20-0504 Monday “Daily Bugle”

20-0504 Monday “Daily Bugle”

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Monday, 4 May 2020

  1. Federal Trade Commission Requests Public Comment on the Fuel Rating Rule
  2. DHS/CBP Requests Public Coments on Application and Approval to Manipulate, Examine, Sample or Transfer Goods
  3. State/DDTC Suspends Duration of Several ITAR Requirements
  1. Items Scheduled for Future Federal Register Edition
  2. Commerce/BIS: No New Postings
  3. State/DDTC Updates Notice on COVID Measures
  1. The National Herald: “U.S. State Dept. Responds to AHI Request to Remove Arms Prohibition on Cyprus”
  1. E. Hirschhorn: “Foreign Students and Technology Transfer — Distinguishing the Baby from the Bath Water”
  2. Kelley Drye: “BIS Imposes Significant Additional Restrictions on Exports to China, Russia, and Venezuela”
  1. Monday List of Ex/Im Job Openings: 129 Jobs Available – 7 New Job Listings This Week 
  1. ECS Presents Webinar “ITAR/EAR Controls for Non-US Companies” on 24-25 Jun
  1. Bartlett’s Unfamiliar Quotations
  2. Are Your Copies of Regulations Up to Date? Find the Latest Amendments Here.
  3. Weekly Highlights of the Daily Bugle Top Stories
  4. Submit Your Job Opening and View All Job Openings
  5. Submit Your Event and View All Approaching Events

Are You Keeping Up to Date with the Latest Regulations?

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load to your laptop to keep you updated on the latest amendments, and contain over 800 footnotes of section history, key cases, practice tips & tricks, and extensive Tables of Contents.
The ITAR amendments to the ITAR that took effect on 9 March and 25 March are included in the current edition of the BITAR.  Subscribers receive updated editions every time the regulations are amended (usually within 24 hours) so you will always have the current versions of the regulations. Subscribe to the BITAR now to guarantee you have an up-to-date ITAR!    

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Federal Register
, 4 May 2020) [Excerpts]

85 FR 26470: NOTICE
* AGENCY: Federal Trade Commission.
* ACTION: Notice
* SUMMARY: In accordance with the Paperwork Reduction Act of 1995 (PRA), the Federal Trade Commission (FTC or Commission) is seeking public comment on its proposal to extend for an additional three years the Office of Management and Budget (OMB) clearance for information collection requirements in its Fuel Rating Rule (the Rule). The current clearance expires on July 31, 2020.
* DATES: Comments must be received on or before July 6, 2020.
* ADDRESSES: Interested parties may file a comment online or on paper by following the instructions in the Request for Comments part of the SUPPLEMENTARY INFORMATION section below. Write “Fuel Rating Rule; PRA Comment: FTC File No. P072108” on your comment, and file your comment online at https://www.regulations.gov by following the instructions on the web-based form. If you prefer to file your comment on paper, mail your comment to the following address: Federal Trade Commission, Office of the Secretary, 600 Pennsylvania Avenue NW, Suite CC-5610 (Annex J), Washington, DC 20580, or deliver your comment to the following address: Federal Trade Commission, Office of the Secretary, Constitution Center, 400 7th Street SW, 5th Floor, Suite 5610 (Annex J), Washington, DC 20024. … 

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EXIM_a22. DHS/CBP Requests Public Comments on Application and Approval to Manipulate, Examine, Sample, or Transfer Goods

(Source: Federal Register, 4 May 2020) [Excerpts]
85 FR 26487: NOTICE
* AGENCY: U.S. Customs and Border Protection (CBP), Department of Homeland Security.
* ACTION: 30-Day notice and request for comments; extension of an existing collection of information.
* SUMMARY: The Department of Homeland Security, U.S. Customs and Border Protection will be submitting the following information collection request to the Office of Management and Budget (OMB) for review and approval in accordance with the Paperwork Reduction Act of 1995 (PRA). The information collection is published in the Federal Register to obtain comments
from the public and affected agencies. Comments are encouraged and must be submitted (no later than June 3, 2020) to be assured of consideration.

* ADDRESSES: Written comments and recommendations for the proposed information collection should be sent within 30 days of publication of this notice to
. Find this particular information collection by selecting ”Currently under 30-day Review-Open for Public Comments” or by using the search function.

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EXIM_a23. State/DDTC Suspends Duration of Several ITAR Requirements

(Source: Federal Register, 1 May 2020) [This item was scheduled to be published in the Federal Register on 1 May 2020, but due to government technical issues, was not published on that date.]


85 FR 25287; 22 CFR Parts 120, 122, 123, 124, and 129, International Traffic in Arms Regulations: Notification of Temporary Suspension, Modification, or Exception to Regulations
AGENCY: Dep’t of State/DDTC
ACTION: Temporary suspensions, modifications, and exceptions. SUMMARY: The Department of State is issuing this document to inform the public of certain temporary suspensions, modifications, and exceptions for the durations described herein to several provisions of the International Traffic in Arms Regulations (ITAR). These actions are taken in order to ensure continuity of operations within the Directorate of Defense Trade Controls (DDTC) and among entities registered with DDTC pursuant to the ITAR during the current SARS-COV2 public health emergency.
FOR FURTHER INFORMATION CONTACT: Sarah Heidema, Office of Defense Trade Controls Policy, U.S. Department of State, telephone (202) 663-1282, or e-mail DDTCResponseTeam@state.gov., ATTN: Notice of Suspension, Modification, or Exception.
SUPPLEMENTARY INFORMATION: In order to ensure continuity of operations within the Directorate of Defense Trade Controls (DDTC) and among entities registered with DDTC pursuant to part 122 of the International Traffic in Arms Regulations (ITAR), DDTC provides notice of the temporary suspension, modification, or exception to several ITAR provisions. These actions are being taken pursuant to ITAR § 126.2, which allows for the temporary This document is scheduled to be published in the Federal Register on 05/01/2020 and available online at federalregister.gov/d/2020-08839, and on govinfo.gov suspension or modification of provisions of the ITAR, and ITAR § 126.3, which allows for exceptions to provisions of the ITAR. These actions are in the interest of the security and foreign policy of the United States. Further, they are warranted as a result of the exceptional and undue hardships and risks to safety caused by the public health emergency related to the SARSCOV2 pandemic. The President declared a national emergency on March 13, 2020, as a result of this public health crisis. [Footnote: Proclamation 9994 of March 13, 2020, 85 FR 15337 (Mar. 18, 2020).]
   (1) As of February 29, 2020, a temporary suspension, modification, and exception to the requirement in ITAR parts 122 and 129 to renew registration as a manufacturer, exporter, and/or broker and pay a fee on an annual basis by extending ITAR registrations with an expiration date of February 29, March 31, April 30, May 31, or June 30, 2020 – for two (2) months from the original date of expiration.
   (2) As of March 13, 2020, a temporary suspension, modification, and exception to the limitations on the duration of ITAR licenses and agreements contained in ITAR parts 120 through 130, including but not necessarily limited to ITAR §§ 123.5(a), 123.21(a), and 129.6(e), to extend any license or agreement that expires between March 13, 2020 and May 31, 2020 – for six (6) months from the original date of expiration so long as there is no change to the scope or value of the authorization and no Name/Address changes are required. This six (6) month extension is warranted in light of the unique challenges applicants face in the current environment when attempting to coordinate with U.S. and foreign business partners regarding the scope of applications.
   (3) As of March 13, 2020, a temporary suspension, modification, and exception to the requirement that a regular employee, for purposes of ITAR § 120.39(a)(2), work at the 1 Proclamation 9994 of March 13, 2020, 85 FR 15337 (Mar. 18, 2020). company’s facilities, to allow the individual to work at a remote work location, so long as the individual is not located in Russia or a country listed in ITAR § 126.1. This suspension, modification, and exception shall terminate on July 31, 2020, unless otherwise extended in writing.
   (4) As of March 13, 2020, a temporary suspension, modification, and exception to authorize regular employees of licensed entities who are working remotely in a country not currently authorized by a technical assistance agreement, manufacturing license agreement, or exemption to send, receive, or access any technical data authorized for export, reexport, or retransfer to their employer via a technical assistance agreement, manufacturing license agreement, or exemption so long as the regular employee is not located in Russia or a country listed in ITAR § 126.1. This suspension, modification, and exception shall terminate on July 31, 2020, unless otherwise extended in writing. (Authority: 22 CFR 126.2 and 126.3)
Zachary A. Parker, Director, Office of Directives Management, U.S. Department of State.
Billing Code: 4710-25 [FR Doc. 2020-08839 Filed: 4/30/2020 8:45 am; Publication Date: 5/1/2020]

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OGS_a36. State/DDTC Updates Notice on COVID Measures

State/DDTC, 1 May 2020)


Given the extraordinary impact of the COVID-19 pandemic on the national economy and Defense Industrial Base, the Directorate of Defense Trade Controls (DDTC) is temporarily reducing registration fees for DDTC registrants in Tier I and Tier II to $500 for registrations whose original expiration date is between May 31, 2020 and April 30, 2021. Also, DDTC is reducing registration fees to $500 for new applicants who submit their registration application between May 1, 2020 and April 30, 2021. All new registrants are in Tier I in the first year. This will allow new registrants and existing registrants in Tiers I and II, many of which are small and medium-sized enterprises, to receive a reduced registration fee over the course of the coming year. The fee structure for Tier III entities remains unchanged at this time. We anticipate that this temporary reduction in fees for Tier I, Tier II, and new registrants will save regulated industry over $20 million over the course of the coming year.
This temporary reduction in fees shall apply only through April 30, 2021, at which time fees for entities in Tiers I and II will return to the rates that were in effect on April 1, 2020 unless otherwise extended by a subsequent notice in the Federal Register.

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NWS_a17. The National Herald: “U.S. State Dept. Responds to AHI Request to Remove Arms Prohibition on Cyprus”

(Source: The National Herald, 1 May 2020)
The U.S. Department of State responded to American Hellenic Institute (AHI) President Nick Larigakis’ letter, dated April 22, to Secretary of State Mike Pompeo on the issue of removing the arms prohibition on the Republic of Cyprus. President Larigakis wrote to Secretary Pompeo requesting him to utilize the authority delegated to him by President Donald Trump under two recently enacted laws to waive the limitations placed on the transfer of arms to the Republic of Cyprus, and further, to remove the Republic of Cyprus altogether from the list of countries to which arms sales are prohibited under International Traffic in Arms Regulations (ITAR).
On behalf of Secretary Pompeo, Deputy Assistant Secretary of State for European and Eurasian Affairs Matthew Palmer presented the United States’ position on waiving the limitations.
While President Larigakis welcomed the letter’s reaffirmation of the United States’ view of the Republic of Cyprus as a “valued partner and friend in the Eastern Mediterranean” and its assessment that U.S. cooperation with the Republic of Cyprus is at a “historic high,” he expressed obvious disappointment that several of AHI’s points made to remove the arms prohibition were not addressed.
“The letter does not address the issue of removing the Republic of Cyprus from the ITAR list and did not acknowledge AHI’s points related to the issue of access of Russian military vessels to Cypriot ports,” Larigakis said.
The State Department letter also noted, “regarding Russian military vessels’ access, however, the United States continues to urge a halt in Russia’s regular navy port calls to the ROC. There is no doubt these vessels contribute to destabilizing actions in Syria.”
Nevertheless, as Larigakis, said that according to the letter, the State Department will review “all tools available to deepen security cooperation with the Republic of Cyprus.”
Regarding Cyprus’ anti-money laundering efforts, the letter to AHI noted that “the United States government welcomed the February MONEYVAL Mutual Evaluation Report on ROC’s [Republic of Cyprus’] anti-money laundering measures, which showed ROC’s important progress in strengthening AML [anti-money laundering] efforts and combatting illicit financial flows.
On a positive note, Larigakis said that, “as the State Department continues with its review of ways to deepen security cooperation with the Republic of Cyprus, AHI will continue to work with the State Department to reach an understanding that it is in U.S. interests to remove the Republic of Cyprus from the ITAR list altogether, especially if the United States values Cyprus as a partner and cooperation is at a historic high.”
He added that, “on behalf of AHI, I thank Mr. Palmer for expressing his appreciation in the letter for the ‘important role’ AHI plays in contributing to efforts to deepen bilateral relations between the United States and Republic of Cyprus.”
The American Hellenic Institute is a non-profit Greek American public policy center and think tank that works to strengthen relations between the United States and Greece and Cyprus, and within the Greek American community.

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COM_a18E. Hirschhorn: “Foreign Students and Technology Transfer Distinguishing the Baby from the Bath Water”

) [Excerpts of 10-page paper.]
* Author: 
Eric L. Hirschhorn, Esq.
, Senior Adviser, Center for Strategic and International Studies (CSIS). He previously served as the Undersecretary of Commerce for Industry and Security.
The U.S. long has welcomed foreign students to our universities.  They typically have been the best and brightest of their societies and frequently have made their professional lives in the U.S. as significant contributors to our scientific and commercial sectors.  But times have changed, and it may be that some tightened restrictions are in order.  If so, should they be imposed as export controls, visa limitations, or in some other way.  At a minimum, an examination of the issues–preferably a cooperative effort by the academic community and the federal government–is in order.
For many years, the United States has opened its doors to students from other countries who desire to enroll in U.S. colleges and universities. This has provided the United States with many benefits. These students often have been the best and the brightest of their societies. Many have remained in the United States for some or all of their professional careers and contributed significantly to U.S. society. Even those who have returned home commonly have done so with positive feelings toward the United States. Their presence here has helped their societies and ours better understand one another. Finally, from a somewhat mercenary point of view, they typically have paid full tuition, thus helping balance university budgets and, in effect, subsidizing U.S. students attending those schools. Developments in recent years, however, have led many observers to question whether the traditional view of foreign students remains accurate. The United States has not previously faced a situation where another country is deliberately and systematically attempting, by fair or foul means, to gain access to its technology. Today we are seeing a new pattern in the immigration of foreign students-particularly Chinese students in the sciences-to study at our academic institutions. The changes include the number of students who come here, the connections that some have with their home governments (particularly the military and intelligence services of those governments), the courses of study they elect, and the proportion who return home after graduation. Flatly closing the door to foreign students would be a foolish and self-defeating step, but the United States must consider two important questions. First, does the traditional U.S. openness inappropriately ignore or understate the risks attendant upon giving potential adversaries access to important technology? Second, if so, what should the United States do to recalibrate the balance?
United States Controls on Technology Exports . . .
Foreign Students and Technology Transfer . . .
How Does the U.S. Academic Community Fit into This Framework? . . .
What to Do?  

Recently, Secretary of Defense Mark Esper spoke at CSIS’s Global Security Forum. He was asked whether the United States should restrict the admission of students who come from potential adversaries such as China and plan to study technical subjects. One might have expected him to say “yes” but-somewhat surprisingly-he responded only that we need to know who the students are and what they are studying. Importantly, he did not take up the opportunity to suggest that we should restrict students’ entry or courses of study any more than is done today. If the secretary of defense is not clear on what the United States ought to do, I hesitate to offer a solution of my own. It seems clear, though, that the current landscape differs significantly from the historic paradigm and that the academic community needs to work closely with the federal government to ensure that an appropriate balance-one that reflects the considerations noted above-is struck. At a minimum, this review should include whether the exception for “catalog courses” ought to be narrowed or otherwise refined, whether the visa process can be made more robust, and whether the Intelligence Community can provide additional information about the backgrounds of applicants for student visas.

COM_a29. Kelley Drye: “BIS Imposes Significant Additional Restrictions on Exports to China, Russia, and Venezuela”

(Source: Kelley Drye, 1 May 2020)
* Principal Author: Scott Wise, Esq., 1-212-808-7800, Kelley Drye LLP
On April 28, 2020, the Department of Commerce’s Bureau of Industry Security (“BIS”) published three separate rules which, in response to the Administration’s conclusion that “civil-military integration” in China is increasing, impose significant additional restrictions on the export of dual-use items to strategic rivals including China, Russia, and Venezuela. These rules, when implemented, will have an especially acute effect on transactions with China. Specifically, consistent with the Administration’s conclusion that these countries present national security and other foreign policy concerns, BIS restricted exports, re-exports, and in-country transfers to these destinations by: 1) issuing a final rule expanding end-use and end-user restrictions related to China by expanding the scope of prohibitions to include “military end-users” in China and expanding the definition of “military end use”, among other changes; 2) issuing a final rule removing a license exception that allows the export of some items to certain countries that present national security concerns, including China and Russia, provided that the end-use was civilian (license exception CIV); and 3) issuing a proposed rule narrowing the scope of a license exception that allows the re-export of some items that present national security concerns (license exception APR).
These changes, which are largely effective on June 29, 2020, will create additional hurdles in transactions with China, Russia, and Venezuela. Many transactions that were previously authorized under a general license will now require a specific license from BIS. Even transactions that may still be completed without a specific authorization may require significant additional due diligence steps, particularly to ascertain end-users and end-use in China. If your company is currently doing business in these markets, it is important to determine whether these rule changes affect your business and, if so, how to comply with the new regulations.
Final rule increasing restrictions on transactions involving products for military end-use and end-users in China, Russia, and Venezuela
The most important change will have significant effects on the export and re-export of EAR-subject items, including technology, to China by expanding the restrictions related to military end-uses and end-users. The current end-use and end-user controls restrict transactions involving certain enumerated products (i.e., those listed in Supplement 2 to 15 C.F.R. Part 744) that are for a “military end-use” in China, Russia, or Venezuela, or are for a “military end-user” in Russia or Venezuela.[FN/1] End-user and end-use restrictions apply regardless of whether the item would typically require an authorization prior to export based on the item’s classification on the Commerce Control List (“CCL”). BIS expanded these restrictions in several ways. First, the final rule adds a “military end-user” restriction to transactions with China. This will likely significantly increase due diligence burdens on transactions with China, because parties may have to be able to ascertain that the end-user is not involved in the support of restricted “military end-uses.”
Second, the final rule expands the scope of the military end-use restriction, which will apply to all three of China, Russia, and Venezuela. [FN/1] Currently, end-use restrictions apply to transactions in which the item is for the use, development, or production of military items. The final rule expands the scope of this restriction to include an item that “supports or contributes to the operation, maintenance, repair, overhaul, refurbishing, development, or production” of military items. This is designed to capture items that may have a relatively limited supporting role for a military item, where the current restriction can be interpreted to require a more robust relationship between the item involved in a transaction and a military item.
Last, this final rule adds nearly twenty additional Export Control Classification Numbers (“ECCNs”) to Supplement 2, and expands the coverage related to some ECCNs already covered, which currently includes approximate 30 ECCNs, adding ECCNs covering materials processing, telecommunications, and information security, among others. [FN/2]
This rule becomes effective on June 29, 2020.
Final Rule Removing License Exception CIV
License Exception CIV currently authorizes the export, re-export, and transfer of items subject to “NS” controls for civil end-uses and end-users in Country Group D:1, [FN/3] such as China and Russia. The final rule deletes License Exception CIV and will now require individual BIS review of each transaction prior to export of these items in accordance with U.S. export licensing policy. [FN/4]
BIS stated in the final rule that additional guidance regarding the rule is forthcoming. This rule also becomes effective on June 29, 2020.
Proposed Rule Modifying License Exception APR
License Exception APR currently authorizes reexports between and among certain countries, including the re-export of EAR-subject items from most U.S. allies [FN/5] to countries in Country Group D:1 if the item is subject to “NS” controls. This proposed rule would remove that portion of License Exception APR and instead require BIS review and approval of re-exports of NS items to countries such as China and Russia.
BIS requests comments regarding how the proposed rule would potentially impact companies and other stakeholders who currently use or plan to use the License Exception APR. BIS is particularly interested in the volume of transactions and time necessary to complete to future transactions affected by the proposed change, as well as other potential business impact. Comments must be submitted to BIS by June 29, 2020.
These significant new restrictions are primarily aimed at and will especially impact trade with China. [FN/6]. At a minimum, these new rules will significantly increase due diligence burdens on transactions with China, as the U.S. responds to “civil-military integration” in that market. Parties engaged in transactions with China may be required to seek additional certification from their business partners that items exported will violate the expanded end-use and end-user restrictions.
Further, many exports that would have previously been permissible without specific authorization from BIS will now be subject to BIS licensing requirements. This change may create delays as parties go through the licensing process, and BIS is likely to refuse to authorize transactions where there is insufficient clarity on the national security and foreign policy implications of the proposed transaction. Companies exporting covered items to China, or using License Exceptions CIV and/or APR should immediately begin preparation to comply with these rules to minimize disruption.
[FN/1] 15 C.F.R. § 744.21. A military end-user is “the national armed services (army, navy, marine, air force, or coast guard), as well as the national guard and national police, government intelligence or reconnaissance organizations, or any person or entity whose actions or functions are intended to support ‘military end uses’.” 15 C.F.R. § 744.21(g).
[FN/2] The complete list of ECCNs added to the supplement as part of the rule is 2A290, 2A291, 2B999, 2D290, 3A991, 3A992, 3A999, 3B991, 3B992, 3C992, 3D991, 5B991, 5A992, 5D992, 6A991, 6A996, and 9B990.  
[FN/3] See 15 C.F.R. Part 740, Supp. No. 1 (Countries include: Armenia, Azerbaijan, Belarus, Cambodia, China, Georgia, Iraq, Kazakhstan, Kyrgyzstan, Laos, Libya, Macau, Moldova, Mongolia, Russia, Tajikistan, Turkmenistan, Ukraine, Uzbekistan, and Vietnam. The exception specifically excludes North Korea.
[FN/4] License Exception CIV authorized exports for approximately 30 ECCNs. These are identified by “CIV: Yes” under the ECCNs heading on the Commerce Control List.  
[FN/5] See 15 C.F.R. Part 740, Supp. No. 1.
[FN/6] Venezuela is already subject to significant economic sanctions administered by the U.S. Office of Foreign Assets Control (“OFAC”), and OFAC recently increased those restrictions.


(Source: Events & Jobs Editor)

* AIS Global; Coeur d Alene, Idaho; Global Trade Compliance Manager
* Lockheed Martin; Tokyo, Japan; Regulatory Compl Anlyst Sr Stf; Requisition ID: 6360BR
* Robinhood; Menlo Park, CA; Senior Regulatory Counsel – AML, Sanctions, and Export Control
* Valeo; Seymour, IN; U.S. Customs Manager
* Xilinx, Singapore; Trade Compliance Specialist; Requisition ID: 157972

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*What:  ITAR/EAR Controls for Non-U.S. Companies
*When: 24-25 Jun
*Where:  Online
*Sponsor: Export Compliance Solutions & Consulting
*Presenter: Suzanne Palmer, Mal Zerden

 or by calling 866-238-4018 or email 

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EN_a212. Bartlett’s Unfamiliar Quotations

(Source: Editor)


James Brown (James Joseph Brown (3 May 1933 – 25 Dec 2006; was an American singer, songwriter, dancer, musician, record producer and bandleader. A major figure of 20th century rock and soul music and dance, he is often referred to as the “Godfather of Soul” and “Soul Brother No. 1”. In a career that lasted over 50 years, he influenced the development of several music genres.)
  – “Hair is the first thing. And teeth the second. Hair and teeth. A man got those two things, he’s got it all.”
(Editor’s Trivia: While I was a radio announcer in Key West, Florida, and introduced James Brown in a live concert, he autographed several of his albums for me: “To that outa sight swinging cat Jim!”)
Thomas Henry Huxley (4 May 1825 – 29 Jun 1895; was an English biologist and anthropologist who specialized in comparative anatomy.  He is known as “Darwin’s Bulldog” for his advocacy of Charles Darwin’s theory of evolution.)
 – “Every great advance in natural knowledge has involved the absolute rejection of authority.”
Monday is Pun Day:
* Q: 
What do you call a shoe made from a banana peel?  A: A slipper.
* Q: Why do zebras wear stripes?  A: Because they don’t want to be spotted.
* I know a guy who’s addicted to drinking brake fluid, but he insists he can stop any time.
* I got fed up with my wife telling me to stop acting like a flamingo… I had to put my foot down.
* Statistically, 6 out of 7 of Snow White’s seven dwarfs were not Happy.

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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.
Latest Update 
: 19 CFR, Ch. 1, Pts. 0-199.
5 Apr 2019:84 FR 13499: Civil Monetary Penalty Adjustments for Inflation.


24 Feb 2020:
85 FR 10274
: Amendments to Country Groups for Russia and Yemen Under the Export Administration Regulations.


DOC FOREIGN TRADE REGULATIONS (FTR): 15 CFR Part 30.   Last Amendment: 24 Apr 2018: 83 FR 17749: Foreign Trade Regulations (FTR): Clarification on the Collection and Confidentiality of Kimberley Process Certificates.


18 May 2016: Change 2: Implement an insider threat program; reporting requirements for Cleared Defense Contractors; alignment with Federal standards for classified information systems; incorporated and cancelled Supp. 1 to the NISPOM (Summary here.)  

23 Feb 2015: 80 FR 9359, comprehensive updating of regulations, updates the activities and technologies subject to specific authorization and DOE reporting requirements. 

15 Nov 2017, 82 FR 52823: miscellaneous corrections include correcting references, an address and a misspelling.


DOJ ATF ARMS IMPORT REGULATIONS: 27 CFR Part 447-Importation of Arms, Ammunition, and Implements of War.

14 Mar 2019: 84 FR 9239: Bump-Stock-Type Devices.

DOS INTERNATIONAL TRAFFIC IN ARMS REGULATIONS (ITAR): 22 C.F.R. Ch. I, Subch. M, Pts. 120-130.  26 Dec 2019: 84 FR 70887; 23 Jan 2020: 85 FR 3819: Encryption rule and USML Categories I, II, III, and related sections regarding guns & ammo. 
DOT FOREIGN ASSETS CONTROL REGULATIONS (OFAC FACR): 31 CFR, Parts 500-599, Embargoes, Sanctions, Executive Orders

13 Mar 2020:
85 FR 14572:
General Licenses Issued Pursuant to Venezuela-Related Executive Order 13835.


1 Jan 2019: 19 USC 1202 Annex.
  – HTS codes for AES are available here.
  – HTS codes that are not valid for AES are available here.

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