20-0727 Monday “Daily Bugle”

20-0727 Monday “Daily Bugle”

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Monday, 27 July 2020

  1. Justice/ATF: Application for Tax-Exempt Transfer of Firearm and Registration to Special Occupational Taxpayer”
  1. Items Scheduled for Future Federal Register Edition
  2. Commerce/BIS:(No new postings)
  3. State/DDTC: (No new postings)
  4. Whitehouse: “Statement on Unmanned Aerial Systems Exports”
  5. EU Political and Security Committee (CFSP) 2020/1099 about Military Operation in Bosnia and Herzegovina
  1. AboveTheLaw: “Big Law Firm To Pay Penalty Over ITAR Discrimination Claim”
  2. Defense News: “Trump Admin Officially Makes It Easier to Export Military Drones”
  3. Times: “For Now, Chip Gear Immune to U.S. Export Controls”
  1. Lawfare: “Should Congress Play a Role in Arms Sales?”
  2. Skadden: “US Responds to Developments in Hong Kong With Sanctions, US Export Control Amendments”
  3. ST&R Trade Report: “Import, Export, Product Safety Information Collections Under Review”
  1. Monday List of Ex/Im Job Openings: 46 Jobs Available – 7 New Job Openings This Week
  1. ECTI Presents: Import 101 for Aerospace Professionals Webinar: 26 Aug
  1. Bartlett’s Unfamiliar Quotations 
  2. New Edition of Bartlett’s Annotated ITAR (“BITAR”) is Available 
  3. Are Your Copies of Regulations Up to Date? Find the Latest Amendments Here. 
  4. Weekly Highlights of the Daily Bugle Top Stories 
  5. Submit Your Job Opening and View All Job Openings 
  6. Submit Your Event and View All Approaching Events 

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EXIM_a11. Justice/ATF: Application for Tax-Exempt Transfer of Firearm and Registration to Special Occupational Taxpayer”

(Source: Federal Register) [Excerpts]
85 FR 45228
: Notice
Bureau of Alcohol, Tobacco, Firearms and Explosives, Department of Justice.
30-Day notice.
The Department of Justice (DOJ), Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF), will submit 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.
Start Printed Page 45229
Comments are encouraged and will be accepted for an additional 30 days until August 26, 2020.

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Federal Register)

* Treasury/OFAC; NOTICES;
Blocking or Unblocking of Persons and Properties
; [Pub. Date: 28 Jul 2020] (PDF)
Agency Information Collection Activities; Proposals, Submissions, and Approvals
; [Pub. Date: 28 Jul 2020] (PDF)

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OGS_a23. Commerce/BIS: (No new postings)

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Today, President Donald J. Trump is taking action to improve the standards for exporting Unmanned Aerial Systems (UAS).  While the Missile Technology Control Regime (MTCR) is critical in slowing proliferation and promoting peace and security, it is in dire need of modernization as it applies to UAS.  In a sector of rapidly evolving technology, the MTCR’s standards are more than three decades old.  Not only do these outdated standards give an unfair advantage to countries outside of the MTCR and hurt United States industry, they also hinder our deterrence capability abroad by handicapping our partners and allies with subpar technology.  More than two years of discussion with MTCR partners were unable to produce consensus on this overdue reform.  Therefore, the President has decided to invoke our national discretion to treat a carefully selected subset of MTCR Category I UAS, which cannot travel faster than 800 kilometers per hour, as Category II.  As such, the United States has determined that it will overcome the MTCR’s strong presumption of denial for this UAS subset.
This action, which is consistent with MTCR Guidelines and the objectives of the April 2018 UAS Export Policy, will increase our national security by improving the capabilities of our partners and increase our economic security by opening the expanding UAS market to United States industry.  It also sets a strong example for other MTCR partners to adopt the same standard.
United States UAS exports continue to be subject to the rigorous review criteria outlined in the UAS Export Policy, the Conventional Arms Transfer Policy, and the Arms Export Control Act, as well as the specific nonproliferation criteria identified in the MTCR Guidelines.  Likewise, approving or denying a UAS sale to any country is a whole-of-government decision and takes into account our national security, nonproliferation, and foreign policy objectives, as well as the purchasing country’s ability to responsibly use and safeguard United States-origin technology.  The United States looks forward to all MTCR nations joining us in adopting this new standard.

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(Source: Official Journal of the European Union, 27 Jul 2020) [Excerpts]
Having regard to the Treaty on European Union, and in particular the third paragraph of Article 38 thereof,
Having regard to Council Joint Action 2004/570/CFSP of 12 July 2004 on the European Union military operation in Bosnia and Herzegovina
. …
Article 1
The contribution from Ukraine to the European Union military operation in Bosnia and Herzegovina (EUFOR ALTHEA) is accepted and considered to be significant.
 Ukraine is exempted from financial contributions to the budget of EUFOR ALTHEA.
Article 2
This Decision shall enter into force on the date of its adoption.

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(Source: AboveTheLaw blog, 24 Jul 2020) [Excerpts]
The Department of Justice announced on 23 July that the law firm of Arnold & Porter Kaye Scholer, along with legal staffing company Law Resources, will pay a civil penalty to settle discrimination claims. The settlement, totaling $56,500, is for claims that Law Resources, at the direction of Arnold & Porter, refused to hire U.S. citizens with dual citizenship and non-U.S. citizens with work authorization for a document review project in violation of the Immigration and Nationality Act.
As reported by Law.com, the claims were originated by attorney Temitope Ogunrinu. A DOJ investigation revealed dual citizens and non-citizens with work authorization were excluded from the project as a result of Arnold & Porter’s improper interpretation of the International Traffic in Arms Regulations (ITAR). It also found that Law Resources retaliated against Ogunrinu as a result of her objection to the restriction.  …
Arnold & Porter Kaye Scholer said the following about the case:  “This case involves a single incident where the firm mistakenly provided a third-party vendor inaccurate information about the criteria for selecting contractors for a document review,” the firm said in a statement. “As soon as this inadvertent mistake was brought to our attention, the Firm took steps to prevent it from happening again. Additionally, we cooperated fully with the IER in resolving the matter.”
And, as Dreiband went on to say, “We look forward to working with Law Resources and Arnold & Porter to ensure their hiring procedures fully comply with the Immigration and Nationality Act’s prohibition against citizenship status discrimination in employment.”

(Source: Defense News, 25 Jul 2020) [Excerpts]
The U.S. State Department has officially loosened restrictions on exporting military-grade unmanned aerial vehicles to foreign nations, a move long sought by the defense industry.

Under a new policy announced Friday, unmanned aerial systems that fly at speeds below 800 kph will no longer be subject to the “presumption of denial” that, in effect, blocked most international sales of drones such as the MQ-9 Reaper and the RQ-4 Global Hawk.
The U.S. government’s interpretation of the export controls had led to a blanket denial of most countries’ requests to buy “category-1” systems capable of carrying 500-kilogram payloads for more than 300 kilometers. Instead of having a “presumption of denial” for those drones, where export officials needed special circumstances to allow the sale of the drones, the new guidance would mean those officials would now consider proposed sales using the same criteria as they do for other military exports.

(Source: Times, 27 Jul 2020) [Excerpts]
In May, the U.S. tightened trade restrictions on China, requiring semiconductor manufacturers using U.S. equipment to obtain a special license to sell to companies, or “entities,” blacklisted by the United States. Chinese networking giant Huawei tops the U.S. entities list.

“The new controls are specific to Huawei and its affiliates and seek to impose a license requirement on the transfer to Huawei and its affiliates certain semiconductor designs and devices that are the direct products of U.S.-origin design software or U.S.-derived manufacturing tools,” according to a spokesperson for industry association SEMI.
The application process for U.S. export control licenses is onerous, he explained, but so far, no licenses have been denied.
The penalties for willful violations of U.S. export regulations can be severe, SEMI said.  Enforcement is overseen by the Commerce Department’s Bureau of Industry and Security.


(Source: Lawfare Blog, 26 Jul 2020)
* Principal Author: Alexandra Stark, Ph.D., Senior Researcher, New America
Editor’s Note: The Trump administration’s proposal to end the informal practice of notifying Congress well in advance of major arms sales is a departure from long-standing norms and a means of decreasing congressional interference in controversial sales, such as those to help the Saudi war in Yemen. Alexandra Stark of New America explains why this shift would be a mistake, discussing both the role of Congress and why the notification process should continue.
The Trump administration has proposed ending the informal practice of notifying Congress ahead of major arms sales. Despite the high barriers to Congress actually blocking an arms sale, ending this informal practice would close off one of the few channels of influence for the legislative branch to calibrate the United States’s relationships with its security partners around the world-and for citizen organizing to shape and respond to U.S. foreign policy.
Under the terms of the Arms Export Control Act, the president is required to formally notify Congress 30 days before the administration finalizes an arms sale worth $14 million or more (or defense articles or services worth at least $50 million) to a foreign government, or before the issuance of a license in the case of commercial sales. (The window is 15 days for NATO, NATO members, and other close U.S. partners Australia, Israel, Japan, New Zealand, and South Korea; the threshold values are also higher for this category of sales.) But, as Foreign Policy recently reported, the administration is now proposing to do away with informal arms sale notifications that the executive branch has traditionally submitted to Congress well before arms sales are finalized. This normative courtesy dates back to the 1970s, when Congress passed several pieces of legislation, including the 1973 War Powers Resolution and 1976 Arms Export Control Act, asserting its constitutional authority to conduct oversight of U.S. national security policy.

The president is also technically required to notify Congress if a recipient country violates the Arms Export Control Act. While it is rare for a president to do so, it has happened before: In 2007, for example, President George W. Bush informed Congress that Israel may have violated its agreements by using U.S.-supplied cluster munitions during the 2006 Lebanon War.

The Informal Notification Period and Congressional Holds 
The informal notification period allows members of Congress to place holds on arms sales while they raise concerns, receive answers from the administration, and provide input before the deal is finalized. Even with such notifications in place, the barriers to Congress formally blocking a foreign sale are overwhelmingly high in practice. As arms control experts Diana Ohlbaum and Rachel Stohl note that “a major weapons sale proceeds unless Congress enacts a law to stop it. If Congress fails to pass a resolution of disapproval, and to override the inevitable veto, then the arms transfer can be finalized.” Indeed, Congress has never been able to successfully block a sale via a joint resolution of disapproval, although it came closest to doing so in 2019, when a Senate vote failed to override the president’s veto of a joint resolution of disapproval of an arms sale to Saudi Arabia.

Nevertheless, informal congressional notification still serves a critical purpose. During the informal review period, the executive shares information about a sale with Congress prior to the formal notification period. This review period allows the relevant committees to place informal “holds” on specific sales and raise concerns before the formal notification period. The process can also be beneficial for the administration. As Acting Assistant Secretary of State Tina Kaidanow testified in June 2017, the informal process allows for Congress’s “concerns [to be] addressed, in a confidential process with the Administration, so that [the United States’s] bilateral relationship with the country in question is protected.” The administration typically extends “the review period until we can resolve those concerns,” Kaidenow added.

Historically, Congress’s role in conducting oversight this way has been obscured, since in the past an administration would be more likely to end a potential deal that faced a great deal of congressional criticism, thus negating the need for Congress to hold a vote. As then-Senator Joe Biden wrote in 1984, “Congress has never vetoed an arms sale, but that does not mean that Congress has not exercised influence over such sales. The Administration knew that Congress could veto a sale, and that encouraged the Administration to work with Congress, giving early notification of proposed arms sales and taking the opinions of Congress into account.” This informal review is one of few mechanisms that Congress has to actually conduct oversight over U.S. national security policy. Removing this mechanism would continue the erosion of Congress’s role in national security policy over the past few decades. According to the New York Times, if enacted, the proposal “would effectively end congressional oversight of the sale of American weapons and offers of training to countries engaged in wars with high civilian casualties or human rights abuses.”

Informal congressional notifications subject arms sales to public scrutiny and the public will, affording Congress (and its constituents) an avenue for oversight of U.S. national security policy in the face of expansive executive authority, and allowing Congress and the public to assess the costs and benefits of these security partnerships. This allows the U.S. public to exercise meaningful leverage to address the problematic behavior of security partners-like Saudi Arabia and the United Arab Emirates-when they undermine U.S. strategic objectives and when presidential administrations would rather look the other way, as Congress’s ongoing battle with the Trump administration over U.S. support for the war in Yemen demonstrates.

The Battle Between Congress and the Executive Branch Over Yemen. … 

Affirming the Importance of Congressional Oversight. …
Ironically, if the Trump administration presses forward on getting rid of informal notifications, congressional ire could very well become the impetus for broader reform of the arms sales process. As Ohlbaum and Stohl write, while committees’ ability to place a hold on proposed sales “is a courtesy, rather than a legal obligation, a White House decision to ignore these objections” would not be taken lightly by members of Congress but, rather, “would be regarded as an assault on congressional prerogatives.” Even some staunch Trump allies have expressed anger about the administration’s approach on arms sales. “Do away with the emergency exception,” said Senator Graham, after the White House attempted to circumvent Congress last June. “I would not have agreed to that before, but after this maneuver by the administration, count me in.” By trying to push Congress out of the arms sales process, the Trump administration could unwittingly instigate a new era of arms sales reform.

(Source: Skadden, 16 Jul 2020) [Excerpts]
* Principal Author:
Jamie L. Boucher
, Esq., 1-202-371-7369, Skadden LLP
In the wake of China’s new national security law for Hong Kong that went into effect on June 30, 2020, the Trump administration has taken several steps to significantly pare back Hong Kong’s preferential status under U.S. trade law and policy, and to target persons determined to “threaten the peace, security, stability, or autonomy of Hong Kong,” among other activities.
Reports on Foreign Persons Involved in the Erosion of Hong Kong’s Autonomy
The HKAA requires no later than 90 days after enactment that the secretary of state, in consultation with the secretary of the treasury, submit to Congress a report that identifies any foreign person (individual or entity) that is “materially contributing, has materially contributed to, or attempts to materially contribute to the failure of the Government of China to meet its obligations” under the Sino-British Joint Declaration or Hong Kong Basic Law (the Foreign Person Report). For purposes of the HKAA, a foreign person materially contributes to such conduct if the foreign person took action that “resulted in the inability of the people of Hong Kong (A) to enjoy freedom of assembly, speech, press, or independent rule of law; or (B) to participate in democratic outcomes” or “otherwise took action that reduces the high degree of autonomy of Hong Kong.”
Imposition of Sanctions
While the HKAA requires the president to impose sanctions on the foreign persons and foreign financial institutions identified in the Reports, it provides the president some discretion with respect to the timing of such sanctions. The president may impose blocking sanctions (i.e., an asset freeze and transaction ban) and visa restrictions on the persons identified in the Foreign Person Report at any time within one year of delivery, but these sanctions become mandatory at the one-year mark. With respect to foreign financial institutions included in the FFI Report, the HKAA sets forth a menu of 10 sanctions ranging from prohibitions on the institution acting as a primary dealer of U.S. government debt instruments to full blocking sanctions.1 The HKAA also permits the president to impose most of the sanctions on an institution’s principal executive officers.
The president has discretion to impose five or more of the sanctions at any point during the one-year period following delivery of the FFI Report, after which the requirement to impose at least five of the sanctions becomes mandatory. The HKAA requires the president to impose all of the remaining sanctions no later than two years after delivery of the FFI Report.
The HKAA requires the Reports to be updated in an “ongoing manner.”
Limitations on the President’s Ability To Lift Sanctions Imposed Under the HKAA
Section 8 of the HKAA sets out a process for the president to waive or terminate the application of sanctions imposed on certain persons. However, similar to the framework established under the Countering America’s Adversaries Through Sanctions Act, the HKAA subjects to congressional review the president’s decision to waive or terminate the application of sanctions imposed on persons and financial institutions targeted under the HKAA. Congress may issue a joint resolution disapproving of the president’s actions under these waiver and termination provisions, which would prevent the waiver, termination or removal from taking effect.
Section 8 was at the heart of the statement President Trump issued concurrent with signing the HKAA into law. On the matter of waiver and termination, the statement asserted that limitations imposed by Section 8 would be treated by the Trump administration “as advisory and non-binding.”

The Executive Order
As noted above, the executive order formally suspends or eliminates any preferential or differential treatment afforded to Hong Kong under U.S. law and policy, and it directs the heads of agencies to implement any changes necessary to give effect to the July 14, 2020, executive order within 15 days of its issuance.

Beyond this significant policy shift, and unlike the process contemplated in the HKAA, the executive order immediately authorizes the imposition of sanctions on any foreign person (individual or entity) that either the secretary of state or the secretary of the treasury determines is or has been involved, directly or indirectly, in the development, adoption, implementation or execution of China’s new national security law for Hong Kong. The executive order similarly authorizes sanctions for any person, or for a leader or official of any entity, determined “to be responsible for or complicit in, or to have engaged in, directly or indirectly”:
“actions or policies that undermine democratic processes or institutions in Hong Kong”;
“actions or policies that threaten the peace, security, stability, or autonomy of Hong Kong”;
“censorship or other activities with respect to Hong Kong that prohibit, limit, or penalize the exercise of freedom of expression or assembly by citizens of Hong Kong, or that limit access to free and independent print, online or broadcast media”; or
“the extrajudicial rendition, arbitrary detention, or torture of any person in Hong Kong or other gross violations of internationally recognized human rights or serious human rights abuse in Hong Kong.”
In the final section of the executive order, the president reserves the right to revisit the determinations made and actions taken under the executive order, should any “changes in China’s actions ensure that Hong Kong is sufficiently autonomous to justify differential treatment in relation to [mainland China] under United States law.”

The executive order was not accompanied by any immediate designations, meaning no person has yet been blocked under it and added to OFAC’s list of Specially Designated Nationals and Blocked Persons. It therefore remains to be seen how and when the secretaries of state and the treasury may decide to implement the relevant sanctions. Nonetheless, the sanctions regime established through the executive order is, on its own, likely to elicit a strong and potentially in-kind response from China.
On June 29, 2020, the secretary of commerce announced the suspension of all Commerce Department regulations that afford preferential treatment to Hong Kong under the EAR, including the availability of certain export license exceptions. Following the secretary’s announcement, the BIS formally suspended all such license exceptions, effective June 30, 2020. These actions affected several notable provisions under the EAR, including the generally more favorable case-by-case licensing policy for export activities involving Hong Kong as opposed to mainland China and certain license exceptions previously available to Hong Kong under EAR Part 740 (though license exceptions that are available to mainland China remain available for Hong Kong). Exports to Hong Kong must now also comply with certain special requirements applicable to exports to mainland China, including the requirement that exports of over $50,000 that require a license be accompanied by a “PRC End-User Statement” and the prohibition on exports, re-exports or transfers (in-country) of certain “military end-use” or “military end-user” items under EAR Part 744.

Shipments of items that were on dock for loading, on lighter, laden aboard an exporting or transferring carrier, or en route aboard a carrier to a port of export or re-export on June 30, 2020, subject to actual orders, may be processed pursuant to the pre-existing license exceptions. Deemed exports and re-exports to Hong Kong may similarly continue under these exceptions until August 28, 2020, after which time they will be subject to applicable licensing requirements.
In addition to the Commerce Department’s actions, the State Department announced that it will cease exports of U.S.-origin defense equipment to Hong Kong and take steps to impose on Hong Kong the same restrictions on exports of U.S. defense and dual-use technologies that are currently applicable to mainland China.
Going Forward
Global financial institutions and multinational companies with significant business or operations in Hong Kong should review their potential exposure as a result of the HKAA, the executive order and recent changes under U.S. export control laws, and assess whether these developments may warrant modifications to existing practices or closer monitoring of certain business relationships.

With the pace of developments in recent weeks and the escalation playing out between the United States and China, we do not believe the executive order and the HKAA signal the end of the road for legislative and executive branch action regarding Hong Kong. Rather, we believe there is significant risk of continued efforts by the United States to impose political and economic pressure on China – and the likelihood of future responses by China. As with most aspects of the U.S.-China relationship, given the stakes, it will be imperative for U.S. and non-U.S. companies active in Asia to keep a watchful eye on Hong Kong and any further political, economic and legal developments in the weeks and months ahead.

* Contact: 
messages@strtrade.com, 1-305-894-1035
The federal agencies listed below are seeking comments on the proposed extension or revision of information collections concerning the following.
Bureau of Alcohol, Tobacco, Firearms, and Explosives
– form 5300.11, annual firearms manufacturing and exportation report (comments due by Aug. 21)
– inventories: licensed explosives importers, manufacturers, dealers, and permittees (comments due by Aug. 21)
Consumer Product Safety Commission
– procedures for export of noncomplying products (comments due by Sept. 21)
– safety standard for multi-purpose lighters (comments due by Sept. 21)
Department of Agriculture
– importation of live swine (from certain regions), pork, and pork products (comments due by Aug. 24)
U.S. Customs and Border Protection
– forms 7512 and 7512A, transportation entry and manifest of goods subject to CBP inspection and permit (comments due by Sept. 22)


(Source: Events & Jobs Editor)

* Continental; Auburn Hills, MI;
Sr. Trade Facilitation Specialist 

* FLIR Systems;
West Lafayette
, IN; Research Associate
Hellmann Worldwide Logistics
; Doral, FL; Manager, Export Compliance; Contact Details:
Adrien Nicholson
* MDA, Brampton, CA; Export Control Administrator; Job ID:
* Micron Technology; San Jose, CA; Manager, Trade Compliance; Job ID:
* Thermo Fisher Scientific; Atlanta, GA;
Export Compliance Specialist II
UMass Amherst
Center, CA;
Export Ctrl Compliance Spec
; Job ID:
Click here to see the full list. 

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Ashleigh Foor
* What: 
Import 101 for Aerospace Professionals
* When: 26 Aug; 1:00 p.m. (EDT)
* Where: Webinar
* Sponsor: Export Compliance Training Institute (ECTI)
* ECTI Speaker: 
Marc Binder
* Register:
or Ashleigh Foor, 1-540-433-3977,

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EN_a115. Bartlett’s Unfamiliar Quotations

(Source: Editor)

* George Bernard Shaw
(26 Jul 1856 – 2 Nov 1950; was an Irish playwright, critic, polemicist, and political activist. He wrote more than sixty plays, including major works such as “Man and Superman, Pygmalion, and Saint Joan. With a range incorporating both contemporary satire and historical allegory, Shaw became the leading dramatist of his generation, and in 1925 was awarded the Nobel Prize in Literature.)
  – “The more things a man is ashamed of, the more respectable he is.”
* Max Scherzer
(Maxwell M. Scherzer; born July 27, 1984; is an American professional baseball pitcher for the Washington Nationals of Major League Baseball (MLB). He is the tenth pitcher in history to garner at least three Cy Young Awards, the sixth to record two no-hitters in one season, the fifth to produce more than one immaculate inning, and the second to strike out at least 200 batters in a season eight years in a row. He is regarded as one of the greatest pitchers of all time.
  – “Any time I’ve put extra work in, I see results.”
Monday is pun day
* Why are frogs so happy? They eat whatever bugs them!
* What did one flag say to the other? Nothing, it just waved.
* Somebody stole all my lamps… I couldn’t be more de-lighted!
* Why can’t dogs dance very well? Because they have two left feet!
* What did the grape say when it got stepped on?  It let out a little wine.

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

: DoD 5220.22-M. Implemented by Dep’t of Defense. 

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.)  
DOE ASSISTANCE TO FOREIGN ATOMIC ENERGY ACTIVITIES: 10 CFR Part 810.    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
, reducing the registration fee schedule in ITAR 122.3.  The latest edition of the 
is 20 July 2020.

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

17 Jul 2020:
85 FR 43436:
Nicaragua 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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