26-1021: Wednesday's "Export/Import Daily Bugle"

1. President Implements Act Sanctioning Russia and Iran
(Source: 91 FR 66627, 21 Oct 2026)

2. Future Federal Register (Two items)
(Source: Future Federal Register, 21 Oct 2026)

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

4. 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.”

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

6. Commerce/USCS: “Gulf Coast Aerospace & Defense Summit - Free Webinar on 2 Nov 2026”
(Source: USCS, Aerospace & Defense, 20 Oct 2026)

     Airbus, a principal sponsor of the Gulf Coast Aerospace & Defense Summit, will bring delegates from procurement, engineering, supply chain, and technical teams.
     The event will connect regional, U.S., and international companies through networking and matchmaking opportunities with potential customers, partners, and suppliers across commercial, defense, and space sectors.

7. State/DDTC (Nothing new.)
(Source: Defense Directorate of Trade Controls)

8. Treasury/OFAC: “Iran-related Designations; Belarus and North Korea Designations Removals; Issuance of Iran-related and Russia-related General Licenses and Amended FAQs”
(Source: Treasury/OFAC, 21 Oct 2026)

     The Department of the Treasury's Office of Foreign Assets Control (OFAC) is issuing Iran General License GG, "Authorizing the Wind Down of Transactions Involving Karnakis and Karnakis;" and Iran General License HH, "Authorizing Wind Down Activities, Limited Safety and Environmental Transactions, and the Offloading of Cargo Involving Certain Persons or Vessels Blocked on October 21, 2026."
     Additionally, OFAC is issuing Russia-related General License 131K, "Authorizing Certain Transactions for the Negotiation of and Entry Into Contingent Contracts for the Sale of Lukoil International GmbH and Related Maintenance Activities." OFAC is also issuing two amended Frequently Asked Questions, FAQ 1224 and FAQ 1225.
     Lastly, OFAC has made the following changes to the list of Specially Designated Nationals and Blocked Persons (SDN List): [See list HERE.]

9. UK Export Control: “Open General Export Licence (Military Goods, Software and Technology)”
(Source: UK ECJU, 20 Oct 2026)

     Guidance: Open general export licence (military goods, software and technology). Licence for the export of a wide range of military equipment to low-risk destinations.
     20 October 2026 Update: List of permitted destinations expanded to include Bulgaria, Croatia, Czechia, Estonia, Greece, Hungary, Latvia, Liechtenstein, Lithuania, Luxembourg, Poland, Portugal, Romania, Slovakia, Slovenia, South Korea and Switzerland for government, NATO and commercial end-users. . . .

10. US Trade Representative (No relevant items.)
(Source: USTR.gov)

11. White House Actions (No new items of Ex/Im interest.)
(Source: The White House)

12. Expeditors News: “White House Announces Implementation and Waiver of Russian Sanction Duties”
(Source: Expeditors News, 20 Oct 2026) [Excerpts]

     In an Executive Order (EO) published on October 16, 2026, the White House announced the implementation of sanctions authorized under the Lindsey O. Graham Sanctioning Russia and Iran Act of 2026 (the Graham Act), while simultaneously waiving the duties imposed by the legislation.
     The Graham Act was signed into law on September 18, 2026, and authorizes sanctions duties of up to 500 percent ad valorem on goods originating from the Russian Federation. According to the EO, these duties were to go into effect on October 18, 2026.
     However, Section 115 of the Graham Act provides the President with authority to waive the application of these sanctions. The EO states that the waiver is being issued “in the national interests of the United States.”
     The “Implementing the Lindsey O. Graham Sanctioning Russia and Iran Act of 2026” EO is HERE. The text of the Graham Act is HERE.

13. ST&R Trade Report: “Section 338 Tariffs on Imports from Canada Challenged in Court”
(Source: Sandler, Travis & Rosenberg Trade Report, 21 Oct 2026) [Excerpts]. Contact: [email protected], 1-305-894-1035

     The first legal challenge to tariffs imposed under Section 338 of the Tariff Act of 1930 was filed Oct. 20 at the Court of International Trade. The case challenges President Trump’s 50% tariffs on certain Canadian imports, effective Aug. 22, covering roughly $20 billion in annual trade.
     Filed by the Liberty Justice Center on behalf of a U.S. importer and a proposed class of importers, the lawsuit seeks to invalidate the tariffs, halt their collection, obtain refunds, and secure a preliminary injunction.
     The complaint argues that Section 338 was intended to address specific foreign discrimination against U.S. commerce, not serve as a broad tariff authority. It contends that Congress effectively replaced Section 338 with Section 301 of the Trade Act of 1974, that Canada’s cited policies do not justify the tariffs, that many targeted products are unrelated to the alleged discrimination, and that the administration failed to comply with the statute’s 30-day waiting period.
     The suit also warns that a broad interpretation of Section 338 could allow future presidents to impose tariffs without meaningful congressional oversight. . . . [Full article]

14. Washington Tariff & Trade Letter: “DHS DeepSeek Removal Order Extends to Third-Party AI Products, Raising Supplier Due Diligence Questions”
(Source: Washington Tariff & Trade Letter, 21 Oct 2026) [Editor’s summary of paywall publication.]

     The Department of Homeland Security has ordered federal civilian agencies to stop procuring DeepSeek products and remove them from government systems. The order, issued under the Federal Acquisition Supply Chain Security Act, also covers third-party products and services that incorporate DeepSeek technology, creating significant compliance challenges for federal contractors.
     Hogan Lovells partner Elizabeth Cannon said the measure effectively requires AI provenance analysis, as suppliers may need to identify embedded models, subcontractor services, and hosted AI components to determine whether their products are covered. Questions remain about the scope of the phrase “developed using DeepSeek implementations.”
     The order is the second FASC-recommended removal action and was prompted by concerns over possible Chinese government access to data and sensitive information. Separately, China has proposed new controls on exports of advanced AI technologies.
     Together, the U.S. and Chinese measures create dual compliance obligations, requiring companies to assess both AI-model provenance and restrictions on technology transfers. [Full article]

15. Baker McKenzie: “US Moves Syria to Case-by-Case ITAR Licensing Review”
(Source: Global Sanctions and Export Controls Blog, 21 Oct 2026) [Excerpts]

• Principal Author: Janet K. Kim, philippe Reich; Baker McKenzie

     On October 1, 2026, the US Department of State published a final rule amending the International Traffic in Arms Regulations (“ITAR”) to remove Syria from the list of countries subject to a policy of denial for licenses and other approvals for exports, imports of defense articles and defense services. The rule took effect on publication of the final rule, and the State Department will now adjudicate applications for licenses or other approvals involving Syria on a case-by-case basis under the new policy.
     As we previously reported, the State Department rescinded Syria’s designation as a State Sponsor of Terrorism (“SST”) effective August 24, 2026. The updated Tri-Seal Advisory that the Departments of Commerce, State, and the Treasury issued the same day stated that the State Department would amend the ITAR to eliminate the Syria policy of denial once all relevant statutory restrictions were resolved. . . .
     This final rule implements that policy change so that defense article and defense service transfers to Syria are now reviewed on a case-by-case licensing basis. The State Department also stated that the statutory prerequisites for amending Syria’s status under § 126.1 had been satisfied.
     These include:

     The ITAR licensing requirements that previously applied to Syria-related exports and imports remain unchanged. The rule only changes the review policy the State Department applies to applications for authorization, which will now be considered individually.
     Companies should continue to screen Syrian counterparties against the US Treasury Department’s Specially Designated Nationals and Blocked Persons List, which still targets a number of Syrian nationals, including Bashar al-Assad and his associates, human rights abusers, Captagon traffickers, and other actors designated under Executive Order 13894, as amended, and other authorities. . . . [Full article]

16. Herbert Smith: “Defence industry recruitment in Australia: ITAR, AUKUS and Discrimination Risk”
(Source: HSFK Insights, 21 Oct 2026) [Editor’s summary]

• Author: Nicholas Ogilvie, Herbert Smith Freehills Kramer (Australia)

     Australia’s defence sector is expanding rapidly due to AUKUS, sovereign manufacturing initiatives, shipbuilding programs and increased defence spending. Demand is rising for engineers, cyber specialists, advanced manufacturing workers and project professionals, while pressure on global weapons production highlights the need for resilient supply chains.
     Yet recruitment is shaped not only by skills shortages but also by security, export-control and legal requirements. Many roles require security clearances and access to controlled technology, meaning qualified candidates may still be unable to perform certain work.
     The US International Traffic in Arms Regulations (ITAR) remain a major influence on Australian defence hiring. Employers must manage access to controlled technology while avoiding discriminatory hiring practices based on nationality or citizenship.
     Although AUKUS reforms have eased some export-control burdens, compliance obligations remain. Defence employers must balance workforce needs, national security requirements, export-control rules and anti-discrimination laws, often supported by limited statutory exemptions.

17. Sheppard Mullin: “IEEPA Tariffs Struck Down, Replacement Tariffs Expired: What Importers Need to Know Now”
(Source: Global Trade Law Blog, 21 Oct 2026) [Editor’s summary]

• Principal Author: J. Scott Maberry, Sheppard, Mullin Richter & Hampton LLP

     U.S. tariff litigation continues to reshape trade policy. On February 20, 2026, the U.S. Supreme Court ruled that the International Emergency Economic Powers Act (IEEPA) does not authorize presidential tariffs, invalidating tariffs imposed under that statute.
     The administration responded by imposing a 10% global tariff under Section 122 of the Trade Act of 1974. On May 7, 2026, a divided U.S. Court of International Trade panel held those Section 122 tariffs unlawful as well, although the decision has been stayed pending appeal.
     The article examines both rulings, importers’ options for seeking tariff refunds, and the continuing uncertainty surrounding future tariff authority. It also explains key trade-law concepts, including IEEPA, Sections 122, 232, 301, and 338 tariff authorities, Customs liquidation and protests, CBP’s CAPE refund process, balance-of-payments deficits, and industrial overcapacity. [Full article]

18. Volkov: “Your Employees Are Already Using AI. Where Is Your Policy?”
(Source: Volkov Law, 21 Oct 2026) [Excerpts]

• Principal Author: Michael Volkov, Volkov Law Group LLC

     AI is not coming to your company. It is already there. Employees are using AI to draft emails, summarize contracts, write code, and analyze data, often through unapproved personal accounts. Without a responsible AI use policy, you do not have an AI strategy. You have an AI exposure.
     The risks are real. Courts have sanctioned lawyers for AI-generated fake citations, regulators have pursued AI-washing claims, and employees have exposed confidential data through public chatbots. These are governance failures, not technology failures.
     A responsible AI policy should: require approved tools; classify permitted, restricted, and prohibited uses; protect sensitive data; keep humans accountable; require verification of AI outputs; ensure transparency; govern third-party AI use; and establish oversight through a cross-functional governance structure.
     AI is a compliance issue as much as an IT issue, affecting privacy, security, discrimination, intellectual property, and regulatory compliance. Companies that set clear rules, train employees, and maintain accountability will capture AI’s benefits. Those that do not may find themselves answering to regulators. . . . [Full article]

19. Skill Dynamics Presents: “Jurisdiction, Classification, & Confidence” Webinar, 5 Nov 2026
(Source: Skill Dynamics — previously Content Enablers)

20. FD Associates Presents: “ITAR AUKUS Exemption” Webinar, 17 Nov
(Source: Sarah Huffman, [email protected])

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

RECENT:

FULL LIST (Includes above entries.):

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

24. Today in History
(Source: History Channel)

     1805: Battle of Trafalgar. In one of the most decisive naval battles in history, a British fleet under Admiral Lord Nelson defeats a combined French and Spanish fleet at the Battle of Trafalgar, fought off the coast of Spain. At sea, Lord Nelson and the Royal Navy consistently thwarted Napoleon Bonaparte, who led France to preeminence on the European mainland. Nelson’s last and greatest victory against the French was the Battle of Trafalgar, which began after Nelson caught sight of a Franco-Spanish force of 33 ships. Preparing to engage the enemy force on October 21, Nelson divided his 27 ships into two divisions and signaled a famous message from the flagship Victory: “England expects that every man will do his duty.”

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

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26. 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.