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  • 26-1105: Thursday's "Export/Import Daily Bugle"

26-1105: Thursday's "Export/Import Daily Bugle"

Jim Bartlett
Jim Bartlett

Nov 5, 2026

•

20 min read

THE DAILY BUGLE | LOGO IMAGE

THURSDAY, 5 NOVEMBER 2026

SUBSCRIBE | ADVERTISE EVENTS | POST JOB OPENINGS

Subscriptions to the Daily Bugle are $10/month or discounted to $100/year. Groups of 10 or more get an additional 10% discount. Call me at 202-802-0646 for larger discounts for groups of 30 or more. The above link is for NEW subscribers. If you are a CURRENT subscriber, please re-subscribe HERE. But if you choose not to re-subscribe, beginning next Monday (9 Nov), you will no longer receive the Daily Bugle. Thanks! — Jim Bartlett.

TABLE OF CONTENTS

FEDERAL REGISTER

  1. Commerce/BIS Renews TDO Denying Export Privileges of Rossiya Airlines

  2. President Continues the National Emergency With Respect to Iran

  3. President Continues the National Emergency With Respect to Nicaragua

  4. President Continues the National Emergency With Respect to Weapons of Mass Destruction

  5. Future Federal Register

OTHER GOVERNMENT SOURCES

  1. CBP Cargo Systems Messages

  2. CBP Reminder: Licensed Customs Brokers Must Complete Continuing Education by 31 Jan 2027

  3. Commerce/BIS (Nothing new.)

  4. State/DDTC (Nothing new.)

  5. Treasury/OFAC: SDN List Updates; Cyber-related and Transnational Criminal Organizations Designations; Cuba Designations; Publication of Cuba-related Determination

  6. White House Actions (No relevant items.)

NEWS

  1. Breaking Defense: “Republicans Have a Ticking Clock. What Can They Get Done on Defense?”

  2. Diaz: “Upcoming November 9 Deadline: USITC Requests Input on Section 338 Trade Authority”

  3. Expeditors News: “October 2026 Antidumping and Countervailing Duties Updates”

  4. ST&R Trade Report: “FCC Limits Foreign Testing of Electronic Devices”

OPINION

  1. Baker McKenzie: “2026 US Midterm Election Results: How Will Democratic Control of Both Chambers Impact Trade Issues”

  2. Burns, Clif: “Company Agrees To $1.5M OFAC Penalty For Not Using Google”

  3. ST&R Trade Report: “CBP Imposes Heightened Requirements for IORs and Customs Brokers”

  4. Troutman: “Thinking Inside the Box: Why the Fine Print in the Package May Decide the Path of a Tariff-Refund Class Action”

  5. Troutman: “Canada Tariff Reshuffle: 22 Products Out, 100 In Under the 50% Section 338 Duty”

  6. Volkov: “Can You Govern the AI You Can’t See?”

TRAINING EVENTS & CONFERENCES

  1. FD Associates Presents: “U.S. Canada Joint Certification Program” Webinar, 10 Nov 2026

  2. Global Training Center Presents: “Exporting Procedures” Webinar 17 Nov 2026

EX/IM MOVERS & SHAKERS

  1. List of Export/Import Job Openings

EDITOR'S NOTES

  1. Do You Have Access to the Latest and Greatest ITAR and FTR?

  2. Bartlett's Unfamiliar Quotations

  3. Today in History

  4. Are Your Copies of Export/Import Regulations Current?

ITEMS FROM THE FEDERAL REGISTER

1. Commerce/BIS Renews TDO Denying Export Privileges of Rossiya Airlines
(Source: 91 FR 69793, 5 Nov 2026)

  • AGENCY: Commerce Department; Bureau of Industry and Security

  • ACTION: Denial of Export Privileges: Rossiya Airlines.

  • SUMMARY: The Bureau of Industry and Security (BIS) renewed for one year its Temporary Denial Order (TDO) against Rossiya Airlines, finding an ongoing risk of Export Administration Regulations (EAR) violations. First imposed in May 2022 after Russia aviation sanctions took effect, the TDO has been repeatedly renewed because Rossiya continued operating U.S.-controlled aircraft and aircraft containing controlled U.S. content without required BIS authorization. BIS presented evidence that Rossiya repeatedly flew such aircraft on international routes to and from Russia and on domestic Russian flights, despite prior denial orders. No opposition was filed, and BIS determined Rossiya's violations remain continuous, deliberate, and likely to recur.

  • DATE: This Order is effective immediately and shall remain in effect for one year.

2. President Continues the National Emergency With Respect to Iran
(Source: 91 FR 69947, 5 Nov 2026)

  • AGENCY: Executive Office of the President

  • ACTION: Notice; Continuation of the National Emergency With Respect to Iran

  • SUMMARY: On November 14, 1979, by Executive Order 12170, the President declared a national emergency with respect to Iran pursuant to the International Emergency Economic Powers Act and took related steps to deal with the unusual and extraordinary threat to the national security, foreign policy, and economy of the United States constituted by the situation in Iran. Our relations with Iran have not yet normalized. Therefore, in accordance with section 202(d) of the National Emergencies Act (50 U.S.C. 1622(d)), I am continuing for 1 year the national emergency with respect to Iran declared in Executive Order 12170.

  • DATE: Nov. 3, 2026

3. President Continues the National Emergency With Respect to Nicaragua
(Source: 91 FR 69951, 5 Nov 2026)

  • AGENCY: Executive Office of the President

  • ACTION: Notice; Continuation of the National Emergency With Respect to the Situation in Nicaragua

  • SUMMARY: The situation in Nicaragua, including the violent response by the Government of Nicaragua to the protests continues to pose an unusual and extraordinary threat to the national security and foreign policy of the United States. For this reason, the national emergency declared on November 27, 2018, must continue in effect beyond November 27, 2026. Therefore I am continuing for 1 year the national emergency declared in Executive Order 13851 with respect to the situation in Nicaragua.

  • DATE: November 3, 2026

4. President Continues the National Emergency With Respect to Weapons of Mass Destruction
(Source: 91 FR 69949, 5 Nov 2026)

  • AGENCY: Executive Office of the President

  • ACTION: Notice; Continuation of the National Emergency With Respect to the Proliferation of Weapons of Mass Destruction

  • SUMMARY: The proliferation of weapons of mass destruction and the means of delivering them continues to pose an unusual and extraordinary threat to the national security, foreign policy, and economy of the United States. For this reason, I am continuing for 1 year the national emergency declared in Executive Order 12938, as amended.

  • DATE: November 3, 2026

5. Future Federal Register
(Source: Future Federal Register)

  • Commerce; Industry and Security Bureau; Notices; Agency Information Collection Activities; Proposals, Submissions, and Approvals: Application Process to Waive the Import Qualification Criteria Measures to Restrict Stockpiling of Polysilicon and Polysilicon Derivatives. Scheduled Pub. Date: 6 Nov 2026. Permalink

  • Commerce; Industry and Security Bureau; Notices; Section 232 National Security Adjustments to Imports of Specialty Pharmaceuticals and Associated Ingredients. Scheduled Pub. Date: 6 Nov 2026. Permalink

  • U.S. Customs and Border Protection; Rules: Heightened Requirements for Foreign Importers of Record. Scheduled Pub. Date: 6 Nov 2026. Permalink

  • U.S. Customs and Border Protection; Notices: Document Image System Pilot for Used Self-Propelled Vehicles Export Document Submission; Renewal of Test. Scheduled Pub. Date: 6 Nov 2026. Permalink

OTHER U.S. GOVERNMENT SOURCES

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

  • CSMS # 70370477 - ACE Production Standard Invasive Maintenance from 10:00 p.m. ET Saturday, November 07, 2026, to 4:00 a.m. ET Sunday, November 08, 2026

  • CSMS # 70370373 - Information: Quota Bulletin 26-408 2027 Caribbean Basin Trade Partnership Act

  • CSMS # 70329550 - ACE Statement Issue

  • CSMS # 70314289 - Further Modifying Section 338 Additional Duties on Certain Goods of Canada

7. 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.

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

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

10. Treasury/OFAC: SDN List Updates; Cyber-related and Transnational Criminal Organizations Designations; Cuba Designations; Publication of Cuba-related Determination
(Source: Treasury/OFAC, 5 Nov 2026)

     The Department of the Treasury's Office of Foreign Assets Control (OFAC) is publishing a Cuba-related Determination Pursuant to Section 2(a)(i)(A) of Executive Order 14404, "Electronics, Manufacturing, Marine, and Technology Sectors of the Cuban Economy."
     Additionally, OFAC has made the following changes to the list of Specially Designated Nationals and Blocked Persons (SDN List). Visit this page to access the latest version of the SDN list. Visit this link for more information.

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

NEWS

12. Breaking Defense: “Republicans Have a Ticking Clock. What Can They Get Done on Defense?”
(Source: Breaking Defense News, 5 Nov 2026) [Excerpts]

     Republicans face a narrow lame-duck window to advance FY2027 defense legislation after suffering major midterm losses that will hand Democrats control of Congress in January. Analysts say prospects for passing defense appropriations, reconciliation funding, or the Pentagon's $67 billion Iran-war supplemental request are poor, particularly because Senate appropriations require Democratic support. Some observers now expect delays into 2027 and warn of a possible government shutdown.
     Democrats are preparing aggressive oversight efforts focused on the Iran war, defense spending, and alleged favoritism in Pentagon contracting. Defense Secretary Pete Hegseth also faces impeachment threats from some lawmakers, while speculation continues about a possible resignation and Senate appointment.
     If budget negotiations slip into the next Congress, Democrats are expected to seek lower defense spending, enhanced oversight, and restrictions on future Iran-related military operations. [Full article]

13. Diaz: “Upcoming November 9 Deadline: USITC Requests Input on Section 338 Trade Authority”
(Source: Customs & International Trade Law Blog, 5 Nov 2026) [Editor’s Summary]
• Author: Jennifer Diaz, Esq., Diaz Trade Law LLP

     The U.S. International Trade Commission (USITC) is requesting public comments on how to implement Section 338(g) of the Tariff Act of 1930, a rarely used law addressing discriminatory foreign trade practices.
     The agency is considering procedures to identify foreign barriers that disadvantage U.S. commerce, gather information from affected businesses, and provide findings and recommendations to the President.
     For exporters, the initiative could create a formal avenue to report discriminatory treatment abroad. For importers, it signals the potential future use of Section 338, which authorizes the President to impose additional duties of up to 50% on products from countries found to engage in discriminatory practices.
     The notice does not impose new tariffs or restrictions. Instead, it seeks input on defining discriminatory conduct, collecting confidential business information, and evaluating complaints. . . . [Full article]

14. Expeditors News: “October 2026 Antidumping and Countervailing Duties Updates”
(Source: Expeditors News, 4 Nov 2026) [Editor’s Summary]

     In October of 2026, the U.S. International Trade Administration (ITA) announced several preliminary and final antidumping (AD) and countervailing duty (CVD) determinations and initiated new trade remedy investigations.
     Additional details on these cases, including the affected HTS numbers, and duty rates, can be found in the official notices linked below.
     Preliminary determinations were published for the following investigations:

  • Affirmative determination in the CVD investigation of N-Cyclohexylbenzothiazole-2-Sulfenamide (CBS) from China.

  • AD) investigations of oil country tubular goods (OCTG) from Austria, the United Arab Emirates (UAE), and Taiwan.

     The following AD and CVD investigations were initiated:

  • AD investigations of corrugated die-cut cardboard boxes from China, Malaysia, and Türkiye, and a CVD investigation of corrugated die-cut cardboard boxes from Türkiye.

  • AD and CVD investigations of certain amine compounds from China.

     Final determinations were published for the following AD and CVD cases:

  • AD investigations of chromium trioxide from India and the Republic of Türkiye and the CVD Investigation of chromium trioxide from India.

  • AD investigations of high purity dissolving pulp from Brazil and Norway and the CVD Investigation of high purity dissolving pulp from Brazil.

  • CVD investigation of truck bed covers from China.

15. ST&R Trade Report: “FCC Limits Foreign Testing of Electronic Devices”
(Source: Sandler, Travis & Rosenberg Trade Report, 5 Nov 2026) [Excerpts]. Contact: [email protected], 1-305-894-1035

     The Federal Communications Commission has adopted final rules that alter its approach to the regulatory regime that governs the testing of all electronic devices that consumers in the U.S. use. Electronic devices must be tested at an FCC-recognized lab before they can be used or marketed in the U.S.
     Starting 1 Dec 2028, the new rules will limit the FCC’s recognition of test labs to those located in the U.S. or in countries that grant U.S. labs reciprocal recognition.
     Currently such countries include the following: . . .    
     The rules also adopt similar restrictions for telecommunications certification bodies and laboratory accreditation bodies, which codifies existing practice.
 [Full article]

OPINION

16. Baker McKenzie: “2026 US Midterm Election Results: How Will Democratic Control of Both Chambers Impact Trade Issues”
(Source: Global Sanctions and Export Controls Blog, 4 Nov 2026) [Editor’s Summary]
• Principal Author: Bruce J. Linskens, Baker McKenzie

     The 2026 midterm elections will shift control of both chambers of Congress to Democrats, reshaping oversight of U.S. trade policy but not fundamentally altering executive authority over tariffs, export controls, sanctions, or CFIUS.
     Tariffs: Most current tariffs can remain without congressional approval because they rely on statutory authorities such as Sections 301, 232, 122, and 338. Democrats are more likely to pursue hearings, investigations, and oversight than repeal. Courts remain the primary near-term check on tariff actions.
     Export Controls: Core export control policies are expected to remain intact, with bipartisan support for restrictions on China. Congress may push for tighter controls on advanced technologies, greater scrutiny of licensing decisions, and enhanced coordination with allies.
     Sanctions: Democratic majorities are likely to increase pressure regarding Russia sanctions, while using oversight powers to review administration policies on Iran and Venezuela. Significant sanctions authority, however, remains with the executive branch.
     CFIUS and Outbound Investment: Expect increased congressional scrutiny of foreign investment, supply-chain resilience, data security, and outbound investment restrictions involving China and strategic technologies.
     [Full article]

17. Burns, Clif: “Company Agrees To $1.5M OFAC Penalty For Not Using Google”
(Source: Export Law blog, 5 Nov 2026) [Editor’s Summary]
• Author: Clif Burns, Clark Hill LLP

     An OFAC enforcement release issued October 27, 2026, announced a $1.53 million settlement with a North Carolina company for nine apparent sanctions violations involving a blocked Russian end user, MMZA.
     Although MMZA was not listed on the SDN List, it was majority-owned by Almaz Antey, a blocked entity, making MMZA blocked under OFAC’s 50 Percent Rule.
     OFAC stated the company failed to conduct sufficient due diligence but did not explain what that would have entailed. In practice, a basic Internet search could have revealed MMZA’s connection to Almaz Antey.
     Public sources identified MMZA as part of the Almaz Antey group, and Almaz Antey’s SDN status was readily discoverable. Once ownership was confirmed, the sanctions risk would have been clear.
     The lesson is straightforward: when dealing with an unfamiliar customer or counterparty, always begin with a simple Internet search. Basic, publicly available information can provide critical sanctions compliance insights and help avoid costly violations. . . . [Full article]

18. ST&R Trade Report: “CBP Imposes Heightened Requirements for IORs and Customs Brokers”
(Source: Sandler, Travis & Rosenberg Trade Report, 5 Nov 2026) [Editor’s Summary]. Contact: [email protected], 1-305-894-1035

     U.S. Customs and Border Protection (CBP) has issued an interim final rule, effective January 5, 2027, establishing new requirements for foreign importers of record (IORs), new verification duties for customs brokers, and stronger penalties for noncompliance.
     The rule defines a U.S. IOR as a qualifying U.S. individual or entity meeting citizenship, ownership, or property-based criteria. U.S. IOR status must be declared at entry and may be verified by CBP.
     Foreign IORs may no longer make formal or informal consumption entries unless they are validated under the Customs Trade Partnership Against Terrorism (CTPAT) program or use a CTPAT-validated licensed customs broker. CBP may further restrict foreign IOR use of informal entry if risks to revenue, security, or public safety arise.
     Customs brokers must verify whether clients qualify as U.S. IORs and cease filing entries for nonqualifying clients unless the broker is CTPAT-validated.
     The rule also requires powers of attorney for customs business transactions and expands CBP’s ability to impose substantial penalties under 19 U.S.C. §1592, potentially up to the domestic value of the merchandise.
     Comments are due by January 5, 2027; full broker compliance is expected by May 6, 2027. [Full article]

19. Troutman: “Thinking Inside the Box: Why the Fine Print in the Package May Decide the Path of a Tariff-Refund Class Action”
(Source: JD Supra, Troutman Pepper Locke, 5 Nov 2026) [Excerpts]
• Author: Ryan Last, Troutman Pepper Locke LLP

     Key Points

  • On November 2, 2026, the Western District of Washington held in Hastings v. Microsoft Corp. that the Warranty & Agreement (W&A) included with an Xbox Series X requires individual arbitration of a proposed class action seeking a share of IEEPA tariff refunds and bars the plaintiff from suing on behalf of a class.

  • Because the Product Guide inside the Xbox box told purchasers they “must accept” the agreement and called out its arbitration and class waiver terms, the Western District of Washington found in Hastings that the customer had adequate notice and agreed by keeping and using the product.

  • Section 11 of the W&A, which covers disputes concerning a product’s “price,” led the court in Hastings to conclude that a claim that the product’s price was inflated falls within the arbitration clause.

  • When a plaintiff offers no evidence that his box differed, a declarant’s description of Microsoft’s standard packaging was enough for the court in Hastings to reject his argument that Microsoft had not proven the Product Guide was in his box.

  • Even after a class waiver like the one enforced in Hastings v. Microsoft Corp., plaintiffs’ firms may respond with mass arbitration demands, and the arbitration fees and filing costs that many consumer clauses impose on companies can quickly create settlement pressure.

20. Troutman: “Canada Tariff Reshuffle: 22 Products Out, 100 In Under the 50% Section 338 Duty”
(Source: Troutman Pepper Locke, 5 Nov 2026) [Excerpts]
• Author: Ryan Last, Troutman Pepper Locke LLP

     Key Points:

  • A presidential proclamation dated October 23, 2026, removes 22 Canadian product subheadings from, and adds 100 to, the 50% ad valorem duty imposed under Section 338 of the Tariff Act of 1930 for goods entered for consumption or withdrawn from warehouse for consumption on or after October 30, 2026.

  • The president may impose additional duties of up to 50% ad valorem on products of a country that discriminates against U.S. commerce, and may amend those duties whenever the public interest requires, under Section 338 of the Tariff Act of 1930.

  • Although the Section 338 duty responds to Canada’s motor vehicle tariffs, most of the Canadian goods newly covered as of October 30, 2026, including sweetened cocoa powder, paints, carpets, and window air conditioners, fall outside the auto sector.

  • The HTSUS subheading, not the product descriptions in the proclamation’s annexes, determines whether the Section 338 duty applies to a Canadian product, because those descriptions are for information only.

  • Section 338 duties apply in addition to duties under Section 232 of the Trade Expansion Act of 1962, so covered Canadian goods also bear ordinary duties and any Section 232 duties.

21. Volkov: “Can You Govern the AI You Can’t See?”
(Source: Volkov Law, 5 Nov 2026) [Editor’s Summary]
• Principal Author: Michael Volkov, Volkov Law Group LLC

     You cannot govern AI you cannot see. That’s why the first step is not a policy. It’s an inventory. Once you’ve found every AI tool in your company, including the shadow ones, sort them into tiers.
     High-risk tools that make decisions about people or money, with human review of every output. Moderate risk, customer-facing tools with sampling and disclosure. Low-risk internal productivity tools on approved platforms.
     Then build your guardrails: a short, concrete, acceptable use policy that tells employees what they can and cannot paste in. Vendor diligence that asks who owns the model, where it’s hosted, and whether it trains on your data.
     Verification scaled to risk, because in the Avianca case, the court sanctioned the lawyers, not the chatbot.
     And an incident plan that covers AI-specific events like a data leak or a deepfake executive call.
     Here’s the 90-day plan: First 30 days: see it. Inventory and brief the board. Next 30: govern it. Tier and adopt policy.
     Final 30: use it. Pilot one compliance AI use case with validation. Govern first, deploy second. [Full article]

TRAINING EVENTS & CONFERENCES

22. FD Associates Presents: “U.S. Canada Joint Certification Program” Webinar, 10 Nov 2026
(Source: Sarah Huffman, [email protected])

  • What: “U.S. Canada Joint Certification Program” webinar

  • Where: At Your Computer

  • When: 10 Nov (Tues), 11 am – 12:30 pm EST

  • Summary: Is the Joint Certification Program process getting you down? This webinar demystifies the U.S. Canada JCP, how to complete the DD2345, the underlying requirements, and how U.S. Export control regulations intersect.

  • Presenter: John Herzo, Senior Compliance Associate, FD Associates

  • Sponsor: FD Associates, Inc

  • Register: HERE. Fourth participant from the same company is free. For more information call 703-847-5801 or email HERE.

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

  • What: Exporting Procedures Webinar

  • When: Tuesday, 17 November 2026

  • Where: Online

  • Summary: Industry experts will deliver practical Do’s and Don’ts of exporting designed to deepen your knowledge and sharpen your skills in navigating complex export compliance requirements. Our detailed course materials will be your go-to resource for managing export compliance with confidence.

  • Presenter: Trudy Wilson

  • Register: HERE. More information: email [email protected].

EX/IM MOVERS & SHAKERS

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

Submit job openings HERE.

(To view job description, click Job ID or Title.)

RECENT:

  • Ace Hardware. Job location: Oak Brook, IL. International Trade Compliance Manager

  • Axelon. Job location: Neenah, WI. Title: Export Coordinator

  • CesiumAstro. Job location: Austin, TX, or Westminster, CO. Title: Senior Trade Compliance Administrator. Job ID: 2026639. Contact: Matthew Gibson, 737-408-5431

  • CesiumAstro. Job location: Austin, TX, or Westminster, CO. Title: Trade Compliance Administrator II. Job ID: 2026634. Contact: Matthew Gibson, 737-408-5431

  • Datamark. Job location: El Paso, TX. Title: Licensed Customs Broker

  • Eastman Chemical. Job location: Kingsport, TN. Title: Trade Attorney

  • Forward Air. Job location: Euless, TX. Title: Export Coordinator - Ocean

  • Forward Air. Job location: Des Plaines, IL. Title: Export Specialist - Air

  • Forward Air. Job location: Groveport, OH. Title: Customs Brokerage Coordinator

  • Global Scouting Group. Job location: Chicago, IL. Title: Licensed Customs Broker - Freight Forwarding

  • HII Mission Technologies. Job location: Pocasset, MA. Title: Trade Compliance Manager. Job ID: 30928. Contact: Shelly Finnern, 202-449-0090

  • HII Mission Technologies. Job location: McLean, VA. Title: Trade Compliance Manager. Job ID: 30752. Contact: Shelly Finnern, 202-449-0090

  • HII Mission Technologies. Job location: Fairfax, VA. Title: Trade Compliance Manager. Job ID: 30948. Contact: Shelly Finnern, 202-449-0090

  • Micro-LAM. Job location: Portage, MI. Title: Trade Compliance Manager. Job ID: R-10156. Contact: Kevin Brozovich, 269-615-4821

  • Patagonia. Job location: Ventura, CA. Title: Trade Compliance Leader

  • Sunny Wing Logistics. Job location: El Monte, CA. Title: Senior Customs Broker / Customs Compliance Specialist

  • WL Gore. Job location: Newark, DE. Title: Export Control Specialist. Job ID: 2455

FULL LIST (Includes above entries.):

  • Ace Hardware. Job location: Oak Brook, IL. International Trade Compliance Manager

  • Altimeter Solutions. Job location: Londonderry, NH. Title: Remote Export Compliance Coordinator. Job ID: JP6978

  • Amazon Global Logistics. Job location: U.S. Remote. Title: Customs Compliance Specialist. Job ID: 10538268

  • Axelon. Job location: Neenah, WI. Title: Export Coordinator

  • Axiom Law. Job location: U.S. Remote. Title: Export Trade Compliance Attorney

  • BAE Systems. Job location: Hybrid (multiple locations). Title: Senior Manager, Global Trade

  • Barnes & Thornburg. Job location: Washington, DC. Title: International Trade Associate

  • Caterpillar. Job location: Singapore. Title: Manager Regional Trade Compliance

  • CesiumAstro. Job location: Austin, TX, or Westminster, CO. Title: Senior Trade Compliance Administrator. Job ID: 2026639. Contact: Matthew Gibson, 737-408-5431

  • CesiumAstro. Job location: Austin, TX, or Westminster, CO. Title: Trade Compliance Administrator II. Job ID: 2026634. Contact: Matthew Gibson, 737-408-5431

  • Continental Electronics. Job location: Richardson, TX. Title: Trade Compliance Analyst. Job ID: 36830. Contact: Maria Jabara, 1-310-658-7787

  • Datamark. Job location: El Paso, TX. Title: Licensed Customs Broker

  • Dedicated Computing. Job location: Waukesha, WI. Title: International Trade Compliance Specialist

  • Eastman Chemical. Job location: Kingsport, TN. Title: Trade Attorney

  • Elanco. Job location: Indianapolis, IN. Title: Senior Counsel, Global Trade

  • Eli Lilly. Job location: Indianapolis, IN. Title: Associate Director - Trade Sanctions Compliance. Job ID: R-108914. Contact: Bailey Patten, 1-864-875-1659

  • Entegris. Job location: Chaska, MN. Title: Senior Trade Compliance Specialist. Job ID: REQ-13241

  • Expeditors. Job location: Noorderlaan, Antwerpen, Belgium. Title: Customs Brokerage Agent

  • Expeditors. Job locations: Brisbane, CA; Grapevine, TX. Title: Customs Brokerage Agent

  • Export Compliance Solutions & Consulting. Job location: U.S. Remote. Title: Sales Representative-Software Sales. Contact: Suzanne Palmer

  • Forward Air. Job location: Euless, TX. Title: Export Coordinator - Ocean

  • Forward Air. Job location: Des Plaines, IL. Title: Export Specialist - Air

  • Forward Air. Job location: Groveport, OH. Title: Customs Brokerage Coordinator

  • GE Aerospace. Job locations: Evendale, OH; Lynn, MA; Norwalk, CT. Title: Lead Specialist, International Trade Compliance. Job ID: R5039226

  • General Atomics. Job locations: San Diego, CA (hybrid) or another U.S. location including Washington, DC; Huntsville, AL; Tupelo, MS; Denver, CO. Title: Senior Trade Compliance Integrator. Job ID: 52696BR. Contact: James Van Eenenaam

  • General Dynamics. Job location: Scranton, PA. Title: Regulations Compliance Specialist II. Job ID: 2026-35876

  • Global Scouting Group. Job location: Chicago, IL. Title: Licensed Customs Broker - Freight Forwarding

  • Hillspire. Job locations: Arlington, VA; Los Angeles, CA; Menlo Park, CA. Title: Export Compliance Senior Manager

  • HII Mission Technologies. Job location: Pocasset, MA. Title: Trade Compliance Manager. Job ID: 30928. Contact: Shelly Finnern, 202-449-0090

  • HII Mission Technologies. Job location: McLean, VA. Title: Trade Compliance Manager. Job ID: 30752. Contact: Shelly Finnern, 202-449-0090

  • HII Mission Technologies. Job location: Fairfax, VA. Title: Trade Compliance Manager. Job ID: 30948. Contact: Shelly Finnern, 202-449-0090

  • Honda. Job location: Lincoln, AL. Title: Customs Administrator

  • Honeywell Aerospace. Job location: Charlotte, NC. Title: Trade Compliance General Counsel. Job ID: 147681

  • IDD Aerospace. Job location: Redmond, WA. Title: Trade Compliance Specialist. Job ID: 8626. Contact: Anne Singh, 1-425-628-5983

  • Immigration & Customs Enforcement (ICE). Job location: Birmingham, AL. Title: General Attorney, Immigration and Customs

  • L3Harris. Job location: Palm Bay, FL. Title: Senior Manager, Trade Compliance - Sector Lead Empowered Official. Job ID: 43449. Contact: Christina Green, 702-497-1450

  • Lockheed Martin. Job locations: Syracuse, NY; Owego, NY. Title: International Trade Compliance, Senior Staff. Job ID: 733880BR. Contact: Rebecca Edwards, 1-203-540-7922

  • Lockheed Martin. Job location: Hybrid. Title: Operations Team Lead - Senior Staff - U.S. Export - Level 5

  • Lockheed Martin. Job location: Orlando, FL. Title: International Trade Compliance Staff--Level E4

  • Mastronardi Produce. Job location: Livonia, MI. Title: Customs Manager (Certified Customs Specialist). Job ID: CUSTO011196. Contact: Tiziana Mastronardi, 1-519-796-7710

  • McCarter & English. Job locations: Newark, NJ; Stamford, CT; New York, NY. Title: Trade Specialist. Job ID: 001. Contact: Christine Lydon

  • Medtronic. Job location: Washington, DC. Title: Principal Legal Counsel, Global Trade Legal & Compliance (Import)

  • Medtronic. Job location: Washington, DC. Title: Senior Principal Legal Counsel, Global Trade Legal & Compliance (Export)

  • Micro-LAM. Job location: Portage, MI. Title: Trade Compliance Manager. Job ID: R-10156. Contact: Kevin Brozovich, 269-615-4821

  • Northrop Grumman. Job location: Keyser, WV. Title: Global Trade Analyst. Job ID: R10255574

  • Northrop Grumman. Job location: Australia-Fortitude Valley. Title: Senior Principal Compliance Officer. Job ID: R10255693

  • Northrop Grumman. Job locations: 9 locations. Title: Sr. Principal International Trade Compliance Analyst. Job ID: R10240096

  • Northrop Grumman. Job locations: 9 locations. Title: Principal International Trade Compliance Analyst - Level 2 or 3. Job ID: R10243563

  • Northrop Grumman. Job locations: McLean, VA; Linthicum, MD; Warner Robins, GA. Title: Sr. Principal International Trade Compliance Analyst. Job ID: R10249827

  • Patagonia. Job location: Ventura, CA. Title: Trade Compliance Leader

  • PCC Airfoils. Job location: Douglas, GA. Title: Facility Trade Compliance Officer. Job ID: 13286

  • Planet. Job locations: DC Metro Area; Denver, CO; San Francisco, CA; Remote. Title: Technical Program Manager, Trade Compliance. Job ID: 8014103. Contact: Ashley McNally

  • Planet Labs. Job location: San Francisco, CA. Title: Senior Analyst, International Trade Compliance. Job ID: 8069677. Contact: Albert Zuniga

  • Quantinuum. Job location: Arlington, VA (hybrid). Title: Director of Export & Compliance. Job ID: 1015

  • Radiant. Job location: Renton, WA. Title: International Operations Specialist Lead

  • Rapiscan Systems. Job location: Billerica, MA. Title: Trade Compliance Manager. Job ID: 37117. Contact: Jon Logins, 1-978-584-6450

  • Rieter AG. Job location: Winterthur, Switzerland. Title: Head of Trade Compliance. Contact: Jasmin Bauer

  • Sidley Austin. Job location: Washington, DC. Title: International Trade Analyst. Job ID: LI-KG1

  • SpaceX. Job location: Washington, DC. Title: Counsel, Global Trade Compliance

  • SpaceX. Job location: Hawthorne, CA. Title: Counsel, Global Trade Compliance

  • SpaceX. Job location: Starbase, TX. Title: Counsel, Global Trade Compliance

  • Sunny Wing Logistics. Job location: El Monte, CA. Title: Senior Customs Broker / Customs Compliance Specialist

  • TE Connectivity. Job location: Hybrid in Wayne, PA, or Greensboro, NC. Title: Senior Manager, Global Trade Services - Automotive. Job ID: 158441

  • Teledyne. Job locations: Garland, TX; Billerica, MA; Elkridge, MD. Title: Trade Compliance Director, Aerospace & Electronics Segment. Job ID: REQ33489

  • Teledyne. Job locations: Billerica, MA; Elkridge, MD; Goleta, CA; Hudson, NH. Title: Export Licensing Specialist (EAR / ITAR). Job ID: 36249

  • Torres Trade Law. Job location: Dallas, TX. Title: International Trade & National Security Associate. Job ID: 154. Contact: Olga Torres, 1-214-295-8473

  • Tower Semiconductor. Job location: Newport Beach, CA. Title: Export and Trade Compliance Director. Job ID: 9597. Contact: Alyssa Olaosebikan, 1-949-435-8549

  • Unical Aviation. Job location: Glendale, AZ. Title: Senior Export Control Manager. Job ID: 2026-0778. Contact: Rebecca Whiteley, 1-626-949-3325

  • Unical Aviation. Job location: Glendale, AZ; Boca Raton, FL; or Herndon, VA. Title: Senior Legal Counsel

  • U.S. Air Force. Job location: Peterson AFB, CO. Title: Intelligence Specialist (Foreign Disclosure) (GG 13). Job ID: 889268300. Contact: IC - Air Force DCIPS, 800-525-0102

  • U.S. Commerce/BIS. Job location: Washington, DC. Title: Export Policy Analyst (GS 12-13). Job ID: BIS-OASEA-DHA-27-13072553. Contact: Cathy Mason

  • U.S. Commerce/BIS. Job location: Washington, DC. Title: Export Policy Analyst (GS 11-12). Job ID: 889883600. Contact: Cathy Mason

  • U.S. Commerce/ITA. Job location: Washington, DC. Title: Supervisory Foreign-Trade Zones Analyst (GS 15). Job ID: ITA-EC-DE-27-13084545

  • U.S. Customs & Border Protection. Job location: Seattle, WA. Title: General Attorney, Office of Chief Counsel

  • U.S. Defense Technology Security Administration. Job location: Alexandria, VA (plus telework). Title: Lead Export Control Analyst (GS 15). Job ID: ST-13078583-26-AES

  • U.S. Federal Trade Commission. Job location: Chicago, IL. Title: General Attorney (Trade Regulation) (GS 12 – 15). Job ID: 13078587-26-BCP

  • U.S. International Trade Commission (ITC). Job location: Washington, DC. Title: Attorney Advisor, Office of General Counsel (GS 14-15). Job ID: 887898700. Contact: Melanie West

  • WL Gore. Job location: Newark, DE. Title: Export Control Specialist. Job ID: 2455

EDITOR'S NOTES

25. Do You Have Access to the Latest and Greatest ITAR and FTR?

Bartlett's Annotated ITAR ("BITAR") (1 Nov 2026) and Bartlett's Annotated FTR ("BAFTR") (6 July 2026) are Word documents to download to your laptop to keep you updated on the latest amendments to the International Traffic in Arms Regulations (22 CFR 120-130) and the Foreign Trade Regulations (15 CFR Part 30).

They contain over a thousand footnotes of section histories, key cases, practice tips, Consent Agreements, glossaries, errors in the official text, and an extensive Tbles of Contents. You download the updated edition as soon as the regs are amended, so you'll always have the latest regulations.

But if the official on-line version of the ITAR is free, why subscribe to the BITAR?

Answer: Compare the BITAR with the Government's free version.

BITAR Advertisement _1 Sep 2024_.pdf

Compare the BITAR with the Government's free version

Download this PDF by clicking the button below.

411.65 KB • File

You'll see why all export professionals must use the BITAR and BAFTR.

Subscribe today!

26. Bartlett's Unfamiliar Quotations
(Source: BrainyQuotes)

  • Ella Wheeler Wilcox (5 Nov 1850 – 20 Oct 1919; was an American author and poet. Her works include Poems of Passion and Solitude, which contains the lines “Laugh, and the world laughs with you; weep, and you weep alone.” Her autobiography, The Worlds and I, was published in 1918, a year before her death.)
         - “To sin by silence, when we should protest, Makes cowards out of men.”
         - “With every deed you are sowing a seed, though the harvest you may not see.”

  • Will Durant (William James Durant; 5 Nov 1885 – 7 Nov 1981; was an American historian and philosopher, best known for his 11-volume work, The Story of Civilization, which details the history of Eastern and Western civilizations. It was written in collaboration with his wife, Ariel Durant, and published between 1935 and 1975. He was earlier noted for The Story of Philosophy, described as “a groundbreaking work that helped to popularize philosophy”)
         - “We are what we repeatedly do. Excellence, then, is not an act, but a habit.”
         - “Civilization begins with order, grows with liberty and dies with chaos.”
         - “To speak ill of others is a dishonest way of praising ourselves. Nothing is often a good thing to say, and always a clever thing to say.”

27. Today in History
(Source: History Channel)

     1941: The order is given: Bomb Pearl Harbor. On November 5, 1941, the Combined Japanese Fleet receive Top-Secret Order No. 1: In just over a month's time, Pearl Harbor is to be bombed, along with Malaya (now known as Malaysia), the Dutch East Indies and the Philippines.
     The attack on Pearl Harbor occurred on December 7, 1941, when the Imperial Japanese Navy Air Service launched a surprise military strike against the United States Naval Base at Pearl Harbor, on the island of Oahu, Hawaii.
     In response, the United States declared war on Japan on December 8, 1941, one day after the Japanese attack on Pearl Harbor in Hawaii.

28. 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.

DHS

DHS CUSTOMS REGULATIONS

19 CFR, Ch. 1, Pts. 0-199.

26 Sep 2026 (91 FR 55170) Electronic Export Manifest final rule, prescribed a new 19 CFR 123.93 requiring rail export manifest information to be sent electronically. The rule is effective October 26, 2026, and CBP will begin enforcing it on October 26, 2027.

DOC EAR

DOC EXPORT ADMINISTRATION REGULATIONS (EAR)

15 CFR Subtitle B, Ch. VII, Pts. 730-774.

28 Aug 2026 (91 FR 5547), a correction of a typo in Supplement No. 1 to Part 774, in the original rule of 24 Aug 2026 (91 FR 52501), which removed Chinese and Turkish entities.

DOC FTR

DOC FOREIGN TRADE REGULATIONS (FTR)

15 CFR Part 30

11 June 2026 (91 FR 35383): Amendment to Correct Errors. It fixed the note to § 30.2(a)(1)(iv), which still pointed to § 30.16, a section the March 30 rule had removed.

(The latest Bartlett's Annotated FTR ("BAFTR") is 6 Jul 2026.)

DOD NISPOM

DOD NATIONAL INDUSTRIAL SECURITY PROGRAM OPERATING MANUAL (NISPOM)

DoD 5220.22-M, 32 CFR Part 117

19 Aug 2021 (86 FR 46597): Extended compliance date for reporting and approval of foreign travel under SEAD 3 for contractors. A second, broader amendment was proposed in December 2023 but has not been published as a final rule.

DOJ ATF

DOJ ATF ARMS IMPORT REGULATIONS

27 CFR Part 447: Importation of Arms, Ammunition, and Implements of War

6 May 2026 (91 FR 24352, 34348, 24362, 24364): Revised four sections in 27 CFR § 447 and 479, to refer to Commerce regulations and court cases.

DOS ITAR

DOS INTERNATIONAL TRAFFIC IN ARMS REGULATIONS (ITAR)

22 C.F.R. Chapter I, Subchapter M, Parts 120-130

Oct. 1, 2026 (91 FR 62313): Removed Syria from ITAR § 126.1(d)(1). On Oct. 13, 2026, changes to Sections 120.54 and 121.0 took effect.

(The latest edition of Bartlett's Annotated ITAR ("BITAR") is Nov. 1, 2026)

DOT OFAC

DOT FOREIGN ASSETS CONTROL REGULATIONS

(OFAC FACR): 31 CFR, Parts 500-599, Embargoes, Sanctions, Executive Orders

“Title 31 was last amended 9/30/2026, amending numerous OFAC sanctions regulations, including: 31 CFR Parts 510, 525, 526, 528, 535, 536, 539, 544, 546, 547, 548, 549, 551, 552, 553, 555, 558, 560, 561, 562, 566, 569, 570, 576, 578, 579, 582, 583, 584, 586, 587, 588, 589, 590, 591, and 594.”

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