20-0204 Tuesday “Daily Bugle'”

20-0204 Tuesday “Daily Bugle”

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Tuesday, 4 February 2020

  1. Items Scheduled for Publication in Future Federal Register Editions 
  2. Commerce/BIS: (No new postings.) 
  3. DHS/CBP Publishes Guidance on Decrease in Section 301 Duties on Certain Products of China; $300B-Action -Tranche 4A 
  4. DoD/DCSA Publishes Policy Memo 20-03  
  5. State/DDTC Announces Launch of DEECS Platform on February 18th 
  6. Indian MoD Publishes Strategy for Export of Defence Products Under ‘Make In India’ Programme 
  1. STR: “Foreign Affiliate of US Company Penalized $26,250 for Anti-Boycott Violations ”  
  1. Kirkland & Ellis: “Insight: Economic Sanctions and Export Controls Update Q4 2019” 
  2. N. Turner: “Sanctions Top-5 for the Week Ending 31 January 2020” 
  3. Steptoe: “OFAC Removes Secondary Sanctions on COSCO Division Targeted for Iran Oil Imports” 
  4. A. Causin: “FIPS 140-2 Minimum Encryption Standard. Must Meet Requirements for Cyber Incident Reporting
  1. FD Associates Presents “The ITAR, The EAR, and the transition of USML I, II, and III to the EAR” Seminar, 11 Feb in Tysons Corner, VA 
  2. MITA Presents “Trade Compliance 2020: Trade Compliance Hits the Big Time” in Madison, WI 
  3. FCC Academy Presents “Designing & Implementing an ICP” 3 & 4 March in Amsterdam 
  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 and View all Job Openings 

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. Items Scheduled
for Publication in Future Federal Register Editions

(Source: Federal Register)

[No items of interest today.]

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. Commerce/BIS: (No new postings.)

(Source: Commerce/BIS)

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DHS/CBP Publishes Guidance on Decrease in Section 301 Duties on Some Products of China; Tranche 4A

(Source: DHS/CBP, 4 Feb 2020)
On August 20, 2019, the United States Trade Representative (USTR) published a Modification of Section 301 Action in 84 FR 43304 introducing another imposition of additional tariffs on products of China with an annual trade value of approximately $300 billion which is referred to as Tranche 4. The tariff subheadings subject to additional duties under Tranche 4 are separated into two lists with different effective dates – List 1, Trance 4A, covered by Annexes A and B, became effective September 1, 2019. The tariff subheadings subject to additional duties under list two (Tranche 4B) are addressed in Annexes C and D.
On January 22, 2020, USTR published in the Federal Register (85 FR 3714) the determination to modify the action being taken in the Section 301 Investigation for the additional duty rate to decrease from 15 percent to 7.5 percent for the products of China covered by the $300 billion tariff action Tranche 4/Annex A. Additionally, the assessment of additional duties on products of Annex C of the $300 billion section 301 trade remedy are suspended indefinitely per 84 FR 69447 (December 18, 2019).
Products Covered by Tranche 4, Annex A (Described in Annex B) –
duty decrease from 15 percent ad valorem to 7.5 percent, effective February 14, 2020
Per 85 FR 3714, the decrease in import duties for Chinese goods covered by the Tranche 4, Annex A list of products subject to the Section 301 action are effective with respect to goods entered, or withdrawn from warehouse for consumption, on or after 12:01 AM eastern daylight time on February 14, 2020.
Any article classified in a subheading covered by Annex A that is a product of China and that is entered, or withdrawn from warehouse for consumption, on or after February 14, 2020 is subject to the decreased Section 301 ad valorem duty rate of 7.5 percent, in addition to the general (Column 1) rate of duty for the imported merchandise. Therefore, in addition to any regular chapter reporting requirements, the following HTS number and duty rate must be reported:
HTS                     Duty Rate
9903.88.15           7.5 percent
Merchandise covered by Tranche 4A/Annex A that was admitted to a foreign trade zone under Privileged Foreign status will be subject to tariff classification at the rate of duty and tax in force on the date of filing the application for privileged foreign status. See 19 CFR 146.65(a)(1).
Immediate delivery procedures are not applicable.
For more information related to the decrease in duties imposed on the tariff subheadings for the products of China covered by the $300 billion tariff action Tranche 4, Annex A, refer to 85 FR 3714, issued January 22, 2020.
For questions on this and other trade remedy issues, please see Cargo Systems Messaging Service (CSMS) #40969690 – Information on Trade Remedy Questions and Resources.

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Publishes Policy Memo 20-03
, 2 Feb 2020)
DSCA Policy Memo 20-03, Calendar Year (CY) 2020 Transportation Costs Look Up Table Rates has been posted.
Memo provides the CY20 transportation costs to be applied to sensitive and hazardous end items that are shipped to Foreign Military Sales customers via the Defense Transportation System. These CY20 rates will be published as E-Change 465 to the Security Assistance Management Manual, Appendix 2, A2.2. DFAS-Indianapolis will update the Defense Integrated Financial System (DIFS) with the new rates effective 10 February 2020.
This memo adds CY2020 Transportation Rates to A2 – Transportation Cost Look-Up Tables.

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State/DDTC Announces Launch of DEECS Platform on February 18th

(Source: State/DDTC, 4 Feb 2020)
The Registration and Licensing applications will be released on the DECCS platform on February 18th.  Until that time, please continue to process requests as normal. More information will be posted here on how to get started with DECCS. 

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(Source: Indian MoD, 3 Feb 2020)

Various strategies have been firmed up and reforms introduced to enhance Defense exports. These measures are listed below:
(1) Special Chemicals, Organisms, Materials, Equipment and Technologies (SCOMET) Category 6 titled ” Munitions List” that was hitherto “Reserved” has been populated and Military Stores list notified vide Notification No.115(RE-2013)/2009-2014 dated 13th March 2015 stands rescinded.
(2) The Director General of Foreign Trade (DGFT) vide Public Notice No. 4/2015-20 dated 24th April, 2017, notified Department of Defense Production (DDP) as the Licensing Authority for export items in Category 6 of SCOMET. The export of items specified in Category 6 (Munitions List) except those covered under Notes 2 & 3 of Commodity Identification Note (CIN) of the SCOMET is now governed by the Standard Operating Procedure issued by the Department of Defense Production (DDP), Ministry of Defense.
(3) Standard Operating Procedure (SOP) for the export of munitions list items has been simplified and placed on the website of the DDP.
(4) A completely end-to-end online portal for receiving and processing authorization permission has been developed. The applications submitted on this portal are digitally signed and the authorization issued is also digitally signed.
(5) The Government has notified the Open General Export License (OGEL)- a onetime export license , which permits the industry to export specified items to specified destinations, enumerated in the OGEL, without seeking export authorization during the validity of the OGEL.
(6) Scheme for Promotion of Defense Exports has been notified to provide an opportunity to the prospective exporters an option to get their product certified by the Government and provides access to the testing infrastructure of Ministry of Defense for initial validation of the product and its subsequent field trials. The certificate can be produced by the prospective exporter for marketing their products suitably in the global market.
(7) A separate Cell has been formed in the Department of Defense Production to co-ordinate and follow up on export related action including enquiries received from various countries and facilitate private sector and public sector companies for export promotion.
(8) A Scheme to provide financial support to Defense Attaches for taking up actions for promoting exports of Indian made defense products both of public and private sector in the countries to which they are attached has been notified.

(9) Targets have been set for the Defense Public Sector Undertakings and OFB for export of Defense products. 

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STR: “Foreign Affiliate of US Company Penalized $26,250 for Anti-Boycott Violations”

The Bureau of Industry and Security reports that a foreign affiliate of a U.S. company has agreed to a $26,250 penalty to settle allegations that it violated the anti-boycott regulations. If this penalty is not paid within 30 days BIS may suspend the affiliate’s export privileges for one year.
A BIS order states that on two occasions, in connection with the sale and/or transfer of goods or services to Oman and the United Arab Emirates, the affiliate knowingly failed to delete, amend, or otherwise take exception to a prohibited boycott-related condition in letters of credit from applicant-customers in Oman and the UAE. In addition, the affiliate failed to report its receipt of a request to take an action that would further or support a restrictive trade practice or unsanctioned foreign boycott.


Kirkland & Ellis: “Insight: Economic Sanctions and Export Controls Update Q4 2019”
(Source: Kirkland & Ellis, 3 Feb 2020)
* Principal Author: Mario Mancuso, Esq., mario.mancuso@kirkland.com, 1-202-389-5070, Kirkland & Ellis LLP
The fourth quarter of 2019 included significant regulatory and policy developments related to economic sanctions and export controls. Kirkland & Ellis attorneys discuss these actions and what they may indicate about trends and takeaways in 2020.
The View From Washington: Key Takeaways
(1) Legislative and regulatory developments reflect a continued focus on China, in particular with regard to human rights abuses and the U.S. information and communications technology supply chain.
(2) The U.S. Department of Justice updated and clarified its policy regarding corporate voluntary self-disclosures for “willful” violations of sanctions and export controls.
(3) The U.S. Department of State Directorate of Defense Trade Controls (DDTC) issued a long-awaited rule regarding the treatment of export-controlled technical data stored in the cloud.
BIS Proposed Rules-Information and Communications
Technology and Services Supply Chain
On Nov. 27, the U.S. Department of Commerce Bureau of Industry and Security (BIS) published a proposed rule on securing the information and communications technology and services supply chain, pursuant to President Donald Trump’s May 15, 2019, corresponding executive order.
The proposed rule focuses on information and communications technology and services (ICTS) transactions “that pose an undue risk to critical infrastructure or the digital economy in the United States.” To address these risks, it proposes a review process that bears structural resemblance to the Committee on Foreign Investment in the United States (CFIUS) process.
The proposed rule subjects specific transactions initiated, ongoing, or finished after May 15, 2019, that involve persons or property subject to the jurisdiction of the United States, a contractual or other property interest of a foreign person, and ICTS developed by a “foreign adversary” to Commerce’s review on a transaction-by-transaction basis. Though no specific “foreign adversary” has been named, its focus is generally understood to be China or individually named Chinese companies.
China-Related Legislation
On Nov. 27, President Trump signed into law legislation including the Hong Kong Human Rights and Democracy Act of 2019 that, absent a presidential waiver, requires the president to impose sanctions on persons involved in human rights abuses in Hong Kong. The legislation also urges, though it does not require, that the Commerce Department take steps, including consideration of adjustments to U.S. export controls, “to prevent the supply of crowd control and surveillance equipment that could be used inappropriately in Hong Kong.”
On Dec. 3, the House of Representatives passed the UIGHUR Act of 2019. The bill calls for sanctions against “senior Chinese officials” responsible for the repression of Uighurs, as well as significant export controls restricting the flow to China of technology that can be used for human rights abuses, including items for use in
(1) facial, voice, and biometric recognition;
(2) monitoring of the internet and social media;
(3) surveillance and restriction of communications; and
(4) monitoring of individual location or movement.
It remains to be seen whether the bill will become law.
DOJ National Security Division Voluntary Self-Disclosure Policy
On Dec. 13, the DOJ’s National Security Division (NSD) Counterintelligence and Export Control Section announced an updated policy for companies to submit voluntary self-disclosures to the NSD of potentially willful export controls and sanctions violations (the VSD Policy).
The VSD Policy clarifies that, if a company voluntarily discloses, cooperates with the NSD, and timely and appropriately remediates the issue, then absent aggravating factors there will be a presumption of a non prosecution agreement without a fine.
If aggravating factors warrant a fine, the NSD will recommend a fine at least 50% lower than it would recommend absent a VSD. The VSD Policy likewise clarifies that a disclosure of willful conduct to other agencies (such as the Office of Foreign Assets Control, BIS, and DDTC) will not qualify for the benefits described therein, unless that conduct is also independently disclosed to the NSD.
Nord Stream 2 and TurkStream Sanctions
On Dec. 20, President Trump signed into law the National Defense Authorization Act for 2020 (the NDAA), which included sanctions concerning the Nord Stream 2 pipeline and the offshore section of the TurkStream pipeline. The NDAA authorizes sanctions on certain “vessels engaged in pipe-laying” for the pipelines. The sanctions also apply to any corporate officer or controlling shareholder who has knowingly “sold, leased, or provided those vessels,” or “facilitated deceptive or structured transactions” for the construction of these pipelines, as well as any foreign person who knowingly provides underwriting services, insurance, or reinsurance for such vessels.
The Trump administration has 60 days to identify sanctioned companies and individuals, who will then have 30 days to wind down operations. Though Nord Stream 2 is nearly completed, Allseas, a Swiss-Dutch company retained by Gazprom to lay pipe on the project, has announced that it is ceasing work on the project, which could cause delays.
DDTC ‘Cloud Computing’ Rule
On Dec. 26, DDTC issued a long-anticipated interim final rule which confirms that certain storage of unclassified technical data in the cloud is not subject to restrictions under the International Traffic in Arms Regulations. The rule, which builds upon a 2015 proposed rule and mirrors a similar rule implemented in 2016 under the Export Administration Regulations, confirms that “the electronic transmission and storage of properly secured unclassified technical data via foreign communications infrastructure does not constitute an export.”
The rule clarifies that the security criteria are satisfied if the data is secured using end-to-end encryption that meets National Institute for Standards and Technology certification standards for FIPS 140-2 compliance, or meets or exceeds the 128-bit security strength achieved by the Advanced Encryption Standard (known as AES-128).

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(Source: LinkedIn, 4 Feb 2020)  
* Principal Author: Nicholas Turner, Esq., nicholas.turner@cliffordchance.com, Clifford Chance LLP
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) lifted sanctions on COSCO Shipping Container (Dalian) Co. Ltd., several affiliates, and one individual, who were placed on the List of Specially Designated Nationals (SDNs) in September 2019 for engaging in significant transactions involving Iranian petroleum. A second COSCO subsidiary, affiliates, and executives remain sanctioned.  
(2) OFAC announced a USD 1,125,000 settlement with a Connecticut-based shipping company for violations of the defunct Burmese Sanctions Regulations. According to the settlement notice, the company engaged in shipments of sand from Myanmar to Singapore supplied by Myawaddy Trading Limited, at the time an SDN under OFAC’s Burma (Myanmar) sanctions program.
(3) The United States, Canada, and the European Union joined forces in sanctioning several recently elected government officials in Crimea. Additionally, OFAC named a private railway company and its CEO as SDNs pursuant to Executive Order 13685 for operating a new rail service across the Kerch Strait Bridge connecting Crimea to the Russian mainland. OFAC previously sanctioned entities involved in the construction of the bridge.
(4) The US State Department announced the designation of the Atomic Energy Organization of Iran (AEOI) and its head as SDNs under Executive Order 13382. Meanwhile, the State Department renewed secondary sanctions waivers for 60 days for Russian, Chinese, and EU companies working at several nuclear sites in Iran pursuant to the Joint Comprehensive Plan of Action (JCPOA).
(5) Medical patients in Iran have benefited from treatments paid for under the auspices of the US “humanitarian mechanism,” the US Treasury Department announced. The framework, introduced in October 2019, allows parties involved in certain Iran-related transactions to receive written confirmation that their activities are not subject to secondary sanctions. The medical payments, which were made through Switzerland, are the first to be approved under the mechanism.
What can we learn from OFAC’s latest settlement? For starters, don’t manipulate shipping documents. According to the settlement notice, the US company’s affiliate in Singapore was aware of Myawaddy Trading Limited’s involvement, but nonetheless accepted bogus documents listing a different Burmese counterparty. Next lesson: no means no. According to OFAC, the company continued to engage in exports involving the SDN after OFAC declined a specific license for it. (Specifically, a company executive “received OFAC’s denial letter, but allegedly failed to forward it to others.”)
The details of the case are more interesting than I have space for here. Long story short, the company was purchased by new owners, undertook a look-back and compliance remediation, and self-disclosed the violations to OFAC, significantly reducing its potential monetary penalty. (Full settlement here.)

Bonus item: The US Treasury Department published a page with information and links about US-government initiatives to combat human trafficking, including through sanctions and anti-money enforcement.

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Steptoe: “OFAC Removes Secondary Sanctions on COSCO Division Targeted for Iran Oil Imports”

(Source: Steptoe & Johnson LLP, 3 Feb 2020)
* Principal Author: Peter Jeydel, Esq., pjeydel@steptoe.com, 1-202-429-6291, Steptoe & Johnson LLP
On January 31, 2020, the US Treasury Department’s Office of Foreign Assets Control (OFAC) lifted sanctions on China-based COSCO Shipping Tanker (Dalian) Co., Ltd. (COSCO Dalian), five affiliates, and one individual who were named as Specially Designated Nationals (SDNs) in September 2019 for knowingly engaging in a significant transaction for the transport of oil from Iran. Despite last week’s reprieve, another COSCO subsidiary, COSCO Shipping Tanker (Dalian) Seaman and Ship Management Co., Ltd., as well as several affiliates and their executives, remain on the SDN List.
The September 2019 designations disrupted parts of the global shipping market, leading to a significant increase in some rates. OFAC’s announcement came several days before the scheduled expiration on February 4, 2020 of a general license authorizing US persons to engage in transactions for the maintenance or winding down of certain transactions with COSCO Dalian.
De-Listing Demystified?
OFAC has previously stated that it would consider removing persons from the SDN List under some circumstances because the “ultimate goal of sanctions is not to punish, but to bring about a positive change in behavior.” While there is little public guidance for companies hoping to be removed from the SDN List, OFAC advises that a sanctioned person (acting alone or with the assistance of counsel) “may submit arguments or evidence that the person believes establishes that insufficient basis exists for the designation.” Additionally, the person “may propose remedial steps on the person’s part, such as corporate reorganization, resignation of persons from positions in a blocked entity, or similar steps, which the person believes would negate the basis for designation.”
In the case of COSCO Dalian, the Chinese government may have sought de-listing as part of ongoing US trade negotiations. While diplomatic considerations may play a role in de-listing, the decision ultimately comes down to OFAC’s view of the facts underlying the SDN designation and, taking into consideration the views of other relevant agencies, whether the target’s commitments are sufficient to assuage US foreign policy or national security concerns. According to reports, US officials may have decided to continue sanctioning other COSCO affiliates to maintain leverage through secondary sanctions designed to discourage Iranian oil trading.
Persons who intend to file an application for de-listing must ensure that any disclosure made to the US government is not only accurate and complete, but typically must demonstrate one or more of the following:  
(1) the US government’s designation was based on incorrect factual information,  
(2) US policy has changed in a way that no longer warrants designation, or, most typically,  
(3) the target has changed its behavior in a way that is consistent with US policy objectives. The latter includes, among other things, ceasing any sanctionable activity. However, even a successful application for removal from the SDN List can take many months.

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A. Causin: “FIPS 140-2 Minimum Encryption Standard. Must Meet Requirements for Cyber Incident Reporting
(Source: Author)
* Author: Art Causin, Comtech Telecommunications Corp.,
The State Department amended the International Traffic in Arms Regulations (ITAR) on 26 January 2020 in an interim final rule which becomes effective on 25 March 2020, adopting the cloud computing encryption standards that the Commerce Department adopted in 2015.  This mean that contractors will soon be free to use cloud storage providers that meet the FIPS 140-2 minimum encryption standard – right?  Not so fast!
The new ITAR section 120.54,
Activities That Are Not Exports, Reexports, Retransfers, or Temporary Imports, provides that the properly secured (by end-to-end encryption) electronic transmission or storage of unclassified technical data via foreign communications infrastructure does not constitute an export, reexport, retransfer, or temporary import.   So, yes, the new regulation does harmonize the EAR & ITAR policies regarding encrypted data transfers and remote storage in the cloud. Unfortunately, that is only part of the story… 
Most ITAR related contracts impose directly, or pass down, DFAR clauses. The new ITAR section does not eliminate the provisions of DFARS § 252.204-7012 (Defense Federal Acquisition Regulations System, § 48 CFR 252.204-7012) 
“Safeguarding Covered Defense Information and Cyber Incident Reporting,” which require that cloud service providers must also meet the Federal Risk and Authorization Management Program (FEDRAMP) requirements, including requirements for cyber incident reporting.  
DFARS § 252.204-7012 (b)(2)(ii)(D) states: “If the Contractor intends to use an external cloud service provider to store, process, or transmit any
covered defense information in performance of this contract, the Contractor shall require and ensure that the cloud service provider meets security requirements equivalent to those established by the Government for the Federal Risk and Authorization Management Program (FedRAMP)
Moderate baseline and that the cloud service provider complies with requirements in paragraphs (c) through (g) of this clause for
cyber incident reporting,
malicious software,
media preservation and protection, access to additional information and equipment necessary for
forensic analysis, and
cyber incident damage assessment.

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FD Associates Presents “The ITAR, The EAR, and the transition of USML I, II, and III to the EAR” Seminar,
11 February
in Tysons Corner, VA

* When:  Tuesday, 11 Feb, 2020
* Where:  
The Tower Club
, 8000 Towers Crescent Dr Suite 1700, Vienna, VA 22182
* Sponsor:  
FD Associates
* Presenters: Jenny Hahn, President, FD Associates. Presenter will also be available for private counseling session after the workshop
* Register 
HERE, call 1-703-847-5801, or email info@fdassociates.net.

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TE_a213. MITA Presents “Trade Compliance 2020: Trade Compliance Hits the Big Time” in Madison, WI

(Source: Editor)
* What: Half-Day trade conference (Agenda)
* When: Next Tues, 11 Feb 2020
* Where: Fluno Center, 601 University Ave., Madison, Wisconsin
* Sponsor: Madison International Trade Association (MITA)
* Presenters: Keynote Julie Pojar, Manager of International Trade Compliance at Kohler Co., followed by a post-lunch trade compliance “speed-dating” sessions, and a series of afternoon of “deeper dive” roundtables featuring trade compliance experts from Harley-Davidson, Husch Blackwell, M.E. Dey, LR International, International Customs Services Inc., the UW-Madison Export Control Office, and Jim Bartlett, Full Circle Trade Law, Wash DC.

* Register HERE or email anagaric@rocketmail.com.

TE_a314. FCC Academy Presents “Designing & Implementing an ICP” 3 & 4 March in Amsterdam

* What:  Training Course on “How to Design and Implement an Internal Compliance Program (ICP) for Export Controls and Sanctions Agenda
* When:  Tuesday 3 March – Wednesday, 4 March 2020
* Where:  Park Plaza Victoria Hotel, Amsterdam, The Netherlands
* Sponsor:  Full Circle Compliance
* Presenters: Ghislaine Gillessen & Marco F. Crombach
* Register HERE


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The official versions of the following regulations are published annually in the U.S. Code of Federal Regulations (C.F.R.), but are updated as amended in the Federal Register.  The latest amendments are listed below.
Latest Update 
: 19 CFR, Ch. 1, Pts. 0-199.
5 Apr 2019:5 Apr 2019, 84 FR 13499-13513: Civil Monetary Penalty Adjustments for Inflation.


23 Jan 2020: 85 FR 4136-4188: Control of Firearms, Guns, Ammunition and Related Articles the President Determines No Longer Warrant Control Under the United States Munitions List (USML) 
DOC FOREIGN TRADE REGULATIONS (FTR): 15 CFR Part 30.   Last Amendment: 24 Apr 2018: 83 FR 17749-17751: Foreign Trade Regulations (FTR): Clarification on the Collection and Confidentiality of Kimberley Process Certificates


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.)  

23 Feb 2015: 80 FR 9359, comprehensive updating of regulations, updates the activities and technologies subject to specific authorization and DOE reporting requirements. 

25 Nov 2019: 84 FR 64740-64754: Rules of Practice in Explosives License and Permit Proceedings; Revisions Reflecting Changes Consistent With the Homeland Security Act of 2002
DOJ ATF ARMS IMPORT REGULATIONS: 27 CFR Part 447-Importation of Arms, Ammunition, and Implements of War.

14 Mar 2019: 84 FR 9239-9240: Bump-Stock-Type Devices.

DOS INTERNATIONAL TRAFFIC IN ARMS REGULATIONS (ITAR): 22 C.F.R. Ch. I, Subch. M, Pts. 120-130.  23 Jan 2020: 85 FR 3819:

Department of State final rule amending § 121.1, USML Categories I, II, and III, and numerous related sections (effective Mar. 9, 2020).
DOT FOREIGN ASSETS CONTROL REGULATIONS (OFAC FACR): 31 CFR, Parts 500-599, Embargoes, Sanctions, Executive Orders.
22 Nov 2019:

84 FR 64415-64417: Venezuela 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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