26-1102: Monday's "Export/Import Daily Bugle"

1. State Sanctions Sergey Sergeyevich Zelenyuk, Matrix LLC, and Special Technology Services LLC FZ
(Source: 91 FR 69031, 2 Nov 2026)

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 must complete 20 hours of Continuing Education (CE) by January 31, 2027. Failure to meet these requirements will result in the revocation of your Customs Broker’s license.
     Visit the “Customs Broker Triennial Status Report (TSR) and Continuing Education (CE) Requirements” HERE, and “Customs Broker Continuing Education” HERE. CE Requirements: Individual brokers must complete 20 hours of CE credits to maintain their license for the current triennial.
     Brokers should file their TSR as soon as their CE credits are complete. The deadline is January 31, 2027.

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

6. DSCA Updates SAMM Chapter 14
(Source: Defense Security Cooperation Agency)

     DSCA posts Policy Memo 26-105, “Recognition of Accounts Payable Accruals in the Security Assistance Accounts Financial Statements.”
     This memorandum updates the Security Assistance Management Manual (SAMM) with corrective action identified in "Defense Security Cooperation Agency FY 2022 Financial Statement Audit Notice of Findings and Recommendations (NFR) SAA-2022-N0010" for the Defense Security Cooperation Agency (DSCA) to develop policies and procedures to recognize, measure, record, and report accruals for Accounts Payable (AP) in the Security Assistance Accounts (SAA) financial statements.
     This memo adds Section C14.8.7., Accounts Payable Accrual Requirement, to Chapter 14.

7. State/DDTC DECCS System Will Be Out 5 Nov 2026
(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.

8. UK Export Control: “Military Goods, Software and Technology Undertaking Template”
(Source: UK ECJU, 30 Oct 2026)

     The Open General Export Licence (Military Goods, Software and Technology), issued by the Department for Business, Innovation, Science and Trade (BIST), includes a number of conditions which companies must be able to show they can meet in order to use the licence correctly.
     You can register for this Open General Export Licence with the Export Control Joint Unit (ECJU), which administers the UK’s export licensing system.
     The most effective way to demonstrate that some of the conditions of this OGEL have been met, particularly those under paragraph 6(3)(a) (conditions dealing with permitted use), is to obtain a consignee undertaking.
     You need to obtain and keep the original consignee undertaking (NOT just a copy) for your records. This will be requested and inspected at an export control compliance audit. Copies of originals are only allowed as an interim measure (no more than three months).
     Consignee undertakings are valid for the term of the contract and it is important that you ensure that the undertaking in relation to any particular shipment is not out of date when that shipment is made against the licence.
     The ECJU consider it best practice that consignee undertakings are renewed every 12 months.
     The undertaking must be:

9. US Trade Representative Issues Statement of Intention to Terminate Rwanda and South Africa from the AGOA Trade Preference Program
(Source: USTR.gov, 2 Nov 2026) [Excerpts]

     Ambassador Jamieson Greer issued a statement today following President Trump’s notice to Congress and the governments of Rwanda and South Africa of his intent to terminate these countries from the African Growth and Opportunity Act (AGOA) trade preference program, as of January 1, 2027. . . .

10. White House Actions (No relevant items.)
(Source: The White House)

11. Expeditors News: “CBSA Announces Changes to Health Canada Consumer Product Import Requirements”
(Source: Expeditors News, 29 Oct 2026)

     The Canada Border Services Agency (CBSA) has announced upcoming changes to the Single Window Integrated Import Declaration (IID) requirements under the Electronic Commerce Client Requirements Document (ECCRD) Addendum v1.7.
     The changes will affect goods regulated under Health Canada’s Consumer Products Program and include:

     CBSA is expecting to implement the changes in February 2027, to give time for testing and for importers to review affected products to ensure HS classifications, product categories, and applicable regulatory information are accurate and available ahead of implementation.
     Additional information on the v1.7 update is HERE. CBSA’s ECCRD homepage can be found HERE.

12. FedEx News: “U.S. Modifies Section 338 Additional Duties on Certain Products of Canada”
(Source: FedEx Regulatory News, 30 Oct 2026) [Excerpts]

     The scope of the 50% Section 338 ad valorem duty imposed on certain Canadian-origin products is being modified, effective October 30, 2026, according to the Presidential Proclamation entitled “Further Modifying the Scope of 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.”
     What is changing? Effective October 30, 2026, the scope of Canadian products became subject to the Section 338 50% ad valorem duty was modified in the Harmonized Tariff Schedule of the United States (HTSUS) Chapter 99 provisions by removing 22 HTSUS classifications and adding 100 new HTSUS classifications.
     U.S. Customs and Border Protection (CBP) issued Cargo Systems Messaging Service (CSMS) #70314289 on October 29, 2026, to provide implementation instructions for this new Section 338 proclamation, which include the applicable HTSUS numbers and available exemptions. . . . [Full article]

13. ST&R Trade Report: “$1 Million Criminal Penalty for Sanctions and Export Violations”
(Source: Sandler, Travis & Rosenberg Trade Report, 2 Nov 2026) [Editor’s Summary]. Contact: [email protected], 1-305-894-1035

     Extreme Networks has settled U.S. sanctions and export control violations involving sales to a Russian defense manufacturer owned by a sanctioned entity.
     Through its Russian subsidiary, the company supplied networking equipment and services to the prohibited customer, while employees concealed the end user from compliance personnel, leading to false export filings.
     The case is significant as the first “near-miss” resolution under DOJ’s 2026 Corporate Enforcement and Voluntary Self-Disclosure Policy.
     Although Extreme Networks disclosed the misconduct, DOJ found the disclosure untimely because it occurred only after the company learned a news report was about to expose the matter. Consequently, the company was ineligible for a declination of prosecution.
     DOJ nevertheless credited the company’s extensive cooperation and remediation efforts, including stronger screening controls, additional compliance personnel, termination of the distributor relationship involved, and enhanced M&A due diligence.
     These measures helped secure a non-prosecution agreement and avoided the appointment of an external compliance monitor. . . . [Full article]

14. ST&R Trade Report: “AD/CVD News: Aluminum Foil, Steel Products, Strontium Chromate, Wind Towers”
(Source: Sandler, Travis & Rosenberg Trade Report, 2 Nov 2026) [Excerpts]. Contact: [email protected], 1-305-894-1035

     The International Trade Administration and/or International Trade Commission have recently announced the following actions in antidumping and/or countervailing duty cases:

15. The News: “Tesla and Samsung Push Back Against US Tariffs on Vietnam Ahead of Probe Deadline”
(Source: The News International, 2 Nov 2026) [Editor’s Summary]

     Tesla and Samsung urged the U.S. to avoid new tariffs on Vietnamese imports, warning they would disrupt supply chains and raise costs for American businesses and consumers.
     Their comments were submitted as the Trump administration nears a November 29 deadline to complete a Section 301 investigation into Vietnam's alleged intellectual property violations.
     Tesla told U.S. regulators that key components and manufacturing equipment cannot currently be sourced domestically in sufficient quantities, making Vietnamese production essential.
     Samsung emphasized Vietnam's central role in its global supply chain for smartphones, electronics, and network equipment, noting it has invested about $25 billion in the country.
     While major technology, retail, and apparel companies oppose additional duties, U.S. steel, wood, solar, and seafood producers support stronger trade protections. The administration is also investigating Vietnam over industrial overcapacity, adding to uncertainty over future trade measures. . . . [Full article]

16. The Travel: “CBP Confiscates $250,000 Souvenirs At Philadelphia Airport Due To Declaration Rules”
(Source: The Travel, 30 Oct 2026) [Excerpts]

     A little shopping is often part of international travel, but souvenirs can create problems if they are not declared at customs. One Pennsylvania woman learned that lesson after returning from Amsterdam to Philadelphia International Airport (PHL).
     During a baggage inspection on October 25, she told CBP officers she had purchased only a few thousand dollars’ worth of items. However, CBP already knew she had bought two Cartier pieces totaling $251,629: a bracelet worth $183,818 and a ring worth $67,811.
     According to CBP, she had several opportunities to declare the jewelry before officers confronted her with the information. She then disclosed the purchases and admitted discarding the packaging and receipts.
     CBP seized the jewelry for alleged customs violations and began the process of revoking her Global Entry membership, highlighting the importance of accurately declaring purchases made abroad. [Full article]

17. Akin: “New Chinese Export Control Measures Tighten Restrictions on the Export of Advanced Technologies and Dual-Use Goods, Strengthen Enforcement”
(Source: Akin Gump Insights, 30 Oct 2026) [Editor’s Summary]
• Principal Author: Jingli Jiang, Akin Gump Strauss Hauer & Feld LLP

     Between October 13 and 19, 2026, China’s Ministry of Commerce (MOFCOM), with other agencies, expanded export controls across technology and dual-use sectors. Key measures include proposed controls on 40 AI, biomedicine, and photovoltaic (PV) technologies, including prohibitions and licensing requirements for selected advanced technologies. Pending implementation of the revised technology catalogue, exporters must register covered technology transfers with MOFCOM.
     New dual-use controls, effective November 18, 2026, cover UAVs, tunnel-boring machines, dredgers, and related technologies. China also revised customs procedures for identifying potentially controlled exports, establishing review timelines and expanding coverage to e-commerce, postal, and traveler-carried shipments.
     At the same time, MOFCOM introduced or proposed facilitation measures, including streamlined procedures, automatic authorizations in certain cases, and a new export-certificate system for selected civil aviation items.
     Companies involved in AI, biomedicine, PV, UAV, tunneling, or dredging activities should assess technology flows, registration obligations, licensing lead times, and information-sharing requirements with Chinese counterparties. . . . [Full article]

18. Baker McKenzie: “China Steps Up Export Control Enforcement with New Investigation Measures”
(Source: Global Sanctions and Export Controls Blog) [Editor’s Summary]
• Principal Author: Frank Pan (China), Baker McKenzie

     On October 30, China’s Ministry of Commerce (MOFCOM) released draft Measures on Dual-Use Items Export Control Investigation and Enforcement for public comment through November 29. The draft formally establishes enforcement procedures for MOFCOM’s own export control investigators, including interrogations and the seizure or detention of items, assets, documents, and facilities.
     The proposal signals a major shift in China’s export control regime. Enforcement would no longer rely primarily on Customs inspections of physical shipments, but increasingly on investigations conducted directly by MOFCOM. This could expand enforcement into areas such as intangible technology transfers that fall outside Customs’ traditional jurisdiction.
     The draft also introduces, for the first time, a specific incentive for voluntary self-disclosure. Companies that submit a detailed written disclosure within three months of discovering a violation may receive penalty mitigation. The separate treatment of this provision suggests greater credit than general voluntary reporting.
     As a result, companies should strengthen compliance programs, monitoring systems, and internal investigations to identify potential violations quickly and evaluate timely self-disclosure.

19. Breaking Defense: “Industry Needs More Consistent Demand Signal to Scale UGV production: Autonomy Consortium Exec”
(Source: Breaking Defense, 2 Nov 2026) [Editor’s Summary]

     The Army’s goal of scaling unmanned ground vehicles is being sabotaged by the service’s inability to provide clear, coherent demand signal to industry, according to Warren Sponsler, the COO of the National Advanced Mobility Consortium (NAMC), a nonprofit organization bridging the Pentagon and industry for ground drone projects.
     Sponsler said the Army’s numerous autonomy and robotics demonstrations often create confusion rather than clarity. With so many events and shifting priorities, especially for small firms, companies struggle to decide where to invest limited resources and which opportunities may lead to actual contracts. He argued the Army should focus demonstrations on specific capability needs and provide a clearer path to procurement and revenue.
     Programs such as FUZE’s xTech competitions offer a better model because they tie demonstrations to defined requirements and potential contract awards.
     However, broader ground-autonomy efforts remain difficult to track. The Army has repeatedly reorganized programs, renamed initiatives, and restructured autonomy offices, creating uncertainty about long-term funding priorities.
     Sponsler believes the planned Army and Pentagon autonomy organizations, including FASCOM and AUTOWARCOM, could improve coordination, reduce duplication, better align resources, and provide industry with clearer signals about future capability needs and investment opportunities. . . . [Full article]

20. Diaz: “What Happened in October in International Trade”
(Source: Customs & International Trade Law Blog, 30 Oct 2026) [Editor’s Summary]
• Author: Jennifer Diaz, Diaz Trade Law LLP

     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 purchasing Russian energy or facilitating sanctions evasion. The administration declined new Section 232 tariffs on wind turbines.
     CBP deployed Phase 3 of its CAPE refund system, proposed a post-de minimis framework for low-value imports and Entry Type 13 mail entries, delayed postal formal-entry requirements until Jan. 20, 2027, and allowed Entry Type 13 filings before all PGA data is complete.
     DOJ made trade fraud a corporate enforcement priority and secured a five-year prison sentence in a North Korea sanctions case. USTR launched consultations for the 2027 USMCA review and continued Section 301 tariffs on China.
     Treasury issued the first Outbound Investment Security Program penalty, fining Amidi LLC $200,000. FinCEN warned of Iranian regime abuse of religious charity networks. DHS added three Chinese companies to the Uyghur Forced Labor Prevention Act Entity List.
     State sanctioned five Chinese entities for trade secret theft. BIS settled export control allegations with Lambda Research. OFAC announced settlements with Pegasus Worldwide Logistics and Bank of America and sanctioned a cartel network.
     Other developments included a challenge to Canadian tariffs at the CIT, FMC enforcement actions, FDA import compliance measures, FCC restrictions on devices containing chips from covered entities, and congressional tariff-relief proposals.

21. ST&R Trade Report: “Legislative Update: Tariffs, Imports”
(Source: Sandler, Travis & Rosenberg Trade Report, 2 Nov 2026) [Excerpts]. Contact: [email protected], 1-305-894-1035

     Tariffs. The Trade Relief for American Development and Employment Act (H.R. 10759) would establish a tariff-funded program to protect U.S. manufacturers, workers, farmers, and supply chains from disproportionate economic harm resulting from tariffs and foreign retaliatory measures.
     H.R. 10929 would impose a 50 percent duty rate on hemp products imported from China and establish mandatory testing requirements for all imports of certain cannabinoid products.
     Imports. H.R. 10866 would amend the Ending Importation of Russian Oil Act to prohibit the Office of Foreign Assets Control from issuing a waiver with respect to importation of Russian energy products.
     The Stopping Legalized Organized Trafficking and Harm to Sloths Act (HR. 10867) would prohibit the importation of certain species of sloth. . . . [Full article]

22. ST&R Trade Report: “IEEPA Refunds: Trick or Treat?”
(Source: Sandler, Travis & Rosenberg Trade Report, 31 Oct 2026) [Excerpts]. Contact: [email protected], 1-305-894-1035

     Halloween is past, but importers are still looking for IEEPA tariff refunds. But beware, they may come with a trick.
     U.S. Customs and Border Protection’s most recent status report in the IEEPA tariff litigation provides the clearest picture yet of the new process for obtaining refunds on finally liquidated entries. That’s a treat!
     CAPE Phase 3 covers finally liquidated entries filed by plaintiffs for which the Court of International Trade has ordered reliquidation, including entries subject to a protest.
     CBP is opening Phase 3 on a rolling basis. Currently, plaintiffs that provided valid importer of record numbers before Aug. 14 can file declarations. But beware, when an importer becomes eligible, CBP sends notification to the importer’s counsel, not directly to the importer.
     Now here’s the trick: CAPE Phase 3 itself doesn’t give access to all finally liquidated entries. CBP says Phase 3 covers entries of plaintiffs for which the CIT has ordered reliquidation.
     So, for importers pursuing this route, there’s still a trip to the CIT before getting to CAPE Phase 3.
     Another treat – earlier this month, the CIT certified the Freestyle World case as a class action covering importers that paid the challenged IEEPA duties between Feb. 1, 2025, and Feb. 19, 2026, excluding companies that have filed their own refund suits. If the class ultimately prevails, it could provide qualifying importers a path to refunds without filing individual CIT actions.
     But here’s the second trick: class certification isn’t a refund order. The certification is likely to be appealed and could be overturned. Even in the best-case scenario, this route will likely take considerable time before importers actually see any refunds. . . . [Full article]

23. US Naval Institute: “AUKUS Needs a Better Way to Communicate”
(Source: US Naval Institute Proceedings, October 2026) [Editor’s Summary]
- Author: Scott Sumner

     “I know a U.S. weapons program that will cost X and take Y years to implement. Yet someone elsewhere can deliver it in half the time and at half the cost.”
     A senior defense executive recently used this example to highlight a persistent problem: despite recent export-control reforms, the United States and its allies still struggle to share defense data efficiently.
     The 2024 AUKUS regulatory changes removed many legal barriers, but they did not create a common technical framework for secure cross-border information sharing.
     Today, allied programs often rely on encrypted emails, isolated file-transfer systems, manual reviews, and even USB drives. Differing security classifications, compliance requirements, and national frameworks in the United States, United Kingdom, and Australia create costly delays that slow collaboration.
     To realize AUKUS’s potential, partners need a shared architecture built on four principles: object-level access controls, multinational classification labeling, federated trust and auditing, and affordable access for small and medium-sized suppliers.
     Without these capabilities, AUKUS risks remaining a collection of disconnected systems rather than a truly integrated defense innovation ecosystem.

24. Volkov: “Fund It, Find It, Tell Us: What DOJ’s Criminal Division Chief Told the C-Suite About Compliance and Self-Disclosure”
(Source: Volkov Law, 1 Nov 2026) [Editor’s Summary]
• Principal Author: Michael Volkov, Volkov Law Group LLC

     At a Chicago third-party risk conference, DOJ Criminal Division head A. Tysen Duva urged boards and executives to adequately fund compliance programs and self-disclose misconduct promptly. He emphasized that well-resourced compliance functions are critical to detecting, investigating, and remediating wrongdoing, particularly amid evolving AI- and cyber-related risks.
     Duva highlighted the DOJ’s Corporate Enforcement Policy, stressing that companies that voluntarily disclose misconduct before whistleblowers or the media alert the government may qualify for a declination, while delayed disclosure can result in substantially greater penalties.

What Companies Should Do Now

25. White & Case: “Mexico’s Customs Law Reform: Lower Seizure Thresholds and Higher Penalties for Hydrocarbon-Related Customs Violations”
(Source: White & Case Alert, 30 Oct 2026) [Editor’s Summary]
• Principal Author: David Bond, White & Case LLP

     Effective January 1, 2027, Mexico will significantly tighten customs valuation enforcement. Customs authorities may seize imported goods for any level of undervaluation, eliminating the previous 50% threshold and removing protections previously available through customs guarantees for certain goods.
     Audits will be mandatory whenever declared values fall below reference values. For duty-deferral regimes, the presumption of a customs violation drops from 50% to 20%.
     A new 20% discrepancy threshold governs release of seized goods: discrepancies under 20% may be secured by a guarantee or cash deposit, while discrepancies of 20% or more require a cash deposit.
     The reform also sharply increases penalties for inaccurate customs filings involving hydrocarbons and petroleum products to 50%-100% of the goods’ commercial value.
     Importers should strengthen valuation documentation, review guarantee arrangements, prepare for mandatory electronic value declarations (MVE) being phased in through January 2027, and closely monitor implementing regulations expected by December 31, 2026. [Full article]

26. Skill Dynamics Presents: “Jurisdiction, Classification, & Confidence” Webinar 5 Nov 2026

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

     Lisa Bencivenga has been appointed Director of Compliance and Licensing and T. Brent Jones as Director of Technology Assessment at Beatrice & Asuncion, PLLC, a new law firm specializing in civil and criminal export-enforcement. Contact Lisa and Brent at 703-403-0474.

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

RECENT:

FULL LIST (Includes above entries.):

30. New Edition of the BITAR is Available
(Source: Editor, 1 Nov 2026)

     The 1 Nov 2026 edition of Bartlett’s Annotated ITAR (The BITAR) is available for download HERE. I added footnotes to the sections amended Sep. 18, 2026, that became effective Oct. 19, 2026. I also added dozens of footnotes to the sections in ITAR parts 122, 123, 124, 126, and 130 that were proposed for amendment on June 15, 2026, so you can prepare for the changes if they are implemented.

32. Bartlett's Unfamiliar Quotations
(Source: BrainyQuote)

33. Today in History
(Source: History Channel)

     1948: Truman defeats Dewey. In one of the greatest upsets in presidential election history, Democratic incumbent Harry S. Truman defeated his Republican challenger, Governor Thomas E. Dewey of New York, by over two million popular votes. In the days preceding the vote, political analysts and polls were so behind Dewey that on election night, long before all the votes were counted, the Chicago Tribune published an early edition with the banner headline “DEWEY DEFEATS TRUMAN.”
     Harry Truman was thrust into the presidency by Franklin D. Roosevelt’s death in 1945. He seemed to stand a slim chance of retaining the White House. Despite his effective leadership at the end of World War II and sound vision in the confused postwar world, many voters still viewed Truman as an ineffectual shadow of his four-term predecessor.
     Most were sure that Dewey would take the White House. Truman, a one-time farmer who was elevated to the pinnacle of American politics because of his reputation for honesty and integrity, won the nation’s affection, and he narrowly won a second term.

34. 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.

35. 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.