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20-0205 Wednesday “Daily Bugle”

20-0205 Wednesday “Daily Bugle”

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Wednesday, 5 February 2020

  1. Items Scheduled for Publication in Future Federal Register Editions 
  2. Commerce/BIS: (No new postings.) 
  3. DoD/DCSA Publishes Policy Memo 19-14 
  4. State/DDTC: (No new items.)
  1. Evening Standard: “Metro Bank in Probe Over Iran and Cuba Sanctions Breaches”
  2. FAS: “US Stands By the Chemical Weapons Convention”
  1. Baker McKenzie: “Canada’s International Agreements with the European Union and UK Post-Brexit”
  2. Sidley: “Defeating Economic Sanctions in the EU: A Strategic Analysis of Litigation Options”
  3. Steptoe: “Client Advisory: The Asia Pacific Top Ten FCPA Enforcement Actions of 2019”
  1. ECTI Presents “United States Export Controls (ITAR/EAR/OFAC) Seminar Series” in Washington, DC: March 2-5, 2020 
  2. 19th Annual ‘Partnering for ComplianceTM’ Export/Import Control Conference” on 10-12 Mar in Orlando
  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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EXIMITEMS FROM TODAY’S FEDERAL REGISTER

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OGSOTHER GOVERNMENT SOURCES

OGS_a11
. Items Scheduled
for Publication in Future Federal Register Editions

(Source: Federal Register)

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OGS_a22
. Commerce/BIS: (No new postings.)

(Source: Commerce/BIS)

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OGS_a33
.
DoD/DCSA Publishes Policy Memo 19-14
(Source: 
DoD/DCSA
, 5 Feb 2020)
 
 
This memorandum updates Enhanced End-Use Monitoring (EEUM) procedures described in Chapter 8 of the Security Assistance Management Manual (SAMM). Currently, there is no way to identify or track EEUM defense articles considered “Case-Unique.” Enhanced Case-Unique articles are items not generally treated as EEUM but are designated as EEUM for specific Foreign Military Sales (FMS) exports.
 
This memo revises:
 
C8.4.1. Definition.
C8.4.2.1. Determining the MASL EUM code.
C8.4.2.2. Developing LOA physical security and accountability EEUM Note.
C8.4.2.3. Publishing physical security and accountability EEUM notes for inclusion on the LOA.
C8.4.2.4. Developing and validating EEUM checklists.
Table C8.T2.
Figure C8.F1.
Figure C8.F2. Designating Enhanced Case Unique Defense Articles Process Flow

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COMNEWS

NWS_a15.
FAS: “US Stands By the Chemical Weapons Convention”

(Source: Federation of American Scientists, 4 Feb 2020)
 
While the Trump Administration has retreated from negotiated arms control agreements in many areas ranging from nuclear weapons to anti-personnel landmines, the US is still committed to the Chemical Weapons Convention (CWC), which generally prohibits the production and use of chemical weapons.
Last week the State Department certified to Congress – as a required condition of continued US participation in the CWC – that the consortium of CWC member countries known as the Australia Group “remains a viable mechanism for limiting the spread of chemical and biological weapons-related materials and technology.” . . .
  
 

NWS_a26.
Evening Standard: “Metro Bank in Probe Over Iran and Cuba Sanctions Breaches”

(Source: Evening Standard, 4 Feb 2020) 

 

Metro Bank is undergoing a major review of its compliance controls after handling money from Cuba and Iran in breach of strict US and EU sanctions.
 
The review is being handled by a top-level team of investigators at law firm DLA Piper, which was hired after the Iranian funds were received by the bank last year.
Metro notified US officials of the Cuba offence in November 2017.
 
It is the latest in a series of problems for the bank which spent much of last year reeling from the impact of a major error in the way it accounted for its property loans.
 
Both its founder chairman Vernon Hill and chief executive Craig Donaldson quit amid the ensuing fallout.
Metro admitted to the sanctions breaches in a 200-page fundraising prospectus in September but gave no further details beyond a brief, four-sentence paragraph on page 32. . . .  

COMCOMMENTARY

COM_a17. 
Baker McKenzie: “Canada’s International Agreements with the European Union and UK Post-Brexit”

(Source: Baker McKenzie, 3 Feb 2020)
 
* Principal Author: International Trade Compliance Blog, ITCUpdate@bakerxchange.com, Baker McKenzie
 

On February 1, 2020, the Canada Gazette published a notice from Global Affairs Canada that states that agreements concluded by Canada with the European Union, with Member States acting on behalf of the European Union, and with the European Union and its Member States acting jointly shall continue to apply to the United Kingdom for the duration of the transition period following its departure from the European Union. If there is any change to this situation, further communications will be published through the Canada Gazette. 

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(Source: Sidley Austin LLP, 4 Feb 2020) [Excerpts]

* Principal Author: Arnoud R. Willems, Esq., awillems@sidley.com, 32-2-504-6409, Sidley Austin LLP
 
Sanctions are part of the UN toolbox to secure international peace and security. States are also increasingly relying on sanctions to pursue foreign policy objectives. It is noteworthy that both the UN and the EU have been gradually shifting from sanctions against states to sanctions targeting specific individuals and entities.  
 
However, targeted sanctions follow highly politicized procedures with little transparency; the criteria on which targeted sanctions are based risk either not being provided, or being too broadly and ambiguously phrased. This article reviews the mechanisms available to targeted individuals and entities to challenge the legality of sanctions. It starts with the experience that has matured before the EU courts to assess the current state of affairs and the limits this litigation may encounter. It then identifies alternative strategies to litigate sanctions, including by raising new claims based on criminal practice and using different legal fora such as the ICJ. …
 

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* Principal Author: Wendy Wysong, Esq., wwysong@steptoe.com, 852-2158-8441, Steptoe & Johnson LLP
 
Of the record-breaking USD 2.9 billion in fines imposed by US authorities in 2019 for violations of the Foreign Corrupt Practices Act (FCPA), almost 95% involved Asia Pacific, primarily China and India, but also Indonesia, Vietnam, Thailand, and South Korea.
 
This year, the US Department of Justice (DOJ) and the Securities & Exchange Commission (SEC) had cases against well-known multinational corporations operating in the region, and continued their emphasis on individual accountability, announcing prosecutive actions against 35 individuals in 2019, [FN/1] including several former Alstom executives for bribery in Indonesia; former Goldman Sachs executives in connection with Malaysian sovereign wealth fund (1MDB); and the former president, CEO, and Chief Legal officer of Cognizant accused of paying bribes in India.
 
Here is a roundup of the top-ten FCPA enforcement actions in Asia Pacific.
 
(1) Telefonaktiebolaget LM Ericsson (Ericsson)
 
In the largest FCPA settlement to date, Ericsson, a Sweden-based telecommunications company, agreed in December to pay penalties totaling more than USD 1 billion to the SEC and DOJ to resolve allegations of FCPA violations in 16 countries, including China, Indonesia, and Vietnam. The company entered into a deferred prosecution agreement (DPA) with DOJ, consented to an injunction with the SEC, and agreed to a three-year compliance monitor. Its Egyptian subsidiary pled guilty to FCPA conspiracy charges.
 
Ericsson admitted that it operated a scheme that spanned five countries and 17 years. In China, it made payments to agents, consultants, and other service providers to fund gifts, travel, and entertainment for state-owned telecommunication company officials to win their business. In Vietnam and Indonesia, Ericsson’s local subsidiary paid a consulting company to create off-the-books slush funds, using code names and creating sham transactions and invoices.
 
Takeaway
: According to DOJ, Ericsson did not receive full credit for cooperation and remediation because of the seriousness and scope of the misconduct, its failure to disclose allegations of corruption, to produce certain materials in a timely manner, and to adequately discipline employees as part of its remediation.
 
(2) Fresenius Medical Care AG (FMC)
 
In March, FMC, a German-based company that provides dialysis equipment and services, agreed to pay more than USD 231 million in penalties, disgorgement, and prejudgment interest, pursuant to an SEC cease and desist order and a non-prosecution agreement (NPA) with DOJ, which also required a two-year monitorship. FMC admitted that it paid bribes for years in 17 countries, including China.
 
Takeaway
: DOJ found that FMC did not qualify for a declination under the Corporate Enforcement Policy (CEP), although it submitted a voluntary self-disclosure (VSD) because of the breadth of the bribery and because the company “did not timely respond to certain requests by the [DOJ] and, at times, did not provide fulsome responses to requests for information.”
 
(3) Microsoft
 
Another example of a well-known multinational company running into the FCPA buzzsaw was Microsoft’s July 2019 settlement with DOJ and the SEC for a total of USD 25.3 million to resolve alleged bribery in four countries, including Thailand. Microsoft Corp. resolved its liability with the SEC, paying disgorgement and prejudgment interest, for actions of its overseas subsidiaries. The SEC found that Microsoft’s subsidiary in Thailand funded technology equipment and travel to government officials through slush funds maintained by third party vendors and resellers.
 
While Microsoft did not receive credit for a VSD, it did get credit from both the SEC and DOJ for its full cooperation and remedial measures.
 
Takeaway
: A reminder that incorporation of financial data of a foreign subsidiary into the parent corporation’s books and records is sufficient to trigger the books and records provision in the FCPA.
 
(4) Samsung Heavy Industries
 
In November 2019, Samsung, a South Korean engineering company, agreed to enter into a DPA with DOJ to pay penalties of more than USD 75 million, half of which would be paid to Brazilian authorities, for FCPA violations by its US subsidiary uncovered as part of the larger investigation of Petrobras, a state-owned entity. Samsung Heavy Industries admitted that its subsidiary paid commission payments to an intermediary knowing that some would be used for bribes to encourage Petrobras to enter into a contract to charter a drill ship Samsung was selling to a US company.
 
Takeaway
: DOJ asserted its jurisdiction against a South Korean company that bribed officials in Brazil, based on the involvement of the company’s US branch office.
 
(5) Lawrence Hoskins
On November 8, 2019, a jury convicted UK citizen Lawrence Hoskins, a former Alstom executive, on bribery and money-laundering in Indonesia. The conviction was based on DOJ’s proof that Hoskins, who had never stepped foot in the United States, had acted as an agent for a “domestic concern,” Alstom’s US subsidiary. Two other Alstom executives, whose guilty pleas were announced in 2019, testified in the Hoskins trial.
 
Takeaway
: The US Court of Appeals for the Second Circuit had narrowed the jurisdictional bases for liability for non-US persons in 2018, ruling against DOJ’s expansive reading of the FCPA to include conspiracy. Despite that appellate setback, DOJ will use Hoskins’ conviction to pursue non-US defendants as agents, where they would not otherwise be covered by the FCPA.
 
(6) Cognizant Technology Solutions
 
Cognizant resolved allegations of bribes paid through a contractor to Indian government officials for building permits in February. The resolution involved an SEC cease and desist order with a civil fine of USD six million, as well as disgorgement and prejudgment interest of USD 19 million. DOJ issued a “declination with disgorgement” letter, requiring an additional USD three million disgorgement of profits (outside the SEC’s statute of limitations), based on its VSD, cooperation, and remediation. DOJ and the SEC also charged the CEO and Chief Legal Officer for their approval of the bribery. The COO separately settled charges with the SEC in September 2019, paying a USD 50,000 penalty and agreeing to cooperate.
 
Takeaway
: DOJ declined prosecution, despite the involvement of senior management, an aggravating factor according to the CEP, which could have negated the mitigative benefits of the VSD.
 
(7) Other DOJ Declinations
 
Misonix (in June and August) and PAR Technology (in May) announced in their SEC filings that DOJ and SEC had concluded their investigations and decided not to bring charges. Both companies voluntarily disclosed the violations, fully cooperated, and undertook remedial measures. Misonix had disclosed misconduct by a distributor of the company’s products in China. PAR disclosed it had made payments to customs officials in China and other actions in Singapore that lacked proper documentation.
 
Three other companies received declinations from DOJ but were penalized by the SEC.
 
In August, Juniper Networks, a California-based tech company, entered into an SEC cease and desist order and agreed to pay a USD 11.7 million civil penalty. Two of Juniper’s Chinese subsidiaries allegedly paid for government officials’ travel, obtaining approval based on false trip agendas.
In September, Quad/Graphics, a Wisconsin marketing company, paid almost USD 10 million to the SEC, to resolve allegations that its Chinese subsidiary used sham sales agents to make improper payments to government officials. The company had voluntarily disclosed, cooperated, and remediated.
Also, in September, Westport Fuel Systems, a Canadian fuel technology company, and its former CEO resolved charges of bribery of a public official in China by paying USD four million and USD 120,000 respectively to the SEC. The company had allegedly transferred shares of stock to a Chinese private equity fund in which the government official held an interest.
 
Takeaway
: Timely self-disclosure, full cooperation with authorities, and swift and appropriate remedial measures are factors that can increase the likelihood of receiving a DOJ declination.
 
(8) Individual Accountability
 
In addition to Cognizant’s C-suite and Westport’s CEO, other individuals were held accountable for bribery in Asia, including:
 
a) Patrick Ho: In March, Hong Kong’s former Home Secretary, Ching Ping Patrick Ho, was sentenced after conviction in 2018 to three years and ordered to pay a USD 400,000 criminal fine for attempting to pay USD two million in bribes to the president of Chad for oil rights as well as providing other gifts and future proceeds to officials in Uganda for business advantages on behalf of a Chinese energy company.
 
b) 1 MDB: In May, Malaysian national Ng Chong Hwa, also known as “Roger Ng,” a former Goldman Sachs banker, was extradited from Malaysia to the United States to face charges of conspiracy to launder money embezzled in the 1 Malaysia Development Berhad (1MDB) conspiracy to violate the FCPA. In December, Tim Leissner, the former chairman of Goldman Sachs in Southeast Asia, agreed with the SEC to disgorge USD 43.7 million (offset by DOJ’s forfeiture order entered pursuant to his 2018 guilty plea) and accept a permanent ban from the securities industry.
 
c) Ng Lap Seng: In August, the US Court of Appeals for the Second Circuit confirmed Ng’s conviction relating to bribery of UN officials for support of a construction project in Macau. The court’s ruling clarified that a prohibited quid pro quo under the FCPA’s anti-bribery provisions is broader than the “official acts” that must be proved under the domestic anti-bribery statute.
 
d) Jeffrey Shiu Chow: The former lawyer at Keppel Offshore & Marine, a Singaporean shipyard company, was sentenced in November to time served and probation, after he cooperated in the FCPA prosecution of Keppel. Chow admitted he had knowingly approved contracts to overpay an agent that he knew was making bribe payments to a state-owned energy fund.
 
e) Yanliang Li and Hongwei Yang: The former executives of a China subsidiary of a multi-level marketing company were charged with conspiracy to violate the FCPA in November by paying bribes to Chinese officials to obtain licenses, influence government investigation, and suppress negative media reports. Li also was charged by the SEC.
 
(9) Tourism Authority of Thailand
 
In January, DOJ dismissed an indictment against the former governor of Thailand’s tourism authority, Juthamas Siriwan, and her daughter. The duo was charged in 2009 with laundering bribes they had received from Gerald and Patricia Green, film producers who sought Thai film festival contracts. For ten years, the Siriwans had fought extradition because the FCPA does not extend to bribe recipients, a limitation DOJ had attempted to overcome by charging money laundering. The US court considering the propriety of those charges stayed the Siriwans’ motion to dismiss, while Thailand decided to prosecute the two, who were convicted and sentenced to 50 and 44 years. The Greens had been sentenced to six months following their FCPA convictions.
 
Takeaway
: While DOJ did not obtain judicial approval in this early attempt to address demand-side bribery, the agency has increasingly asserted money laundering charges against foreign officials not otherwise subject to the FCPA, in addition to tax violations, mail and wire fraud, and other ancillary offenses. Similar FCPA-adjacent indictments were prevalent in 2019, and bribe recipients should expect further scrutiny in the future.
 
(10) Princelings
 
After five years of investigations, two banks resolved charges related to their hiring of relatives of public officials in China. Deutsche Bank paid USD 16 million to the SEC in August for allegedly employing relatives at the request of executives of state-owned enterprises, with whom the bank was seeking business. In September, Barclays paid USD 6.3 million to the SEC related to allegations of hiring their clients’ relatives by its Asia Pacific subsidiaries.
 
Takeaway
: While hiring relatives of government officials is not prohibited, precautions should be taken to ensure their qualification, supervision, and insulation from influence over business opportunities.    
 
Conclusion
 
In 2019, we saw some of the largest fines in the history of FCPA enforcement as well as the affirmation of the wide jurisdictional reach of the law. With a continued focus of DOJ on China, we anticipate the Asia Pacific region to remain a hot spot for FCPA enforcement in 2020. Companies will need to carefully consider how to investigate and remediate potential violations of the FCPA and whether to self-disclose those potential violations to US authorities in order to benefit from mitigation credit in any potential enforcement action.
 

[FN/1] This number includes 30 actions against 27 individuals announced for the first time in 2019, but also follow-on convictions and sentences in cases announced prior to 2019
.

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TEEX/IM TRAINING EVENTS & CONFERENCES

TE_a110.
ECTI Presents “United States Export Controls (ITAR/EAR/OFAC
)
 Seminar Series” in Washington, DC: March 2-5, 2020

(Source:
Jill Kincaid
)
 
* What: United States Export Controls (ITAR/EAR/OFAC) Seminar Series in Washington, DC
* When: ITAR Seminar: March 2-3, 2020; EAR/OFAC Seminar: March 4-5, 2020
* Where: Washington, DC: Embassy Suites Alexandria Old Town
* Sponsor: Export Compliance Training Institute (ECTI)
* ECTI Speakers: Greg Creeser, Maarten Sengers, Timothy O’Toole, and Jim Bartlett
* Register
here
or 
Jessica Lemon
, 540-433-3977.

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TE_a211. 19th Annual ‘Partnering for Compliance’ Export/Import Control Conference” on 10-12 Mar in Orlando

 
* What: The 19th Annual “Partnering for Compliance (TM)” export control program will focus intensely on a broad spectrum of export/import regulatory and compliance matters of current relevance to companies and individuals involved in global trading. Senior-level government officials and trade experts will provide first-class training.
* Where: Holiday Inn Orlando International Airport Hotel (completely renovated)  
* When: Tue – Thu, 10-12 Mar: “19th Annual ‘Partnering for ComplianceTM’ Export Control Program”
* Speakers confirmed: DoS/DDTL: Terry Davis & 1 other;  DoS/DDTC: Jae Shin;  DoC/BIS: Sharron Cook & Special Agents Lauren Nieland & Tina Stasulli Korb, BIS/OEE;  DoD/DTSA: Tracy Minnifield; DoT/OFAC: Nell Williams, Enforcement  &  Anthony Musa (Invited), Licensing;  Census Bureau: Omari Wooden;  DHS/CBP: Nils Borregaard;  ICE: Timothy Dwyer.
* Opening Keynote: Delegation of the E.U. to the U.S. (Invited)
* Customs/Import: Braumiller Law Group PLLC: Adrienne Braumiller & Bruce Leeds
* USMCA – Speaker Invited
* Cost: Export 3-day program: $650.
* Remarks: Maximum capacity is 200 participants to maintain informal and collaborative environment for both programs.
* As time permits, all Government and trade speakers will informally hold short “one-to-one” meetings with participants on a “first-come, first-served” basis.
* Certificates of Completion granting: 4.5 IIEI CEUs and 20 CES NCBFAA Credits for 3-day Exports program, and 6.5 CCS NCBFAA Credits for 1-day Customs/Import Boot Camp will be awarded for each program.
* NOTE: Sharron Cook, BIS will discuss: BIS Update on latest news; Specially Designed; License Exceptions: STA, RPL, APR, LVS & TMP; Foreign subsidiaries for Controlled Technical Data (500 & 600 series); Electronic Compliance; Best Practice re participants of JCPOA.
* More information re both programs: Click Here
 
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TE_a312. 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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ENEDITOR’S NOTES

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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.
 
Agency 
Regulations 
Latest Update 
DHS CUSTOMS REGULATIONS
: 19 CFR, Ch. 1, Pts. 0-199.
 
 
 
5 Apr 2019:5 Apr 2019, 84 FR 13499-13513: Civil Monetary Penalty Adjustments for Inflation.

DOC EXPORT ADMINISTRATION REGULATIONS (EAR): 15 CFR Subtit. B, Ch. VII, Pts. 730-774.

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

DOD NATIONAL INDUSTRIAL SECURITY PROGRAM OPERATING MANUAL (NISPOM): 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. 
DOE EXPORT AND IMPORT OF NUCLEAR EQUIPMENT AND MATERIAL; 10 CFR Part 110.

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
 
 
 
 

  USITC HARMONIZED TARIFF SCHEDULE OF THE UNITED STATES (HTS, HTSA or HTSUSA),

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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