26-1028: Wednesday's "Export/Import Daily Bugle"

1. Today’s Federal Register (No relevant items.)
(Source: Federal Register)

2. Future Federal Register (No relevant 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. Commerce/BIS (Nothing new.)
(Source: Commerce/BIS)

6. DSCA Posts SAMM Clarification Updates
(Source: Defense Security Cooperation Agency, 27 Oct 2026)

     DSCA Posts Policy Memo 26-127 Clarification Updates.
     This memorandum updates the Security Assistance Management Manual (SAMM) with clarification changes.
     This memorandum does not contain contextual policy changes.

7. Justice: Seattle man arrested on indictment for illegally shipping restricted items to Russia by going through straw buyers in Turkey, Korea, and Kazakhstan
(Source: U.S. Attorney's Office, Western District of Washington; 27 Oct 2026) [Excerpts]

     A 53-year-old Seattle man was arrested this morning on a twelve-count indictment charging he illegally conspired to ship restricted goods to Russia, violating sanctions put in place after Russia invaded Ukraine.
     Ilya Pankov, aka Ilia Pankov worked for Pacific Route Inc. also known as Pacific Terminals and allegedly conspired to evade United States’ export control laws and regulations and smuggle export-controlled mining and other equipment to Russia, without the required license and authorization.
     Pankov appeared in U.S. District Court in Seattle today and entered a plea of “Not guilty.” Trial was scheduled in front of U.S. District Judge Tana Lin on January 4, 2027.
     “As alleged in the indictment, Mr. Pankov conspired with others to find ways to send restricted items to a variety of companies in Russia, and then lied about it to export regulators,” said Acting U.S. Attorney Neil Floyd. . . .
     Pacific Route is a procurement company, established in 2008 and incorporated in Washington State, that exports construction and mining equipment. . . .
     In furtherance of the crime, Pankov and others filed false Electronic Export Information and misrepresented whether a license was needed for the export. . . .
     The indictment alleges that at least $225,000 in proceeds from the illegal sales were then laundered through bank accounts connected with Pacific Route Inc. . . .

8. State/DDTC System Down for Maintenance 5 Nov (Thurs) 5-7 pm ET
(Source: Directorate of Defense Trade Controls)

     The Defense Export Control and Compliance System (DECCS) will undergo system maintenance on Thursday, November 5th, 2026, from 5:00 to 7:00pm (ET).
     Industry users may experience service degradation, interruptions, or limited application functionality within DECCS during this maintenance window. If you experience any issues, please log back in after the maintenance window.

9. Treasury/OFAC: Extreme Networks to Pay $1.5 Million to Settle Sanction Violation Charges
(Source: Treasury/OFAC, 28 Oct 2026)

     The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) yesterday announced a $1,529,685 settlement with Extreme Networks, Inc. ("Extreme"), a North Carolina headquartered cloud networking solutions provider.
     Between September 2018 and March 2022, Extreme exported networking equipment and related services on nine occasions from the United States to Joint Stock Company (JSC) Moskovskiy Mashinostroitelniy Zavod Avangard, a Russian defense manufacturer that is blocked by operation of law and majority owned by designated JSC Concern Almaz Antey.
     The settlement amount reflects OFAC's determination that these apparent violations were voluntarily self-disclosed and egregious.
     For more information, visit the Enforcement Release and Settlement Agreement. Visit this link for more information.

10. UK Export Control: Guidance on Providing Professional and Business Services to Persons Connected with Russia
(Source: UK ECJU, 27 Oct 2026)

     Page summary:

11. US Trade Representative: “America First Seafood Strategy Charts Course to Restore U.S. Seafood Dominance”
(Source: USTR.gov, 28 Oct 2026) [Excerpts]

     The White House unveiled the historic America First Seafood Strategy, outlining a whole-of-government approach to revitalize the U.S. fishing industry by removing foreign trade barriers and unlocking new markets for U.S. fishermen.
     U.S. seafood exports reached $5.53 billion in 2025, increasing 12% compared to 2024, and many of our trading partners have committed to remove trade barriers that undercut our global competitiveness. U.S. seafood exports are continuing to trend upwards in 2026.

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

13. Breaking Defense: “Navy Faces ‘Years-Long’ Maintenance Crunch Amid Record-Breaking, Extended Deployments”
(Source: Breaking Defense News, 28 Oct 2026) [Editor’s summary]

     The Navy expects a years-long maintenance backlog as destroyers, carriers, and other ships return from exceptionally long deployments, forcing difficult choices between repairs and modernization. More than a dozen destroyers remain deployed, but leaders warn private shipyards lack capacity to absorb the coming surge in work. Deferred maintenance may delay upgrades, increase future costs, and leave some vessels idle or returning to sea without all needed repairs completed.
     Compliance implications: Defense contractors supporting ship repair, maintenance, dry docks, naval systems, missiles, radars, launch systems, and modernization programs should anticipate increased Navy demand, shifting procurement priorities, schedule changes, and possible funding reallocations.
     Supply chain, export-control, and vendor management teams should monitor opportunities tied to maintenance and sustainment contracts, while remaining alert to industrial-base expansion initiatives and accelerated sourcing requirements over the next several years. [Full article]

14. Diaz: “Reporting Customs Fraud: A Guide to False Claims Act Whistleblower Claims”
(Source: Customs & International Trade Law Blog, 27 Oct 2026) [Editor’s Summary]
• Author: Jennifer Diaz, Esq., Diaz Trade Law LLP

     This article highlights growing use of the False Claims Act (FCA) as an enforcement tool against customs fraud and tariff evasion.
     FCA liability may arise when importers knowingly underpay duties through country-of-origin fraud, transshipment, undervaluation, tariff misclassification, AD/CVD evasion, or false import documentation.
     Compliance Implications: Trade compliance personnel, customs brokers, and management should assume employees, former employees, competitors, suppliers, and brokers may report suspected customs fraud through FCA qui tam actions. Successful whistleblowers can receive 15% to 30% of government recoveries, creating strong incentives to report misconduct.
     Practical Advice: Review and document customs controls for valuation, HTS classification, origin determinations, AD/CVD compliance, and import recordkeeping. Investigate internal allegations promptly and maintain evidence supporting tariff classifications and origin claims.
     Distinguish good-faith classification disputes from conduct that could be viewed as knowingly false. Companies facing significant duty exposure should consider privileged compliance audits and corrective disclosures where appropriate.
     Increased FCA scrutiny means customs errors that appear intentional can trigger treble damages, penalties, and whistleblower-driven investigations beyond traditional CBP enforcement. [Full article]

15. Expeditors News: “USTR Requests Comments on Continued Maritime Section 301 Suspension”
(Source: Expeditors News, 27 Oct 2026) [Editor’s Summary]

     In a Federal Register Notice (FRN) published on October 26, 2026, the Office of the United States Trade Representative (USTR) announced that it is requesting public comments on a proposal to continue the suspension of certain Section 301 fees on maritime transport services.
     The Section 301 action includes fees that would apply to certain Chinese-made, owned, or operated vessels entering U.S. ports, as well as certain crane and chassis parts. These measures were suspended for one year beginning November 10, 2025, as part of a trade agreement between the U.S. and China.
     USTR is proposing to suspend this action for an additional two months, through January 9, 2027, to “allow for further negotiation with China regarding the acts, policies, and practices at issue in this investigation.” . . .
     FRN 2026-21755 is HERE.

16. ST&R Trade Report: “In the News: EU Tariff Truce, Canada Talks, FTAs”
(Source: Sandler, Travis & Rosenberg Trade Report, 28 Oct 2026). Contact: [email protected], 1-305-894-1035

     U.S.-EU aircraft trade truce under strain. “The United States has not announced new tariffs or formally declared that the European Union violated the agreement. However, Greer’s remarks signal that Washington is questioning whether the financing arrangement is consistent with the commitments made by both sides.” [IANS]
     White House tempers tough talk on Canada trade. “In Washington, a White House official who is not typically involved in trade talks suggested over the weekend that a trade agreement was imminent … But neither the American nor the Canadian statements since then appeared to support such a sunny reading of the situation.” [NBC News]
     Canada opens free trade talks with Turkey. “Carney said Canadian negotiators would come to Ankara next month for the first round of free trade talks.” [AFP]
     Canada, UAE sign free trade deal. “The Prime Minister’s Office said the trade deal will reduce or eliminate tariffs on more than 99 per cent of current Canadian exports to the UAE once it’s fully implemented. The office says the agreement will also address non-tariff barriers, create a more predictable environment for trade and investment and expand market access for Canadian goods and services, including those in the industrial, agricultural, forest, fish and seafood, environmental and engineering sectors.” [The Canadian Press]

17. Baker McKenzie: “China Proposes New Sanctions Tool in Response to Trade Secret Theft”
(Source: Global Sanctions and Export Controls Blog, 27 Oct 2026)
• Principal Author: Frank Pan (China), Baker McKenzie

     On October 26, 2026, China’s Ministry of Commerce (“MOFCOM”) published the draft Special Provisions on the Protection of Chinese Trade Secrets, introducing a new sanctions tool targeting foreign infringement of Chinese trade secrets. Once finalized, the rules would authorize MOFCOM to impose sanctions on foreign companies, organizations and individuals where such infringement harms, or poses an actual threat to, China’s sovereignty, security or development interests. MOFCOM may initiate investigations before imposing sanctions, and third parties may also submit relevant leads or reports.
     Available sanctions would include restrictions on trade, exports and investment, entry and work restrictions, and monetary penalties, broadly consistent with measures available under China’s existing sanctions and countermeasures regimes. The measures may be revoked, suspended or mitigated depending on remedial actions taken by the sanctioned party and MOFCOM’s verification.
     The timing is notable. The Draft, open for public comments until November 24, appears to be a direct response to the U.S. government’s recent sanctions under the Protecting American Intellectual Property Act against five Chinese companies for alleged theft of U.S. trade secrets.

18. Burns, Clif: “Panama Law Firm Becomes Second Law Firm Added to the SDN List”
(Source: Export Law blog, 27 Oct 2026) [Editor’s Summary]
• Author: Clif Burns, Clark Hill LLP

     OFAC designated Greek/Panamanian law firm Karnakis and Karnakis as an SDN under E.O. 13902, asserting that by forming, administering, and supplying nominee officers/directors for companies moving Iranian petroleum and petrochemicals, the firm was “operating” in Iran’s petroleum and petrochemical sectors.
     The article questions OFAC’s rationale, noting the firm provided legal and corporate services rather than directly participating in the sector itself.
     Compliance Implications: Service providers, including law firms, corporate agents, trust companies, ship registrars, and maritime intermediaries, should not assume they are insulated from sanctions risk because they provide professional services rather than trade goods.
     OFAC appears willing to scrutinize corporate formation, beneficial ownership structuring, nominee arrangements, and maritime services that facilitate sanctioned trade.
     Companies supporting shipping, energy, or high-risk jurisdictions should conduct enhanced due diligence on beneficial owners, vessel operators, cargoes, and end users; document screening decisions; and assess whether services could be viewed as enabling sanctioned-sector activity.
     The case signals expanding sanctions exposure for facilitators and raises uncertainty about where OFAC draws the line between servicing a sector and operating within it.
     [Full article]

19. Shapiro: “Something Wicked This Way Ships: The Global Supply Chain Behind Halloween Candy”
(Source: Samuel Shapiro & Co. Inc.; Shap Blog, 28 Oct 2026) [Editor’s summary]

     Halloween candy illustrates key supply-chain risks for seasonal imports: success depends on synchronizing ingredients, packaging, production, transportation, customs clearance, and retailer delivery windows months before sales begin. Manufacturers plan Halloween programs years in advance, with product launches starting as early as July.
     Compliance Implications: Importers should manage seasonal products backward from the retailer’s required shelf date, not the holiday itself.
     Critical risks include origin sourcing disruptions (cocoa, sugar, packaging), missed sailings, port congestion, customs documentation errors, temperature-sensitive transportation, and packaging delays that can halt production even when ingredients are available.
     Practical Advice: Verify that suppliers, packaging vendors, carriers, customs brokers, and distribution centers are working to the same timeline.
     Ensure import documentation is complete before arrival, maintain contingency plans for high-risk inputs, and communicate handling requirements for temperature-sensitive goods.
     For seasonal merchandise, a short delay can eliminate the selling window and convert inventory into markdowns or write-offs.
     This article reinforces a core compliance principle: focus on the entire supply chain and retailer delivery deadlines, not merely vessel arrival dates or customs clearance milestones.
     [Full article]

20. ST&R Trade Report: “No Section 232 Tariffs for Now on Imports of Wind Turbines”
(Source: Sandler, Travis & Rosenberg Trade Report, 28 Oct 2026) [Excerpts]. Contact: [email protected], 1-305-894-1035

     President Trump has declined to impose Section 232 tariffs on imports of wind turbines and their parts and components, at least for the time being.
     Trump made this decision despite the Department of Commerce’s determination in its Section 232 investigation that these goods are being imported under such circumstances as to threaten to impair U.S. national security.
     Among other things the DOC concluded that U.S. wind energy is reliant on imports of foreign-produced wind turbine components and subcomponents and that imports of these goods have increased over the last decade.
     However, instead of imposing Section 232 tariffs on such imports, the president instead directed the DOC and the Office of the U.S. Trade Representative to pursue or continue the negotiation of agreements with foreign trading partners to adjust imports. . . .
     The proclamation gives some insight into the reasons tariffs were not imposed. One is that “the unpredictability of wind energy makes it less reliable than other energy sources” and that as a result “resources that are used to support wind energy and wind energy projects could instead [be] used to strengthen more reliable energy sources.”
     Another is that the U.S. already imposes Section 232 tariffs on aluminum, steel, and copper and some wind turbine components and subcomponents are made of significant amounts of those products and are therefore already subject to those tariffs. . . . [Full article]

21. Torres: “Mexico's Foreign Investment Screening Reform: A National Security Mechanism Born from Trade Politics”
(Source: Torres Insights, 28 Oct 2026) [Editor’s Summary]
• Principal Author: Olga Torres, Esq., Torres Trade Law, PLLC

     Mexico is proposing a CFIUS-style national security review process for certain foreign investments, largely driven by U.S. pressure tied to USMCA renewal and North American supply-chain security.
     Acquisitions exceeding 49% foreign ownership in companies operating in sensitive sectors (critical technologies, dual-use items, aerospace, defense, semiconductors, AI, cybersecurity, data, energy, critical infrastructure, and essential inputs) could require pre-approval.
     Compliance implications: Export/import compliance, M&A, and trade teams should add foreign investment screening to transaction due diligence involving Mexico.
     Expect enhanced beneficial ownership disclosures, scrutiny of dual-use and controlled technologies, mitigation requirements, and ongoing compliance obligations.
     Companies involved in nearshoring, defense, aerospace, semiconductors, cybersecurity, data processing, and critical infrastructure should monitor the final rules closely.
     Investments may face delays of roughly 60 business days or more, and transactions may be approved, conditioned, or blocked based on national-security concerns rather than traditional competition or trade factors. [Full article]

22. Volkov: “Remediation, Cooperation, and What Every Compliance Program Should Take From the Bank of America Penalties” (Part V)
(Source: Volkov Law, 27 Oct 2026) [Editor’s Summary]
• Principal Author: Michael Volkov, Volkov Law Group LLC

     The first four posts in this series described what went wrong. This one asks what Bank of America is required to do now, how its cooperation and remediation were treated, and what a compliance officer at any institution should do on Monday morning.
     For compliance professionals, the key lesson is that regulators penalize delayed action as much as control failures. The bank must now conduct extensive lookbacks, independent reviews, and program validations, creating years of additional cost and scrutiny beyond the $1.2 billion penalty.
     Practical takeaways: treat regulatory orders as deadlines, not warnings; test monitoring systems aggressively and act on validation findings; establish measurable false-negative tolerances with board oversight; ensure risk ratings rely on internal data rather than law-enforcement triggers; and require documented senior approval when compliance recommends exiting a customer relationship.
     Lookbacks should address root causes, not narrow symptoms, and institutions remain fully responsible for compliance even when vendors are involved. Regulators gave little or no credit for remediation that began only after regulatory pressure and for incomplete or delayed cooperation.
     The strongest defense is early, comprehensive remediation, complete monitoring coverage across products and channels, and an integrated AML/sanctions program that converts identified risks into timely management decisions. . . . [Full article]

23. Skill Dynamics Presents: “Export Control & Sanctions Enforcement: A Danish & Nordic Perspective” Webinar 19 Nov 2027
(Source: Skill Dynamics — previously Content Enablers)

24. Partnering for Compliance™ Presents: “12th Annual Customs/Import Boot Camp Conference” 21 Jan 2027
(Source: Ailish M. Nic Phaidin)

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

RECENT:

FULL LIST (Includes above entries.):

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

28. Today in History
(Source: History Channel)

     1886: Statue of Liberty dedicated. The Statue of Liberty, a gift of friendship from the people of France to the people of the United States, is dedicated in New York Harbor by President Grover Cleveland. Designed by French sculptor Frederic-Auguste Bartholdi, the 151-foot statue was the form of a woman with an uplifted arm holding a torch. Its framework of gigantic steel supports was designed by Eugene-Emmanuel Viollet-le-Duc and Alexandre-Gustave Eiffel, the latter famous for his design of the Eiffel Tower in Paris.

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.