26-1026: Monday's "Export/Import Daily Bugle"

1. USTR Seeks Comments on Suspending Section 301 Action on China’s Targeting of the Maritime, Logistics, and Shipbuilding Sectors
(Source: 91 FR 67388, 26 Oct 2026)

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

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)

     To maintain your Customs Broker license, you are required to complete 20 hours of Continuing Education (CE) by 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. . . .
     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.
     [Full requirements]

5. CBP to Hold UFLPA Enforcement Statistics Dashboard Webinar 28 Oct 2026
(Source: OTR Webinars)

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

7. Justice: “U.S. Government Contractor Arrested for Allegedly Leaking National Defense Information”
(Source: Dept. of Justice Office of Public Affairs, 23 Oct 2026) [Excerpts]

     A U.S. government contractor was arrested by the FBI this morning for allegedly leaking national defense information to another individual who repeatedly posted classified information to an online publication.
     “National defense information is classified to protect the American people from bad actors around the world who wish to do us harm,” said Attorney General Todd Blanche. “The details alleged in this affidavit reflect the behavior of a government contractor who exempted himself from a federal law governing the protection of classified information. . . .”
     “Following a referral from the Agency, on Friday, October 23rd, the FBI arrested a contractor who provided services to CIA for alleged unauthorized disclosures of classified information,” . . .
     Ian A. Brinksman, 42, of the District of Columbia was arrested following a search of his residence and charged by criminal complaint with unlawfully transmitting national defense information.
     According to the criminal complaint, beginning in 2020, the defendant worked as an employee of a U.S. government agency based in the Eastern District of Virginia and later in 2022 began working as a developer for systems integration for “Company 1,” a contractor to the same U.S. government agency. During all times relevant to the complaint, Brinksman held a Top Secret security clearance with Sensitive Compartmented Information (SCI) access.
     As further detailed in the complaint, Brinksman had an ongoing personal relationship with an individual who maintains an online publication on Substack (Individual 1). A fundraising article reportedly published by Individual 1 in September 2026 claimed Individual 1 had “published reporting based on classified [relevant U.S. government agency] assessments.” Individual 1 posted on her social media profile, “I also accept leaks.”

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

9. Treasury/OFAC Issues Amended FAQs re Blocking and Rejecting Transactions and Filing Reports with OFAC
(Source: Treasury/OFAC, 26 Oct 2026)

     The Department of the Treasury’s Office of Foreign Assets Control (OFAC) has amended several FAQs (10, 32, 33, 34, 35, 36, 41, 42, 49, 50, and 53) as part of its review of published guidance. This batch includes the FAQ topics on Blocking and Rejecting Transactions and on Filing Reports with OFAC.

10. UK Export Controls: “Proposed Amendments to UK Strategic Export Controls”
(Source: UK ECJU, 23 Oct 2026)

     This notice provides advance information on proposed amendments to the UK’s strategic export control framework.
     Subject to ministerial and Parliamentary approval, regulations are expected to be laid before Parliament in November 2026 and expected to come into force in early December 2026.
     The proposed amendments would update the UK’s strategic export control framework.
     The regulations and accompanying explanatory memorandum will be published on legislation.gov.uk in due course.

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

12. ABA Banking Journal: “Recent News from Treasury’s Office of Foreign Assets Control”
(Source: ABA Banking Journal, 26 Oct 2026)

     Iran-related Sanctions: Treasury targets Iran sanctions-evasion network under Operation Economic Outcast: The Treasury Department sanctioned a Panama- and Greece-based law firm, shipping agents and cargo vessels for supporting Iranian shipping and sanctions-evasion activity as part of Operation Economic Outcast.
     Treasury said the action targets networks helping Iran generate revenue and access the global financial system, while FinCEN is coordinating with European partners to investigate financial institutions’ potential ties to Iran and its proxies. Read more.
     Iran-related and Russia-related Sanctions. OFAC issues Iran- and Russia-related general licenses: OFAC issued two Iran-related general licenses authorizing certain wind-down and other limited transactions involving recently blocked persons and vessels, as well as a Russia-related general license authorizing certain transactions involving the potential sale of Lukoil International GmbH. OFAC also amended two Russia-related FAQs and updated its Specially Designated Nationals and Blocked Persons List. Read more.

13. Breaking Defense: “Pentagon, Lockheed Agree to Decade-Long F-35 Framework Deal for Hundreds of Jets”
(Source: Breaking Defense, 22 Oct 2026) [Editor’s summary]

     The Pentagon and Lockheed Martin have announced a proposed 10-year framework agreement for the F-35 Joint Strike Fighter program, covering at least 850 U.S. aircraft across 10 production lots, along with spare parts, sustainment, and modernization kits.
     The deal would maintain production at 156 aircraft annually and includes a pledge by Lockheed to invest $7 billion in program-related improvements.
     Pentagon officials say the agreement would strengthen the defense industrial base, improve efficiency, and provide long-term planning stability. Lockheed argues the arrangement would support supplier investments, expand capacity, improve quality, and lower costs through economies of scale and pooled parts procurement.
     However, significant questions remain. The agreement requires congressional authorization and funding, and contract terms, pricing, and schedules have not yet been finalized.
     The Pentagon has not disclosed the total cost or estimated taxpayer savings. House lawmakers have proposed conditions requiring full spare-parts packages and at least 5% cost savings before approving multi-year procurement authority.
     A major unresolved issue is whether Congress will authorize the proposed multi-year sustainment portion of the deal. Previous attempts at long-term F-35 maintenance agreements stalled because cost savings and readiness improvements could not be demonstrated.
     The program’s lifetime cost is estimated at nearly $2 trillion, making sustainment and readiness key concerns.

14. Diaz: “Breaking Trade News--338 Lawsuit, Postal Rule Date Extended, No New 232 Tariffs on Wind Turbines”
(Source: Customs & International Trade Law Blog, 23 Oct 2026) [Editor’s Summary]
• Author: Jennifer Diaz, Diaz Trade Law LLP

     Administration: President Trump implemented the Lindsey O. Graham Sanctioning Russia and Iran Act, imposing a 500% duty on Russian-origin goods and 100% duties on certain countries buying Russian energy or aiding sanctions evasion. The Administration declined new Section 232 tariffs on wind turbines, leaving existing steel, aluminum, and copper tariffs unchanged.
     CBP: Formal-entry requirements for postal shipments were delayed to Jan. 20, 2027. CBP also eased Entry Type 13 filing requirements and seized 2,772 counterfeit-certified ceramic sinks in Virginia.
     CIT: A food importer challenged Canadian tariffs under Section 338; litigation continues over forced-labor Section 301 tariffs. The court also ruled it lacked jurisdiction over certain pending classification protests.
     Commerce: Opened AD/CVD investigations on corrugated cardboard boxes from China, Malaysia, and Türkiye, and an antidumping case on Chinese amine compounds.
     Sanctions & Compliance: OFAC expanded Iran-related sanctions and issued Russia GL 131K. State sanctioned five Chinese entities for IP theft. FinCEN warned of Iranian abuse of religious charities. FDA issued cosmetics-recall guidance and updated import alerts. FCC blocked two devices containing covered foreign chips.
     [Full article]

15. Expeditors News: “UK HMRC Updates Guidance on Import VAT Valuation”
(Source: Expeditors News, 23 Oct 2026)

     In guidance updated on October 21, 2026, the United Kingdom’s HM Revenue & Customs (HMRC) clarified how import value-added tax (VAT) should be calculated on imported goods. HMRC confirms that the value for import VAT is based on the customs value of the goods, plus applicable customs duties, taxes, and certain transport and related incidental costs.
     The guidance also reiterates the use of Method 2, a simplified valuation approach that allows importers to apply standard UK incidental expense rates rather than declaring actual costs.
     Under Method 2, the following rates apply:

     The guidance encourages importers to review their customs valuation and import VAT calculation processes to ensure continued accuracy and compliance with HMRC requirements. HMRC’s updated VAT guidance is HERE.

16. IsraelDefense: “US Government Contractor Arrested for Allegedly Leaking Classified Defense Data”
(Source: IsraelDefense News, 26 Oct 2026)

     Ian A. Brinksman is accused of unlawfully transmitting top secret intelligence to his partner, who repeatedly published classified assessments on Substack.
     The FBI has arrested a government contractor on suspicion of leaking classified national defense information to another individual who repeatedly published classified material online. The suspect is Ian A. Brinksman.
     According to a Justice report, Attorney General Todd Blanche emphasized that national defense information is classified to protect the American people from adversaries around the world seeking to cause harm. Brinksman, 42, of Washington, D.C., was arrested following a search of his home and is charged in a criminal complaint with the unlawful transmission of national defense information.
     The details of the case drew sharp reactions from top U.S. law enforcement and intelligence officials, who made clear that the alleged actions constitute a severe breach of public trust and federal law.
     Blanche noted that the details alleged in the affidavit reflect the conduct of a government contractor who exempted himself from federal law governing the protection of classified information, adding that the Department of Justice will continue to prosecute individuals who leak classified information and endanger national security. . . .
     [Full article]

17. ST&R Trade Report: “List of Canadian Goods Subject to Section 338 Tariff Modified”
(Source: Sandler, Travis & Rosenberg Trade Report, 26 Oct 2026). [Excerpts]. Contact: [email protected], 1-305-894-1035

     President Trump issued Oct. 23 a proclamation making further modifications to the list of Canadian goods subject to a Section 338 tariff of 50 percent.
     Products initially subject to this tariff (as set forth here, here, and here) include wine and other alcoholic beverages, cosmetics, ice skates, hockey sticks, fishing rods, cement, paper and wood items, honey, textiles and apparel, machinery, jewelry, furniture, and other items. The president later added more than 100 goods to this list and removed ten (see here and here for more details).
     The newest proclamation removes 22 products from the tariff list, including certain plywood sheets, paper products, machinery and refrigeration equipment, and packing crates and boxes. . . .
     [Full article]

18. WTTL: “Commerce Blocks Export-Control Exception for South Korea”
(Source: Washington Tariff & Trade Letter, 26 Oct 2026) [Editor’s summary of article in subscription publication.]

     Senior Commerce Department officials have reportedly frozen expansion of the License Exception Implemented Export Controls (IEC) program, rejecting recommendations to add South Korea and Vietnam and halting preliminary discussions with Saudi Arabia.
     The program provides licensing relief for certain advanced technologies to countries that adopt export controls comparable to those of the United States.
     According to reporting by Politico, career officials viewed IEC as an incentive for partners to align with U.S. controls and reduce technology diversion to China. Despite South Korea tightening its export-control regime in 2024, it remains ineligible for IEC. The freeze leaves licensing requirements unchanged for affected exports of specified quantum-computing, semiconductor-manufacturing, additive-manufacturing, and related technologies.
     IEC was established by BIS in September 2024 as part of worldwide controls on selected advanced technologies. BIS currently lists 14 eligible destinations, including Australia, Canada, Japan, the Netherlands, and the United Kingdom. South Korea, Vietnam, Saudi Arabia, India, Israel, Singapore, Switzerland, Taiwan, the UAE, China, and Russia are not listed.
     South Korea remains subject to a presumption of approval for relevant license applications, but exporters generally must still obtain licenses. The reported freeze raises questions about whether foreign governments will continue aligning their controls with U.S. policy if the anticipated licensing benefits do not materialize. [Full article]

19. ArentFox: “As the (Customs and Trade) World Turns”
(Source: ArentFox Perspectives/Alerts, 26 Oct 2026) [Excerpts]
• Principal Author: Andrew McArthur, ArentFox Schiff LLP

     In this October 2026 edition, we cover:

     [Full article]

20. Burns, Clif: “Abr-ITAR-cadabra! You Are Now on the USML”
(Source: Export Law blog, 23 Oct 2026) [Editor’s Summary]
• Author: Clif Burns, Clark Hill LLP

     Language in the recently proposed ITAR amendments may reveal one of those worst nightmare scenarios that have been frightening people for years (and not just at Halloween).
     You buy a 3A611.x part from a vendor, you put it in a product you manufacture and sell, and then, after you have thousands of your product in the field, you learn that one midnight the part turned not into crazed gremlins, but an even more frightening ITAR item!
     How could this transformation happen? Did somebody give the part food after midnight? No, it was repurposed and — poof! — it’s now a part specially designed for a defense article on the USML. And thanks to the “see-through” rule, your items using that part may now be subject to all of the export controls in the ITAR.
     DDTC does not specifically address the issue of previously manufactured parts, but, as a practical matter, even if DDTC says earlier manufactured parts are not transformed, if the part used on the submarine is identical, it will be difficult to document whether the part is controlled or not.
     What’s driving this horror scenario is a strange explanation given in the Federal Register notice for a new “release” in the definition of “specially designed.”
     The new release is intended to deal with a supposed problem for items developed as parts of defense articles where the relevant USML listing does not cover “specially designed parts” for that item. The release, DDTC suggests, is needed in case that part is later used in a defense article in a USML category that does cover specially designed parts.
     Here is the explanation of the concern: For example, consider a component originally developed for an electronic support system described in paragraph (a)(4)(i) of USML Category XI. If the component is not described elsewhere on the USML, it is subject to the EAR and described in Export Control Classification Number (ECCN) 3A611.x. Years later, the unmodified component is reused in an electronic support system.
     The practical consequences of this mysterious transmogrification can be considerable. If post-transition you export the article with the part you will have to register under Part 122. The 60-day notice requirement will apply to a transfer of ownership or control of your company to a foreign person. The ability to use license exceptions STA and APR disappears in a puff of smoke.
     Let’s see if this proposal makes it into the final rule. I’m not placing a bet one way or the other. [Full article]

21. Srpske: “Without an OFAC license, NIS Reserves Last 2-3 Months”
(Source: Srpske Novine, 26 Oct 2026) [Editor’s summary]

     The U.S. Office of Foreign Assets Control (OFAC) license allowing Petroleum Industry of Serbia (NIS) to operate expires on October 30. NIS has requested a new special license from the U.S. Treasury to continue operating without interruption, emphasizing its importance to Serbia’s fuel supply and the operation of the Pancevo refinery.
     Energy analyst Zeljko Markovic said he expects OFAC to grant an extension, citing improving U.S.-Russia dialogue and ongoing discussions regarding NIS’s ownership structure. However, the duration of any extension remains uncertain.
     If OFAC does not extend the license, Markovic said the Pancevo refinery would initially continue processing existing crude oil inventories. Once those stocks are depleted, refining operations would stop. Fuel supplies to the Serbian market would nevertheless continue through existing fuel reserves and imports for an estimated two to three months. Shortages would become a risk only if the issue remained unresolved beyond that period.
     Markovic also noted that global oil prices have risen sharply, with Brent crude trading around $115 per barrel, up from roughly $60 earlier. Elevated diesel prices reflect both higher crude costs and limited refining capacity. Additional Russian diesel supplies and releases from reserves may help stabilize prices but are unlikely to cause significant declines. [Full article]

22. ST&R Trade Report: “Beef Import Regulations Would be Amended Under USDA Proposal”
(Source: Sandler, Travis & Rosenberg Trade Report, 26 Oct 2026) [Excerpts]. Contact: [email protected], 1-305-894-1035

     The Department of Agriculture’s Animal and Plant Health Inspection Service is proposing to lower from 4 ºC to 2 ºC the minimum maturation temperature for fresh (chilled or frozen) boneless beef and ovine meat from certain listed regions or countries affected with foot-and-mouth disease.
     Comments on this proposal are due no later than Dec. 21. APHIS states that all other existing mitigations for the importation of beef from regions or countries affected with FMD would remain unchanged.

23. Volkov: “475 Sanctions Violations: Screening, Cooperation, and the Cost of Getting No Credit”
(Source: Volkov Law, 25 Oct 2026) [Editor’s Summary]
• Principal Author: Michael Volkov, Volkov Law Group LLC

     In this episode of Corruption, Crime and Compliance, Michael Volkov examines OFAC’s $11,662,930 settlement with Bank of America for 475 apparent sanctions violations, together with what the full Treasury package shows about remediation and cooperation.
     He walks through four failure modes: payments through 35 blocked banks, exact matches of names and dates of birth ranked as low priority, stale watchlists caused by vendor and internal errors, and mishandled business accounts tied to blocked persons.
     Volkov explains why OFAC gave no penalty reduction for remediation or cooperation, pointing to a narrow initial lookback, piecemeal responses, reckless conduct, and prior cautionary letters, and he outlines what the bank must now do under the FinCEN, OCC, and OFAC resolutions.
     He closes with eight practical lessons, including prioritizing exact matches, verifying daily watchlist updates, reviewing auto-clear rules, scoping lookbacks to root causes, building a self-disclosure process in advance, and integrating AML and sanctions programs.
     [Listen to podcast HERE.]

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

25. Global Training Center Presents: “Exporting Procedures” Webinar 17 Nov 2026
(Source: Global Training Center)

26. FD Associates Presents: “ITAR FMS Exemption” Webinar, 1 Dec 2026
(Source: Sarah Huffman)

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

FULL LIST (Includes above entries.):

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

30. Today in History
(Source: History Channel)

     1825 – The Erie Canal officially opened, linking the Great Lakes with the Atlantic Ocean via the Hudson River and transforming U.S. commerce. Work began on the waterway in 1817. Teams of oxen plowed the ground, but for the most part the work was done by immigrants, mostly Irish diggers who had to rely on hand tools. They were paid $10 a month, and barrels of whisky were placed along the canal route as encouragement. West of Troy, 83 canal locks were built to accommodate the more than 500-foot rise in elevation. After more than two years of digging, the 363-mile Erie Canal from Albany to Buffalo was opened on October 26, 1825, by Governor Clinton.

     1881 – The famous Gunfight at the O.K. Corral took place in Tombstone, Arizona. After silver was discovered nearby in 1877, Tombstone quickly grew into one of the richest mining towns in the Southwest. Wyatt Earp, a former Kansas police officer working as a bank security guard, and his brothers, Morgan and Virgil, the town marshal, represented “law and order” in Tombstone, though they also had reputations as being power-hungry and ruthless. The Clantons and McLaurys were cowboys who lived on a ranch outside of town and sidelined as cattle rustlers, thieves and murderers. In October 1881, the struggle between these two groups for control of Tombstone and Cochise County ended in a blaze of gunfire at the O.K. Corral. The famous gunfight that ensued lasted all of 30 seconds, and around 30 shots were fired. Though it’s still debated who fired the first shot, most reports say that the shootout began when Virgil Earp pulled out his revolver and shot Billy Clanton point-blank in the chest, while Doc Holliday fired a shotgun blast at Tom McLaury’s chest. Though Wyatt Earp wounded Frank McLaury with a shot in the stomach, Frank managed to get off a few shots before collapsing, as did Billy Clanton. When the dust cleared, Billy Clanton and the McLaury brothers were dead, and Virgil and Morgan Earp and Doc Holliday were wounded. Ike Clanton and Claiborne had run for the hills.

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.