20-0413 Monday “Daily Bugle”

20-0413 Monday “Daily Bugle”

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Monday, 13 April 2020

(No items of interest today.) 
  1. Items Scheduled for Future Federal Register Edition
  2. Commerce/BIS: (No new postings.)
  3. State/DDTC: (No new postings.)
  4. Treasury/ORAC Issues Venezuela General License 5C and Amends FAQs
  1. Baker McKenzie: “European Commission Introduces Additional Retaliatory Tariffs on Certain US-originating Products”
  1. STR: “Kenya Trade Deal Could Set Precedent for Other AGOA Countries; Comment Deadline is 15 April”
  2. STR: “COVID-19: Update on Trade Agency Operations in Response to Pandemic”
  3. STR: “Export and Sanctions Penalties Increased”
  1. Monday List of Ex/Im Job Openings: 132 Jobs Available – 10 New Job Openings This Week 
  1. ECS Presents 8-Part Export Controls Webinar Series 8 Apr to 27 May
  2. ECS Presents “ITAR/EAR Boot Camp: Achieving Compliance”
  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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The ITAR amendments to the ITAR that took effect on 9 March and 25 March are included in the current edition of the BITAR.  Subscribers receive updated editions every time the regulations are amended (usually within 24 hours) so you will always have the current versions of the regulations. Subscribe to the BITAR now to guarantee you have an up-to-date ITAR!    

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Items Scheduled for Future Federal Register Editions 
(Source: Federal Register)

* State Department: Meetings — Defense Trade Advisory Group (DTAG); Scheduled Pub. Date: 14 Apr 2020

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Commerce/BIS: (No new postings.)

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Treasury/OFAC Issues Venezuela General License 5C and Amends FAQs

10 Apr 2020: The Department of the Treasury’s Office of Foreign Assets Control (OFAC) is issuing General License 5C, “Authorizing Certain Transactions Related to the Petróleos de Venezuela, S.A. 2020 8.5 Percent Bond on or After July 22, 2020.”
OFAC is amending a related Frequently Asked Question:
Q: What does Venezuela-related General License 5C authorize?
A: The President issued Executive Order (E.O.) 13835 on May 21, 2018. Subsection 1(a)(iii) of E.O. 13835 prohibits U.S. persons from engaging in transactions related to the sale, transfer, assignment, or pledging as collateral by the Government of Venezuela (GOV) of any equity interest in an entity owned 50 percent or more by the GOV. One effect of subsection 1(a)(iii) is to require authorization before U.S. persons may engage in certain transactions regarding any equity interest in an entity owned 50 percent or more by the GOV. After E.O. 13835 was issued, OFAC received inquiries about how and whether subsection 1(a)(iii) of E.O. 13835 could affect the ability to enforce bondholder rights to the CITGO shares serving as collateral for the Petróleos de Venezuela, S.A. (PdVSA) 2020 8.5 percent bond. OFAC issued General License 5 on July 19, 2018, which removed E.O. 13835 as an obstacle to holders of the PdVSA 2020 8.5 percent bond gaining access to their collateral.
General License 5 was replaced and superseded on October 24, 2019, and most recently by General License 5C, with a delay in effectiveness until July 22, 2020. Between October 24, 2019 and July 22, 2020 (the date the authorization in General License 5C becomes effective), there is no authorization in effect that licenses against subsection 1(a)(iii) of E.O. 13835 applicable to the holders of the PdVSA 2020 8.5 percent bond. As a result, during such period, transactions related to the sale or transfer of CITGO shares in connection with the PdVSA 2020 8.5 percent bond are prohibited, unless specifically authorized by OFAC.
To the extent an agreement may be reached on proposals to restructure or refinance payments due to the holders of the PdVSA 2020 8.5 percent bond, additional licensing requirements may apply. OFAC would encourage parties to apply for a specific license and would have a favorable licensing policy toward such an agreement.

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NWS_a15. Baker McKenzie: “European Commission Introduces Additional Retaliatory Tariffs on Certain US-originating Products”

Baker McKenzie Blog, 10 Apr 2020) [Excerpts]


COM_a16. STR: “Kenya Trade Deal Could Set Precedent for Other AGOA Countries; Comment Deadline is 15 April”

Sandler, Travis & Rosenberg, 10 Apr 2020) [Excerpt] 

Companies that source from any beneficiary country under the African Growth and Opportunity Act have a stake in the forthcoming U.S.-Kenya trade agreement because it will likely serve as a model for similar deals with those countries and could impact intra-African trade. Such companies may therefore want to submit by the April 15 deadline information on the following issues, which the Office of the U.S. Trade Representative will consider in developing U.S. negotiating positions with Kenya.
  • General and product-specific negotiating objectives
  • Relevant barriers to trade in goods and services 
  • Economic costs and benefits to U.S. producers and consumers of the removal or reduction of tariffs and non-tariff barriers
  • Treatment of specific goods, including product-specific import or export interests or barriers, experience with particular measures that should be addressed, and ways to address export priorities and import sensitivities
  • Fees, charges, and taxes affecting bilateral trade in goods and services
  • Customs and trade facilitation issues, including those related to pre-shipment inspection
  • Sanitary and phytosanitary measures and technical barriers to trade
  • Transparency issues
  • Other measures or practices, including those of third-country entities, that undermine fair market opportunities for U.S. businesses, workers, farmers, and ranchers

COM_a27. STR: “COVID-19: Update on Trade Agency Operations in Response to Pandemic”

Sandler, Travis & Rosenberg, 14 Apr 2020) [Excerpt]

Federal trade regulatory agencies have recently announced the following with regard to their operations in response to the COVID-19 pandemic. …
Department of Agriculture

Veterinary Health Certificates

The Department of Agriculture’s Animal and Plant Health Inspection Service has announced that effective April 8 for shipments arriving through May 16, U.S. Customs and Border Protection agriculture specialists may accept all import documents uploaded to CBP’s Document Image System for animal products and byproducts regulated by APHIS, regardless of the disease status of the exporting country. This includes veterinary health certificates and supporting documents for veterinary import permit requirements.

However, APHIS will continue to require original hard copy veterinary health certificates for shipments of the following high-risk products: 
  1. Fetal bovine serum, newborn calf serum, calf serum, donor bovine serum, and adult bovine serum from all countries, and 
  2. Fresh and/or frozen meat and poultry from all countries when the original hard copy certificate has not been provided to USDA’s Food Safety Inspection Service (if it has, CBP agriculture specialists may accept a copy uploaded to DIS).
APHIS states that shipments arriving in the U.S. without a veterinary health certificate, either the original or a copy uploaded to DIS, will be refused entry or held until the required documents are received. If there is reason to believe a certificate uploaded to DIS is fraudulent, CBP will retain the shipment on hold until the original is reviewed.

Fruit from New Zealand

APHIS has temporarily suspended the preclearance program for apples and pears from New Zealand. APHIS states that while it is unable to send preclearance inspectors to New Zealand due to COVID-19 travel restrictions and safety concerns, imports of apples and pears from New Zealand will be allowed to continue subject to existing U.S. requirements; i.e., to enter all U.S. ports of entry without preclearance if they undergo required inspection on arrival and meet all general requirements of 7 CFR 319.56-3, including all pest mitigation restrictions and treatments ordered by the port of entry inspector.

Department of Homeland Security

The DHS issued a 
temporary rule that prohibits exports of certain types of personal protective equipment being used to treat COVID-19 without explicit approval by the Federal Emergency Management Agency. This rule became effective April 7 and will remain in force until Aug. 8.

U.S. Customs and Border Protection

Goods Imported for Relief Efforts
CBP has issued the following guidance on the processing of goods imported for COVID-19 relief efforts, including international donations accepted by FEMA via the International Assistance System Concept of Operations as well as goods imported by U.S. charities (or other private entities) to assist with disaster relief.  
IAS imports 
Under the IAS CONOPS, the importation has been sanctioned by the State Department as an approved shipment after FEMA exercises its gift acceptance authority pursuant to section 701(b) of the Stafford Act and the goods are eligible to be entered without payment of duty or taxes pursuant to 19 USC 1322(b) or 19 USC 1318(b)(2). The requirement for advance electronic filing of cargo information may be waived for these shipments. For IAS goods, upon arrival at a port, a cargo manifest must be provided by the arriving carrier and screened by the port for high-risk factors in accordance with CBP policy. IAS goods do not require a formal entry and may be released off the manifest. 
Arriving foreign shipments processed under these guidelines must be logged and tracked locally by the port in accordance with existing policies to document the following: port of entry, importer, consignee, description of goods, quantity, country of origin, and destination.
The IAS process only applies to government-to-government assistance (nation-state to nation-state) and the shipments must be accepted by the U.S. government through the State Department. For individuals who provide assistance outside the auspices of a nation-state, domestic U.S. law applies.
Charitable organization imports – CBP may not remit the duty on the entry of any goods imported for disaster relief by a private group or individual pursuant to 19 USC 1322(b) unless the recipient is a recognized tax-exempt charitable organization. These private groups or individuals must provide a letter from the charity, on the charity’s letterhead, with the charity’s Internal Revenue Service number(s), stating that they are willing to accept the imported goods and that the organization intends to donate the imported goods. Shipments meeting these criteria do not require a formal entry and may be released off the manifest.
CBP states that any goods not meeting the above criteria can still be entered under established entry procedures.
Use of Automated Systems
CBP highly recommends using its automated systems to their fullest extent possible, including as follows, to minimize exposure and sustain trade activities.
  • Transmit entries and entry summaries to the Automated Commercial Environment
  • Update current account and point of contact information in the ACE portal, to include email
  • Submit supporting documentation or responses to CBP requests for information (Form 28) through the ACE portal or the Document Image System
  • Transmit post-summary activities, such as protests and post-importation claims, through ACE
  • Filers submitting post-summary corrections that require a payment of duties may opt to receive a bill or may still mail payment to the port of entry
CBP also encourages importers and filers to take advantage of the Automated Clearinghouse for electronic payment to the greatest extent possible. In the event that the use of electronic submissions cannot be utilized, documentation may be mailed to the port of entry for processing, to include checks for payment of duties, taxes and fees, liquidated damages, prior disclosures, etc.

COM_a38. STR: “Export and Sanctions Penalties Increased”

Sandler, Travis & Rosenberg, 14 Apr 2020) [Excerpts]

The Office of Foreign Assets Control has issued a final rule adjusting its maximum civil monetary penalties for inflation, as follows, effective April 9.
  • $1,529,991 (up from $1,503,470) for violations of the Foreign Narcotics Kingpin Designation Act and the Foreign Narcotics Kingpin Sanctions Regulations
  • The greater of $307,922 (up from $302,584) or twice the amount of the underlying transaction for violations of the International Emergency Economic Powers Act and the Narcotics Trafficking Sanctions Regulations, the Weapons of Mass Destruction Trade Control Regulations, the Zimbabwe Sanctions Regulations, the Syrian Sanctions Regulations, the Weapons of Mass Destruction Proliferators Sanctions Regulations, the Darfur Sanctions Regulations, the Democratic Republic of the Congo Sanctions Regulations, the Belarus Sanctions Regulations, the Lebanon Sanctions Regulations, the Iranian Assets Control Regulations, the Iranian Transactions and Sanctions Regulations, the Iranian Financial Sanctions Regulations, the Hizballah Financial Sanctions Regulations, the Iraq Stabilization and Insurgency Sanctions Regulations, the Global Magnitsky Sanctions Regulations, the Magnitsky Act Sanctions Regulations, the Western Balkans Stabilization Regulations, the Global Terrorism Sanctions Regulations, and the North Korea Sanctions Regulations
  • $90,743 (up from $89,170) per violation on any person who violates any license, order, or regulation issued under the Trading with the Enemy Act
  • The greater of $81,283 (up from $79,874) or twice the amount of which a financial institution was required to retain possession or control for violations of the Foreign Terrorist Organizations Sanctions Regulations
  • $13,910 (up from $13,669) for violations of the Clean Diamond Trade Act and the Rough Diamonds Control Regulations …


(Source: Events & Jobs Editor)

* Atlas Copco; Charlotte, NC; CT Trade Compliance Lead – NASA region
* CF Industries; Deerfield, IL; Manager, Transportation Compliance
* DynCorp International; Fort Worth, TX; Contracts Manager (Contingent Upon Award; Requistion ID:
* L3Harris Technologies; Rochester, NY; Spec, Trade Compliance; Requistion ID: CS20203001-40022
* Marotta Controls; Township of Montville, NJ; Contracts & Compliance Manager
* Maxim Integrated; San Jose, CA; Supply Chain Management Analyst; Requistion ID: R7495BR
* PSEG; Clifton, NJ; Sr. Analyst – Centralized Work Planning & Scheduling; Requisition ID: 60301
* Surefire LLC; Fountain Valley, CA; Manager, International Trade Compliance; Contact Details: sgreenberg@surefire.com
* The Aerospace Corporation; El Segundo, CA; Export Control Staff IV; Requistion ID: 53146
* Vitabiotics Ltd; London, UK; Export Manager, APAC

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*What: U.S. Export Controls – Separate subjects on separate days:

Wed. April 8: Introduction to Export Controls & the Elements of the ITAR
Wed. April 15: Introduction to the EAR & Export Authorizations
Thurs. April 23: Fundamentals of Jurisdiction & Classification
Wed. April 29: How to Complete ITAR Export Authorizations
Wed. May 6: Required Elements of a Compliance Program
Wed. May 13: Overview of the Most Commonly Used ITAR Exemptions
Wed. May 20: Overview of the Most Commonly Used EAR Exceptions
Wed. May 27: Top 10 Violations & Tips to Prevent
* When: 1-2:30 pm Eastern, on the above dates
* Where: Webinar on your computer
* Sponsor: Export Compliance Solutions & Consulting
* Presenter: Suzanne Palmer, Mal Zerden
* Register here:

– Link to 8-pack of seminars
, with professional certification option

* More information: 1-866-238-4018 or email liz@exportcompliancesolutions.com.

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*What: ITAR/EAR Boot Camp: Achieving Compliance

*When: July 7-8, 2020
*Where: Sheraton Grande; Seattle, WA
*Sponsor: Export Compliance Solutions & Consulting
Suzanne Palmer, Mal Zerden

* More information: 1-866-238-4018 or email liz@exportcompliancesolutions.com.

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EN_a112. Bartlett’s Unfamiliar Quotations

(Source: Editor)

Henry Clay (12 April 1777 – 29 Jun 1852; was an American attorney and statesman who served as speaker of the U.S. House of Representatives, and as U.S. secretary of state. He helped found the National Republican Party.)
  – “Statistics are no substitute for judgment.”
  – “The Constitution of the United States was made not merely for the generation that then existed, but for posterity- unlimited, undefined, endless, perpetual posterity.”
Thomas Jefferson (13 Apr 1743 – 4 Jul 1826; was an American statesman, diplomat, lawyer, architect, philosopher, and Founding Father who served as the third president of the United States from 1801 to 1809. The principal author of the Declaration of Independence, Jefferson was a proponent of democracy, republicanism, and individual rights, motivating American colonists to break from the Kingdom of Great Britain and form a new nation; he produced formative documents and decisions at both the state and national level.)
  – “No freeman shall be debarred the use of arms.”
  – “I never considered a difference of opinion in politics, in religion, in philosophy, as cause for withdrawing from a friend.”
Monday is Pun Day:
* If vegetarians eat vegetables, what do humanitarians eat?
* The guy who fell onto an upholstery machine last week is now fully recovered.
* I had a photographic memory but it was never fully developed.
Q: Why can’t bicycle can’t stand alone? A: It’s just two tired.

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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 2019:84 FR 13499: Civil Monetary Penalty Adjustments for Inflation.


24 Feb 2020:
85 FR 10274
: Amendments to Country Groups for Russia and Yemen Under the Export Administration Regulations.


DOC FOREIGN TRADE REGULATIONS (FTR): 15 CFR Part 30.   Last Amendment: 24 Apr 2018: 83 FR 17749: 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. 

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.

DOS INTERNATIONAL TRAFFIC IN ARMS REGULATIONS (ITAR): 22 C.F.R. Ch. I, Subch. M, Pts. 120-130.  26 Dec 2019: 84 FR 70887; 23 Jan 2020: 85 FR 3819: Encryption rule and USML Categories I, II, III, and related sections regarding guns & ammo. 
DOT FOREIGN ASSETS CONTROL REGULATIONS (OFAC FACR): 31 CFR, Parts 500-599, Embargoes, Sanctions, Executive Orders

13 Mar 2020:
85 FR 14572:
General Licenses Issued Pursuant to Venezuela-Related Executive Order 13835.


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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