26-1027: Tuesday's "Export/Import Daily Bugle"

1. Commerce/BIS Renews Temporary Denial Orders for Mahan Airways and 11 Additional Parties
(Source: 91 FR 67542, 27 Oct 2026)

2. CBP Customs Broker Permit User Fee Due 29 Jan 2027
(Source: 91 FR 67594, 27 Oct 2026)

3. Future Federal Register (No relevant 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)

     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]

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

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

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

9. Treasury/OFAC Updates Sanctions FAQs
(Source: Treasury/OFAC, 27 Oct 2026)

     The Department of the Treasury's Office of Foreign Assets Control (OFAC) is amending several Frequently Asked Questions (FAQs) today (10, 32, 33, 34, 35, 36, 41, 42, 49, 50, and 53).This batch includes the FAQ topics on Blocking and Rejecting Transactions and on Filing Reports with OFAC.

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

11. Expeditors News: “White House Announces Modifications to Section 338 Tariffs”
(Source: Expeditors News, 26 Oct 2026)

     In a Presidential Proclamation published on October 23, 2026, the White House announced modifications to the list of Canadian products subject to the 50% Section 338 tariffs.
     As of October 30, 2026, the following goods will no longer be subject to the Section 338 tariffs:

     The modifications also add more than 100 products that will now be subject to Section 338 tariffs. The newly covered products span several industries and include, but are not limited to cocoa powder, acrylic paints, soaps, artificial waxes, chemical residuals, vinyl flooring, fiberboard, and certain carpet products.
     These changes will go into effect at 12:01 a.m. Eastern Time on October 30, 2026. The “Further Modifying the Scope of the Products of Canada Subject to the Additional Duties Imposed to Offset Canadian Discrimination Against the Commerce of the United States with Respect to Motor Vehicles” is HERE. The accompanying fact sheet is HERE.

12. ST&R Trade Report: “Further Suspension of China Ship Fees, Crane Tariffs Considered”
(Source: Sandler, Travis & Rosenberg Trade Report, 27 Oct 2026). Contact: [email protected], 1-305-894-1035

     The Office of the U.S. Trade Representative is accepting comments through Oct. 30 on a proposal to extend for two months the suspension of fees on Chinese vessels and higher tariffs on imports of Chinese port equipment.
     Earlier this year USTR suspended through 11:59 p.m. EST on Nov. 9, 2026 (1) the fees imposed on Chinese-owned or -operated vessels and Chinese-built vessels, which had been in effect since Oct. 14, and (2) the imposition of 100 percent tariffs on imports of certain ship-to-shore cranes and cargo handling equipment from China.
     These measures were announced following a determination by USTR that China’s targeting of the maritime, logistics, and shipbuilding sectors for dominance is unreasonable and burdens or restricts U.S. commerce and is therefore actionable under the Section 301 trade law.

13. WTTL: “Treasury Proposes Broader Outbound Investment Controls, Extending Restrictions to Biotechnology”
(Source: Washington Tariff & Trade Letter, 23 Oct 2026) [Excerpts of subscription publication]

     The U.S. Treasury Department has proposed a major expansion of outbound investment restrictions under the Comprehensive Outbound Investment National Security (COINS) Act.
     The Oct. 22 proposal would broaden existing controls on semiconductors, artificial intelligence, and quantum technologies, while adding biotechnology, hypersonic technologies, and additional high-performance computing activities. Comments are due Dec. 7, 2026.
     The proposal would extend coverage beyond China, Hong Kong, and Macau to include Cuba, Iran, North Korea, and Russia. It would apply not only to acquisitions but also to certain equity investments, loans with governance rights, joint ventures, business expansions, and some private-fund investments.
     Biotechnology provisions have drawn particular attention because they could affect investments involving vaccines, cell and gene therapies, monoclonal antibodies, sequencing technologies, and related research tools. Industry groups support the national security goals but warn overly broad restrictions could hamper innovation, competitiveness, and medical research partnerships.
     Under the proposal, companies would be responsible for conducting due diligence to determine whether transactions are prohibited or require notification, with violations potentially resulting in penalties or forced divestment. . . .
     [Full article]

14. Baker McKenzie: “Mexico: Customs Law Amendments Expand Precautionary Seizure for Undervalued Imports Beginning 1 Jan 2027”
(Source: Global Sanctions and Export Controls Blog, 27 Oct 2026) [Editor’s Summary]
• Principal Author: José Hoyos-Robles (Mexico); Baker McKenzie

     Mexico’s president issued a decree on Oct. 23, 2026, amending the Customs Law effective Jan. 1, 2027. The changes significantly expand customs authorities’ power to initiate audits and seize imported goods when the declared customs value is lower than the transaction value of identical or similar goods. The current 50% undervaluation threshold will be eliminated, potentially exposing more importers to enforcement actions.
     The reform also establishes new procedures for releasing seized goods. Importers will have 10 business days to request substitution of a seizure by posting a cash deposit or, in some cases, a customs guarantee. Different requirements apply depending on whether the value difference is below or above 20%.
     Additional changes affect temporary imports, creating a presumption of violation when declared values are at least 20% below comparable transaction values. Penalties for violations involving hydrocarbons and petroleum products will increase sharply, reaching 50% to 100% of the goods’ commercial value.
     Importers should review valuation documentation, pricing arrangements, and forthcoming implementing regulations before the law takes effect. . . . [Full article]

15. Bass, Berry & Sims: “International Trade Enforcement Roundup”
(Source: Bass, Berry & Sims) [Editor’s Summary]
• Principal Author: Faith Dibble; Bass, Berry & Sims PLC

     Key Takeaways:

     [Full article]

16. Breaking Defense: “How the Pentagon Wants to Buy Cyber Outcomes, Not Equipment”
(Source: Breaking Defense, 27 Oct 2026) [Editor’s Summary]

     The Pentagon is pursuing a new cyber operations model called Cyber Effects-as-a-Service (CEaaS) to address a growing gap between demand for cyber capabilities and the government's ability to provide them.
     Rather than contracting for specific tools or software, CEaaS would contract for operational outcomes, with private companies using their own expertise, personnel, and infrastructure under government direction and oversight.
     Defense officials, led by Assistant Secretary of Defense Katie Sutton, argue that industry must evolve from a traditional contractor role to a more active operational partner.
     The Pentagon believes commercial firms, particularly innovative venture-backed startups, can deliver cyber capabilities faster than government acquisition processes. Recent tabletop exercises involving industry, AI firms, and U.S. Cyber Command explored how this approach could work in practice.
     Supporters say CEaaS reflects the reality that much of cyberspace is built and operated by the private sector and could help address government capacity shortfalls. Critics and legal experts, however, warn of significant risks, including contractor liability, escalation with adversaries, governance challenges, and excessive reliance on private firms for sensitive cyber operations.
     Many key questions remain unresolved, including how responsibilities, authorities, and risks would be allocated between government and industry. . . . [Full article]

17. Human Rights Watch: “European Union -- Tighten Surveillance Export Controls”
(Source: Human Rights Watch, 26 Oct 2026) [Editor’s summary]

     Human rights organizations urged EU Trade Commissioner Maroš Šefčovič to strengthen the EU’s 2021 Dual-Use Regulation governing exports of surveillance technology. In a submission to the European Commission’s review of the regulation, the groups argue that EU member states continue to export surveillance tools to countries where they may be used for repression and human rights abuses.
     The organizations contend that Commission guidelines issued in 2024 have weakened key provisions of the regulation by limiting human rights scrutiny for certain surveillance exports and reducing transparency about licensing decisions. They also criticize inconsistent implementation among member states.
     The groups recommend stronger human rights standards for both listed and unlisted surveillance technologies, stricter due diligence requirements modeled on the Corporate Sustainability Due Diligence Directive, and clearer accountability when governments approve exports despite warning signs.
     They also call for regular reviews of technologies covered by export controls, stronger application of the regulation’s “catch-all” provision for unlisted surveillance items, and far greater public disclosure of export-license applications, approvals, denials, destinations, end users, and rationales.
     Overall, they argue the EU should tighten oversight to prevent surveillance technology from facilitating human rights violations abroad. . . . [Full article]

18. Miller & Co: Modifications to Section 338 Tariffs on Canadian Products
(Source: Miller & Company Law Firm, 26 Oct 2026) [Editor’s summary]
• Principal Author: Marshall Miller, Miller & Company, PC

     On Oct. 23, 2026, President Trump modified the 50% Section 338 tariffs on certain Canadian imports that were first imposed on July 20 and revised Sept. 8.
     The proclamation removes several products from the tariff list, including certain plywood, paper products, machinery, refrigeration equipment, and packing crates and boxes.
     At the same time, it adds a range of Canadian-origin goods, including certain paints, varnishes, soaps, lubricants, cocoa powder, valves, carpets, wood products, fiberboard, paper products, builders’ joinery, and municipal and clinical waste products.
     The changes apply to goods entered or withdrawn from warehouse for consumption on or after 12:01 a.m. ET on Oct. 30, 2026. Products subject to the Section 338 action remain subject to the additional 50% duty regardless of USMCA eligibility and in addition to any applicable Section 232 tariffs.
     Importers should review Annex I and Annex II to determine whether their products are affected and to identify the corresponding HTSUS amendments.

19. Volkov: “Can a Cybersecurity Certification Trigger FCA Liability?”
(Source: Volkov Law, 27 Oct 2026)
• Principal Author: Michael Volkov, Volkov Law Group LLC

     You don’t need a data breach to commit False Claims Act fraud. You just need a cybersecurity certification that isn’t true.
     Honeywell Aerospace just paid more than $2 million to resolve allegations that, from April 2020 through December 2023, it billed on a Defense Department contract while failing to meet the cybersecurity standard known as NIST SP 800-171, the standard for protecting controlled unclassified information.
     Those are allegations only. There was no finding of liability. But notice what’s missing from the story: a breach.
     DOJ’s theory is simpler. If you certify compliance to get paid and it is inaccurate, every payment claim can be a false claim.
     And notice who started this case: a whistleblower, a former employee who received more than $370,000 of the recovery.
     Cyber fraud cases are often brought by the insiders who see the gap between what the company tells the government and what its network actually looks like.
     If you hold defense contracts, don’t rely on point-in-time attestation. Independently verify your controls. Take internal security concerns seriously, and remember this exposure can run quietly for years across many billing cycles.
     The risk is rising, not falling.

20. FD Associates Presents: “Brokering Under the ITAR” Webinar, 3 Nov 2026
(Source: Jenny Hahn)

21. FD Associates Presents: “ITAR AUKUS Exemption” Webinar, 17 Nov 2026
(Source: Sarah Huffman)

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

RECENT:

FULL LIST (Includes above entries.):

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

25. Today in History
(Source: History Channel)

     1904: New York City subway opens. On October 27, 1904, New York City Mayor George McClellan took the controls on the inaugural run of the city’s innovative new rapid transit system: the subway. While London boasted the world’s oldest underground train network (opened in 1863) and Boston built the first subway in the United States in 1897, the New York City subway soon became the largest American subway system.

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

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27. 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.