20-0417 Friday “Daily Bugle”

20-0417 Friday “Daily Bugle”

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Friday, 17 April 2020

  1. USITC: “COVID-19 Related Goods: U.S. Imports and Tariffs; Institution of Investigation”
  1. Items Scheduled for Future Federal Register Edition
  2. Commerce/BIS: (No new postings.)
  3. State/DDTC: (No new postings.)
  4. Treasury/OFAC: Humanitarian Assistance and Trade to Combat COVID-19
  5. EU: Syria Sanctions Continuance
  6. Singapore Customs: “TradeNet Extended Downtime”
  7. UK ECJU: “Export Controls – Dual-Use Items, Software and Technology, Goods for Torture, and Radioactive Sources”
  1. Export Compliance Daily: “China Says it Received ‘Positive’ Feedback After Increasing Export Inspections”
  2. WORLDecr: ” ‘China Exploiting the Moment’, Says UK Lawmaker as Chipmaker Comes Under Scrutiny”
  1. Baker McKenzie: “UK ECJU Issues Guidance on Remote Compliance Checks”
  2. Baker McKenzie: “EC Limits Export Authorisation Requirements and Extends Geographical and Humanitarian Exemptions”
  3. Steptoe: “Considerations for Conducting Remote Internal Investigations” (Part I of III)
  4. Tuttle Law: “FDA Entries with a Disclaim B Will Be Rejected as of 19 Apr”
  5. Winston & Strawn: “Tips for Compliance Departments During the COVID-19 Pandemic”
  1. Bryce Bittner Moves to McKinsey & Company
  1. ECTI Presents United States Export Control (ITAR/EAR/OFAC) Seminar in Singapore: 14-17 Sep
  2. FCC Academy Presents Webinar: “An Introduction to EU/Dutch Dual-use and Military Export Controls”; 12 May
  3. Friday List of Approaching Events: 121 Events Posted This Week, Including 15 New Events
  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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USITC: “COVID-19 Related Goods: U.S. Imports and Tariffs; Institution of Investigation”

Federal Register, 17 Apr 2020) [Excerpts]

85 FR 21459: Notice of investigation.
* AGENCY: United States International Trade Commission.
* ACTION: Notice of investigation.
* SUMMARY: Following receipt on April 7, 2020, of a request from the House Committee on Ways and Means and the Senate Committee on Finance (the Committees), under section 332(g) of the Tariff Act of 1930, the U.S. International Trade Commission (Commission) instituted Investigation No. 332-576, COVID-19 Related Goods: U.S. Imports and Tariffs, for the purpose of providing a report that identifies imported goods related to the response to COVID-19, their source countries, tariff classifications, and applicable rates of duty.
* Background: As requested by the Committees, the Commission will conduct an investigation and prepare a report that, to the extent practical, identifies imported goods related to the response to COVID-19, their source countries, tariff classifications, and applicable rates of duty. For each product that the Commission so identifies, the Commission will seek to provide:
   1. The 10-digit HTS code for the article;
   2. its legal description;
   3. general duty rate;
   4. any special or additional rates of duty imposed on the article, the dates on which the rates were imposed, and the authorities under which they were imposed;
   5. whether any such duties have been suspended and, if so, the date of suspension as well as how long the suspension is scheduled to last;
   6. the total rate of duty imposed on such article, including any
special or additional rate of duty; and
   7. the major countries of origin for each such article, and the
import value of each such article from each country for the years 2017-2019. …

Back to top.

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Items Scheduled for Future Federal Register Editions 
[No items of interest today.]

* * * * * * * * * * * * * * * * * * * *  

Commerce/BIS: (No new postings.)

* * * * * * * * * * * * * * * * * * * *  

* * * * * * * * * * * * * * * * * * * *  

Treasury/OFAC: Humanitarian Assistance and Trade to Combat COVID-19
, 16 Apr 2020)

On April 16, the United States Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued a 
Fact Sheet
highlighting the most relevant exemptions, exceptions, and authorizations for humanitarian assistance and trade under the 
North Korea
, and 
 sanctions programs. The Fact Sheet also outlines specific guidance for OFAC-administered sanctions programs related to personal protective equipment (PPE).


For more information regarding e scope of any sanctions programs’ requirements, or the applicability or scope of any humanitarian-related authorizations, please contact OFAC’s Sanction Compliance and Evaluation Division at (800) 540-6322 or (202) 622-2490, or by email at OFAC_Feedback@treasury.gov.

* * * * * * * * * * * * * * * * * * * *  

EU: Syria Sanctions Continuance 
The Council intends to maintain the restrictive measures against the mentioned in this notice persons and entities with new statements of reasons. Those persons and entities are hereby informed that they may submit a request to the Council to obtain the intended statement of reasons for maintaining their designation, by 24 April 2020.
The persons and entities concerned may submit at any time a request to the Council, together with any supporting documentation, that the decision to include and maintain them on the list should be reconsidered, to the address provided above. Such requests will be considered when they are received. In this respect, the attention of the persons and entities concerned is drawn to the regular review by the Council of the list. In order for requests to be considered at the next review, they should be submitted by 8 May 2020.

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Singapore Customs: “TradeNet Extended Downtime”
(Source: Singapore Customs, 17 Apr 2020)
Singapore Customs will be performing system maintenance work which will affect TradeNet for the following date and time.

Date   Time  Duration 

03 May 2020  
4am to 4pm 
12 hours 

17 May 2020  4am to 12pm 8 hours

31 May 2020  4am to 12pm  8 hours 

* * * * * * * * * * * * * * * * * * * *  

UK ECJU: “Export Controls — Dual-Use Items, Software and Technology, Goods for Torture, and Radioactive Sources”

, 16 Apr 2020)
The UK Export Control Joint Unit (ECJU) updates its guide to licensing procedure and other restrictions for export of controlled dual-use items, software and technology, goods for torture and radioactive sources, by adding email address for use during COVID-19 period.

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Export Compliance Daily: “China Says it Received ‘Positive’ Feedback After Increasing Export Inspections”

(Source: Export Compliance Daily, 17 Apr 2020) [Excerpts]


China has received “positive” feedback after increasing inspections of certain medical exports, a Commerce Ministry official said, despite reports of lengthy customs delays due to the measures. The measures, announced earlier this month, increased inspections of 11 medical goods after China received international criticism about the quality of the goods. “Since the implementation of the relevant measures, the effect has been obvious and the international community has made positive comments,” a ministry official said during an April 16 press conference, according to an unofficial translation of a transcript. “I would like to emphasize again that China does not and will not restrict the export of anti-epidemic materials.”
Companies operating in China have faced exporting delays due to the inspections, which have led to a backlog of shipments. The restrictions have stranded U.S.-bound face masks, test kits and other medical equipment as “large quantities” of medical goods are sitting in Chinese warehouses and unable to receive official clearances, according to an April 16 report in The Wall Street Journal.
China said its customs authorities have “taken active measures to speed up customs clearance” but are still focusing on inspections to catch counterfeit goods and export violations. “We hope that the relevant national governments and buyers choose products that have been certified by Chinese regulatory authorities and qualified enterprises, and fully communicate with Chinese companies in terms of product standards,” the ministry official said. …

WORLDecr: ” ‘China Exploiting the Moment’, Says UK Lawmaker as Chipmaker Comes Under Scrutiny”

(Source: WORLDecr, 17 Apr 2020) [Excerpts]

A major British-based chip developer, Imagination Technologies (customers of which include Apple), has aroused the scrutiny of lawmakers on both sides of the Atlantic as it looks to transfer ownership to China, with probes on both sides of the Atlantic, by the Committee on Foreign Investment in the United States (‘CFIUS’) and by a UK parliamentary committee appearing to have derailed those intentions.

Senior company officials, including the chief executive, are reported to have recently quit the company with press reporting one to have said in his resignation letter: ‘I will not be part of a company that is effectively controlled by the Chinese government.’
In September 2017, Imagination Technologies was acquired by Canyon Bridge, a US-based, but Chinese state-owned investment company that itself is owned by China’s state-owned investment fund, China Reform Holdings. The transfer is understood to have been approved by the UK government on the basis that Canyon Bridge was licensed and regulated under US law.
Canyon Bridge has subsequently moved its headquarters to the Cayman Islands. …
British lawmaker Tom Tugendhat said that China is trying to exploit the global pandemic to seize control of companies such as Imagination Technologies and changing the way the internet works.
‘We’re seeing quite a lot of action by the Chinese state, or state-owned companies, that seem to be exploiting this moment,’ Tugendhat, the chair of the Foreign Affairs Select Committee, told Sky.


COM_a112. Baker McKenzie: “UK ECJU Issues Guidance on Remote Compliance Checks”

(Source: Baker McKenzie Blog, 15 Apr 2020)
The UK Export Control Joint Unit (ECJU) has issued new guidance on the operation of remote compliance checks in light of the COVID-19 pandemic. The guidance covers the key points below.
First, the guidance requests that all businesses that have closed due to the pandemic should inform their compliance officer as soon as possible enclosing a formal notice confirming the closure.
Second, the ECJU will accept digital or copy consignee undertakings in lieu of original documents, accompanied with an email explaining why it is not possible to submit an original. The ECJU has reserved the right to request originals at the next onsite visit. Moreover, the ECJU has asked that businesses should keep it informed of any inability to access physical or electronic records as a result of the COVID pandemic.
Third, dates for remote compliance checks will be confirmed 4-6 weeks in advance. In preparing for the check, businesses are asked to complete a pre-visit questionnaire and return it to the ECJU 7 days before the remote check. The returned questionnaire should enclose a list of exports made under the relevant export licences for the past 2 years. 
Lastly, the ECJU notes that businesses are experiencing delays in obtaining Ministry of Defence (“MOD“) approvals. As a result, the ECJU will accept evidence of application to the MOD and email acknowledgement from the MOD team. The ECJU has reserved the right to request copies of the authorisations at the next on-site visit.

Baker McKenzie: “EC Limits Export Authorisation Requirements and Extends Geographical and Humanitarian Exemptions”

(Source: Baker McKenzie Blog, 15 Apr 2020)
On 14 April 2020, the EC began a consultation with Member States on an adjustment to the emergency export authorisation scheme put in place on 15 March which expires on 25 April 2020.  


The highlight point of the new draft regulation, set to apply for a limited period of 30 days (as of 26 April 2020), is that it will extend only to protective face masks. This is based on the Commission’s view that this is the only product category where export authorisation is necessary to protect public health in the EU.
The regulation exempts from the authorisation requirement exports to Western Balkan states (Albania, Bosnia and Herzegovina, North Macedonia, Montenegro, Serbia, Kosovo), Gibraltar, and territories of Member States outside the customs union. The scheme explicitly requires Member States to authorise exports of emergency supplies in the context of humanitarian aid and to process the relevant applications in an expedite manner.
The regulation introduces a mandatory consultation process with the EC for each export authorisation, which will be coordinated by a new clearing house responsible for efforts to match supply and demand for protective face masks in the EU. Member States are obligated to report all granted and refused authorisations under the scheme to the EC, which will report publicly on developments.    
The EC has included a review clause that will allow it to adjust the scope of products failing within the regulation in light of new developments.

Steptoe: “
or Conducting Remote Internal Investigations”
(Part I of III)
, 16 Apr 2020) [Part II will be published Monday]
* Principal Author:
Patrick F. Linehan
, Esq., 1-202-429-8154,
Steptoe & Johnson LLP
As the world grapples with containing the spread of COVID-19, restrictions on travel and social distancing practices have had the effect of slowing the pace of corporate investigations, which typically involve some degree of travel and human interaction, particularly for evidence-gathering and in-person witness interviews.  
Given the uncertainty surrounding when these restrictions may be lifted, as well as when law enforcement agencies will resume business as usual, companies will likely need to move forward with investigations using remote techniques.[
1] Some of the legal and practical considerations in conducting remote investigations are set forth below, but they may vary by jurisdiction.
When conducting interviews remotely, it might be tempting for a participant to record the interview given the ability to do so without detection. Of course, regardless of the interview format, in deciding whether to record an interview, companies should always consider whether the recording will be discoverable or otherwise subject to production as part of its defense or future cooperation efforts.[
But should exceptional circumstances warrant the investigating company’s recording of an interview, or conversely, should the company want to prevent a witness’s surreptitious recording of the interview, it should be aware of the laws and regulations governing unauthorized recordings.  
Further, given the greater likelihood of remotely conducted interviews occurring across multiple jurisdictions, it is critical that companies understand the rules in each potentially relevant jurisdiction and which jurisdictions’ rules are likely to apply.
Under applicable U.S. federal law, as well as the law of most states, a recording requires only the consent of a single party to the communication. Accordingly, call participants wishing to record an interview in these jurisdictions can do so without obtaining the consent of the other parties because their own consent alone is sufficient.  

Companies seeking to record an interview should consider whether the employee’s consent is required under internal policies or any contractual obligations. Even without a legal obligation to obtain consent, it may be worth notifying the interviewee as a professional courtesy – or at a minimum, to answer honestly if the interviewee asks if the interview is being recorded.
Conversely, companies seeking to avoid the recording of an interview in a one-party consent jurisdiction should ask the interviewee at the outset whether he or she is recording, make clear that the company does not consent and instruct the interviewee that he or she is prohibited from doing so.[
Fifteen U.S. states require that all parties to a conversation consent to it being recorded, with violations potentially resulting in either civil or criminal penalties.[
4] Among these states, some embrace the idea of implied consent, where consent is found as long as a party continues with the conversation after being told by the other party that it is being recorded, while others require that each participant consent explicitly to the recording.
In all-party consent jurisdictions, companies are well-advised either to seek the interviewee’s express consent or conversely, to make clear its non consent to any recording by the interviewee.  
Determining the governing law can be challenging when participants span both one-party and all-party consent jurisdictions. In these situations, the most conservative approach is to assume that the law of the most stringent state in which any participant is located applies.  

In Kearney v. Salomon Smith Barney Inc., for example, a California court determined that it was necessary to apply California law (an all-party consent jurisdiction) where a corporation in Georgia (a one-party consent jurisdiction) recorded calls with witnesses in California, because failing to do so would
impair California’s interest in protecting the degree of privacy afforded to California residents by California law more severely than the application of California law would impair any interests of the State of Georgia.[
For remote interviews where any participant is outside of the U.S., recording without consent may also be a civil or criminal offense. Where it is not a criminal offense (for example, in the U.K.), covertly recording someone may give rise to a breach of privacy laws and, consequently, to a potential civil claim for substantial damages.  
To the extent that interviews present the possibility of capturing information about EU data subjects, companies will also want to consider whether the act of recording an interview is covered by the EU General Data Protection Regulation, which applies to certain companies located outside of Europe and includes a fine of up to €20 million (~$22 million) or, in the case of an undertaking, 4% of annual global turnover. Other applicable data privacy laws also should be considered.
See the
Footnotes here

Tuttle Law: “FDA Entries with a Disclaim B Will Be
Rejected as of 19 Apr”
(Source: Tuttle Law, 16 Apr 2020)
CBP announced in 
CSMS #42394155 of April 16, 2020 that starting Sunday, April 19, 2020 FDA entries with a Disclaim B will be REJCTED. The only valid disclaim code for FDA is “A”. Trade may continue to use Disclaim A for products that are not regulated by the FDA (i.e. certain masks). Additional information on Disclaim B rejections is available in CSMS #42082100 of March 19, 2020.
Prior to ACE, trade would see FD0 flags associated with some HTS codes, which indicated that data was not required per agency guidelines. With the implementation of ACE, the Disclaim B (data not required per agency guidelines) was removed, and the FD0 flag not utilized. (
Further questions, or information regarding HTS flags contact 

COM_a516. Winston & Strawn: “Tips for Compliance Departments During the COVID-19 Pandemic”

(Source: Winston & Strawn, 16 Apr 2020)

Without question, the primary focus for many companies in this unprecedented healthcare crisis is the need to protect and save lives. However, following that comes the need to continue business operations, obtain much-needed supplies, and transport products on a global scale. And “business as usual” is anything but, with operational challenges creating a nightmare scenario for many compliance officers. Existing supply chains have shut down, new suppliers have entered the market, and competition is fierce.  
To adapt to meet these new demands, companies are finding new or untested suppliers, using the services of new or untested agents, and doing all of this at record speed. In the midst of this pandemic, the time pressure and perceptions of “new liberties” arising from work from home atmospherics may lead to requests to skip critical compliance steps and controls. While there is some solace and forgiveness from customers “in the same boat,” there is little doubt that the federal government will closely scrutinize business decisions once this crisis subsides. Indeed, in certain compliance areas the federal government is not waiting for the crisis to subside. The Department of Justice (DOJ) has already announced a task force to combat fraud, hoarding, and price gouging, and has even brought an action against a company in Austin, Texas for “illegal conduct related to the pandemic.” On the international side, on April 14, the International Criminal Police Organization (INTERPOL) announced
that it had identified an international fraud scheme offering non-existent COVID-19 masks for sale. The scheme worked by using compromised emails, advance-payment fraud, and money laundering – and was identified by financial institutions and authorities across Germany, Ireland, and the Netherlands.
First, there is no “crisis cartel” exception to illegal antitrust agreements. Businesses should therefore remain cognizant to not engage in any behavior that could be construed as communicating with competitors to fix prices, rig bids, or allocate markets or customers. Those behaviors are per se illegal and are subject to severe penalties, including significant criminal fines and substantial prison time. Both the DOJ and the Federal Trade Commission (FTC) have explicitly stated that they “will not hesitate” to bring cases against corporations and individuals that violate antitrust laws during this time of crisis. Attorney General William P. Barr, himself, recently emphasized that the DOJ is looking to aggressively prosecute criminal antitrust violations related to the pandemic. In addition, the DOJ and FTC just on April 13 issued a joint warning that the agencies are on alert for “collusion or other anticompetitive conduct in labor markets, such as agreements to lower wages or to reduce salaries or hours worked.” The DOJ may criminally prosecute such conduct and the FTC can even pursue invitations to collude in the labor market.  
Second, the federal government is focused on preventing companies from hoarding and profiteering. On March 24, the White House issued Executive Order 13910, which criminalizes the hoarding and price gouging of critical items during the pandemic, including ventilators, face masks, and gloves. Violations of the Defense Production Act are punishable by up to a year in prison, a $10,000 fine, or both. On the same day, Attorney General William Barr issued a memorandum to all U.S. Attorneys with guidelines about how to enforce federal anti-hoarding and profiteering laws and announcing the COVID-19 Hoarding and Price Gouging Task Force. The Task Force aims to “develop effective enforcement measures to combat COVID-19-related market manipulation. By April 2, the FBI had already discovered hoarded supplies “during an enforcement operation” conducted by the Task Force. The government announced that this was “the first of many such investigations that are underway.”  
The bank regulators also have provided guidance on increased exposure to financial crimes related to the COVID-19 crisis. In particular, financial institutions have been put on notice of the following COVID-19 emerging trends:
   (1)imposter scams;
   (2)investment scams;
   (3)product scams; and
   (4)insider trading.
Following the trend from prior natural disasters, the Financial Crimes Enforcement Network has also flagged its “2017 Advisory to Financial Institutions,” where financial institutions were warned of benefits fraud, charities fraud, and cyber-related fraud. The April 14 INTERPOL announcement of fraud typifies the heightened risk profiles as governments and the private sector look to new supply chains for much-need medical supplies.  
Though the immediate concerns of the federal government appear focused on protecting access to critical items, the U.S. financial system, and preventing individual harm in the workforce, there is little doubt that anti-competitive conduct flowing from other forms of corruption will result in similar criminal proceedings once this crisis has passed. It is axiomatic that corruption and fraud opportunities, whether related to private or government conduct, are increased during times of crisis and economic destabilization. The need to clear supplies or products through customs, find ways to reduce economic losses, obtain lucrative contracts, speed drug studies in foreign markets, utilize financial institutions, or donate to government or charitable relief efforts are replete with corruption and fraud opportunities. And delays in any of these efforts can lead to catastrophic results. In this type of environment, standard processes may need to adjust to emergency procedures.
With the current landscape in mind, compliance officers can help keep businesses safe and compliant by focusing on a risk-based, practical approach. By creating emergency procedures, compliance can be seen as part of the ethical solution and not simply as a roadblock that individuals in the organization may seek to circumvent. As you assess your risks, we suggest you focus on the following:
   (1) Use your normal procedures wherever possible, including making independent decisions about pricing, customers, and markets;
   (2) Where time is of the essence, abbreviated procedures should continue to require basic due diligence to confirm that the supplier or counter-party is a legitimate business – particularly where the counter-party is an untested business partner. A review for potential red flags specific to the crisis should be implemented, including whether the supplier is demanding payment in advance, offering unusual delivery terms, refusing to use letters of credit, has no known track history in the business, requires payments to third parties, or appears “too good to be true”;
   (3) Put all agreements in writing. If the business must prepare emergency agreements that lead to less review time, create a template and stick by it. Make certain there are sufficient protections in all agreements, including clauses that require post-engagement due diligence. Such clauses will allow the company to quickly terminate the agreement if needed;  
   (4) If a company does not have time to conduct full due diligence on every vendor, supplier and agent, at a minimum the company should have due diligence conducted on any agents before they begin working for the company. It is critical, however, that abbreviated due diligence should never exclude sanctions or embargo checks;
   (5) Do not delay post-engagement due diligence, including collection of beneficial ownership information;
   (6) Conduct post-transaction testing;
   (7) Educate company personnel that even a pandemic does not excuse otherwise illegal or high-risk conduct under U.S. laws; and
   (8) Reinforce the “Tone from the Top” and ethical commitment of the company via electronic reminders to company personnel and third parties.


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ECTI Presents
United States Export Control (ITAR/EAR/OFAC) Seminar in Singapore: 14-17 Sep
* What: United States Export Controls (ITAR/EAR/OFAC) Seminar Series in Singapore (for Asia-Pacific and other non-US based companies)
* When: ITAR Seminar: 14-15 Sep; EAR/OFAC Seminar: 16-17 Sep
* Where: Singapore, Orchard Hotel Singapore, 442 Orchard Road, Singapore
* Sponsor: Export Compliance Training Institute (ECTI)
* ECTI Speaker Panel: John Black, Scott Gearity, and Timothy O’Toole
* Register
, or contact 
Jessica Lemon
, 1-540-433-3977.

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FCC Academy Presents Webinar: “An Introduction to EU/Dutch Dual-use and Military Export Controls“; 12 May

(Source: FCC Academy)
* What: Introduction to EU / Dutch Dual-Use and Military Export Controls
* When: 12 May 
* Where:  Online
* Sponsor: FCC Academy 
* Presenter: Marco F.N. Crombach MSc (Director)
* Register: 

, or email

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20. Friday List of Approaching Events: 121 Events Posted This Week, Including 15 New Events

(Sources: Event sponsors) 
Submit your event in the Submission section at the end of this newsletter.  
[Editor’s note:  This Daily Bugle Event List has grown so large that we have run out of space to display it!  This week we begin a new practice of displaying only the new events in the Daily Bugle, while maintaining a 
LINK HERE to the full list.] 
* 6 May:
Importing 101: The Real Basics
; Sandler, Travis & Rosenberg
* 13 May
COVID-19 Impact on Trade
; Sandler, Travis & Rosenberg
* 14 May:
Preparing for a Customs Investigation
; Sandler, Travis & Rosenberg
* 19 – 22 May:
Complying with US Export Controls
* 26 May:
Understanding Exporting & Incoterms
; Chamber International
* 28 May:
CBP Audit Surveys: What’s at Stake
; Sandler, Travis & Rosenberg
* 11 Jun: The ABC of Foreign Military Sales; FCC Academy
* 11 Jun:
Methods of Payment & Letters of Credit
; Chamber International
On Location:
* 19 – 21 Aug: Atlanta, GA; HTS & Export Classification Training; Masters Method
* 22 – 24 Sep: San Jose, Ca; HTS & Export Classification Training; Masters Method
* 14 – 16 Oct: Chicago, IL; HTS & Export Classification Training; Masters Method

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EN_a121. Bartlett’s Unfamiliar Quotations

(Source: Editor)


* J. P. Morgan (17 Apr 1837 – 31 Mar 1913; was an American financier and banker who dominated corporate finance on Wall Street throughout the Gilded Age. As the head of the banking firm that ultimately became known as J.P. Morgan and Co., he was a driving force behind the wave of industrial consolidation in the United States spanning the late 19th and early 20th centuries. Over the course of his career on Wall Street, J.P. Morgan spearheaded the formation of several prominent multinational corporations including U.S. Steel Corporation, International Harvester and General Electric.)
  – “Well, I don’t know as I want a lawyer to tell me what I cannot do. I hire him to tell how to do what I want to do.”
  – “A man generally has two reasons for doing a thing. One that sounds good, and a real one.”
* Thomas Middleton (18 Apr 1580 – Jul 1627; was an English Jacobean playwright and poet. Middleton stands with John Fletcher and Ben Jonson among the most successful and prolific of the playwrights at work during the Jacobean period. He was among the few to achieve equal success in comedy and tragedy, and a prolific writer of masques and pageants.)
  – “Anything for a quiet life.” 
(Editor’s note: Yesterday we mistakenly reprinted Tuesday’s birthday quotations rather than yesterday’s new quotation.  We know you don’t want to miss any of them, so below is the one I intended to run yesterday.)

* Anatole France (born François-Anatole Thibault; 16 Apr 1844 – 12 Oct 1924; was a French poet, journalist, and novelist with several best-sellers. Ironic and skeptical, he was considered in his day the ideal French man of letters. He was a member of the Académie Française, and won the 1921 Nobel Prize in Literature “in recognition of his brilliant literary achievements, characterized as they are by a nobility of style, a profound human sympathy, grace, and a true Gallic temperament”.)
 – “An education isn’t how much you have committed to memory, or even how much you know. It’s being able to differentiate between what you know and what you don’t.”
  – “We do not know what to do with this short life, yet we want another which will be eternal.”


Friday funnies:
* When you lose your children in the house, turn off the wi-fi.  They’ll come out immediately.
* When your wife is mowing the lawn, that’s not the best time to ask her when dinner will be ready.
* Home quarantine advice:  Every few days, try on your jeans to see if they still fit.  Pajamas will have you believe all is well in the kingdom.
* This quarantine has turned us into dogs.  We roam the house all day looking for food.  We are told “no!” if we get close to strangers, and we get excited about car rides.
* In another few weeks of confinement, 88% of the blondes will have disappeared from the earth.

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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

10 Apr 2020:
85 FR 20158:

North Korea 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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