20-0911 Friday “Daily Bugle”

20-0911 Friday “Daily Bugle”

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Friday, 11 September 2020

  1. Treasury/OFAC: “Blocking or Unblocking of Persons and Properties”
  2. Commerce/BIS: “Wassenaar Arrangement 2018 Plenary Decisions Implementation-Revisions Related to National Security Controls-“
  1. Items Scheduled for Future Federal Register Edition
  2. Commerce/BIS: (No new postings)
  3. State/DDTC: (No new postings)
  4. Treasury/OFAC: “Treasury Sanctions Russia-Linked Election Interference Actors”
  5. EU Council: “EU Extends Sanctions Against Violations of Territorial Integrity for a Further 6 Months”
  1. EU Sanctions: “EU Renews Ukraine/Russia Sanctions for 6 Months”
  2. Reuters: “China’s Expanded Export Controls Pose Fresh Challenge to Global Tech Industry”
  1. Allen & Overy: “China: Technology Export Control and Beyond”
  2. Baker McKenzie: “BIS Announces Review of Foundational Technologies and Seeks Public Comments”
  1. ECTI Presents: 24 Sep; “Riding the Wave of Current and New Tariffs – Update on US Trade Remedies Webinar”
  2. FCC Academy Presents 4 Webinars: U.S. Export Controls: ITAR & EAR | FMS | Designing and Implementing an ICP
  3. Friday List of Approaching Events: 201 Events Posted This Week, Including 3 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 
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  5. Submit Your Event and View All Approaching Events 

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Bartlett’s Annotated ITAR and Bartlett’s Annotated FTR are Word documents to down-

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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EXIM_a11. Treasury/OFAC: “Blocking or Unblocking of Persons and Properties”

(Source: Federal Register) [Excerpts]
85 FR 56290: Notice
* AGENCY:Office of Foreign Assets Control, Treasury.
* ACTION:Notice.
* SUMMARY:The Department of the Treasury’s Office of Foreign Assets Control (OFAC) is publishing the names of one or more persons that have been placed on OFAC’s Specially Designated Nationals and Blocked Persons List based on OFAC’s determination that one or more applicable legal criteria were satisfied. All property and interests in property subject to U.S. jurisdiction of these persons are blocked, and U.S. persons are generally prohibited from engaging in transactions with them.

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EXIM_a22. Commerce/BIS: “Wassenaar Arrangement 2018 Plenary Decisions Implementation-Revisions Related to National Security Controls-“

(Source: Federal Register) [Excerpts]
85 FR 56294: Rule
* AGENCY:Bureau of Industry and Security, Commerce.
* ACTION:Final rule.
* SUMMARY:The Bureau of Industry and Security (BIS) maintains, as part of its Export Administration Regulations (EAR), the Commerce Control List (CCL), which identifies certain items subject to Department of Commerce jurisdiction. This final rule revises the CCL and other corresponding parts of the EAR, to implement changes made to the Wassenaar Arrangement List of Dual-Use Goods and Technologies and Munitions List (WA Lists) maintained by the governments participating in the Wassenaar Arrangement on Export Controls for Conventional Arms and Dual-Use Goods and Technologies (Wassenaar Arrangement, or WA) at the December 2018 WA Plenary meeting. The Wassenaar Arrangement advocates implementation of effective export controls on strategic items with the objective of improving regional and international security and stability. BIS published a final rule on May 23, 2019, implementing certain new controls on emerging technologies, as decided at the 2018 Plenary meeting. This rule harmonizes the CCL with the remaining decisions reached at the 2018 Plenary meeting by revising Export Control Classification Numbers (ECCNs) controlled for national security reasons in each category of the CCL, except Category 4. This rule also makes other associated changes to the EAR, as well as adjustments to license exception eligibility for national security-controlled items and revisions to reporting requirements.

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OGS_a24. Commerce/BIS: (No new postings)

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(Source: Treasury/OFAC, 10 Sep 2020)
Today, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated four Russia-linked individuals for attempting to influence the U.S. electoral process. Russia uses a variety of proxies to attempt to sow discord between political parties and drive internal divisions to influence voters as part of Moscow’s broader efforts to undermine democratic countries and institutions. In the United States, Russia has used a wide range of influence methods and actors to target our electoral process, including targeting U.S. presidential candidates.
Treasury designated Andrii Derkach (Derkach) pursuant to Executive Order (E.O.) 13848 for his efforts to influence the 2020 U.S. presidential election. Derkach, a Member of the Ukrainian Parliament, has been an active Russian agent for over a decade, maintaining close connections with the Russian Intelligence Services. Derkach has directly or indirectly engaged in, sponsored, concealed, or otherwise been complicit in foreign interference in an attempt to undermine the upcoming 2020 U.S. presidential election. Today’s designation of Derkach is focused on exposing Russian malign influence campaigns and protecting our upcoming elections from foreign interference. This action is a clear signal to Moscow and its proxies that this activity will not be tolerated. The Administration is working across the U.S. Government, and with state, local, and private sector partners, to make the 2020 election secure.
“Andrii Derkach and other Russian agents employ manipulation and deceit to attempt to influence elections in the United States and elsewhere around the world,” said Secretary Steven T. Mnuchin. “The United States will continue to use all the tools at its disposal to counter these Russian disinformation campaigns and uphold the integrity of our election system.”
Derkach’s Election Influence Efforts
From at least late 2019 through mid-2020, Derkach waged a covert influence campaign centered on cultivating false and unsubstantiated narratives concerning U.S. officials in the upcoming 2020 Presidential Election, spurring corruption investigations in both Ukraine and the United States designed to culminate prior to election day. Derkach’s unsubstantiated narratives were pushed in Western media through coverage of press conferences and other news events, including interviews and statements.
Between May and July 2020, Derkach released edited audio tapes and other unsupported information with the intent to discredit U.S. officials, and he levied unsubstantiated allegations against U.S. and international political figures. Derkach almost certainly targeted the U.S. voting populace, prominent U.S. persons, and members of the U.S. government, based on his reliance on U.S. platforms, English-language documents and videos, and pro-Russian lobbyists in the United States used to propagate his claims.
Treasury Continues to Hold Russian Actors Accountable
Today’s designation of Derkach is another example of the Treasury department promoting accountability for Kremlin-linked individuals seeking to undermine confidence in U.S. democratic processes. Treasury has previously designated the Russian troll factory known as the Internet Research Agency (IRA), and its Russian financier Yevgeniy Prigozhin. Prigozhin has been designated by the United States pursuant to E.O. 13661, E.O. 13694, as amended, and most recently by E.O. 13848 for providing material support to the IRA’s influence activities against the 2018 U.S. midterm elections.
Today, Treasury also designated three IRA actors pursuant to E.O. 13694, as amended by E.O. 13757, and E.O. 13848 for having acted or purported to act for or on behalf of, directly or indirectly, the IRA, an entity designated pursuant to E.O. 13694, as amended, and E.O. 13848. Russian nationals Artem Lifshits, Anton Andreyev, and Darya Aslanova, as employees of the IRA, supported the IRA’s cryptocurrency accounts. The IRA uses cryptocurrency to fund activities in furtherance of their ongoing malign influence operations around the world.
OFAC coordinated today’s action against the IRA with the U.S. Attorney’s Office for the Eastern District of Virginia and the United States Secret Service.
As a result of today’s designations, all property and interests in property of these targets that are subject to U.S. jurisdiction are blocked, and U.S. persons are generally prohibited from engaging in transactions with them. Additionally, any entities 50 percent or more owned by one or more designated persons are also blocked.

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(Source: Council of the European Union, 10 Sep 2020)
Today the Council decided to extend the sanctions targeting persons and entities that continue to undermine or threaten the territorial integrity, sovereignty and independence of Ukraine, for a further 6 months until 15 March 2021.
The existing restrictive measures provide for both travel restrictions and the freezing of assets, and will continue to apply to 175 persons and 44 entities.
The decision was adopted by the Council by written procedure. The legal acts will be published in the Official Journal on 11 September 2020.
Restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine were first introduced on 17 March 2014.
Other EU measures in place in response to the crisis in Ukraine include economic sanctions targeting specific sectors of the Russian economy, currently in place until 31 January 2021, and restrictive measures in response to the illegal annexation of Crimea and Sevastopol, limited to the territory of Crimea and Sevastopol and currently in place until 23 June 2021.
The list of sanctioned persons and entities are kept under constant review and subject to periodic renewals by the Council.

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(Source: EU Sanctions, 11 Sep 2020)
The EU Council has renewed sanctions for 6 months until 15 March 2021 targeting people and entities that continue to undermine or threaten the territorial integrity, sovereignty or independence of Ukraine. The measures, which comprise travel restrictions and asset freezing measures, will continue to apply to 175 people and 44 entities. Press release here.

(Source: Reuters, 11 Sep 2020) [Excerpts]
The latest additions to China’s list of controlled technology exports could upset a broad range of industries and raise the possibility that some global tech giants might have to split off their Chinese operations, legal experts said.
The new list of technologies under export controls announced on Aug. 28 came as an unwelcome surprise to an industry already grappling with the uncertainty posed by trade tensions between China and the United States.
The move was initially seen as a means of giving Beijing a say in any sale of video app TikTok, but advisers to Chinese and foreign firms say the potential consequences go much further.
The revisions could also affect a bevy of multi-national companies that conduct research and development inside China, adds Nicolas Bahmanyar, cybersecurity senior consultant at LEAF law firm in Beijing. …


(Source: Allen & Overy, 11 Sep 2020)
* Principal Author: Victor Ho, Esq., 86-10-6535-4381, Allen & Overy
Victor Ho
Managing Partner, Beijing/Shanghai
Jack Wang
Richard Qiang
Jill Ge
Senior Associate
Paul Jing
Senior Associate
As technology and IP have increasingly become the focal point of tensions between the U.S. and China, the Chinese Government announced its amendments to the Catalogue of Technologies Prohibited or Restricted from Export (the Catalogue) on 28 August 2020. It is worth noting that China has long had a technology export control regime in place. The most recent update has put into specific focus as it is been widely speculated that it is a reaction to the recent sanctions the U.S. Government has imposed on Chinese companies as well as the potential forced sale of TikTok’s U.S. operations. 
To what extent the amendments to the Catalogue would increase regulatory hurdles in connection with technology transactions is yet to be determined and is likely to vary on a case-by-case basis.  Having said that, the inclusion of artificial intelligence and other emerging technologies in the Catalogue seems to indicate that China is taking a firmer stance on key area where Chinese technology has made significant strides. Overall, this may be a signal of wider protectionist approach beyond the export control regime.
China technology export regime revisited
Technology exports in China are mainly governed by the Regulations on the Administration of the Import and Export of Technology, together with the Measures for the Administration of Technology Import and Export Contract Registration and the Measures for the Administration of Export-Prohibited and Export-Restricted Technologies (collectively, the Technology Export Regulations). 
Pursuant to the Technology Export Regulations, technologies are divided into three categories: export-prohibited, export-restricted and freely transferrable. The Ministry of Commerce (MOFCOM) and the Ministry of Science and Technology (MOST) have maintained a catalogue of export-prohibited and export-restricted technologies setting forth specific technical parameters or “control points” for export purposes. The export of technology falling within the prohibited category is banned, while the export of technology in the restricted category is subject to prior approval by MOFCOM. This means that contracts for the export of restricted technology are invalid under PRC law until approval by MOFCOM. 
The Technology Export Regulations are intended to apply broadly, covering the acts of transferring technologies from China to outside China “in the form of trade, investment or economic and technological cooperation”. At least the following constitutes an act of export: (i) assignment of patents or patent applications; (ii) licence of patents; (iii) transfer of know-how; and (iv) technical services. 
What is new in the Catalogue?
MOFCOM and MOST last updated the Catalogue in 2008. In a span of more than a decade, as a key part of its industrial plans, China has invested significantly in cultivating domestic technology industries and developing cutting-edge and emerging technologies resulting in significant advancements in a range of areas.  
The additions to the Catalogue, to some extent, reflect the trends and shifts in technology development, particularly in relation to technologies of strategic importance or pertaining to national security. A summary of notable additions to the Catalogue is set out at the end of this alert. The highlights include the following:
  • A total of 23 categories have been added to the restricted list.
  • These include a wide range of technologies such as 3D printing, drone, laser, password security, high-performance detection, and design and manufacturing technology of core components of petroleum equipment.
  • The technical parameters of 21 existing categories have been updated to include new technologies.
  • For information processing technology, the additions include personalised information push services based on data analytics, speech synthesis technology, voice evaluation technology, as well as artificial intelligence interactive interface technology.
  • For biotech and pharmaceutical industry, newly added restricted technologies include oral rotavirus vaccines and polysaccharide protein binding technology.
Furthermore, the Catalogue also removed a small number of relatively older technologies:
  • Four categories of technologies have been removed from the export prohibited list, including microbial fertilising, caffeine production (by chemical synthesis or semi-synthesis) and medicine production (by chemical synthesis or semi-synthesis) technologies.
  • Five categories of technologies that are restricted from export have been removed, including Newcastle disease vaccine, natural medicine production and information security firewall software technologies.
Notably, MOFCOM published the draft amendments to the Catalogue for public comments in June 2018. Most of the changes mentioned above were included in the earlier draft version.
Implications for technology and IP transactions
According to the Technology Export Regulations, export of any restricted technology requires both a pre-approval and post-verification by MOFCOM. Applications need to be submitted to MOFCOM at the provincial level. Local MOFCOM will transmit the application for review and consultation with local MOST. This leaves considerable discretion to the agencies in processing the applications, ranging from requiring the details of the technology to be exported, to interpreting the technical parameters which appear to be broadly worded under the Catalogue, and potentially regulating the export of sensitive technologies in various different forms.   
In particular, in addition to an outbound IP assignment or licensing arrangement, typical licence-back or grant-back clauses in connection with a joint venture cooperation or a pure inbound licensing deal would arguably constitute a technology export. Export of finished products involving sensitive technologies as well as cross-border technical service arrangements could also fall within the purview of the export control regime.
This might be the reason why ByteDance may have to suspend negotiations over the pending sale of TikTok and reassess the requisite PRC regulatory requirements that might be triggered by the potential deal. The Catalogue now sets out restricted categories relating to personalised information push service technology based on data analytics, as well as a set of artificial intelligence technology, including voice recognition, microphone array and interaction and understanding technology. TikTok is reported to rely on an array of proprietary algorithms for its artificial intelligence and related spheres that potentially fall within these restricted categories. 
Although the TikTok implications have drawn a significant amount of attention to China’s existing export control regime, we note that the export approval process has been rarely triggered historically. Most provincial MOFCOMs have limited experience in dealing with these types of applications. As such, the actual, broader implications of the recent amendments to the Catalogue will likely vary, depending on the nature of the IP, the sensitivity of the technology, as well as the parties involved and the structuring of the transaction. 
Potential impact on the FDI regime and beyond
While the immediate implications for the technology and IP transactions are yet to be fully assessed, the amendments to the Catalogue have signalled China’s intention to enhance the protection of its emerging technologies in the sense of both national security and strategic importance. 
Similarly, regulatory control and intervention in the other contexts might become more visible and active, in light of the increasing tension in the US-China relationship.
From the foreign direct investment perspective, the Tech Import and Export Regulation will apply in if an inbound transaction both falls into the national security review regime and involves technologies listed out in the Catalogue, in which case the relevant intellectual property authorities will carry out technology review. The amendments to the Catalogue substantially extend the scope of the sensitive technologies especially in regard to those cutting-edge technologies, and possibly may reframe the regulatory landscape of the inbound transactions caught by the amended Catalogue. This is likely to be a countervailing trend compared to the lift of the foreign investment approvals in recent years. 
In the meantime, MNCs which have or plan to build up R&D centres or similar tech division in China, may need to assess the potential impact from the amended Catalogue, and consider structuring proper intellectual property arrangement to both satisfy the commercial needs of business operation and minimise compliance exposure in the changing regulatory environment.

(Source: Baker McKenzie, 10 Sep 2020)
* Principal Author: Terrence Gilroy, Esq., 1-212 626-4724, Baker McKenzie
On August 27, 2020 the Department of Commerce’s Bureau of Industry and Security (“BIS”) published a long-awaited advance notice of proposed rulemaking (“ANPRM”) seeking public comment on criteria for identifying “foundational technologies” that are essential to US national security with a view to imposing export controls on such uncontrolled technologies. BIS will use the public comments during the interagency process aimed at developing new export controls on foundational technologies. After the interagency process is finalized, BIS will issue a “rules and comment periods” for any such new export controls. 
This process is being undertaken pursuant to Section 1758 of the Export Control Reform Act of 2018 (“ECRA”), which mandates the establishment of a regular multi-agency process for identifying appropriate controls on emerging and foundational technologies that are “essential to the national security of the United States” and that are currently subject to very limited controls, or none at all, under other existing US export control regimes. BIS proposed a similar rulemaking process for “emerging technologies” in 2018, for more information on that process visit our prior blog post here.
BIS is accepting comments to the ANPRM by mail and via the Federal eRulemaking Portal until October 26, 2020. BIS strongly encourages companies to submit detailed comments to help shape appropriate controls for foundational technologies going forward.
Unlike the emerging technologies ANPRM, the foundational technologies ANPRM does not describe specific categories of technology, but notes that the term foundational technologies includes not only “technology” but also “commodities” and “software” as those terms are used in the Export Administration Regulations (“EAR”), and that BIS does not seek to expand jurisdiction over technologies that are not currently subject to the EAR, such as “fundamental research”. BIS did provide certain examples it may consider to be “foundational technologies,” as follows:
  • Items that are currently subject to control for military end use or military end user reasons under Supplement No. 2 to part 744 of the EAR, such as semiconductor manufacturing equipment and associated software tools, lasers, sensors, and underwater systems that can be tied to indigenous military innovation efforts in China, Russia or Venezuela.
  • Items that are currently classified as the AT level or as EAR99 but are being utilized or required for innovation in developing conventional weapons, enabling foreign intelligence collection activities, or weapons of mass destruction applications.
In order to assist BIS in this process, the ANPRM seeks public comment on:
  • How to further define foundational technology to assist in identification of such items;
  • Sources to identify such items;
  • Criteria to determine whether controlled items identified in AT level Export Control Classification Numbers (ECCNs), in whole or in part, or covered by EAR99 categories, for which a license is not required to countries subject to a U.S. arms embargo, are essential to U.S. national security;
  • The status of development of foundational technologies in the United States and other countries;
  • The impact specific foundational technology controls may have on the development of such technologies in the United States;
  • Examples of implementing controls based on end-use and/or end-user rather than, or in addition to, technology based controls;
  • Any enabling technologies, including tooling, testing, and certification equipment, that should be included within the scope of a foundational technology; and
  • Any other approaches to the issue of identifying foundational technologies important to US national security, including the stage of development or maturity level of a foundational technology that would warrant consideration for export control.

Companies should be cognizant that any confidential technical data they provide in their comments may not be kept confidential and could be published by BIS on the Federal eRulemaking Portal.  Baker McKenzie would be happy to assist interested companies in preparing and submitting public comments in response to this ANPRM. 


(Source: Ashleigh Foor, ashleigh@learnexportcompliance.com)
* What: Riding the Wave of Current and New Tariffs – Update on US Trade Remedies
* When: 24Sep; 1:00 p.m. (EDT)
* Where: Webinar
* Sponsor: Export Compliance Training Institute (ECTI)
* ECTI Speaker: Melissa Proctor
* Register: bit.ly/ECTIRidingTheWave / or Ashleigh Foor, 1-540-433-3977, ashleigh@learnexportcompliance.com.
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The ABC of Foreign

The ABC of Foreign Military Sales (FMS)
Tuesday, 29 September 2020
Designing and Implementing an ICP
Tuesday, 6 October 2020 More Info
Wednesday, 7 October
More Info
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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.]

Published every Friday or last publication day of the week. Send events to events@fullcirclecompliance.eu, composed in the below format:
# * Date: (Location;) “Event Title”; <Weblink>” Event Sponsor;

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EN_a115. Bartlett’s Unfamiliar Quotations

(Source: Editor)

* O. Henry (William Sydney Porter; 11 Sep 1862 – 5 Jun 1910; better known by his pen name O. Henry, was an American short story writer. His stories are known for their surprise endings.)
  – “Californians are a race of people; they are not merely inhabitants of a State.”
  – “She plucked from my lapel the invisible strand of lint (the universal act of woman to proclaim ownership).”
Friday Funnies
* An elderly man owned a farm with a large pond in the back. It was clean and large enough for swimming, so he fixed it up with a diving board, picnic tables, and some fruit trees.  One summer afternoon the old farmer decided to go down near the pond to collect some fruit in a five-gallon bucket he carried.  As he neared the pond, he heard splashing and girls laughing.  As he got closer, he saw cheerleader uniforms piled on the tables and about a dozen young women skinny-dipping in his pond.  He made them aware of his presence, and they all fled to the deep end up to their chins.  One of the girls shouted to him, “We’re not coming out until you leave!”  The old man frowned, and said, “Now hold on…  I surely don’t want you ladies to think I’m an uncouth sort of man who would come down here to peek at you swimming, or to make you get out of the pond naked.”  Holding up the bucket he said, “I’m just here to feed the alligator.”
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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 


5 Apr 2019: 84 FR 13499:

Civil Monetary Penalty Adjustments for Inflation. 
27 Aug 2020: 85 FR 52898Additions of Entities to the Entity List and Revisions of entries on the Entity List.

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.


29 Jul 2020: 85 FR 45513 Extension to Certain Temporary Suspensions, Modifications, and Exceptions due to Corona Virus.  The latest edition of the BITAR is 29 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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