20-0612 Friday “Daily Bugle”

20-0612 Friday “Daily Bugle”

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Friday, 12 June 2020

  1. Commerce/BIS Extends Comments Deadline for Section 232 National Security Investigation of Certain Imports
  2. State Department Updates the List of Entities and Subentities Associated with Cuba (Cuba Restricted List)
  1. Items Scheduled for Future Federal Register Edition
  2. Commerce/BIS: (No new postings)
  3. State/DDTC: “Outage Notice on 13 Jun from 9:30 to 11:00 am”
  4. EU Commission Is Launching a Trade Policy Review on Tuesday, 16 Jul
  5. EU Approves Free Trade Agreement between the European Union and the Socialist Republic of Viet Nam
  6. EU Publishes Notice to Importers Concerning the Application of The Registered Exporter System Within the Framework of the Overseas Association Decision
  1. WORLDecr: “UN Extends Authorization to Search Ships for Violations of Libya Arms Embargo”
  1. Steptoe: “OFAC Clarifies Sanctions on Iranian Domestic Humanitarian / Safety Activity”
  2. ST&R Trade Report: “Nearly 3,500 Petitions for Duty Suspensions or Reductions Listed in Preliminary MTB Report”
  1. ECS Presents Webinar: 7-8 Jul; “ITAR/EAR Boot Camp — Achieving Compliance”
  2. Friday List of Approaching Events: 234 Events Posted This Week, Including 22 New Events
  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 

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EXIM_a11. Commerce/BIS Extends Comments Deadline for Section 232 National Security Investigation of Certain Imports

* 85 FR 35899: Notice of extension of comment period
* AGENCY: Bureau of Industry and Security, Office of Technology Evaluation, U.S. Department of Commerce.
* ACTIONS: Extension of comment period.
* SUMMARY: On May 19, 2020, the Bureau of Industry and Security (BIS) published the Notice of Request for Public Comments on Section 232 National Security Investigation of Imports of Laminations for Stacked Cores for Incorporation into Transformers, Stacked Cores for Incorporation into Transformers, Wound Cores for Incorporation into Transformers, Electrical Transformers, and Transformer Regulators. Today’s notice extends the deadline for written comments to July 3, 2020 and for rebuttal comments to July 24, 2020.
* DATES: The comment period for the proposed rule published May 19, 2020 at 85 FR 29926, is extended until July 3, 2020. The due date for rebuttal comments is July 24, 2020. Rebuttal comments may only address issues raised in comments filed on or before July 3, 2020.

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85 FR 35972: Notice
* ACTION: Updated publication of list of entities and subentities; notice.
* SUMMARY: The Department of State is publishing an update to its List of Restricted Entities and Subentities Associated with Cuba (Cuba Restricted List) with which direct financial transactions are generally prohibited under the Cuban Assets Control Regulations (CACR). The Department of Commerce’s Bureau of Industry and Security (BIS) generally will deny applications to export or reexport items for use by entities or subentities identified by the Department of State in the Federal Register or at https://www.state.gov/cuba-sanctions/cuba-restricted-list/, unless such transactions are determined to be consistent with sections 2 and 3(a)(iii) of NSPM-5.
* DATES: Applicable on June 12, 2020.
* FOR FURTHER INFORMATION CONTACT: Emily Belson, Office of Economic Sanctions Policy and Implementation, 202-647-6526; Robert Haas, Office of the Coordinator for Cuban Affairs, tel.: 202-453-8456, Department of State, Washington, DC 20520.

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* Commerce/BIS: NOTICES; Agency Information Collection Activities; Proposals, Submissions, and Approvals:5-Year Record Retention Requirement for Export and Boycott Transactions [Pub.Date 15 Jun 2020] (PDF)

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OGS_a24. Commerce/BIS: (No new postings)

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  Several applications within the Defense Export Control and Compliance (DECCS) platform will be unavailable from 9:30 AM (EDT) to 11:00 AM (EDT) on Saturday, June 13th for scheduled system maintenance. This will impact the following applications:
  • Advisory Opinions
  • Commodity Jurisdiction
  • User Management
Please ensure work in progress is saved prior to the scheduled downtime. Please let us know if you have any questions or concerns.

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6. EU Commission Is Launching a Trade Policy Review on Tuesday, 16 Jul

(Source: European University Institute, 12 Jun 2020)
   International trade plays a central role in the EU’s economy and helps drive its prosperity and that of its partners. But EU’s trade policy is evolving in an increasingly challenging environment both externally and internally. In addition, the COVID-19 pandemic has added to the growing list of challenges requiring a strong EU trade policy response.
   Against this backdrop, the European Commission is launching a Trade Policy Review, including wide public consultation and stakeholder outreach. This process will help to shape the direction of EU trade policy for the coming years, delivering meaningful responses to challenges such as:
·      Supporting a swift and sustainable economic recovery post-Coronavirus
·      Enhancing the climate and digital transformations of the EU economy
·      Pursuing a model of ‘open strategic autonomy’, to continue reaping the benefits of openness, while protecting Europe from unfair practices
·      Updating the multilateral rulebook, including WTO reform
·      Strengthening EU resilience to deal with future challenges, including pandemics
·      Getting maximum value from the network of EU trade deals
  Join us for a timely conversation with Phil Hogan, EU Commissioner for Trade, to discuss the details of this review process and how citizens and stakeholders can make their voices to help the Commission formulate the direction of EU trade policy going forward. The event will be moderated by Bernard Hoekman, coordinator of the RESPECT project.
Outside EUI premises –
Robert Schuman Centre for Advanced Studies

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  Article 1 – The Free Trade Agreement between the European Union and the Socialist Republic of Viet Nam (‘the Agreement’) is hereby approved on behalf of the Union.
The text of the Agreement is attached to this Decision.
  Article 2 – For the purposes of Articles 9.20 and 9.23 of the Agreement, any modifications or rectifications to Sections A to D and F of Annexes 9-A and 9-B to the Agreement shall be approved, on behalf of the Union, by the Commission, after consultation with the special committee appointed by the Council in accordance with Article 207(3) of the Treaty.
  Article 3 – The President of the Council shall, on behalf of the Union, give the notification provided for in paragraph 2 of Article 17.16 of the Agreement, in order to express the consent of the Union to be bound by the Agreement (3).
  Article 4 – This Decision shall enter into force on the date of its adoption.
Done at Brussels, 30 March 2020.

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   By virtue of Council Decision 2013/755/EU (1) on the association of the overseas countries and territories (‘OCTs’) with the European Union (‘Overseas Association Decision’ – OAD), the European Union grants trade preferences to the OCTs. Annex VI of that Decision concerns the definition of the concept of ‘originating products’ and methods of administrative cooperation. Council Decision (EU) 2019/2196 (2), of 19 December 2019, totally replaced the text of Annex VI, with a date of application starting on 1 January 2020.
   As from 1 January 2020, in accordance with Article 21 (General Requirements) and Article 26 (Statement on origin and information for cumulation purpose) of Annex VI of the OAD, preferential tariff treatment is granted at import in the European Union only on presentation of a statement on origin made out, either by a registered exporter, or by any exporter where the total value of the originating products consigned does not exceed EUR 10 000.
   As from 1 January 2020, certificates of origin EUR.1 issued by the competent authorities in an OCT before 1 January 2020, or origin declarations made out by an exporter in an OCT before 1 January 2020 are not valid proofs of origin to grant the benefit of the preferential tariff treatment of the OAD in the European Union.
   For the application of the system of registered exporters (the REX system), an OCT has to comply with the two pre-requisites laid down in Articles 36 and 39 of Annex VI of the OAD. An OCT which does not have fulfilled the two pre-requisites is not able to apply the REX system, and as a consequence is not in a position to benefit from the OAD preferential tariff treatment until it has fulfilled the two pre-requisites.
   In order to comply with the obligation of publication under Article 37 of Annex VI of the OAD, detailed information about the dates of application of the REX system by all OCTs is available on the Europa Website (3). The operators are encouraged to consult this website on a regular basis to check whether and when the OCTs are able to apply the REX system.

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WORLDecr, 11 Jun 2020) [Excerpts]
   The UN Security Council has extended an authorization allowing member states to inspect vessels suspected of violating its arms embargo on Libya for another year.
   The Council said in a 5 June videoconference meeting that it had ‘unanimously decided to extend for one year a series of authorizations for Member States to inspect vessels on the high seas off the coast of Libya suspected of violating that country’s arms embargo.’
   The authorization allows states ‘acting nationally or through regional organizations, to inspect vessels on the high seas bound to or from Libya, given reasonable grounds to believe that they are in violation of the Council’s arms embargo.’
   A UN arms embargo on Libya has been in force since 2011 but largely ignored by countries in the region and beyond. The flood of arms has fueled a civil war that has intensified since last year between the UN-recognized Government of National Accord (‘GNA’) in Tripoli and the Libyan National Army (‘LNA’) led by renegade general Khalifa Haftar.
   Following May reports that Russia had sent mercenaries and fighter planes to fight for Haftar against GNA forces that are mainly backed by Turkey, the United States has begun to show renewed interest in Libya, warning that arms supplies must stop and the UN embargo respected.
   The European Union has also renewed interest in enforcing the embargo. At the start of April, EU countries launched a maritime mission to inspect vessels at sea to ensure they are not carrying arms or illicit cargo to or from Libya.


* Principal Author: Peter Jeydel, Esq., 1-202-429-6291, Steptoe & Johnson LLP

   On June 5, 2020, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC)
four new Iran-related frequently asked questions (FAQs) regarding Executive Order (EO) 13902 of January 14, 2020, “Imposing Sanctions with Respect to Additional Sectors of Iran.”

   In relevant part, EO 13902 authorizes sanctions against any person the Secretary of the Treasury, in consultation with the Secretary of State, determines to operate in the construction, mining, manufacturing, or textiles sectors in Iran (and any additional sectors that may in the future be designated by the US government). In addition, EO 13902 authorizes sanctions against any persons or foreign financial institutions engaged in sanctionable activity related to the targeted sectors such as providing material assistance to a blocked person or knowingly engaging in a significant transaction in connection with a targeted sector.
   These new FAQs from OFAC provide definitions to clarify the scope of these sanctions. (Click here to view FAQ 831, which defines each of the targeted sectors.
Click here to view FAQ 832
and its broad definition of “significant goods or services.”
Click here to view FAQ 833
and the guidance it provides on the terms “knowingly” and “significant” for the purposes of EO 13902.)
   While the clarifying guidance provided in the new FAQs is helpful, the most noteworthy aspect of the FAQs are statements that US secondary sanctions under EO 13902 do not apply to certain types of activities in these otherwise targeted sectors in Iran when dealing with the provision of goods or services for humanitarian, hygiene, or safety needs for domestic use within Iran. [FN/1]
   Specifically, FAQ 830 states that secondary sanctions under EO 13902 do not apply to persons in Iran who are engaged in the manufacture of “medicines, medical devices, or products used for sanitation, hygiene, medical care, medical safety, and manufacturing safety, including soap, hand sanitizer, ventilators, respirators, personal hygiene products, diapers, infant and childcare items, personal protective equipment, and manufacturing safety systems, solely for use in Iran and not for export from Iran . . .”.  The reference to “for use in Iran and not for export” presumably would disqualify certain manufacturing entities and facilities in Iran that might produce items not just for domestic consumption but also for export.  How due diligence will be conducted to determine if a manufacturer is not producing for export from Iran could be a challenge, particularly without easy access to the manufacturer’s management and corporate location.
   FAQ 830 also restates OFAC’s policy that persons engaged in transactions related to the provision of agricultural commodities, food, medicine, or medical devices to Iran will not be subject to sanctions under EO 13902.
Similarly, FAQ 832 states that OFAC would not sanction the provision of “goods that ensure the protection of life and prevention of injuries to persons operating” in the targeted sectors, such as personal protective equipment, safety devices, and alarm systems, or “services that ensure the protection of life and prevention of injuries to persons operating in” these sectors, such as cleaning, safety inspections, and services necessary for use of the aforementioned protective goods.
  Presumably, this policy is intended to avoid targeting purely domestic Iranian businesses (including state-owned entities) otherwise operating in targeted sectors as long as these businesses are: (i) involved only in activities related to the provision of goods or services for humanitarian, hygiene, or safety needs for use only domestically within Iran, as specified above, and (ii) are not affiliated with the IRGC or designated under the terrorism or proliferation authorities. This policy therefore allows limited types of continued trade with Iran in the interest of humanitarian, hygiene, and safety concerns, including items for preventing and treating COVID-19 in Iran.  For more on this topic, see our earlier posts on sanctions guidance issued
by the EU
by the US
on trade with sanctioned countries during the COVID-19 crisis.
OFAC makes clear that parties in Iran’s export sector are still subject to sanctions under EO 13902, and that sanctions continue to apply to activities involving the Islamic Revolutionary Guard Corps (IRGC) or its affiliates, or Specially Designated Nationals (SDNs) listed under authorities relating to support for international terrorism or proliferation of weapons of mass destruction.

* Contact: 
messages@strtrade.com, 1-305-894-1035

   The International Trade Commission has submitted to Congress its
preliminary report
on the petitions for duty suspensions and reductions that have been filed with the ITC under the revamped miscellaneous trade bill process. This report lists 3,479 petitions covering products in categories such as chemicals (53.4 percent of petitions filed), machinery and equipment (20.6 percent), textiles, apparel, and footwear (16.7 percent), and natural resources and agriculture (9.4 percent).

These petitions are characterized as follows.
  – meets the statutory requirements for inclusion in an MTB without modification (category I, 874 petitions)
  – meets the statutory requirements with specified technical changes (category II, 1,229 petitions), adjustments in the amount of duty suspension or reduction (category III, 526 petitions), or modifications in product scope (category IV, 3 petitions)
  – does not contain the required information or was not filed by a likely beneficiary (category V, 42 petitions)
  – not recommended for inclusion in an MTB because the product description could not be administered, a domestic producer objected, or the estimated duty revenue loss was more than $500,000 per year (category VI, 805 petitions)
   The ITC is accepting additional public comments on section VI petitions from June 12 through June 22.
   The ITC expects to deliver its final report to Congress by Aug. 9. Congress will make the final decision regarding those imported articles that will be included in a final MTB.


*When: 7-8
*Where: Your Computer
*Sponsor: Export Compliance Solutions & Consulting
*Presenter: Suzanne Palmer, Mal Zerden

here or by calling
1-866-238-4018 or email

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(Sources: Event sponsors)  

Submit your event in the Submission section at the end of this newsletter.  
[Editor’s note:  This Daily Bugle Event List has grown so large that we have run out of space to display it, so we are displaying here only the new events in the Daily Bugle, while maintaining a 
LINK HERE to the full list.]

* 16 Jun: “
Preparing Your Business for the COVID-19 World
; Thompson Hine
* 18 Jun: “
A Webinar On Investigations and VSDs
; P.A.E.I.
* 25 Jun: “
; Strategic Trade Research Institute (STRI)
* 30 Jun: “
USMCA: The modernized NAFTA
; International Business Training
* 7 Jul: “
USMCA: The modernized NAFTA
; International Business Training
* 9 Jul: “
A Practical Guide to AES Filing“; ECTI
* 4 Aug: “
Export Documentation
; Chamber International
* 13 Aug: “
Export Documentation & Import Procedures Online Course
; Chamber International
* 25 Aug: “
Understanding Exporting & Incoterms
; Chamber International
* 30 Sep: “
Understanding Exporting
; Chamber International
On Location:

* 15- 17 Sep:
Annapolis, MD, USA
; “
3nd Annual ITAR/EAR Symposium and Managing ITAR/EAR Complexities
* 15 – 16 Oct: Toronto, CA

ITAR/EAR Controls for Non-U.S. Companies

* 25-28 Oct: Denver, CO, USA;
Annual Conference & Exposition
* 18-19 Nov: Santa Clara, CA, USA; “
Annual Year-End Review of Import/Export Developments
; Baker McKenzie
* 28 Jan 2021: Orlando, FL, USA; “
Customs Import Boot Camp 2021
“; Partnerships International, Inc.
* 9-11 Mar 2021: Orlando, FL, USA; “
Partnering For Compliance 2021 Export Control Conference
; Partnerships International, Inc.

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EN_a114. Bartlett’s Unfamiliar Quotations

(Source: Editor)

* Harriet Martineau (12 Jun 1802 – 27 Jun 1876; was a British social theorist and Whig writer, often cited as the first female sociologist. Martineau wrote many books and a multitude of essays from a sociological, holistic, religious, domestic, and perhaps most controversially, feminine perspective. She also translated various works by Auguste Comte, and she earned enough to support herself entirely by her writing, a rare feat for a woman in the Victorian era.)
  – “Any one must see at a glance that if men and women marry those whom they do not love, they must love those whom they do not marry.”
  – “Men who pass most comfortably through this world are those who possess good digestions and hard hearts.”
Friday funnies:
After about 10 years, a wife was concerned that their child did not resemble either parent, so she got a DNA test and found out the child was not theirs.  When she told her husband what she had found out, he replied, “Well, don’t you remember?  When were leaving the hospital the baby pooped all over and you told me to take him back in the hospital and change him, so I went back inside and got a clean one and left the dirty one there.”  The wife fainted.

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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.


5 June 2020: 85 FR 34495 and 85 FR 34503: Additions and Amendments of the Entity List.   
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.

6 May 2020: 85 FR 26847, Notice (not an amendment) temporarily reducing the registration fee schedule in ITAR 122.3 until April 30, 2021. 


DOT FOREIGN ASSETS CONTROL REGULATIONS (OFAC FACR): 31 CFR, Parts 500-599, Embargoes, Sanctions, Executive Orders

5 Jun 2020:
85 FR 84510:

Syria Sanctions Regulations. 


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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