20-1021 Wednesday “Daily Bugle”

20-1021 Wednesday “Daily Bugle”

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Wednesday, 21 October 2020

(No items of interest posted) 

  1. Items Scheduled for Future Federal Register Edition
  2. Commerce/BIS: (No new postings)
  3. Commerce/Census: “Tips on How to Resolve AES Response Messages”
  4. State/DDTC: “You are Invited to the Virtual DTAG Plenary Meeting on October 22, 2020”
  5. EU External Action: “Non-Proliferation Treaty: Remarks by the High Representative/Vice-President Josep Borrell”
  1. EU Sanctions: “OFAC Reaches $4.1m Settlement with Berkshire Hathaway Inc”
  1. DLA Piper: “China’s New Export Control Law”
  2. Wiggin: “Foreign Financial Institutions Face U.S. Sanctions for ‘Significant’ Transactions with Sanctioned Hong Kong Officials”
  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 
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* Treasury/OFAC; NOTICES; Blocking or Unblocking of Persons and Properties; [Pub. Date: 22 Oct 2020] (PDF) (PDF) (PDF)

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OGS_a22. Commerce/BIS: (No new postings)

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OGS_a33. Commerce/Census: “Tips on How to Resolve AES Response Messages”
(Source: Commerce/Census, 20 Oct 2020)
When a shipment is filed to the AES, a system response message is generated and indicates whether the shipment has been accepted or rejected.  If the shipment is accepted, the AES filer receives an Internal Transaction Number (ITN) as confirmation.  Though the shipment is accepted, the filer may still receive a Verify Message, Compliance Alert, Informational Message or Warning Message along with their ITN.  However, if the shipment is rejected, a Fatal Error notification is received and must be corrected to receive a valid ITN. 
To help you take the appropriate action for the different AES Response Messages, here are some tips on how to address the most frequent messages that were generated in AES for this month.
Fatal Error Response Code:  147
Narrative: Routed Export Indicator Missing
Severity: Fatal
Reason: The Routed Export Indicator is missing.
Resolution: A routed export transaction is a transaction in which the Foreign Principal Party in Interest (FPPI) authorizes a U.S. agent to facilitate the export of items from the United States and to prepare and file Electronic Export Information (EEI).  You must report the Routed Export Indicator as Yes or No. 
Verify whether or not this is a routed export transaction, correct the shipment and resubmit.
Response Code:  171
Narrative: Transportation Reference Number Not Allowed for MOT
Severity: Fatal
Reason: The Transportation Reference Number is not allowed to be reported for the Mode of Transportation declared for this shipment.
Resolution:  A Transportation Reference Number identifying the carrier’s transportation instrument is required for vessel shipments and allowed for the other major modes of transportation (air, rail or truck). A Transportation Reference Number cannot be reported for a shipment using any other mode of transportation (i.e., mail, fixed or other). 
Verify the Mode of Transportation Code and Transportation Reference Number, correct the shipment and resubmit.   
For a complete list of Fatal Error Response Codes, their reasons, and resolutions, see Appendix A – Commodity Filing Response Messages.
It is important that AES filers correct Fatal Errors as soon as they are received in order to comply with the Foreign Trade Regulations. These errors must be corrected prior to export for shipments filed predeparture and as soon as possible for shipments filed postdeparture but not later than five calendar days after departure.
For more information or questions, contact the U.S. Census Bureau’s Trade Data Collection Branch.
Telephone: (800) 549-0595, select option 1 for AES

Blog: blogs.census.gov/globalreach

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  The Defense Trade Advisory Group (DTAG) will meet in open session from 1:00 p.m. to 5:00 pm EDT tomorrow, 22 October.  The membership of DTAG consists of private sector defense trade representatives appointed by the Assistant Secretary of State for Political-Military Affairs, who advise the Department on policies, regulations, and technical issues affecting defense trade.
  The following agenda topics will be discussed and final reports presented:  
   (1) Provide feedback to DDTC as DDTC works to consolidate exemptions into a single part of the ITAR.
   (2) Help develop a comprehensive compliance risk matrix to help prevent ITAR violations and diversions by various business functions involved in ITAR activities.
   (3) Suggest a draft (a) form or attachment that indicates when Part 130 information will be reported (e.g, annually, but in a separate filing, at the same time as the company’s registration), and (b) Part 130 (annual) report form.
  The meeting will be held in WebEx. There will be one WebEx invitation for each attendee, and only the attendee should use the invitation. In addition, each attendee should access the virtual meeting from a private location. Please let us know if you need any of the following accommodations: live captions, digital/text versions of webinar materials, or other (please specify).  
  Members of the public may attend this virtual session and will be permitted to submit written questions before the date of the meeting.  Members of the public may also submit a brief statement (less than three pages) to the committee in writing for inclusion in the public minutes of the meeting. Members of the public who wish to attend this session must provide name and contact information, including an email address and a phone number, and any request for reasonable accommodation to the DTAG Alternate Designated Federal Officer (ADFO), Neal Kringel, via email at DTAG@state.gov by COB today, October 21, 2020. (The 5 October deadline was waived.)
  FOR FURTHER INFORMATION CONTACT: Ms. Barbara Eisenbeiss, PM/DDTC, SA-1, 12th Floor, Directorate of Defense Trade Controls, Bureau of Political-Military Affairs, U.S. Department of State, Washington, DC 20522-0112; telephone (202) 663-2835 or email DTAG@state.gov.

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(Source: European Union External Action, 20 Oct 2020) [Excerpts]
We are all concerned about the deteriorating security environment as well as the continued pressure on the nuclear non-proliferation architecture, illustrated by the demise of the Intermediate-Range Nuclear Forces in Europe Treaty. We regretted it a lot when it happened and we continue regretting it now.
It is essential that all States Parties comply with their Non-Proliferation Treaty obligations and fully implement all commitments under the Treaty.
Upholding and preserving the Non-Proliferation Treaty must remain a key priority for the European Union’s foreign policy. The European Union strongly supports all three pillars of the Treaty – non-proliferation, nuclear disarmament and peaceful uses of nuclear energy – and will continue to promote comprehensive, balanced and full implementation of the 2010 Review Conference Action Plan.
Through intensive diplomatic engagement backed up by the [Common Foreign and Security Policy] (CFSP) funded Council Decisions we are promoting the ratification of the Comprehensive Test Ban Treaty and the preparations of negotiations for a Fissile Material Cut-off Treaty. We are also proud to support regional conferences in preparation for the Non-Proliferation Treaty Review Conference. 
We are going to redouble our efforts to uphold international norms, to restore dialogue and trust, and to promote transparency and confidence-building measures.
Together with Member States, we are preparing a strong and forward-looking common European Union position for the Non-Proliferation Treaty Review Conference. And I would like to stress some of the key elements of our position in the context of your Report. …

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(Source: EU Sanctions, 21 Oct 2020)
The U.S. OFAC has announced that Berkshire Hathaway, Inc, a Nebraska based multinational conglomerate holding company, has agreed to pay $4,144,651 (on behalf of itself and its Turkish subsidiary Iscar Kesici Takim Ticareti ve Imalati Limited Sirket) to settle civil liability for 144 violations of the Iranian Transactions and Sanctions Regulations (ITSR), which took place between 2012 and 2016.

Despite changes to the US Iran sanctions programme in 2012, Berkshire’s Turkish subsidiary sold cutting tools and related disposable inserts to two Turkish intermediary companies, in the knowledge that the goods would be supplied to an Iranian distributor for resale to Iranian end-users, including some meeting the definition of the “Government of Iran”.
OFAC determined that this was an egregious case involving intentional concealment by the subsidiary of its dealings with Iran over three years. Mitigating factors included the voluntary self-disclosure by Berkshire on behalf of its subsidiary, Berkshire’s substantial cooperation and remedial measures, comprised of replacing personnel complicit in the violations and enhancement of the compliance procedures for its foreign subsidiaries. OFAC Notice and web notice.


(Source: DLA Piper, 19 Oct 2020)
* Principal Author: Nathan Bush, Esq., 65-6512-6065, DLA Piper
On October 17, 2020, the Standing Committee of China’s National People’s Congress (NPC) passed the Export Control Law of the People’s Republic of China (the ECL), which will take effect on December 1, 2020.1 The ECL establishes China’s first comprehensive framework for restricting exports of military and dual-use products and technology for national security and public policy reasons. Through the ECL, exports and transfers of products, technology, and services may be prohibited or subject to licensing requirements based on the product features, end-users, destinations, or end-uses. While many administrative features resemble foreign export control practice, certain provisions -notably the ECL’s requirement that exporters seek licenses for export transactions not covered by published control lists that might potentially harm China’s national security or national interests, broad authorization to restrict exports to foreign companies deemed to threaten such harms, and an explicit authorization to retaliate against foreign abuses of export control rules -pose new risks and challenges for Chinese exporters and their customers.
Legislative Context
The ECL’s promulgation capped an accelerated legislative process amidst escalating tensions with the U.S. and other export markets. Before the ECL’s enactment, China’s export control rules were littered through the Foreign Trade Law, the Customs Law, the Criminal Law, and a montage of administrative regulations. As Chinese companies were increasingly penalized for violating foreign export controls or designated for export restrictions in recent years, the Chinese government accelerated the development of an integrated export control regime. Starting from a June 2017 draft prepared by the Ministry of Commerce, the NPC moved with a typical speed from initial publication of a draft law in December 2019 to the promulgation of the final law ten months later. Much as the September 2020 Provisions on the Unreliable Entity List established a counterpart to foreign economic sanctions regimes, the ECL upgrades China’s counterparts to foreign export control measures.
Modern export control policies necessarily involve complex technical issues, interfaces with multilateral conventions on weapons of mass destruction (WMD), and blunt foreign policy and security policy judgments. Crucial elements of Chinese export controls will likely be fleshed out through the drafting of new implementing measures and conforming revisions of existing regulations. Nevertheless, the final text of the ECL signals likely enforcement priorities and compliance risks.
Decentralized Administration
The ECL largely preserves China’s decentralized export control administrative structure. The “departments under the State Council and departments under the Central Military Commission that undertake the functions of export control” are collectively defined as “State Export Control Authorities” and charged with responsibility for export control activities “within their respective jurisdictions.” The ECL calls for the establishment of an “export control coordination mechanism,” and specifically calls for departments under the State Council (though not the Central Military Commission) to collaborate and share information. Other jurisdictions similarly charge different agencies with regulating exports within their core competencies, but this can result in overlapping licensing regimes and control lists based on different nomenclature and procedures.
Controlled Items
The ECL defines “controlled items” to include dual-use items (with both civilian and military applications), military products, and nuclear materials. In addition, “controlled items” include “other goods, technologies, services, etc., that are related to the maintenance of national security and interests and the implementation of international obligations such as non-proliferation.” The final text of the ECL broadened the coverage of “controlled items” from prior drafts.
 Throughout the ECL, references to “national security” in prior drafts were replaced with references to “national security and interests.” Distinguishing “national security” from “national interests” provides an explicit basis for export control measures designed to advance foreign policy or industrial policy goals unrelated to conventional defense and security risks.
 The final text extends the definition of “controlled items” to encompass “data such as technical documentation relating to the items.” Chinese media reports suggest that this amendment ensures that source code, algorithms, and similar data are clearly subject to export controls.
The ECL itself does not prescribe the format, nomenclature, methodology, or scope through which the various State Export Control Authorities might define the controlled items subject to export controls within their respective jurisdiction. Significantly, some of the most controversial aspects of U.S. export controls involve coverage rules, such as the “de minimis rule” and “foreign direct product rule” bringing certain products manufactured outside the U.S. with U.S.-origin components, equipment, or technology within the ambit of U.S. export controls and licensing requirements. It remains to be seen whether any State Export Control Authorities follow suit in defining controlled items.
Covered Transfers and Transactions
The ECL defines “export controls” as restrictions on “transfer of controlled items from the territory of the People’s Republic of China to overseas” and “the provision of controlled items by any citizen or incorporated or non-incorporated organization of the People’s Republic of China to any foreign organization or individual.” The ECL also applies to “the transit, transshipment, through transportation, or re-export of controlled items, or the export of controlled items from any bonded areas, export processing zones or other special customs supervision zones or export supervised warehouses, bonded logistics centers or other bonded supervision premises to overseas.” The ECL’s restrictions and licensing requirements may thus apply to a broad range of conduct and transactions. For example, the reference to “re-exports” may cover subsequent transfers of controlled items to third countries (and, potentially, to transfers within the same foreign country). Given the expansive definition of controlled items to include “technologies” and “data,” disclosures of controlled technology to third persons may also be treated as exports (similar to the U.S. concept of deemed exports).
Product Control Lists and Temporary Controls
The ECL authorizes a general framework for State Export Control Authorities to identify controlled items subject to export controls through published “control lists.” Control lists are to be updated periodically. In addition to general control lists, the ECL authorizes State Export Control Authorities to list items for “temporary controls” for a provisional period of up to two years before determining whether or not to list the items on a control list.
Duties of Exporters to Anticipate Risks from Unlisted Products
Significantly, the ECL obliges exporters to assess independently whether an export might sufficiently implicate national security or national interests so as to require a license, even if the product is not listed on any control list or temporary controls. An exporter must apply for an export license “if an exporter knows or ought to know or is notified by the State export control authorities that any relevant goods, technologies or services outside the control lists that are to be exported by it may pose” a risk of “endangering national security and interests” or use in connection with WMD or terrorist purposes. The ECL further directs the exporter to confer with the State Export Control Authorities if it cannot make this determination. Consequently, exporters bear responsibility for gauging whether a specific export transaction might warrant an export license, even if no published control lists expressly require one. As a practical matter, exporters face a contingent enforcement risk for any unlicensed exports from China later deemed inimical to Chinese national interests.
Licensing System
Exporters must apply for an export license from the relevant State Export Control Authority in order to export any item listed on a control list or subject to temporary controls. License applications are to be assessed based on: national security and interest; international obligations; the type of export; the sensitivity of the concerned controlled item; the country or region to which the export is to be made; the end-user and the end use; the exporter’s credit history; and any other factors to be prescribed by law or regulations.
End-user and End-use Certifications
In connection with the application, exporters are required to provide documentation establishing the intended end-use and end-user for the controlled items to be issued by the end-user or the government at the end-user’s destination. End-users are required to commit not to change the end-use or transfer the item to any third-party without authorization from the State Export Control Authorities. Exporters and importers are further obliged to report any potential change in the end-use or end-user. The ECL directs the State Export Control Authorities to develop risk management systems for monitoring end-users and end-uses of controlled items.
End-user Control List
In addition to the product-based control lists, the ECL directs State Export Control Authorities to establish control lists of importers and end-users determined to (i) violate end-user or end-use restrictions; (ii) “possibly endanger national security and interests,” or (iii) use controlled items for terrorist purposes. State Export Control Authorities are broadly authorized to prohibit, restrict, or suspend trade in controlled items or “adopt other measures as necessary” towards any exporter or end user on a control list. Exporters must apply for authorization to engage in otherwise-prohibited trade with designated entities.
Consequently, companies outside of China that are involved in activities deemed to jeopardize Chinese national interests (not limited to national security) may be vulnerable to export controls cutting off supplies from Chinese exporters. Notably, the final text of the ECL inserted language allowing importers or end users to seek removal from the entity control list, underscoring the potential restoration of export flows upon the termination of offending conduct.
The ECL provides that “any organization or individual outside the territory” of the PRC that “endangers the national security and interests” of the PRC or “obstructs the fulfillment of non-proliferation or other international obligations shall be dealt with and pursued for legal liability under the law.” While this provision implies the establishment of extraterritorial jurisdiction over offshore conduct violating the ECL, the literal language is not further defined in the ECL.
Facilitation of Export Control Violations
The ECL prohibits any organization or individual from knowingly providing agency, freight, shipping, customs clearance, third-party e-commerce trading platforms, financing, and other services to exporters engaged in export control violations. Violations by such third parties may be subject to fines from RMB 500,000 of up to five times the gains made from the illegal activities.
Investigative Powers & Penalties
When investigating suspected violations, State Export Control Authorities are empowered to inspect places of business; interview relevant persons; review and copy documents and materials; inspect means of transport used for export; seize or detain the items in question; and inquire into relevant bank accounts and similar issues. Investigative measures can be carried out against “the person under investigation,” not limited to a Chinese exporter. Requests for information may be addressed to “any stakeholders and other relevant organizations or individuals.” Consequently, a foreign end-user’s Chinese subsidiaries and personnel may become implicated in export control investigations. Penalties for exporters obstructing or resisting inspections or investigations may include fines, suspension of business, and revocation of export rights for the relevant controlled items.
Offenses & Penalties
Chapter IV of the ECL lists the elements and administrative penalties of various export-control offenses, including: unlicensed exportation of controlled items; unlicensed transactions with controlled end-users or importers; violations of export license terms; violations of export prohibitions; fraud, bribery, or forgery involving export licenses; and facilitation of export control violations. Depending on the nature of the offense, penalties may include fines of up to RMB 5 million or ten times the gains made from the illegal activities, business suspension, revocation of export business qualifications, and restrictions on the responsible individuals’ future involvement in export activities. Where administrative violations of ECL also constitute crimes, criminal penalties may also apply.
Reciprocity or Retaliation
New language appended at the end of the promulgated text warns that if “any country or region abuses export control measures and endangers the national security and interests” of the PRC, then the PRC “may reciprocally take measures based on the actual situation.” Beyond the unveiled threat to foreign governments, this article might also be construed as authorizing the State Export Control Authorities to devise and deploy targeted export restrictions in response to specific foreign export control measures.

Chinese exporters and their foreign customers should assess their compliance and potential exposure under the ECL, adopt measures for monitoring compliance, and periodically update their risk assessments as product lines, supply chains, and distribution chains develop-and as China’s export control policies evolve.

(Source: Wiggin, 20 Oct 2020)
* Principal Author: Tahlia Townsend, Esq., 1-202-800-2473, Wiggin
On October 14, 2020, pursuant to Section 5(a) of the Hong Kong Autonomy Act (“HKAA”)[FN/1], the State Department issued a report to Congress (“the Report or Section 5(a) Report”) identifying ten Hong Kong officials deemed responsible for materially contributing to the erosion of the democratic freedoms and autonomy of Hong Kong.  The U.S. Department of Treasury, Office of Foreign Assets Control (“OFAC”) imposed sanctions on all the individuals identified by the State Department back in August,[FN/2] so the Report did not create any new U.S. sanctions targets. However, the Report effectively imposed a November 13 deadline for foreign financial institutions (“FFI”) to terminate all “significant” transactions involving these officials, or face mandatory U.S. sanctions.  Importantly, the term foreign financial institution is broadly defined to include not only banks, but also insurance companies, brokers or dealers in securities or commodities, investment companies, dealers in precious metals, stones, or jewels, travel agencies, businesses engaged in sales of cars, airplanes, boats, and other vehicles, persons involved in real estate closings and settlements, and others.[FN/3] 
Detail: Under the HKAA, not less than 30 days and not more than 60 days following the Section 5(a) Report (i.e., between November 13 and December 13), the Secretary of State must:
  • submit a second report to Congress identifying FFI that knowingly conduct “significant” transactions with persons identified in the Report;
  • within one year, impose on those FFI five sanctions from a menu ranging from prohibiting foreign exchange transactions, to prohibiting all transactions with U.S. financial institutions, to prohibiting exports to the FFI, to full-blown asset-blocking sanctions on the FFI and/or its principal executive officers; and
  • impose additional sanctions from the menu if the FFI appears in consecutive reports (as a result of continuing to perform transactions with targets of the Hong Kong sanctions). 
In a series of Frequently Asked Questions (“FAQ”) published the same day as the Report, OFAC provided the following key pieces of guidance:
  • OFAC will not count as “significant” any transaction that constitutes “good-faith wind down” of business with a named individual within 30 days of the Report, or any transaction for which a U.S. person would not require a specific license from OFAC (i.e., transactions that are exempt from regulation (such a personal communications) or for which OFAC has issued a general license (none at the time of publication)). See FAQ 848, 850.
  • In determining whether a transaction is “significant,” OFAC will consider “the totality of the facts and circumstances, including: (i) the size, number, and frequency of the transaction(s); (ii) the nature of the transaction(s); (iii) the level of awareness of management and whether the transaction(s) are part of a pattern of conduct; (iv) the nexus between the transaction(s) and the sanctioned party; (v) the impact of the transaction(s) on statutory objectives, including whether the transaction(s) (a) have a significant and lasting negative effect that contravenes the obligations of China under the Joint Declaration and the Basic Law, (b) are likely to be repeated in the future, and (c) have been reversed or otherwise mitigated through positive countermeasures taken by that FFI; (vi) whether the transaction(s) involve deceptive practices; and (vii) such other factors as the Secretary of the Treasury deems relevant.  See FAQ 850.
  • Before imposing sanctions, the Treasury Department will contact the FFI to inquire about its transactions with the sanctioned party.  See FAQ 848. FFI’s may be able to avoid sanctions if the transaction(s): (a) do not have a significant and lasting negative effect that contravenes the obligations of China under the Joint Declaration and the Basic Law; (b) is not likely to be repeated in the future; and (c) has been reversed or otherwise mitigated through positive countermeasures taken by the FFI.
To the extent they have not already done so, FFIs should carefully evaluate whether they have relationships with the individuals identified in the Report and take steps to mitigate their sanctions risk, including an assessment of whether likely transactions with the individuals would be deemed “significant” under the factors described above, and termination of such transactions no later than November 13, 2020.
FFIs should also bear in mind that Executive Order 13936 authorizes imposition of sanctions at any time on additional parties participating in the suppression of democratic freedoms in Hong Kong, and the HKAA requires the State Department to provide annual updates identifying such parties.  Accordingly, relationships that do not currently expose FFIs to the risk of sanctions may present risk in the future.
[FN/1]H.R.7440 – Hong Kong Autonomy Act
[FN/2]“Treasury Sanctions Individuals for Undermining Hong Kong’s Autonomy”, August 7, 2020, https://home.treasury.gov/news/press-releases/sm1088
[FN/3]See HKAA Section 2, defining “financial institution” by reference to 31 U.S. Code 5312.


EN_a19. Bartlett’s Unfamiliar Quotations

(Source: Editor)

* Samuel Taylor Coleridge (21 Oct 1772 – 25 Jul 1834; was an English poet, literary critic, philosopher and theologian who, with his friend William Wordsworth, was a founder of the Romantic Movement in England and a member of the Lake Poets.)
  – “Advice is like snow – the softer it falls, the longer it dwells upon, and the deeper it sinks into the mind.”
* Alfred Nobel (Alfred Bernhard Nobel; 21 Oct 1833 – 10 Dec 1896; was a Swedish chemist, engineer, inventor, businessman, and philanthropist. He held 355 different patents, dynamite being the most famous. The synthetic element nobelium was named after him. Having read a premature obituary which condemned him for profiting from the sales of arms, he bequeathed his fortune to institute the Nobel Peace Prize.)
  – “The truthful man is usually a liar.”
  – “If I have a thousand ideas and only one turns out to be good, I am satisfied.”
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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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