20-1103 Tuesday “Daily Bugle”

20-1103 Tuesday “Daily Bugle”

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Tuesday, 3 November 2020

  1. Treasury/OFAC: “Notice of OFAC Sanctions Actions”
  1. Items Scheduled for Future Federal Register Edition
  2. Commerce/BIS: (No new postings)
  3. Justice: “Chinese National Pleads Guilty To Attempting To Illegally Export Maritime Raiding Craft And Engines To China”
  4. State/DDTC: (No new postings)
  5. UK OFSI Publishes Statutory Guidances About Nicaragua, Bosnia and Herzegovina and Lebanon
  1. Cadwalader Cabinet: “OFAC Updates General License Authorizing Certain Transactions with Iran-Related Entities”
  2. EUS: “Germany Amends Dual-use & Military Export List”
  3. FT: “China Gears up to Fight Back in Tech War Over Chips”
  4. GIR: “Huawei Launches FOIA Suit Against US Agencies in Blockbuster Sanctions Case”
  1. Husch Blackwell: “October 2020 Trade Law Update”
  2. Nicholas Turner: “Sanctions Top-5 for the Week Ending 30 Oct”
  3. Wiley: “ATF Interpretive Change Restricts Handgun Imports and May Require NFA Registration”
  1. ECTI Presents 17 Dec; ITAR Compliance for US Persons Working Outside the United States: What You Need to Know Webinar
  2. FCC Academy Presents: 1 and 3 Dec; “U.S. Export Controls: ITAR/EAR” and “FMS”
  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, 3 Nov 2020) [Excerpts]
85 FR 69684: 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 entity and
aircraft 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 this person and these aircraft
are blocked, and U.S. persons are generally prohibited from engaging in
transactions with them.
* FOR FURTHER INFORMATION CONTACT: OFAC: Associate Director for Global
Targeting, tel.: 202-622-2420; Assistant Director for Sanctions
Compliance & Evaluation, tel.: 202-622-2490; Assistant Director for
Licensing, tel.: 202-622-2480; or Assistant Director for Regulatory
Affairs, tel.: 202-622-4855.

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OGS_a23. Commerce/BIS: (No new postings)

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(Source: Justice, 2 Nov 2020)
  Ge Songtao (50, Nanjing, People’s Republic of China) has pleaded guilty to conspiring to submit false export information through the federal government’s Automated Export System and to fraudulently export to China maritime raiding craft and engines, and attempting to fraudulently export that equipment in violation of U.S. law. Ge Songtao faces a maximum penalty of 15 years in federal prison. A sentencing date has not yet been set.
  According to the plea agreement, Ge Songtao was the chairman of Shanghai Breeze Technology Co. Ltd., a company headquartered in Shanghai, China. Beginning in 2018, he was interested in identifying a source of supply of U.S.-manufactured combat rubber raiding craft equipped with engines that can operate using gasoline, diesel fuel, or jet fuel. These vessels and multi-fuel engines are used by the U.S. military and can be operated after being launched from a submerged submarine or dropped into the ocean by an aircraft. No comparable engine is manufactured in China.
  One of Ge Songtao’s U.S.-based employees, co-defendant Yang Yang, attempted to order seven of the raiding craft equipped with these engines from a U.S. manufacturer. When the U.S. manufacturer suggested that Yang Yang purchase cheaper gasoline-fueled engines, she insisted that she wanted to purchase the military-model multi-fuel engines. To induce the manufacturer to sell this equipment, Yang falsely represented that her customer was an entity called United Vision Limited in Hong Kong, rather than Shanghai Breeze Technology Co. in Shanghai. One of Yang’s Chinese co-workers had told her that American manufacturers would be more likely to sell to an entity in Hong Kong rather than one in mainland China. By misrepresenting what company was buying the equipment, and where it was located, Yang caused the entry of false information in the Department of Commerce’s Automated Export System in violation of federal law.
  On September 15, 2020, Yang Yang pleaded guilty to the same two charges to which Ge Songtao has pleaded guilty. On August 13, 2020, co-defendant Zheng Yan pleaded guilty to conspiring to submit false export information and to fraudulently export the raiding craft and engines in violation of U.S. law. The trial of remaining co-defendant Fan Yang, is scheduled to begin on February 1, 2021.

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* Guidance on the Nicaragua (Sanctions) (EU Exit) Regulations 2020, which comes into force from 11pm on 31 December 2020.
* Guidance on the Bosnia and Herzegovina (Sanctions) (EU Exit) Regulations 2020, which comes into force from 11pm on 31 December 2020.
* Guidance on the Lebanon (Sanctions) (Assassination of Rafiq Hariri and others) (EU Exit) Regulations 2020, which comes into force from 11pm on 31 December 2020.
  This guidances assist people in implementing and complying with the Sanctions (EU Exit) Regulations 2020. They cover the prohibitions and requirements imposed by the regulations. They also provide guidance on best practice for:
  • Complying with the prohibitions and requirements
  • Enforcing them
  • Circumstances where they do not apply
  These guidances should be read alongside more detailed sanctions guidance published by the Office of Financial Sanctions Implementation (OFSI).

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(Source: Findknowdo, 27 Oct 2020) [Excerpts]

  OFAC updated a general license permitting transactions relating to humanitarian trade to cover certain dealings with the National Iranian Oil Company (“NIOC”). The General License also includes any entity in which NIOC owns at a 50 percent or greater interest.
  In General License 8A (“GL 8A”), OFAC authorized certain transactions involving NIOC that otherwise would be prohibited under the Global Terrorism Sanctions Regulations (or “GTSR”) and the Iranian Transactions and Sanctions Regulations(or “ITSR”). Previously, the General License covered only transactions with the Central Bank of Iran (“CBI”).
  OFAC specified that the exportation or reexportation of goods to NIOC or CBI remains prohibited.
  Additionally, OFAC amended six related FAQs to address the changes made by GL 8A and updated its Specially Designated Nationals and Blocked Persons List (or “SDN List”) to include new Iran-related individuals, entities and vessels.

  Germany’s Federal Ministry for Economic Affairs and Energy has issued the 16th regulation amending the Foreign Trade Ordinance, which updates its dual-use and military export list. The amendments came into effect on 29 October 2020.
New additions to the list include:

  • Certain small firearms and components relating to hunting and sports;
  • Software specially designed or modified for the conduct of military offensive cyber operations;
  • Certain land vehicles featuring specific military equipment;
  • Certain equipment relating to radiation weapons systems; and
  • Items required for environmental testing facilities in which weapons, ammunitions and armaments are evaluated.

(Source: Financial Times, 3 Nov 2020) [Excerpts]

For years, China’s race with the US for global tech supremacy has been a boon for its chip industry. Rapid advances in artificial intelligence, a growing domestic consumer technology market, supercomputer programmes and a rapid military build-up have all fuelled demand for semiconductors. This has intensified an urgency to make more of the chips domestically. Over the past decade, Beijing poured more than $100bn in subsidies into enterprises such as Shanghai-based Semiconductor Manufacturing International Corporation. 

As a result, SMIC and its peers built new fabrication capacity faster than chipmakers anywhere else in the world, and their revenues ballooned to Rmb756bn last year, up from Rmb144bn 10 years ago. But now, as the US-China tech race has become a tech war, China needs its semiconductor companies to fight. The question is: can they win? Jolted into action by a proliferating web of US sanctions against companies such as telecom equipment maker Huawei and SMIC, Beijing issued a rallying cry last week: the nation must “make technological self-sufficiency the strategic backbone of national development”. By 2025, the government has decreed, the country should make 70 per cent of its semiconductors domestically, up from barely a third today. That might have been achievable if Washington had stopped at Huawei. 

The latest US moves against the technology group block any shipments of chips made with US technology to Huawei or any other party for the Chinese company’s products without a special export licence. While that is a blow to Huawei and threatens the survival of its subsidiary HiSilicon, China’s largest chip design company, it did not affect the rest of the country’s chip sector.   

But that changed when the US told its semiconductor equipment companies last month that their supplies to SMIC were now also subject to export controls. 

That means Washington can put the brakes on expansion by China’s largest contract chip manufacturer. The machines used to etch the surface of silicon wafers, apply microscopic layers of chemicals to them, or clean and test the chips remain a technology frontier. And US companies hold a commanding share in segments of this market. 
China has its own stable of budding chip equipment makers, but they accounted for only 8 per cent of the $11.4bn China’s chipmakers invested in equipment last year. Analysts at brokerage Jefferies believe that aggressive expansion plans for fabrication capacity in China “provide a significant opportunity” for Naura, AMEC and ACMR, the largest Chinese equipment makers. Jefferies estimates that Chinese chipmakers are set to spend about $100bn on machinery between 2021 and 2026. The problem is that none of them are quite there yet. Despite China’s push towards localisation, the chip manufacturers supported by Beijing’s cash tap such as SMIC preferred to use equipment from global market leaders including Applied Materials, Lam Research and KLA-Tencor of the US, Dutch equipment maker ASML or Tokyo Electron of Japan. “Each time Chinese equipment makers received a piece of the subsidiary pie, they made some breakthrough, declared victory and then stopped,” said an executive at a foreign supplier to SMIC. That could change now. Companies, government officials and research institutes are hatching plans to build “de-Americanised” fabrication plants.
  But any such project would have to run on machinery cobbled together from different vendors because no single Chinese company can offer equipment for the whole chip manufacturing process. For some particularly sophisticated segments, it would have to buy gear from ASML and Tokyo Electron or even find used US equipment. According to Douglas Fuller, an expert in the Chinese chip industry at City University of Hong Kong, a private industry study involving US equipment makers explored options for circumventing Washington’s export controls. One possibility discussed was creating a production line at SMIC, equipped with machinery from American companies but made outside the US. 
Any such move could trigger US government steps to close loopholes. On the other hand, Beijing could respond to resistance by Chinese chipmakers to buy local by making subsidies for new chip plants conditional on the use of local equipment. Either way, backed by the world’s largest market, China’s chip companies have more than a fighting chance. But they are in for a long, messy battle.

  Huawei has launched a lawsuit against several US government departments for failing to turn over material that the Chinese phone parts manufacturer says could prove charges against it and its CFO are politically motivated.  …


* Principal Author: Nithya Nagarajan, Esq., 1-202-378-2409, Husch Blackwell
In Husch Blackwell’s October 2020 Trade Law Newsletter, you’ll learn about the following updates in international trade and supply chain law:
  • U.S. and Brazil updated Agreement on Trade and Economic Cooperation (ATEC) to increase transparency and combat corruption
  • The WTO ruled that the EU can impose up to $4 billion in tariffs on U.S. imports
  • The ITC found that glass containers from China do not injure U.S. industry, a major victory for importers of glass container products from China
  • An update on U.S. Department of Commerce decisions
  • U.S. International Trade Commission – Section 701/731 proceedings
  • An update from U.S. Customs & Border Protection
  • Summary of decisions from the Court of International Trade
  • Updates from the Court of Appeals for the Federal Circuit
  • October export controls and sanctions
Read the full update here.

(Source: Medium, 3 Nov Sep 2020)

* Author: Nicholas Turner, Esq., 852-5998-7559, Steptoe & Johnson HK 
  Here are five things that happened this week in the world of economic sanctions that I think you should know about.
  1. The US Office of Foreign Assets Control (OFAC) named eight entities in China, Hong Kong, and Singapore as Specially Designated Nationals(SDNs) under Executive Order 13846 for their involvement in sales of Iranian petrochemical products. According to a Treasury Department news release, the entities are linked to Hong Kong-based Triliance Petrochemical Co. Ltd., which OFAC sanctioned in January 2020. In September 2020, OFAC sanctioned 11 Triliance-linked entities in Iran, China, Hong Kong, and the United Arab Emirates.
  2. In related news, the US State Department named five entities and five individuals in Iran, China, and Singapore as SDNs under Executive Order 13846 for Iran-related petroleum transactions. Meanwhile, the US Department of Justice announced the filing of a forfeiture complaintagainst a shipment of Iranian missiles seized en route to Yemen in August 2020 and the sale of 1.1 million barrels of Iranian gasoil seized from four vessels en route to Venezuela in July 2020.
  3. In yet more Iran sanctions news, OFAC and the State Department designated eight individuals, 11 entities, and two vessels as Specially Designated Global Terrorists(SDGT) under Executive Order 13224 for petroleum transactions linked to Iran’s Islamic Revolutionary Guard Corps (IRGC). At the same time, OFAC issued an updated General License 8A  and updated six Frequently Asked Questions (FAQs) on humanitarian transactions involving SDGTs.
  4. OFAC issued amendments to three general licenses under the Cuban Assets Control Regulations (CACR) to prohibit persons subject to US jurisdiction from engaging in licensed remittance transactions that involve entities on the US State Department’s List of Restricted Entities and Subentities Associated with Cuba. The new rule is effective from 26 November 2020.
  5. A spokesperson for the PRC Foreign Ministry announced that China would impose unspecified sanctions on several big-name US defense contractors for planned sales of defensive weapons to Taiwan pursuant to the US Taiwan Relations Act of 1979. (With the recently adopted PRC Export Control Law and Provisions for the Unreliable Entity List, these announcements could come with “specified sanctions” someday.)
  It’s Tuesday morning here in Hong Kong. Election-day polls in the United States will open in about 12 hours. By tomorrow in Asia, we could know the outcome of the presidential and most congressional races (or maybe not). I started writing the Sanctions Top-5 in 2017 as an outlet for thinking about sanctions under the then-new Trump presidency. Thank you to everyone who has read, commented, and contributed over the past three-and-a-half years. It’s been fun!
  What will this year’s elections mean for US sanctions? If the past four years have shown us anything, it’s that elections matter bigly when it comes to sanctions policy. There have been massive shifts on Iran, Cuba, Venezuela, China, Hong Kong, human rights, and technology export controls, to name just a few areas.
  Bonus item: OFAC issued an advisory on the risks associated with high-value artwork owned by SDNs. While art can be exempted from some OFAC regulations as an “informational material,” the advisory clarifies that the exemption would not apply “to the extent the artwork functions primarily as an investment asset or medium of exchange.” Ceci n’est pas un blocked asset! Or is it?

(Source: Wiley, 23 Oct 2020)

*Principal Author: Mike Faucette, Esq., 202-719-4587, Wiley Rein LLP 
  The Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) has recently changed the manner in which it interprets the statutory and regulatory definition of “handgun,” thereby further limiting the types of firearms eligible for importation. These determinations are not public, so it is difficult for the regulated community to assess and track shifting agency positions.
  The Gun Control Act at 18 U.S.C. § 922(l) broadly prohibits the importation of all firearms into the United States. However, so long as a firearm is not military surplus nor subject to the National Firearms Act, section 925(d)(3) provides a limited exception for those firearms considered by ATF to be “generally recognized as particularly suitable for or readily adaptable to sporting purposes.” Over the past half century, ATF has issued several studies and criteria on how it evaluates whether shotguns, rifles, or handguns qualify as “sporting” under the law. The handgun factoring test is the most straightforward of these, with a point tally system that rewards larger and bulkier handguns. If a handgun receives 75 or more points, it is considered “sporting” and approved for importation. However, there is no ATF-issued “sporting purpose” test for a firearm that fails to fit within the definition of handgun, rifle, or shotgun. Accordingly, ATF has long held that such a firearm is not importable.
  Despite ATF previously stating that there is no limit to how long or heavy a handgun should be to qualify as “sporting” under section 925(d)(3), ATF private classification letters issued within the past few months indicate that the agency has shifted course by reinterpreting what constitutes a “handgun.” In company-specific letters, ATF takes the position that if a submitted firearm is too long or too heavy, it fails to meet the definition of “handgun” under the Gun Control Act, as it is not “designed to be held and fired by the use of a single hand.” The Firearms and Ammunition Technology Division (FATD) of ATF-which conducts importability evaluations-says that it is taking a subjective approach to the statute by allowing individual examiners to determine if he or she can fire the weapon with one hand without difficulty.
  This approach is resulting in inconsistent determinations, of which the regulated community should take note. Within the past few months, at least one HK91 pistol-style submission as light as 8 pounds, with a barrel length of 8-3/4 inches and an overall length of 21-3/4 inches, has been determined to fall outside the definition of “handgun.” This is a change from previous determinations where firearms weighing over 8 pounds, with 20-inch barrels, and an overall length of approximately 31-1/2 inches were held by FATD to be “handguns.” Since the letters are not publicly available, it is impossible for regulated companies to know the full range of FATD’s determinations. This has serious implications for regulated businesses.
  In some of the new letters, ATF has begun listing the following “objective design features” when making its evaluations: 
  • Incorporation of rifle sights;
  • Utilization of “rifle caliber ammunition” (both 5.56mm and 7.62mm have been considered as such);
  • Incorporation of “rifle-length barrel;”
  • The “weapon’s heavy weight;”
  • Ability to accept magazines that range in capacity from 20 rounds to 100 rounds, “which will contribute to the overall weight of the firearm”; and
  • Overall length of the weapon which “creates a front-heavy imbalance when held in one hand.” 
  However, ATF also noted in the most recent private ruling that the above design features are “neither binding on future classifications nor is any factor individually determinative[.]” ATF explained without elaboration that “the statutory and regulatory definitions provide the appropriate standard in classifying the firearm.” ATF concluded that “a firearm that is too large, too heavy or . . . otherwise not designed to be held and fired in one hand (as demonstrated by the objective features) cannot be a handgun under the statutory definition and cannot be subject to importation criteria governing handguns.” In light of ATF’s subjective and inconsistent analysis of size and weight, it is difficult to predict how the agency will classify any given firearm under this standard.
Revocation of Existing Import Permits
  ATF acknowledged in one letter this month that certain firearms previously approved for importation and determined to be handguns “may wrongly have been approved for importation” and that “[s]uch firearms may require reevaluation.” Beyond that, ATF has not acknowledged a change in policy. Instead, it argued that “consideration of the objective design features of a firearm to determine the designed and/or intended use is clearly not a change in policy.” Although “ATF has not developed a definitive list of features that determine whether an item is a ‘pistol’ or ‘handgun[,]'” the non-public letters leave importers to consult the above-mentioned list to assess whether their existing import permits may be revoked or whether new applications will be denied.
Consideration of Certain Handguns as Any Other Weapons (AOW)
  The new interpretation of the handgun definition could have additional significant effects on manufacturers and gun owners.
  Under the National Firearms Act, a firearm that has an overall length of less than 26 inches and is neither a pistol, rifle nor shotgun is classified as an “Any Other Weapon” (AOW). This means that if a firearm under 26 inches in overall length is determined not to be a pistol, rifle, or shotgun, it would necessarily be classified as an AOW. AOWs require the payment of a tax and registration with the federal government.
  Under ATF’s new reading of the definition, firearms previously classified as large-sized handguns by ATF may now require registration under the National Firearms Act as an AOW.Possession of such a firearm without registration is punishable by up to ten years in prison. Since ATF has not articulated a standard, it is difficult to definitively know whether a large handgun is now an AOW because it may be deemed by the agency to be “too large, or too heavy” to fit within the statutory definition of handgun. The only definitive way to know is to submit the firearm to ATF for evaluation, a process that can take over a year.
Interim Final Rule on Improper Agency Guidance
  ATF reportedly believes that its new analysis is the only way to conduct evaluations in light of the Department of Justice’s (DOJ) Interim Final Rule on Improper Agency Guidance (IFR)-a procedural rule designed to increase regulatory transparency. That position appears to run contrary to the purpose of the IFR and so far, the agency has not put it in writing. Further, one ATF private letter from this month attempts to shield itself from DOJ’s IFR by indicating that the letter is “not a final classification of the firearm and is not final agency action.” It goes on to say, “if you submit an ATF Form 6 for the importation of the subject firearm, ATF will take appropriate action.” It appears that ATF is saying that the letter is not final agency action until a Form 6 is formally rejected. But given that this firearm was already evaluated pursuant to an ATF Form 6 application, it is unclear what additional steps are available to make this letter final agency action.
  Under ATF’s new interpretation of the handgun definition, millions of AR-15 style pistols could be considered “too large, or too heavy” to fall within ATF’s new interpretation, thereby making them unregistered NFA weapons, and subjecting manufacturers and gun owners to criminal prosecution. Given the private nature of ATF’s classification rulings, and the subjective nature of the analysis, it is extremely difficult to know for sure whether specific firearms fall within the new interpretation. This appears to be part of a continuing trend at ATF to apply firearms statutes in a more restrictive manner without informing the public-a trend that appears unaffected by the IFR. In this uncertain regulatory environment, importers and manufacturers should consult counsel before making significant purchasing, importing, or manufacturing decisions for firearms that could be implicated by ATF’s heretofore unknown and undisclosed analysis.


* What: ITAR Compliance for US Persons Working Outside the United States: What You Need to Know
* When: 17 Dec; 1:00 p.m. (EST)
* Where: Webinar
* Sponsor: Export Compliance Training Institute (ECTI)
* ECTI Speaker: Susan Kovarovics and Megan Barnhill
* Register: here or Ashleigh Foor, 1-540-433-3977, ashleigh@learnexportcompliance.com.
Back to top

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U.S. Export Controls: ITAR & EAR from a non-U.S. Perspective (Tuesday, 1 Dec 2020)
Register or find more information here

The ABC of Foreign Military Sales (FMS) (Thursday, 3 Dec 2020)
Register or find more information here
* Register for both and take advantage of our discounted price!
 * * * * * * * * * * * * * * * * * * * *


EN_a116. Bartlett’s Unfamiliar Quotations

(Source: Editor)

* William Cullen Bryant (3 Nov 1794 – 12 Jun 1878; was an American romantic poet, journalist, and long-time editor of the New York Evening Post.)
  – “Loveliest of lovely things are they on earth that soonest pass away. The rose that lives its little hour is prized beyond the sculptured flower.”
* Andre Malraux (Georges André Malraux; 3 Nov 1901 – 23 Nov 1976; was a French novelist, art theorist, and Minister of Cultural Affairs. Malraux’s novel La Condition Humaine (Man’s Fate) (1933) won the Prix Goncourt.)
  – “Man is not what he thinks he is, he is what he hides.”
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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
Amendment of Cuban Assets Control 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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