TABLE OF CONTENTS
FEDERAL REGISTER
Commerce/BIS Guidance to CBP Regarding “U.S. Content” for Imports from Canada and Mexico
Treasury/OFAC Publishes Names of Persons Added to SDN List
Future Federal Register (No relevant items)
OTHER GOVERNMENT SOURCES
CBP Cargo Systems Messages
CBP Reminder: Licensed Customs Brokers Must Complete Continuing Education by 31 Jan 2027
CBP Events in October 2026
Commerce/BIS (Nothing new.)
Commerce/USCS to Sponsor Transatlantic Defense Industry Access Forum in Poland and Italy in Nov 2026
DTSA: Export Control License Frequently Asked Questions
State/DDTC (No new items.)
Treasury/OFAC Settles with Bank of America for Charges of Sanctions Violations
UK Export Control: “Notice to Exporters 2026/22: Temporary Pause of the Control List Classification (CLC) Service”
White House Actions (No new items of Ex/Im interest.)
NEWS
Breaking Defense: “Didn’t Get Picked for IFPC Interceptor Competition? Army Says Demo Anyway”
Diaz: “CAPE Phase 3 Live, DOJ Trade Fraud Directive, Outbound Investment Penalty”
Expeditors News: “September 2026 Antidumping and Countervailing Duties Updates”
ST&R Trade Report: “Freight Forwarder Gets Penalty for Sanctions and Reporting Violations”
OPINION
Arent Fox: “Informed Decisions, Lower Risk”
Foley & Lardner: “Tariff-ied! This Week in International Trade"
Miller & Chevalier: “Court of International Trade Certifies Class Action for IEEPA Tariff Refunds”
ST&R Trade Report: “U.S., Others Pledge Cooperation on Steel Trade Measures”
Volkov: “Software Updates Are Exports Too: Lambda Research’s BIS Settlement Over Huawei and Entity List Customers”
TRAINING EVENTS & CONFERENCES
Skill Dynamics Presents: “Jurisdiction, Classification, & Confidence” FREE WEBINAR 5 November
EX/IM MOVERS & SHAKERS
In Memoriam: Ben Flowe, 1956-2026
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 Export/Import Regulations Current?
ITEMS FROM THE FEDERAL REGISTER
1. Commerce/BIS Guidance to CBP Regarding “U.S. Content” for Imports from Canada and Mexico
(Source: 91 FR 65162, 14 Oct 2026)
AGENCY: Bureau of Industry and Security, Department of Commerce.
ACTION: Notice.
SUMMARY: This notice provides guidance to U.S. Customs and Border Protection regarding the assessment of “U.S. content” for products of Canada and Mexico that qualify for preferential tariff treatment under the United States-Mexico-Canada Agreement, for purposes of implementing tariffs pursuant to Proclamation 11032 of June 1, 2026.
DATES: The guidance set out in this notice is effective with respect to products that are entered for consumption, or withdrawn from warehouse for consumption, on or after October 14, 2026.
2. Treasury/OFAC Publishes Names of Persons Added to SDN List
(Source: 91 FR 65295, 14 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 that have been placed on OFAC's Specially Designated Nationals and Blocked Persons List (SDN List) based on OFAC's determination that one or more applicable legal criteria were satisfied. All property and interests in property subject to U.S. jurisdiction of these persons are blocked, and U.S. persons are generally prohibited from engaging in transactions with them. The vessels placed on the SDN List have been identified as property in which a blocked person has an interest.
DATES: This action was issued on October 8, 2026. See Supplementary Information for relevant dates.
3. Future Federal Register (No relevant items)
(Source: Future Federal Register)
OTHER U.S. GOVERNMENT SOURCES
4. CBP Cargo Systems Messages
(Source: DHS/CBP/CSMS)
CSMS # 70188060 - Updated Cargo Release Condition Codes Document Posted to CBP.gov
CSMS # 70187331 - ACE Certification Out of Cycle Extended Invasive Maintenance Window on October 17, 2026, from 8:00 a.m. to 9:00 p.m. ET
CSMS # 70165283 - Updated ACE Development and Deployment Schedule Posted to CBP.gov/ACE
CSMS # 70197855 - Harmonized System Update (HSU) 2626 was created on October 9, 2026, and contains 4 harmonized tariff records and 14 ABI records. HSU 2626 contains Section 232 updates. For more information, go HERE.
Additionally, this HSU includes PGA HTS flagging updates. Specifically, the NM8 flag has been removed for National Marine Fisheries Service (NMFS) HTS 0301.19.000.
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.
Credit Earning Period: January 1, 2025 – January 31, 2027.
View Accredited Providers and Eligible Activities: CBP Continuing Education Accreditors and Training
Documentation: Brokers must retain proof of completion (certificates, course codes, course names, dates, educators’ names, and/or transcripts) for at least three years for audit purposes.
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.
Requirement: Filing of the status report and payment of the $100 triennial fee.
Filing Window: December 14, 2026 – February 28, 2027.
How to File: All filings must be submitted electronically via the eCBP Portal.
Requirement Scope: All brokers must file the TSR. Only individual brokers with active licenses must complete CE credits.
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)
Oct 28: UFLPA Enforcement Statistics Dashboard, Wednesday, October 28, at 1:00 p.m. EDT
7. Commerce/BIS (Nothing new.)
(Source: Commerce/BIS)
8. Commerce/USCS to Sponsor Transatlantic Defense Industry Access Forum in Poland and Italy in Nov 2026
(Source: U.S. Commercial Service, Jennifer Sosa, [email protected])
WHAT: Transatlantic Defense Industry Access Forum (in person – not a webinar)
WHEN: 9 Nov 2026 (8:00 AM); 12 Nov 2026 (9:00 PM)
COMMENTS: This is not a trade show. It is a targeted commercial diplomacy program designed to connect U.S. companies directly with the European stakeholders shaping defense procurement, modernization, and transatlantic security cooperation. Led by U.S. Ambassador to NATO Matthew Whitaker, alongside two additional U.S. Ambassadors and senior leaders from NATO, Poland, and Italy.
COST: $3,000. Additional representative $1,000
REGISTER by emailing [email protected] – Deadline this Friday, 16 Oct— or earlier if capacity is reached.
INFO: Jennifer Sosa, U.S. Commercial Service, [email protected], 703-851-9685.
9. DTSA: Export Control License Frequently Asked Questions
(Source: Defense Technology Security Administration)
The following Frequently Asked Questions are posted with answers on the DTSA website:
Does Department of War (DoW) sponsor or approve export license applications?
Which federal regulations govern export licenses?
How do I formally submit an export license application?
How do I determine whether my item is controlled under the ITAR or the EAR?
What should I include when submitting my license application?
What does DoW consider a properly scoped license request?
How can I streamline and/or proactively speed up the DoW review process?
Why is my submitted license experiencing interagency delays?
Can a license be expedited for urgent allied operational needs?
I received a Return Without Action (RWA) on my export license application. I provided the answers (in response to the RWA), why wasn't that sufficient?
If I have a previously approved export license or know another exporter has been approved for the same or similar commodity, will this guarantee approval of a new license request?
I submitted a "replacement" license for the same marketing activity that I did four years ago. Why do I have different/additional/fewer provisos?
What information should I provide in my Commerce 600 series bulk license request to assist DoW in its review?
If we have an approved license authorization, do we still need to get the DoW controlling office approval prior to export as well?
My company is seeking a contract with a foreign provider to launch our satellites. Is my company subject to Special Export Controls (SECs) listed under 22 CFR 124.15?
My company is looking to sell remote sensing satellites to several non-NATO countries. Are there any extra review processes and approvals that we will need?
What should I do if I discover an unauthorized export?
Can I staff foreign nationals on a DoW contract that involves export-controlled technology?
How does DoW view the sharing of technical data with foreign sub-licensee's?
If not specifically funded by DoW, is research and development exempt from being export controlled?
What is a "Deemed Export" and does it apply to DoW personnel?
What is a Technology Transfer Control Plan (TTCP)?
When is a TTCP Required?
What is DTSAs role with TTCPs?
What is the Defense Technology Security Administration's (DTSA's) role in the export license application process?
What happens when DTSA receives a license application?
What is DTSA's timeframe to review license applications?
Can a license be re-issued if there appears to be an error in some of the provisos on a license?
We receive several provisos instructing us not to "Discuss, offer or release" certain technologies…do these provisos apply to and restrict release of non-export-controlled data?
Who should I call when I don't understand or if I disagree with a proviso on my license application?
10. State/DDTC (No new items.)
(Source: Defense Directorate of Trade Controls)
11. Treasury/OFAC Settles with Bank of America for Charges of Sanctions Violations
(Source: Treasury/OFAC, 14 Oct 2026)
The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) today announced an $11,662,930 settlement with Bank of America, N.A. Bank of America agreed to settle its potential civil liability for 475 apparent violations of OFAC sanctions programs targeting Russia, Belarus, Iran, Burma, Somalia, narcotics, and global terrorism.
The apparent violations occurred when Bank of America processed payments involving blocked banks, failed to appropriately prioritize alerts for customers who were exact name matches and date of birth-matches to blocked persons, failed to promptly update watchlists following OFAC designations, and mishandled two business accounts associated with blocked persons due to human error.
The settlement amount reflects OFAC's determination that Bank of America's apparent violations were non-egregious but largely not voluntarily self-disclosed. . . .
12. UK Export Control: “Notice to Exporters 2026/22: Temporary Pause of the Control List Classification (CLC) Service”
(Source: UK ECJU, 12 Oct 2026)
As part of exporters’ due diligence, it is your responsibility to determine whether your goods, software or technology are controlled and to ensure that any required export licence is obtained before an export takes place. To assist with this process, the Export Control Joint Unit (ECJU) has provided a Control List Classification (CLC) Service.
It has become increasingly challenging to provide this service whilst processing export licence applications with minimal delay, especially as ECJU’s licensing teams have been dealing with more complex applications in recent months.
To manage the impact of this, and to ensure resources are prioritised on processing export licence applications, ECJU is pausing the CLC Service from Monday 12 October.
During the pause, ECJU will continue to process requests for CLC advice received prior to the 12 October, but these may take longer to respond to than usual. We request that exporters do not submit new CLC requests during this pause as they will not be processed.
ECJU recognises that the CLC Service provides valuable support to exporters and we are actively looking into options to provide this service in a more resource efficient way in future. . . . [Full article]
13. White House Actions (No new items of Ex/Im interest.)
(Source: The White House)
NEWS
14. Breaking Defense: “Didn’t Get Picked for IFPC Interceptor Competition? Army Says Demo Anyway”
(Source: Breaking Defense News, 14 Oct 2026)
WASHINGTON — After tapping two teams to continue development for a second interceptor for its Indirect Fire Protection Capability (IFPC) Increment 2 launcher, the Army is creating a way for other vendors to keep competing, according to a three-star general.
Lt. Gen. Frank Lozano the Portfolio Acquisition Executive for Fires described the effort as an “off-shoot opportunity” that the service will pursue even as it works with competition winners Lockheed Martin and a team-up from Boeing and Anduril. The opportunity would allow for another competition planned for the fourth quarter of 2027.
“We wanted to turn up the heat on that program,” Lozano told an audience Tuesday at the annual Association of the US Army conference. “I want to run an in parallel, what I call an in-strike competition.” “We basically just said, ‘Hey, if there’s any other company who didn’t make the first cut … but oh by the way, [if] you continue to invest in its second interceptor capability, we’d love for you to come out to the range,’” he later added. “We’ll give you range time. We’ll present targets and will allow you to recompete with an opportunity to get back into the program fold.” . . .
[Full article]
15. Diaz: “CAPE Phase 3 Live, DOJ Trade Fraud Directive, Outbound Investment Penalty”
(Source: Customs & International Trade Law Blog, 10 Oct 2026) [Excerpts]
• Author: Jennifer Diaz, Diaz Trade Law LLP
U.S. Customs and Border Protection (CBP)
Phase three of the Consolidated Administration and Processing of Entries (CAPE) refund system was deployed by CBP on October 6. . . .
CBP issued a proposed rule that would create a framework for low-value imports after the end of de minimis and formally establishing new informal Entry Type 13 for merchandise entering through the mail. Comments are due December 7.
CBP’s Agriculture and Prepared Products Center of Excellence and Expertise (APP) in Miami uncovered a tariff evasion scheme involving tuna caught by foreign-flagged vessels. The investigation uncovered over $8M in lost revenue and almost $9M in expected penalties.
Department of Justice (DOJ)
On October 1, 2026, DOJ’s National Fraud Enforcement Division issued Directive 26-12, which makes trade fraud a corporate enforcement priority and lists ten factors prosecutors must weigh in deciding whether to charge a company.
U.S. Trade Representative (USTR)
USTR announced a public consultation process ahead of the 2027 joint review of the United States-Mexico-Canada Agreement (USMCA). . . .
USTR announced that the 301 tariffs on China’s Acts, Policies, and Practices Related to Technology Transfer, Intellectual Property, and Innovation, that began in 2018, will remain in effect.
USTR announced that 14 economies joined the United States in signing a joint ministerial statement addressing structural excess capacity and production in key manufacturing sectors. . . .
Department of Commerce
Commerce announced on October 6 a preliminary affirmative countervailing duty determination involving N-Cyclohexylbenzothiazole-2-Sulfenamide (CBS) from China. . . .
U.S. Department of Treasury
Treasury announced the first civil penalty ever issued under the Outbound Investment Security Program (OISP): $200,000 against Amidi LLC, the U.S. parent company of the organization known as Plug and Play Tech Center, for failing to notify Treasury of an investment its Chinese fund subsidiary made in a Chinese embodied artificial intelligence company.
Bureau of Industry and Security (BIS)
BIS announced that it reached an administrative enforcement settlement with Lambda Research Corporation involving alleged export control violations.
Federal Maritime Commission (FMC)
The FMC issued an Order asking COSCO Shipping why they failed to pay an award to a complainant. The $24,329 award has gone unpaid for 223 days. The FMC could impose penalties of up to $16.7M for the delayed payment.
A FMC judge ordered non-vessel-operating common carrier Top Shipping Systems (TSS) to pay a Florida-based importer more than $57,000 for withholding two containers in an attempt to obtain overdue payments.
Office of Foreign Assets Control (OFAC)
OFAC announced sanctions list updates on October 5, including designation removals and revisions, an Iran-related sanctions alert, and an amended Iran-related frequently asked question.
Food and Drug Administration (FDA)
FDA released its 2025 CORE+EP annual report on October 6, summarizing investigations of foodborne outbreaks and adverse events involving FDA-regulated foods.
Federal Trade Commission (FTC)
The FTC and U.S. Department of Agriculture announced on October 7 a joint public inquiry into agricultural equipment manufacturing and distribution practices. . . .
Industry News
Pamir Solutions announced that the company gave the Department of Homeland Security Uyghur Forced Labor Prevention Act Entity List Office access to its forced labor risk intelligence platform. . . .
16. Expeditors News: “September 2026 Antidumping and Countervailing Duties Updates”
(Source: Expeditors News, 13 Oct 2026) [Excerpts]
In September of 2026, the U.S. International Trade Administration (ITA) announced several preliminary and final antidumping (AD) and countervailing duty (CVD) determinations and initiated new trade remedy investigations.
Additional details on these cases, including the affected HTS numbers, and duty rates, can be found in the official notices linked below.
Preliminary determinations were published for the following investigations:
CVD investigation of oil country tubular goods (OCTG) from Austria.
CVD investigation of tin mill products from China.
AD investigation of tin mill products from China.
CVD investigation of Tris(hydroxymethyl)aminomethane (tris) from China.
AD investigations of large graphite electrodes from China and India.
CVD investigations of stationary and portable air compressors (air compressors) from China, Malaysia, and Vietnam.
AD investigation of truck bed covers from China.
AD investigations of certain linear hydraulic cylinders and parts thereof from Canada, China, India, Korea, and Mexico, and CVD investigations of certain linear hydraulic cylinders from China, India, and Mexico.
AD investigations of certain fatty acids from Indonesia and Malaysia.
AD and CVD investigations of crystalline silicon photovoltaic cells, whether or not assembled into modules (solar cells) from India, Indonesia, and Laos.
CVD investigation of carbon and alloy steel wire rod from Algeria.
AD investigations of freight rail couplers and parts thereof from the Czech Republic and India, as well as a CVD investigation of freight rail couplers and parts thereof from India.
17. ST&R Trade Report: “Freight Forwarder Gets Penalty for Sanctions and Reporting Violations”
(Source: Sandler, Travis & Rosenberg Trade Report, 14 Oct 2026) [Excerpts]. Contact: [email protected], 1-305-894-1035
The Treasury Department’s Office of Foreign Assets Control reports that a U.S. logistics company and freight forwarder [Pegasus Worldwide Logistics] has agreed to pay $175,015 to settle its potential civil liability for apparent violations of OFAC sanctions and reporting obligations.
The apparent violations occurred when the company arranged for the shipment of equipment from a supplier in China designated on OFAC’s specially-designated national list and failed to identify the equipment as such “due to substantial deficiencies in its compliance review and program.”
For example, the company failed to perform any due diligence at the beginning of the transaction and then conducted only “rudimentary manual sanctions screening” that did not include identifiers such as phone numbers and email addresses.
OFAC states that the base civil monetary penalty amount in this case was $205,900. Aggravating factors include the company’s failure to voluntarily disclose the apparent violations, its “reckless disregard” for U.S. sanctions requirements, and its failure to give heightened attention to sanctions despite its role as an international logistics company. . . .
OPINION
18. Arent Fox: “Informed Decisions, Lower Risk”
(Source: ArentFox Perspectives/Alerts, 14 Oct 2026) [Excerpts]
• Principal Author: Birgit Matthiesen, ArentFox Schiff LLP
Key Takeaways:
Trade compliance and tariff planning are increasingly important.
Companies should avoid making rushed decisions amid change.
Proactive advice can help prevent costly mistakes.
Risk management should be central to trade strategy.
Strong advisor relationships support better business outcomes.
A methodical approach is critical in a complex trade environment.
19. Foley & Lardner: “Tariff-ied! This Week in International Trade"
(Source: National Review, 12 Oct 2026) [Excerpts]
• Principal Author: Gregory Husisian, Foley & Lardner LLP
Key Takeaway: In today’s tariff-heavy enforcement environment, Customs and Border Protection (CBP) is not waiting for problems to reveal themselves. It is increasingly using data mining and other analytics to identify classification, valuation, origin, and other trade-data anomalies, resulting in sharply increased use of CF-28 Requests for Information as a result.
These inquiries should not be treated as routine or being limited to the single entry under review, as CBP expects importers to apply the result of any determination across all analogous entries.
A CF-28 often is a warning that CBP is looking at an entire pattern or type of imports, and importers that fail to respond accordingly risk inviting broader scrutiny, additional duty exposure, and potential enforcement consequences.
Does CBP really have a DEFCON-style tracking center? Well, if NORAD tracks Santa every Christmas Eve, why not? Maybe they even share tracking equipment.
This week’s international trade developments include the following: . . . [Full article]
20. Miller & Chevalier: “Court of International Trade Certifies Class Action for IEEPA Tariff Refunds”
(Source: International and Litigation Alert, 14 Oct 2026) [Editor’s summary]
• Principal Author: Richard A. Mojica, Miller & Chevalier, LLP
In a significant development for importers seeking refunds of tariffs imposed under the International Emergency Economic Powers Act (IEEPA), Judge Richard K. Eaton of the U.S. Court of International Trade (CIT) certified the lead IEEPA refund case as a class action on October 8, 2026. Freestyle World v. United States, slip op. 26-123. The ruling is not final and may be appealed to the U.S. Court of Appeals for the Federal Circuit.
If the certification stands, any refund order ultimately issued by the CIT would apply to all members of the certified class, potentially allowing many importers to recover IEEPA duties without filing their own lawsuits. The court stated that it expected certification to facilitate the refund of unlawfully imposed IEEPA duties to affected importers.
The certified class includes all importers of record that paid duties under the challenged tariff orders between February 1, 2025, and February 19, 2026, excluding companies that have already filed separate refund actions. Class certification is particularly important for importers whose entries were excluded from Customs’ CAPE refund process or who have not pursued individual litigation.
The government opposed certification and may still appeal. A status conference was scheduled for October 13, 2026, to discuss next steps. Importers should continue monitoring developments closely, as an appellate court could reverse the certification decision.
Until the issue is resolved, importers with potentially significant claims should carefully evaluate whether independent legal action remains warranted. . . .
[Full article]
21. ST&R Trade Report: “U.S., Others Pledge Cooperation on Steel Trade Measures”
(Source: Sandler, Travis & Rosenberg Trade Report, 14 Oct 2026) [Excerpts]. Contact: [email protected], 1-305-894-1035
The members of the Global Forum on Steel Excess Capacity – more than two dozen economies that together account for more than half of global steel imports – recently pledged to take further action against global excess steel production capacity.
Asserting that “the global steel industry is in a crisis due to challenges resulting from persistent excess capacity and production that are driven principally by non-market policies and practices that originate outside the GFSEC membership,” the member countries announced a comprehensive framework for joint action that includes the following measures: . . .
Trade data: . . .
Trade remedies: . . .
Export restrictions: . . .
Subsidies: . . .
Other: . . .
22. Volkov: “Software Updates Are Exports Too: Lambda Research’s BIS Settlement Over Huawei and Entity List Customers”
(Source: Volkov Law, 14 Oct 2026) [Excerpts]
• Principal Author: Michael Volkov, Volkov Law Group LLC
Companies that sell software often think of an export as a physical event: a box leaves the warehouse. The Commerce Department’s latest settlement with Lambda Research Corporation is a pointed reminder that for software companies, the export may be an automatic update pushed to a customer overseas months or years after the original sale.
The Bureau of Industry and Security announced the settlement on Friday, citing 66 export control violations involving software and software updates provided to restricted parties in Japan and China between 2021 and 2025.
What BIS Alleged. Lambda, based in Westford, Massachusetts, designs and sells software and hardware for optical and illumination applications, along with related engineering services. According to the reported facts, it ships software on hardware keys, known as dongles, through distributors in Japan and China, and it automatically provides updates to that software.
BIS said the company’s software and updates went to three customers: Huawei Technologies Japan, Shenzhen SiCarrier Technologies, and Sun Yat-sen University. Under the export regulations, those transactions required licenses, and none was obtained.
The first two are on the Entity List. Huawei and its international subsidiaries, including Huawei Japan, were added in 2019 over national security and foreign policy concerns, including suspected sales of products to Iran. Shenzhen SiCarrier was added in 2024, along with 108 other Chinese companies tied to the supply chain for high-end integrated circuits and computers. . . . The third customer, Sun Yat-sen University in Guangzhou, is on the Unverified List, which is a different category with different consequences. . . .
The Resolution. Lambda filed a voluntary self-disclosure with BIS in October 2025 after its own investigation into possible violations. BIS recognized that in the settlement. The agency set a $2 million penalty but deferred it, on condition that Lambda carries out specified improvements to its export compliance program. If the company meets the terms, the penalty is not collected.
The required steps are concrete. . . .
Why This Case Matters. Three features of this settlement deserve attention from any company that sells software or technology internationally: . . . [Full article]
TRAINING EVENTS & CONFERENCES
23. Skill Dynamics Presents: “Jurisdiction, Classification, & Confidence” FREE WEBINAR 5 November
(Source: Skill Dynamics -- previously Content Enablers)
What: “Jurisdiction, Classification, & Confidence", FREE Webinar
When: Thursday, 5 Nov 2026, 12:00 Eastern
Where: At Your Computer
Summary: Presented by Defense Trade Solutions in partnership with Skill Dynamics, this one-hour webinar offers a practical deep dive into ITAR and EAR Jurisdiction & Classification (JCA), with special attention to “specially designed” analysis, so participants can confidently determine whether items, tech data, and software fall under ITAR or EAR.
Presenter: Steven Casazza
Register for Free: and find out more information HERE
EX/IM MOVERS & SHAKERS
24. In Memoriam: Ben Flowe, 1956-2026
(Source: Legacy.com, 14 Oct 2026)
Benjamin Hugh "Ben" Flowe Jr., 70, of Potomac, Maryland, died at home on October 8, 2026, nearly twelve years after he was diagnosed with ALS. He was a nationally recognized export controls lawyer, a devoted Duke fan, the patriarch of his family, and a fierce optimist who refused to let the disease shrink his world.
Ben began practicing law in 1981 at Arent Fox, then worked at Bowman Conner and Verner Liipfert before joining Berliner Corcoran & Rowe in 1997. He was a partner there until he retired in December 2024. At BCR he grew the firm's export controls and sanctions work from a one-person practice into a group known nationally and internationally.
For decades he volunteered on the Commerce Department's Regulations and Procedures Technical Advisory Committee, and he was among the government officials and committee members who oversaw the complete rewrite of the Export Administration Regulations in 1996.
He became a leading authority on the regulations' encryption provisions and lectured on them in the United States and abroad. Colleagues called him the dean of the export control bar in Washington, the man who wrote the book on international export controls, and knew him for his Southern charm, his sense of humor and his generosity as a mentor.
A celebration of life will be held at Bradley Hills Presbyterian Church in Bethesda at a later date. [Full obituary]
25. List of Export/Import Job Openings
(Source: Editor)
Submit job openings HERE.
(To view job description, click Job ID or Title.)
RECENT:
L3Harris. Location of job: Palm Bay, FL. Title: Senior Manager, Trade Compliance - Sector Lead Empowered Official. Job ID #: 43449. Contact: Christina Green, 702-497-1450
Medtronic. Job location: Washington, DC. Title: Senior Principal Legal Counsel, Global Trade Legal & Compliance (Export)
Teledyne. Job locations: Billerica, MA; Elkridge, MD; Goleta, CA; Hudson, NH. Title: Export Licensing Specialist (EAR / ITAR). Job ID: 36249
Teledyne. Job location: Dallas, TX. Title: Trade Compliance Coordinator. Job ID: 31844
FULL LIST (Includes above entries.):
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
Arotech. Job location: Ann Arbor, MI (Hybrid). Title: Director of Trade Compliance. Job ID: 2026-072101. Contact: Erin Heine, 1-734-761-5836
AV. Job locations: 10 U.S. locations. Title: Trade Compliance Officer. Job ID: 8195. Contact: Cherie Labick
Axiom Law. Job location: U.S. Remote. Title: Export Trade Compliance Counsel
BAE Systems. Job location: Hybrid (multiple locations). Title: Senior Manager, Global Trade
Barnes & Thornburg. Job location: Washington, DC. Title: International Trade Associate
Caterpillar. Job location: Singapore. Title: Manager Regional Trade Compliance
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
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
L3Harris. Location of job: Palm Bay, FL. Title: Senior Manager, Trade Compliance - Sector Lead Empowered Official. Job ID #: 43449. Contact: Christina Green, 702-497-1450
Leonid. Job locations: Rancho Cordova, CA; North Canton, OH; Plainfield, IL. Title: Trade Compliance Program Manager
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
Lockheed Martin. Job location: Orlando, FL. Title: International Trade Compliance Staff--Level E4
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)
Medtronic. Job location: Washington, DC. Title: Senior Principal Legal Counsel, Global Trade Legal & Compliance (Export)
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: Sr. 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
Northrop Grumman. Job locations: McLean, VA; Linthicum, MD; Warner Robins, GA. Title: Sr. Principal International Trade Compliance Analyst. Job ID: R10249827
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
Quantinuum. Job location: Arlington, VA (hybrid). Title: Director of Export & Compliance. Job ID: 1015
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 locations: Garland, TX; Billerica, MA; Elkridge, MD. Title: Trade Compliance Director, Aerospace & Electronics Segment. Job ID: REQ33489
Teledyne. Job locations: Billerica, MA; Elkridge, MD; Goleta, CA; Hudson, NH. Title: Export Licensing Specialist (EAR / ITAR). Job ID: 36249
Teledyne. Job location: Dallas, TX. Title: Trade Compliance Coordinator. Job ID: 31844
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
Unical Aviation. Job location: Glendale, AZ; Boca Raton, FL; or Herndon, VA. Title: Senior Legal Counsel
U.S. Customs & Border Protection. Job location: Seattle, WA. Title: General Attorney, Office of Chief Counsel
EDITOR'S NOTES
26. Do You Have Access to the Latest and Greatest ITAR and FTR?
Bartlett's Annotated ITAR ("BITAR") (13 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.
27. Bartlett's Unfamiliar Quotations
(Source: Brainy Quotes)
William Penn (14 Oct 1644 – 30 Jul 1718; was a founding founder of the United States. As one of the earlier supporters of colonial unification, Penn wrote and urged for a union of all the English colonies in what was to become the United States of America. The city of Philadelphia was planned and developed under his directions.)
- "Time is what we want most, but what we use worst."
- “True silence is the rest of the mind, and is to the spirit what sleep is to the body, nourishment and refreshment.”
- “Let the people think they govern and they will be governed.”Katherine Mansfield (Kathleen Mansfield Murry (née Beauchamp; 14 Oct 1888 – 9 Jan 1923; was a prominent New Zealand modernist writer of short stories and poetry. When she was 19, she left colonial New Zealand and settled in England, where she became a friend of D. H. Lawrence, Virginia Woolf, Lady Ottoline Morrel, and others in the orbit of the Bloomsbury Group.)
- “Make it a rule of life never to regret and never to look back. Regret is an appalling waste of energy, you can't build on it it's only good for wallowing in.”
- “Risk! Risk anything! Care no more for the opinions of others, for those voices. Do the hardest thing on earth for you. Act for yourself.”e. e. cummings (Edward Estlin Cummings; 14 Oct 1894 – 3 Sep 1962; often written in all lowercase as “e e cummings”, was an American poet, painter, essayist, author, and playwright. He wrote approximately 2,900 poems, two autobiographical novels, four plays, and several essays. He is often regarded as one of the most important American poets of the 20th century.”
- “To like an individual because he's black is just as insulting as to dislike him because he isn't white.”
- “The most wasted of all days is one without laughter.”Charlie Kirk (Charles James Kirk; 14 Oct 1993 – 10 Sep 2025; was an American political activist, author, and media personality. He co-founded the conservative organization Turning Point USA (TPUSA) in 2012 and served as its executive director. He was the chief executive officer (CEO) of Turning Point Action, Turning Point Academy, and Turning Point Faith; president of Turning Point Endowment; and a member of the Council for National Policy. On September 10, 2025, Kirk was shot and killed while speaking at a TPUSA event on the campus of Utah Valley University during his organization's American Comeback Tour.)
- “America is the only country where even those who hate it refuse to leave.”
- “When people stop talking, that's when you get violence. That's when civil war happens, because you start to think the other side is so evil, and they lose their humanity.”
- “Change my mind.” (This was Kirk’s signature phrase, used during campus debate events.)John Wooden (John Robert Wooden (October 14, 1910 – June 4, 2010) was an American basketball coach and player. Nicknamed "the Wizard of Westwood", he won ten National Collegiate Athletic Association (NCAA) national championships in a 12-year period as head coach for the UCLA Bruins, including a record seven in a row.)
- “Success is peace of mind, which is a direct result of self-satisfaction in knowing you made the effort to become the best of which you are capable.”
28. Today in History
(Source: History Channel)
1066: The Battle of Hastings. King Harold II of England is defeated by the Norman forces of William the Conqueror at the Battle of Hastings, fought on Senlac Hill, seven miles from Hastings, England. At the end of the bloody, all-day battle, Harold was killed—shot in the eye with an arrow, according to legend—and his forces were destroyed. He was the last Anglo-Saxon king of England.
1947: Chuck Yeager breaks the sound barrier. U.S. Air Force Captain Chuck Yeager becomes the first person to fly faster than the speed of sound. Yeager was a combat pilot during World War II and flew 64 missions over Europe. He shot down 13 German planes and was himself shot down over France, but he escaped capture with the assistance of the French Underground. After the war, he was among several volunteers chosen to test-fly the experimental X-1 rocket plane, built by the Bell Aircraft Company to explore the possibility of supersonic flight.
29. 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.
30. 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.
26 Sep 2026 (91 FR 55170) Electronic Export Manifest final rule, prescribed a new 19 CFR 123.93 requiring rail export manifest information to be sent electronically. The rule is effective October 26, 2026, and CBP will begin enforcing it on October 26, 2027.
15 CFR Subtitle B, Ch. VII, Pts. 730-774.
28 Aug 2026 (91 FR 5547), a correction of a typo in Supplement No. 1 to Part 774, in the original rule of 24 Aug 2026 (91 FR 52501), which removed Chinese and Turkish entities.
15 CFR Part 30
11 June 2026 (91 FR 35383): Amendment to Correct Errors. It fixed the note to § 30.2(a)(1)(iv), which still pointed to § 30.16, a section the March 30 rule had removed.
(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. A second, broader amendment was proposed in December 2023 but has not been published as a final rule.
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
Oct. 1, 2026 (91 FR 62313): Removed Syria from ITAR § 126.1(d)(1). On Oct. 13, 2026, changes to Sections 120.54 and 121.0 took effect.
(The latest edition of Bartlett's Annotated ITAR ("BITAR") is Oct. 13, 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.“