20-1014 Wednesday “Daily Bugle”

20-1014 Wednesday “Daily Bugle”

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Wednesday, 14 October 2020

  1. Treasury/OFAC: “Blocking or Unblocking of Persons and Properties (I)”
  2. Treasury/OFAC: “Blocking or Unblocking of Persons and Properties (II)”
  1. Items Scheduled for Future Federal Register Edition
  2. Commerce/BIS: (No new postings)
  3. State/DDTC: (No new postings)
  4. Justice: “Justice Department Charges More than 14,200 Defendants with Firearms-Related Crimes in FY20”
  1. China.org: “Draft Law on Export Control Emphasizes National Security, Interests”
  2. Reuters: “Japan to Sign Agreement Allowing Arms Exports to Vietnam -Nikkei”
  1. Crowell: “Recent Changes in Chinese Export Controls: Are Your China Operations Ready?”
  2. Stroock: “New Rules Affect Mandatory CFIUS Filings and Export Controls”
  3. Thompson Hine: “Trump Administration Issues Additional Iranian Sanctions, Targeting Iranian Banks and Affecting Foreign Banking Transactions”
  1. ECS Presents: 16-17 Nov; “ITAR/EAR Controls for Non-U.S. Companies”
  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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(Source: Federal Register) [Excerpts]
85 FR 65138: Notice
* AGENCY:Office of Foreign Assets Control, Treasury.
* ACTION:Notice.
* SUMMARY:The U.S. 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 list of Specially Designated Nationals and Blocked Persons (SDN 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.
* DATES:See Supplementary Information section for applicable date (s).
[Editor’s Notes: Please see the Source URL for names added to the SDN list.]

 * * * * * * * * * * * * * * * * * * * *  

(Source: Federal Register) [Excerpts]
85 FR 65137: Notice
* AGENCY:Office of Foreign Assets Control, Treasury.
* ACTION:Notice.
* SUMMARY:The U.S. 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.
* DATES:See Supplementary Information section for applicable date(s).
[Editor’s Notes: Please see the Source URL for names added to the SDN list.]

 * * * * * * * * * * * * * * * * * * * *  


(Source: Federal Register)

* Defense Department; PROPOSED RULES; Federal Acquisition Regulation:Revision of Definition of “Commercial Item”; [Pub. Date: 15 Oct 2020]

 * * * * * * * * * * * * * * * * * * * *  

OGS_a24. Commerce/BIS: (No new postings)

 * * * * * * * * * * * * * * * * * * * *  

OGS_a35. State/DDTC: (No new postings)

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(Source: Justice, 13 Oct 2020) [Excerpts]
Today, the Justice Department announced it charged more than 14,200 defendants with firearms-related crimes during Fiscal Year (FY) 2020, despite the challenges of COVID-19 and its impact on the criminal justice process.
These cases have been a department priority since November 2019 when Attorney General William P. Barr announced his commitment to investigating, prosecuting, and combatting gun crimes as a critical part of the department’s anti-violent crime strategy.  These firearms-related charges are the result of the critical law enforcement partnership between U.S. Attorneys’ Offices and the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF), led by Acting Director Regina Lombardo, who has made firearms-related investigations a priority.
“The number one priority of government is to keep its citizens safe,” said Attorney General Barr.  “By preventing firearms from falling into the hands of individuals who are prohibited from having them, we can stop violent crime before it happens.  Violating federal firearms laws is a serious crime and offenders face serious consequences.  The Justice Department is committed to investigating and prosecuting individuals who illegally buy, sell, use, or possess firearms.  Reducing gun violence requires a coordinated effort, and we could not have charged more than 14,000 individuals with firearms-related crimes without the hard work of the dedicated law enforcement professionals at the ATF, our U.S. Attorneys’ Offices across the country, and especially all of our state and local law enforcement partners.”

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(Source: China.org, 14 Oct 2020) [Excerpts]
A draft law on export control was submitted to China’s top legislature for a third reading Tuesday.
The draft, which further emphasizes safeguarding national security and interests, will be discussed at the 22nd session of the Standing Committee of the 13th National People’s Congress, which runs until Saturday.
The draft clarifies that technical data related to the items covered by the law is also subject to export-control stipulations.
China will take countermeasures against countries and regions that abuse export-control measures and pose a threat to China’s national security and interests, according to the draft.
Export-control guidelines will be issued to guide exporters to establish and improve internal compliance systems and regulate operations, according to the draft.
The draft stipulates that those engaged in export-control violations will be investigated for criminal responsibility.

(Source: Reuters, 14 Oct 2020) [Excerpts]
Japan plans to sign an agreement with Vietnam to allow it to export defence equipment and technology to the country, part of a move to strengthen defence capabilities of Indo-Pacific nations to counter Chinese maritime advances. …
Japan ended a decades-old ban on overseas arms sales in 2014 to help beef up the nation’s military and lower the unit cost of home-built military equipment but has so far struggled to strike export deals for finished products.
Japan’s only export deal for a finished product has been one signed with the Philippines in August for the export of a warning and control radar system developed by Mitsubishi Electric, the Nikkei said.


(Source: Crowell, 13 Oct 2020)
* Principal Author: Evan Y. Chuck, Esq., 1-213-310-7999, Crowell
For the first time in nearly two decades, China is revamping its export control regime and issuing its first unified Export Control Law, which combines concepts from more than a dozen existing Chinese laws and related regulations. This alert summarizes the most significant changes from current Chinese export control practice, highlights what may be included in the pending Export Control Law, and comments on anticipated impact on businesses operating in China. We also provide some recommended approaches for companies with China operations (or rely on third parties in China) to consider in advance of implementation of the Export Control Law.
On August 28, 2020, China’s Ministry of Commerce (“MOFCOM“) and Ministry of Science and Technology released an Amendment to the Catalogue of Technologies Prohibited or Restricted from Export by China (“2020 Export Control Catalogue“).  The original catalogue was released along with the Regulations on the Administration of the Import and Export of Technology effective on January 1, 2002 (“Import and Export Regulations“, amended twice in 2011 and 2019).
In addition to the 2020 Export Control Catalogue, the Chinese government is also in the process of finalizing the draft of the Export Control Law. On December 28, 2019, the Standing Committee of the National People’s Congress (“NPC“) released the draft Export Control Law, a revised version of an earlier draft first published by MOFCOM on June 16, 2017. On July 3, 2020, the NPC published a further revised draft. With three rounds of draft being released, the Export Control Law will likely be finalized and published soon. This will be the first comprehensive national export control legislation in China, and China’s first step towards a unified export control regime.
What are the major changes under the 2020 Export Control Catalogue?
A total of 53 categories of technologies have been deleted, revised, or added to the 2020 Export Control Catalogue. Major changes include:
  • Removing 4 items from prohibited list, including 1) microbial fertilizer technology, 2) caffeine production technology, 3) riboflavin (VB2) production process, and 4) vitamin production.
  • Removing 5 items from restricted list, including 1) new city epidemic vaccine technology, 2) natural pharmaceutical production technology, 3) bioactive functional polymer material preparation and processing technologies, 4) chemical synthesis and semi-synthetic drug production technology, and 5) information security firewall software technology.
  • Adding 23 items to restricted list. Among others, several here captured attention, including “computer service” and “software industry”. For instance, technologies relating to AI are listed, including speech synthesis, voice recognition, interactive understanding technology, print scanning and identification, handwriting photographing and identification, and “personalized information push service technology based on data analysis”.

    These items, particularly the last one, could have potential impact for multinational clients seeking to leverage the Chinese consumer base. For example, e-commerce or app based business models that rely on data analytics could be covered by the restricted list. This might include international push marketing tools that use market intelligence from Chinese consumers to suggest products for purchase. Similarly, cloud or app-based tools that multinational companies use to analyze marketing and sales data as part of determining the right product mix to sell to Chinese companies could be impacted.

    In addition, technologies relating to cybersecurity, including cryptographic chips design, implementation technology, quantum cryptography technology have also been added and are now subject to restriction.

What is new under the upcoming China Export Control Law?
Based on the latest draft released on July 3, 2020, the highlights include:
  • Scope of controlled items

    This will cover tangible goods (such as dual-use items, military products, nuclear) and key related technologies and services.

  • Blacklist management system for national security purposes

    For the purpose of “national security interests”, this will include authorization to prohibit export of certain controlled items to any specific destination, country, region, or to any specific entities or individuals. This covers authorization on an ongoing basis to assess destinations, determine the level of risk, and what corresponding control measures are appropriate.

  • Internal Compliance Review System

    This will encourage exporters to establish an internal compliance review system, which once adopted can support the success of their license applications for controlled items.

  • Exporter’s social credit record

    China has imposed a “social credit” system on individuals that grades their contribution to Chinese society. It has extended this concept to companies operating in China across multiple Chinese government agencies. The social credit system helps the Chinese government determine how compliant any given company is to Chinese government regulation, perhaps in a more coordinated manner when compared to other governments. The Export Control Law establishes that companies operating in China will be examined and graded according it its level of compliance or “social credit record.” It authorizes reliance by the export control authorities on “relevant credit records of the exporter”.  A company’s rating can determine, among other things, the level and intensity of the need for government oversight and scrutiny. In this case, it is expected that the export control authorities will also consider the social credit records of the license applicant available in the Chinese social rating systems of other agencies, such as China Customs, foreign exchange, tax and market/competition.

  • Extraterritorial jurisdiction enforcement

    In cases that endanger national security and interests, this will authorize extraterritorial jurisdiction and enforcement. Additional guidance will be needed to answer critical strategic questions, such as how China intends to enforce activity in other countries, such as the United States or UK and EU.

What kinds of activities will be defined as technology export?
According to the Import and Export Regulations, the term “technology export” refers to the transfer of technology from China abroad, through trade, investment, or economic and technical cooperation, including patent assignment, transfer of patent application rights, patent licensing, transfer of trade secrets, technical services, and “other forms of technology transfer”.
The Import and Export Regulations define “technology export” broadly and indicate that the examples of technology export provided above are illustrative and are not meant to be exclusive. We note that the catch-all nature of the definition, (i.e., “other forms of technology transfer”) is vague and provides the Chinese authorities with broad discretion to determine if any given activity would be regulated. Theoretically, the catch-all definition could include disclosing and disseminating technical information to any individuals or organization in any form overseas. Furthermore, it is not clear currently how far China’s jurisdiction will reach. For example, it is not clear how the definition of “technology export” (and exceptions thereto) impacts transfers between and among non-China affiliates or subsidiaries. Similarly, the definition’s impact on the transfer of technology to non-Chinese individuals, whether in China or abroad remains subject to further clarification.
In similar situations, we generally encourage clients to seek additional guidance and determine the relevant Chinese authority’s posture on any given activity. For example, technology that is public, widely-known or of non-Chinese origin could fall under the catch-all definition. It would be prudent in such circumstances to seek input from the relevant Chinese authorities to determine if the Import and Export Regulations would apply.
What are the export control procedures for technology transfer?
Technology is classified into three categories under the draft Import and Export Regulations and each category is subject to different levels of scrutiny.
  • Permitted (free export) Technology

    Permitted technology is eligible for export, subject only to the exporter’s contract registration with the Foreign Economic and Trade Department of China’s State Council (“FETD“). After completing the registration, the exporter may proceed with relevant foreign exchange, banking, tax, and China Customs procedures to effectuate an underlying export transaction by presenting a technology export contract registration certificate issued by FETD. Such registration, however, is not a prerequisite for the exporter to enter into any underlying contract with a non-Chinese buyer.

  • Restricted Technology

    Restricted technology (pursuant to the existing 2020 Export Control Catalogue) cannot be exported before obtaining approval through an application to FETD in what is a two-part process. If the application is approved, the exporter will receive a letter of licensing intent for technology export contract (“LOI“). The exporter may not undertake substantive negotiation or enter into any technology export contract with any overseas party before receiving a LOI. Once a technology export contract has been signed, the exporter must submit an application for a Technology Export License. The technology export contract will become effective when FETD grants the corresponding Technology Export License.

  • Prohibited Technology
    Prohibited Technology (pursuant to the 2020 Export Control Catalogue) is strictly prohibited from export in any way. Violations are subject to warning, confiscation of illegal gains, monetary fines, revocation of foreign trade permit, and even criminal liability.
How should multinational corporations prepare for compliance with the new law?
Given the newly released 2020 Export Control Catalogue which is now in forceand the upcoming Export Control Law, our recommendations for companies with operations in China:
  • Closely monitor ongoing developments in the export control catalogue and implementation rules or industrial guidelines that might be released by the Chinese government;
  • Consider establishing an internal export control review program with an appropriate compliance officer;
  • In the event a company has an affiliate or subsidiary in China contemplating a technology export transaction
    • Establish or strengthen established risk assessment and identification processes for your current products and technology, and classify them into categories of permitted, restricted, and prohibited items;
    • Seek informal opinions or clarifications from Chinese export control authorities during the transaction planning process when any forms of technology transfer are involved;
    • Go through contract registration with FETD for permitted technology even though it is not a prerequisite for an underlying technology export contract to take effect, as the actual enforcement of export control measures might differ from the literal meaning of the law;
    • Provide export control training to employees and add export control related clauses to template export contracts, user terms, and other relevant legal documents as needed.

(Source: Stroock, 13 Oct 2020)
* Principal Author: Chris Griner, Esq., 1-202-739-2850, Stroock
 It has long been recognized that U.S. export regulations have failed to adequately define “emerging technologies” that can play a critical role in U.S. national security – technologies that can have a major impact on national security, but are in the early stages of development.  This month, the Commerce Department’s Bureau of Industry and Security (BIS) issued a final rule[FN/1] implementing new controls on six such “emerging technologies”[FN/2]
(1) hybrid additive manufacturing (AM)/computer numerically controlled (CNC) machine tools;
(2) computational lithography software designed for the fabrication of extreme ultraviolet (EUV) masks;
(3) technology for finishing wafers for 5nm (nanometer) production;
(4) digital forensics tools that circumvent authentication or authorization controls on a computer (or communications device) and extract raw data;
(5) software for monitoring and analysis of communications and metadata acquired from a telecommunications service provider via a handover interface; and
(6) and sub-orbital craft (designed to operate above the stratosphere and land on Earth without completing an orbit).
The BIS rule is now in effect.
The definition of “emerging technologies” has implications that extend beyond U.S. export controls.  “Emerging technologies” are also a concern for the Committee on Foreign Investment in the United States (CFIUS), the multi-agency committee that reviews the national security implications of foreign investments in U.S. businesses.  Investments deemed to present a potential threat to national security may be blocked – or may require restructuring to clear review. 
Notably, “emerging technologies”  are deemed “critical technologies” under CFIUS regulations[FN/3], and  foreign investments involving U.S. businesses that produce, design, test, manufacture, fabricate, or otherwise develop critical technologies are potentially subject to CFIUS jurisdiction, including the possibility of mandatory filing requirements.  
On October 15, a new CFIUS rule goes into effect that, among other things, changes the mandatory filing requirements for certain foreign investments in U.S. critical technologies.  Historically, as we discussed in a previous Stroock Client Alert[FN/4], certain transactions were subject to mandatory filing if the target U.S. business (1) produced, designed, tested, manufactured, fabricated, or developed one or more “critical technologies” and (2) was engaged in one of 27 designated industries identified by North American Industry Classification System (NAICS) codes.  
The new rule replaces the NAICS code industry test with one that is based on “U.S. regulatory authorizations.”[FN/5] Under the new rule, mandatory filing will depend upon whether U.S. regulatory authorizations would be required to “export, re-export, transfer (in country), or retransfer” the technology to certain persons acquiring, directly or indirectly, specified rights or ownership in the U.S. business.  The rule applies even if there is no intent for the U.S. business to make such exports. 
The new rule leaves in place several exemptions from mandatory filing requirements, including those for “excepted investors”[FN/6] and for certain transactions in which the foreign person’s interest is subject to mitigation arrangements pursuant to the National Industrial Security Program Operating Manual (NISPOM).  Notably, however, the  CFIUS rule does not adopt most of the license exceptions available under export control regulations.  Further, even if a transaction is not subject to a mandatory filing requirement, it may be subject to CFIUS’s voluntary filing jurisdiction.  Transactions that are not reviewed and cleared are subject to potential review in perpetuity.   Investments can and have been reviewed after closing, and can result in divestment orders.   
An accurate understanding of the export control classifications for the products and services of a target U.S. company is vital to transaction planning and regulatory compliance.  In all cases, export controls can have significant implications for the manufacture and marketing of technologies, for research and development, for staffing, and for related services – even if the technology never leaves the United States.   Unauthorized exports can carry civil and criminal penalties.  As part of due diligence, investors – foreign and domestic – should consider whether a potential target has properly classified its technology and has an appropriate export control policy in place.  In particular, if a transaction merits CFIUS review, all parties should be aware that CFIUS will pay close attention to how “critical” – and “emerging” — technologies are and will be protected – even when the acquisition involves investors from allied countries. 
[FN/1] Bureau of Industry and Security, Department of Commerce, Final Rule: “Implementation of Certain New Controls on Emerging Technologies Agreed at Wassenaar Arrangement 2019 Plenary,” 85 FR 62583 (Oct. 5, 2020), available at: https://www.federalregister.gov/documents/2020/10/05/2020-18334/implementation-of-certain-new-controls-on-emerging-technologies-agreed-at-wassenaar-arrangement-2019.
[FN/2] As controlled under section 1758 of the Export Control Reform Act of 2018 (50 U.S.C. 4817). See 31 C.F.R. § 800.215(f).
[FN/3] See 31 C.F.R. § 800.215(f).
[FN/4] Stroock Special Bulletin – “Proposed CFIUS Regulations May Shortcut Filing Requirements for Investors From Allied Countries,” May 27, 2020, available at: https://www.stroock.com/news-and-insights/proposed-cfius-regulations-may-shortcut-filing-requirements-for-investors-from-allied-countries.
[FN/5] U.S. regulatory authorizations include (a) licenses or other approvals issued by the Department of State under the ITAR; (b) licenses from the Department of Commerce under the Export Administration Regulations (EAR); (c) certain specific or general authorizations from the Department of Energy; or (d) certain specific licenses from the Nuclear Regulatory Commission.

(Source: Smart Trade, 13 Oct 2020)
* Principal Author: Scott E. Diamond, Esq., 1-202-263-4197, Thompson Hine
On October 8, 2020, the Departments of State and the Treasury announced sanctions on numerous Iranian financial institutions. The Department of the Treasury’s Office of Foreign Assets Control (OFAC) has sanctioned eighteen major Iranian banks. Secretary of the Treasury Steven Mnuchin stated that the sanctions “reflect our commitment to stop illicit access to U.S. dollars.” Secretary of State Mike Pompeo stated that the sanctions “further depriv[e] the Islamic Republic of Iran of funds to carry out its support for terrorist activities and nuclear extortion that threatens the world.” Both the State and Treasury Departments note that these new sanctions do not affect existing authorizations and exceptions for humanitarian exports to Iran.
These new sanctions, which essentially cover all remaining Iranian banks not previously sanctioned by OFAC, have been taken in order to deny the Iranian government financial resources that may be used to fund and support its nuclear program, missile development, terrorism and terrorist proxy networks, and malign regional influence. OFAC has designated and placed on the Specially Designated Nationals (SDN) List the following Iranian banks: (1) Amin Investment Bank, (2) Bank Keshavarzi Iran, (3) Bank Maskan, (4) Bank Refah Kargaran, (5) Bank-e Shahr, (6) Eghtesad Novin Bank, (7) Gharzolhasaneh Resalat Bank, (8) Hekmat Iranian Bank, (9) Iran Zamin Bank, (10) Karafarin Bank, (11) Khavarmianeh Bank (also known as Middle East Bank), (12) Mehr Iran Credit Union Bank, (13) Pasargad Bank, (14) Saman Bank, (15) Sarmayeh Bank, (16) Tosee Taavon Bank (also known as Cooperative Development Bank), (17) Tourism Bank, and (18) Islamic Regional Cooperation Bank (owned or controlled by Eghtesad Novin Bank).
OFAC has authorized U.S. persons to engage in transactions and activities involving these Iranian SDN financial institutions otherwise sanctioned and blocked under E.O. 13902 if such transactions are authorized, exempt, or otherwise not prohibited under the Iranian Transactions and Sanctions Regulations (ITSR). This includes activity permitted under specific licenses issued pursuant to the ITSR as well as activity permitted under the ITSR or general licenses, such as provision of medicine and medical devices, provision of agricultural products, humanitarian activity, certain journalistic activity and other permitted activity.
Non-U.S. persons may be subject to “secondary” sanctions if they engage in transactions involving financial institutions sanctioned under E.O. 13902. However, OFAC’s guidance and FAQs make clear that non-U.S. persons would not be subject to “secondary” sanctions for engaging in humanitarian or other activity permitted for U.S. persons under General License L or other provisions. In addition, OFAC is providing a 45-day period – until November 22, 2020 – for non-U.S. persons to wind down previously non-sanctionable activity with these newly designated Iranian banks.
OFAC has updated its Iran FAQs, providing further guidance on the scope of General License L, and outline the effects of these sanctions on both U.S. and non-U.S. persons, including secondary sanctions exposure. See FAQs 842843844845846, and 847.


EN_a112. ECS Presents: 16-17 Nov; “ITAR/EAR Controls for Non-U.S. Companies”

(Source: ECS)

*What: ITAR/EAR Controls for Non-U.S. Companies
*When: 16-17 Nov
*Where: Your Computer
*Sponsor: Export Compliance Solutions & Consulting (ECS)
*ECS Speakers: Suzanne Palmer, Marc Binder
*Register: Here or write to phyllis@exportcompliancesolutions.com or call 1-866-238-4018
* * * * * * * * * * * * * * * * * * * *


EN_a113. Bartlett’s Unfamiliar Quotations

(Source: Editor)

* e. e. cummings (Edward Estlin “E. E.” Cummings; 14 Oct 1894 – 3 Sep 1962; often styled as e e cummings, as he is attributed in many of his published works,[1] was an American poet, painter, essayist, author, and playwright. He wrote approximately 2,900 poems, two autobiographical novels, four plays, and several essays. He is often regarded as one of the most important American poets of the 20th century. Cummings is associated with modernist free-form poetry. Much of his work has idiosyncratic syntax and uses lower case spellings for poetic expression.)
  – “The most wasted of all days is one without laughter.”
  – “To destroy is always the first step in any creation.”
  – “Private property began the instant somebody had a mind of his own.”
* William Penn (14 Oct 1644 – 30 Jul 1718; was a founding founder of the United States.  As one of the earlier supporters of colonial unification, Penn wrote and urged for a union of all the English colonies in what was to become the United States of America.  The city of Philadelphia was planned and developed under his directions.)
  – “Time is what we want most, but what we use worst.” 
  – “Truth often suffers more by the heat of its defenders than the arguments of its opposers.
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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. 

9 Oct 2020: 
85 FR 64014:  Revisions to the Unverified List (UVL)

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.


28 Sep 2020: 85 FR 60874: Temporary Amendment for Republic of Cyprus. The latest edition of the BITAR is 28 Sep 2020. 

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