 13 Oct 1833 – 1 Mar 1912; was the second premier of Ontario and leader of the Liberal Party of Canada from 1880 to 1887. He is one of only three federal permanent Liberal leaders never to become Prime Minister of Canada. Blake was also the founder, in 1856, of the Canadian law firm now known as Blake, Cassels & Graydon LLP.
          - “As far as I can judge, not much good can be done without disturbing something or somebody.”

30. Today in History
(Source: History Channel)

1307: On Friday, 13 October 1307, around 15,000 members of the Knights Templar were rounded up and arrested in France. After the traditional Crusades to the Holy Land ended in 1291, the Knights Templar grew incredibly wealthy from its vast landholdings and business across Europe, as well as tax-exempt status as a religious order. The order also lent money to nobles and kings, making it arguably the first international bank. In France, where its lavish Paris headquarters was called the Temple, the Knights Templar drew the ire of King Philip IV, whose kingdom was mired in debt. Philip IV seized an opportunity to take down the order and steal their wealth. Some sources attribute the superstition of Friday the 13^th to the events of this date.

1775: Birthday of the U.S. Navy. On October 13, 1775, the Continental Congress authorized construction and administration of the first American naval force—the precursor to the United States Navy. The Department of the Navy was not created until April 30, 1798, but the U.S. Navy traces its heritage and birth to the Continental Congress's action in 1775.

31. Do You Need to Update Your Daily Bugle Profile?
(Source: Editor)

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32. 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.