20-0515 Friday “Daily Bugle”

20-0515 Friday “Daily Bugle”

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Friday, 15 May 2020

  1. DHS/CBP: “Revocation of Customs Brokers’ Licenses”
  2. USTR: “Product Exclusion Extensions”
  1. Items Scheduled for Future Federal Register Edition
  2. Commerce/BIS Addresses Huawei’s Efforts to Undermine Entity List, Restricts Products Designed and Produced with U.S. Technologies
  3. Commerce/BIS Issues Expected Final 90-Day Extension of Temporary General License Authorizations
  4. State/DDTC: Outage Notice for Monday, 18 May
  5. State/DDTC: “DTAG Plenary Session Presents Analyses and Recommendations to DDTC”
  6. Australia Defence Industry: “Going Global–Helping Small Defence Businesses Become Export-Ready”
  7. UK DIT: “Understanding and Measuring Cross-border Digital Trade”
  1. WORLDecr: “US to Investigate Mobile Crane Imports as Possible National Security Threat”
  1. EU Sanctions: “OFAC Updates Listing Information for 490 N. Korea SDNs”
  2. Kelley Drye: “U.S. Treasury Lifts Sanctions on Nynas AB”
  3. Husch Blackwell: “Petition Summary–Passenger Vehicle and Light Truck Tires from Korea, Taiwan, Thailand, and Vietnam”
  1. ECS Presents Webinar “ITAR/EAR Boot Camp– Achieving Compliance”: 7-8 Jul
  2. FCC Academy Presents June Webinars: “U.S. Export Controls: ITAR, EAR, and FMS”
  3. Friday List of Approaching Events: 146 Events Posted This Week, Including 8 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 
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Federal Register, 15 May 2020) [Excerpts]
* 85 FR 29468: Revocation of Customs Brokers’ Licenses
* AGENCY:U.S. Customs and Border Protection, Department of Homeland Security.
* ACTION:Revocation of customs brokers’ licenses.
* SUMMARY:This document provides notice of the revocation by operation of law of customs brokers’ licenses.
* FOR FURTHER INFORMATION CONTACT:Melba Hubbard, Branch Chief, Broker Management, Office of Trade, (202) 325-6986, 
* SUPPLEMENTARY INFORMATION:This document provides notice that, pursuant to section 641 of the Tariff Act of 1930, as amended (
19 U.S.C. 1641), and section 111.30(d) of title 19 of the Code of Federal Regulations (
19 CFR 111.30(d)), the following customs brokers’ licenses were revoked by operation of law, without prejudice, for failure to file a triennial status report. A list of revoked customs brokers’ licenses appears below with both the port, which issued the licenses, and the brokers’ names within the port of issuance whose licenses were revoked, set forth alphabetically.

Last name
First name
Port of issuance
Dennis W
Roberta L
Joni S
This document further provides notice that, pursuant to
19 U.S.C. 1641
19 CFR 111.45(a), the following customs brokers’ licenses and all associated permits were revoked by operation of law for failure to employ at least one qualifying individual who holds a valid customs broker’s license. A list of revoked customs brokers’ licenses appears below with both the port, which issued the licenses, and the brokers’ names within the port of issuance whose licenses were revoked, set forth alphabetically.

Company name
Port of issuance
Franklin Global Strategies
Anji Logistics USA Inc

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Federal Register, 15 May 2020) [Excerpts]

* 85 FR 29503: Notice of product exclusion extensions.
*AGENCY: Office of the United States Trade Representative.
* ACTION: Notice of product exclusion extensions.
* SUMMARY: Effective July 6, 2018, the U.S. Trade Representative imposed additional duties on goods of China with an annual trade value of approximately $34 billion as part of the action in the Section 301 investigation of China’s acts, policies, and practices related to technology transfer, intellectual property, and innovation. The U.S. Trade Representative initiated the exclusion process in July 2018 and, to date, has granted 10 sets of exclusions under the $34 billion action. The fourth set of exclusions was published in May 2019 and will expire in May 2020. On March 12, 2020, the U.S. Trade Representative established a process for the public to comment on whether to extend particular exclusions granted in May 2019 for up to 12 months. This notice announces the U.S. Trade Representative’s determination to extend certain exclusions until December 31, 2020.
* DATES: The product exclusion extensions announced in this notice will apply as of May 14, 2020, and extend until December 31, 2020. U.S. Customs and Border Protection will issue instructions on entry guidance and implementation.
* FOR FURTHER INFORMATION CONTACT: For general questions about this notice, contact Assistant General Counsels Philip Butler or Benjamin Allen, or Director of Industrial Goods Justin Hoffmann at (202) 395-5725. For specific questions on customs classification or implementation of the product exclusions identified in the Annex to this notice, contact traderemedy@cbp.dhs.gov.

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* Commerce/BIS: RULES; Temporary General License: Extension of Validity [Pub. Date: 18 May 2020] (PDF)
* DHS/CBP: NOTICES; Revocation of Customs Brokers’ Licenses; Correction [Pub. Date: 18 May 2020] (PDF)
* Justice/ATF: NOTICES; International Trade Data System Test: Cessation of Voluntary Export Pilot Project [Pub. Date: 18 May 2020] (

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, 14 May 2020)
The Bureau of Industry and Security (BIS) today announced plans to protect U.S. national security by restricting Huawei’s ability to use U.S. technology and software to design and manufacture its semiconductors abroad. This announcement cuts off Huawei’s efforts to undermine U.S. export controls. BIS is amending its longstanding foreign-produced direct product rule and the Entity List to narrowly and strategically target Huawei’s acquisition of semiconductors that are the direct product of certain U.S. software and technology. 

Since 2019 when BIS added Huawei Technologies and 114 of its overseas-related affiliates to the Entity List, companies wishing to export U.S. items were required to obtain a license. However, Huawei has continued to use U.S. software and technology to design semiconductors, undermining the national security and foreign policy purposes of the Entity List by commissioning their production in overseas foundries using U.S. equipment.

“Despite the Entity List actions the Department took last year, Huawei and its foreign affiliates have stepped-up efforts to undermine these national security-based restrictions through an indigenization effort.  However, that effort is still dependent on U.S. technologies,” said Secretary of Commerce Wilbur Ross.  “This is not how a responsible global corporate citizen behaves.  We must amend our rules exploited by Huawei and HiSilicon and prevent U.S. technologies from enabling malign activities contrary to U.S. national security and foreign policy interests.”
  •   Specifically, this targeted rule change will make the following foreign-produced items subject to the Export Administration Regulations (EAR): (i)Items, such as semiconductor designs, when produced by Huawei and its affiliates on the Entity List (e.g., HiSilicon), that are the direct product of certain U.S. Commerce Control List (CCL) software and technology; and
  • Items, such as chipsets, when produced from the design specifications of Huawei or an affiliate on the Entity List (e.g., HiSilicon), that are the direct product of certain CCL semiconductor manufacturing equipment located outside the United States.  Such foreign-produced items will only require a license when there is knowledge that they are destined for reexport, export from abroad, or transfer (in-country) to Huawei or any of its affiliates on the Entity List.
To prevent immediate adverse economic impacts on foreign foundries utilizing U.S. semiconductor manufacturing equipment that have initiated any production step for items based on Huawei design specifications as of [date of rule effective date], such foreign-produced items are not subject to these new licensing requirements so long as they are reexported, exported from abroad, or transferred (in-country) by 120 days from the effective date.

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, 14 May 2020)
The U.S. Department of Commerce announced today it is extending the terms of the existing Temporary General License (TGL) authorizations for Huawei Technologies Co. Ltd. and its non-U.S. affiliates (Huawei) on the Entity List for 90 days.  The terms and duration of any future general licenses will be announced prior to the expiration of this 90-day time period.
This announcement follows public comments received from numerous companies, associations, and individuals about the TGL. The Department continues to assess the national security and foreign policy implications of companies and individuals that have not yet transitioned from Huawei equipment. 
The 90-day extension provides an opportunity for users of Huawei devices and telecommunication providers-particularly those in rural U.S. communities-to continue to temporarily operate such devices and existing networks while hastening the transition to alternative suppliers. 
In announcing this extension, the Department is also notifying the public that activities authorized in the TGL may be revised and possibly eliminated after August 13, 2020. Companies and persons relying on TGL authorizations should begin preparations to determine the specific, quantifiable impact of elimination if they have not done so already.  Those companies and persons should be prepared to submit license applications to the Department to determine which, if any, activities will be authorized in the event that their TGL authorization is eliminated.  The Department will provide prior notice via the Federal Register of a need to submit such applications.
The Bureau of Industry and Security (BIS) in the Department of Commerce is responsible for overseeing these export control activities. BIS’s mission is to advance U.S. national security and foreign policy objectives by ensuring an effective export control and treaty compliance system and promoting continued U.S. strategic technology leadership. BIS is committed to restricting U.S.-origin commodities and technology from use in support of Weapons of Mass Destruction projects, terrorism, or destabilizing military modernization programs. For more information, please visit 

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Outage Notice: The Defense Export Control and Compliance (DECCS) Registration and Licensing applications will be unavailable to industry from 6:00 AM (EDT) through 8:00 AM (EDT) Monday, May 18 for scheduled system maintenance. Please ensure work in progress is saved prior to the scheduled downtime.

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OGS_a57. State/DDTC: “DTAG Plenary Session Presents Analyses and Recommendations to DDTC”
(Source: Daily Bugle Editor, from DDTC On-line session)

On May 14, 2020, the State Department’s Directorate of Defense Trade Controls (DDTC) presented an approximately 3-hour public plenary on-line meeting with the 
Defense Trade Advisory Group (DTAG), an advisory group of approximately 50 members of the public appointed by the Assistant Secretary of State to provide a formal channel for regular consultation and coordination with U.S. private sector defense exporters and defense trade specialists on issues involving U.S. laws, policies, and regulations for exports of defense articles, services, and related technical data.

Responding to a DDTC request, DTAG presented analyses and recommendations to DDTC on the following topics:

Working Group 1 – Compliance Guidelines Update
As a follow-up to the September 29, 2020 Plenary (WG1) presentation on Consent Agreements, State/DDTC requests the DTAG to suggest improvements to its compliance program guidelines.  Such review and analysis can include recommended approaches on how to address compliance programs for large versus small companies, U.S. and non-U.S. companies, manufacturers versus exporters, and different types of industries (e.g., Labs, Universities).  

Working Group 2 – DECCS Implementation. 
On February 18, 2020, State/DDTC launched its new online system, the Defense Export Control and Compliance System (DECCS), version 1.0, for submissions relating to Registration Statements, Licensing, Advisory Opinions and Commodity Jurisdiction requests.   State/DDTC is interested in obtaining industry views on prioritization of enhancements to DECCS 1.0. 

Working Group 3 – Second-Tier Countries (NATO)
As a follow-up to the September 29, 2020 Plenary (WG3) presentation on International Cooperative Programs focusing on the “Five Eyes” countries, State/DDTC would like the DTAG to focus on “Second tier” countries (NATO essentially).  In sum, State/DDTC is seeking recommendations as to how its officers better support interoperability and effective coordination with our NATO allies, as well as to reduce barriers to U.S. competitiveness in the defense markets of NATO member countries.

Working Group 4 – Part 130 Reporting
State/DDTC is requesting the DTAG to explore the possibility of updating the Part 130 reporting rules to reflect the current realities of the international defense trade industry and, at the same time, to increase accuracy and transparency, with a focus on reporting of information required under AECA Section 39(a) on a periodic basis such as semi-annually and on an aggregate basis per recipient with appropriate disclosure of the relevant foreign nation and relevant sale or foreign military program.

The slide presentation presented by DTAG will be published by DDTC on its website in a few days.  The DDTC website link will be posted in the Daily Bugle when available.

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(Source: Australia DEC, 15 May 2020) [Excerpts] 

The Morrison Government is investing in the continued growth of Australia’s defence industry, with small business export grants helping local businesses to pursue new opportunities in global markets.

Minister for Defence Industry, the Hon Melissa Price MP, today announced the latest recipients of the Defence Global Competitiveness Grants. “This funding helps Australian small businesses overcome barriers to accessing export opportunities, and help build their resilience,” Minister Price said.

“By supporting the defence export capability of small and innovative Australian businesses, we are growing our defence industry sector.”These grants are another way the Morrison Government is supporting our defence industry to keep their wheels turning both during and beyond COVID-19.”

Four companies from Queensland, two from South Australia and one each from Tasmania, Victoria and New South Wales are the recipients of a total of nearly $1 million in funding. Minister Price said Pivot Maritime International is the first Tasmanian company to receive a grant under the program, and will use the funding to help build a mission maritime bridge simulator system, opening up additional export opportunities.

“It’s great to see our defence industry growing in all parts of Australia, not just those states with a heavy defence presence,” Minister Price said. 
Heat Treatment Australia will use its grant to build the infrastructure to meet increased demand for testing components supplied internationally for the F-35 program. “Heat Treatment Australia is an excellent example of a small business taking up opportunities in global markets, and how that can lead to businesses growth,” Minister Price said.

“All these companies are a testament to the innovative and competitive spirit of Australia’s defence industry, resulting in greater capability for our Defence Force.” Applications for the Defence Global Competitiveness Grants program can be made at any time through:
www.business.gov.au/dgc. …

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OGS_a79. UK DIT: “Understanding and Measuring Cross-border Digital Trade”
UK Department for International Trade, 14 May 2020)
The research was carried out by Cambridge Econometrics on behalf of the Department for International Trade (DIT) and the Department for Digital, Culture, Media and Sport (DCMS).
Despite the growing importance of cross-border digital trade, little is known about its nature and scale.
The research is the first attempt in the UK to:
  • discuss in a systematic way the measurement challenges in this area
  • compile relevant statistics for the UK and make recommendations for improving these statistics
More specifically, the report:
  • provides an overview of efforts to define the concept of digital trade, focussing especially on the OECD’s ‘Handbook on Measuring Digital Trade
  • reviews the evidence base on digital trade to identify definitional issues; measurement and methodological challenges; coverage of data on digital trade in official statistics and their associated strengths and weaknesses; and non-conventional methods to estimate the value of digital trade (such as credit card data)
  • identifies possible sources of data on digital trade and compiles relevant statistics for the UK
  • identifies data gaps and proposes ways to fill them
Read the document

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NWS_a110. WORLDecr: “US to Investigate Mobile Crane Imports as Possible National Security Threat”
WORLDecr, 14 May 2020) [Excerpts]
The United States has identified mobile cranes as a critical industry because of their extensive use in national defense applications and other critical infrastructure and will begin an investigation into whether their imports threaten to impair national security, the US Department of Commerce has said.
‘We will conduct this review thoroughly and expeditiously,’ said Commerce Secretary Wilbur Ross. ‘This investigation will help determine whether mobile cranes are being imported in such quantities or under such circumstances as to threaten to impair U.S. national security.’
‘The Department of Homeland Security has identified mobile cranes as a critical industry because of their extensive use in national defense applications, as well as in critical infrastructure sectors,’ the Commerce Department said in the 6 May news release.
The decision to launch an investigation follows a petition filed by US producer, The Manitowoc Company, which alleges that increased imports of low-priced mobile cranes from Germany, Austria and Japan, and intellectual property infringement by foreign competition, have harmed the domestic mobile crane manufacturing industry.
Manitowoc claims that low-priced imports and IP infringement resulted in the closure of one of its two production facilities in the United States and eliminated hundreds of skilled manufacturing jobs in Wisconsin.
Manitowoc cites the US International Trade Commission’s (‘USITC’) Dataweb to note that imports of mobile cranes increased by 152% between 2014 and 2019, and a 2015 finding that a Chinese manufacturer misappropriated six trade secrets and infringed on a patent, resulting in the USITC banning the sale of a Chinese crane in the United States.
The investigation will be launched under Section 232 of the Trade Expansion Act, whose purpose is to determine the effect of imports on national security.
The investigation will be conducted by the Department’s Bureau of Industry and Security and will provide the opportunity for public comment once the rule is posted in the Federal Register, the Commerce Department said.


COM_a111. EU Sanctions: “OFAC Updates Listing Information for 490 N. Korea SDNs”
EU Sanctions,
15 May 2020)
* Author: 
Michael O’Kane
, 44-20-7822-7777, 
Peters & Peters
OFAC has 
updated the listing information for 490 Specially Designated Nationals subject to sanctions on North Korea to include the following: “Transactions Prohibited For Persons Owned or Controlled by U.S. Financial Institutions: North Korea Sanctions Regulations section 510.214”. This serves to remind non-US subsidiaries of US financial institutions of the recent amendments to the North Korea Sanctions and Policy Enhancement Act (NKSPEA), which prohibit such subsidiaries from knowingly engaging in financial transactions with people/entities listed under N Korea sanctions (see 

Kelley Drye,
May 2020)
* Principal Author: Eric McClafferty1-212-808-7759Kelley Drye & Warren LLP 
On May 12, 2020, the
U.S. Treasury’s Office of Foreign Assets Control (“OFAC”) announced
 that U.S. persons no longer need OFAC authorization to engage in
dealings with Nynas AB, provided such activities do not involve blocked persons or otherwise prohibited activities.  Further, Nynas AB is no longer subject to U
.S. blocking sanctions as the entity has restructured and is no longer majority-owned by a sanctioned party.
Below are the specific changes:
  • OFAC revoked General License (GL) 13E, “Authorizing Certain Activities Involving Nynas AB,” as it is no longer needed.

  • OFAC issued GL 3H (“Authorizing Transactions Related to, Provision of Financing for, and Other Dealings in Certain Bonds”), which replaces and supersedes GL 3G.  The only change was to remove Nynas AB, which was previously excepted from the GL’s authorization. The GL continues to have restrictions on bonds issued by PDV Holding, Inc. and CITGO.
  • OFAC similarly issued GL 9G (“Authorizing Transactions Related to Dealings in Certain Securities”), replacing and superseding GL 9F, to remove the reference to Nynas AB, meaning that the authorization applies to Nynas AB-issued securities that otherwise meet the criteria set forth in the GL. The GL continues to have restrictions on securities issued by PDV Holding, Inc. and CITGO.
OFAC emphasizes that absent agency authorization, U.S. persons continue to be prohibited from engaging in activities with Petróleos de Venezuela, S.A. (PdVSA), or entities in which PdVSA owns, directly or indirectly, a 50 percent or greater interest.

International Trade Insights, 13 May 2020)
* Principal Author:
Turner Kim
, 1-202-378-2410,
Husch Blackwell LLP

On May 13, 2020, United Steel, Paper and Foresty, Rubber, Manufacturing, Energy, Allied Industrial and Service Workers International Union, AFL-CIO, CLC (“Petitioners”), filed a petition for the imposition of antidumping duties on passenger vehicle and light truck tires (“PVLT tires”) from Korea, Taiwan, Thailand, and Vietnam. In addition, the petition alleges that imports of PVLT tires from Vietnam are unfairly subsidized and requests the imposition of countervailing duties.  

The scope of these investigations is passenger vehicle and light truck tires. Passenger vehicle and light truck tires are new pneumatic tires, of rubber, with a passenger vehicle or light truck size designation. Tires covered by these orders may be tube-type, tubeless, radial, or nonradial, and they may be intended for sale to original equipment manufacturers or the replacement market.  . . .


*When: 7-8
*Sponsor: Export Compliance Solutions & Consulting

*Presenter: Suzanne Palmer, Mal Zerden

here or by calling 866-238-4018 or email 

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(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.] 

* 19 May:
USMCA/T-MEC Update What You Need to Know
Braumiller Law Group PLLC
* 27 May:
CITBA Annual Meeting
* 3 Jun:
How to Submit a Voluntary Disclosure
; Export Compliance Solutions & Consulting
* 10 Jun:
The Role of the Empowered Official
; Export Compliance Solutions & Consulting
* 25 Jun:
How to Submit a Voluntary Disclosure
; Export Compliance Solutions & Consulting
* 2 Jul:
The Role of the Empowered Official
; Export Compliance Solutions & Consulting
On Location:
* 25-26 Aug:
India Homeland Security Expo 2020
; India Homeland Security

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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.


28 Apr 2020:
85 FR 23470
: Elimination of License Exception Civil End Users (CIV).


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.

6 May 2020: 85 FR 26847, Notice (not an amendment) temporarily reducing the registration fee schedule in ITAR 122.3 until April 30, 2021. 


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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