20-0626 Friday “Daily Bugle”

20-0626 Friday “Daily Bugle”

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Friday, 26 June 2020

  1. State: “Sanctions Actions Blocking Property and Suspending Entry of Certain Persons Contributing to the Situation in Syria”
  2. USTR: “Comments Requested on Extension of 301 Exclusions”
  3. USTR: “Enforcement of U.S. Rights in WTO Large Civil Aircraft Dispute”
  1. Items Scheduled for Future Federal Register Edition
  2. Commerce/BIS: (No new postings)
  3. Commerce/Census: “EAR § 758.1 Revised to Require EEI Filing for Exports to China, Russia, or Venezuela Regardless of Value”
  4. State/DDTC: (No new postings)
  1. EU Sanctions: “UN Panel Report on DRC Arms Embargo Violations & Gold Smuggling”
  2. WSJ: “Senate Passes Sanctions Bill on China Over Hong Kong Law”
  1. GRV&R: “CBP Proposes To Deputize Customs Brokers”
  2. Midwest Trade Law: “What’s the Deal on Dealing with Huawei?”
  1. ECS Presents Webinar: 7-8 Jul; “ITAR/EAR Boot Camp — Achieving Compliance”
  2. Friday List of Approaching Events: 215 Events Posted This Week, Including 10 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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Federal Register, 26 Jun 2020)[Excerpts]
85 FR 38481: Notice
* SUMMARY: The Secretary of State imposed sanctions on fifteen individuals pursuant to E.O. 13894, Blocking Property and Suspending Entry of Certain Persons Contributing to the Situation in Syria.
* DATES: The Secretary of State’s determination and selection of certain sanctions to be imposed upon the one individual identified in the SUPPLEMENTARY INFORMATION section are effective on June 17, 2020.
* FOR FURTHER INFORMATION CONTACT: Taylor Ruggles, Director, Office of Economic Sanctions Policy and Implementation, Bureau of Economic and Business Affairs, Department of State, Washington, DC 20520, tel.: (202) 647 7677, email: RugglesTV@state.gov.

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

Federal Register, 26 Jun 2020)[Excerpts]
85 FR 38482: Notice
* AGENCY: Office of the United States Trade Representative.
* ACTION: Notice and request for comments.
* SUMMARY: On August 20, 2019, at the direction of the President, the U.S. Trade Representative determined to modify the action being taken in the Section 301 investigation of China’s acts, policies, and practices related to technology transfer, intellectual property, and innovation by imposing additional duties of 10 percent ad valorem on goods of China with an annual trade value of approximately $300 billion. The additional duties on products in List 1, which is set out in Annex A of that action, became effective on September 1, 2019. On August 30, 2019, at the direction of the President, the U.S. Trade Representative determined to increase the rate of the additional duty applicable to the tariff subheadings covered by the action announced in the August 20 notice from 10 to 15 percent. On January 22, 2020, the U.S. Trade Representative determined to reduce the rate from 15 to 7.5 percent. The U.S. Trade Representative initiated a product exclusion process in October 2019, and as of June 12, 2020, had issued five product exclusion notices under this action. The product exclusions granted under these notices are scheduled to expire on September 1, 2020. The U.S. Trade Representative has decided to consider a possible extension for up to 12 months of particular exclusions granted under these initial five product exclusion notices. The Office of the U.S. Trade Representative (USTR) invites public comment on whether to extend particular exclusions.
* DATES: July 1, 2020: The public docket on the web portal at https://comments.USTR.gov will open for parties to submit comments on the possible extension of particular exclusions.
July 30, 2020 at 11:59 p.m. ET: To be assured of consideration, submit written comments on the public docket by this deadline.
* ADDRESSES: You must submit all comments through the online portal: https://comments.USTR.gov.
* FOR FURTHER INFORMATION CONTACT: Associate General Counsel Philip Butler or Assistant General Counsel Benjamin Allen at (202) 395-5725.

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

EXIM_a33. USTR: “Enforcement of Rights of U.S. in WTO Large Civil Aircraft Dispute”

85 FR 38488: Notice
* AGENCY: Office of the United States Trade Representative.
* ACTION: Request for comments.
* SUMMARY: The U.S. Trade Representative is conducting a review of the action being taken in the Section 301 investigation involving the enforcement of U.S. World Trade Organization (WTO) rights in the Large Civil Aircraft dispute. In connection with this review, the U.S. Trade Representative is considering modifying the list of products of certain current or former European Union (EU) member States that currently are subject to additional duties. Annex I to this notice contains the list of products currently subject to additional duties. Annex II contains a list of products, originally published in the April and July 2019 notices in this investigation, under consideration but not currently subject to additional duties. Annex III contains a new list of products being considered for imposition of additional duties. The Office of the United States Trade Representative (USTR) requests comments with respect to whether products listed in Annex I should be removed from the list or remain on the list; whether the rate of additional duty on specific products should be increased, up to a level of 100 percent; whether additional duties should be imposed on specific products listed in Annex II or Annex III; and on the rate of additional duty of up to 100 percent to be applied to any products drawn from Annex II or Annex III. On June 26, 2020, USTR is opening an electronic portal for submission of comments regarding the review of the action.
* DATES: June 26, 2020: The docket entitled “Comments Concerning the Enforcement of U.S. WTO Rights in Large Civil Aircraft Dispute” will open on USTR’s comment portal: https://comments.ustr.gov/s/.
July 26, 2020: To be assured of consideration, you must submit comments by this date.
* ADDRESSES: You must submit comments through the online comment portal: https://comments.ustr.gov/s/. Follow the instructions for submitting comments in section D below. For issues with on-line submissions, please contact the USTR Section 301 line at (202) 395-5725.

* FOR FURTHER INFORMATION CONTACT: For questions about the investigation, contact Associate General Counsel Megan Grimball at (202) 395-5725, or Director for Europe Michael Rogers at (202) 395-3320. For questions on customs classification of products identified in the annexes to this notice, contact Traderemedy@cbp.dhs.gov.

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(Source: Federal Register)

* Treasury/OFAC: NOTICES; Blocking or Unblocking of Persons and Properties [Pub. Date: 29 Jun 2020] (PDF)

* USTR: NOTICES; Determination Regarding Waiver of Discriminatory Purchasing Requirements with Respects to Goods and Services Covered by Chapter Thirteen of the United States-Mexico-Canada Agreement [Pub. Date: 29 Jun 2020] (PDF)

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OGS_a25. Commerce/BIS: (No new postings)

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

6. Commerce/Census: “EAR
§ 758.1 Revised to /require EEI Filing for Exports to China, Russia, or Venezuela Regardless of Value”
U.S. Census Bureau, 26 Jun 2020)  
   On Tuesday, April 28, 2020, the Department of Commerce, Bureau of Industry and Security published a final rule (https://www.govinfo.gov/content/pkg/FR-2020-04-28/pdf/2020-07241.pdf) that will become effective on Monday, June 29, 2020.  As a result of this rule, the following changes to the filing requirements in the Automated Export System (AES) will be made in order for exporters and authorized agents to successfully report electronic export information. Effective on Monday, June 29, 2020
  • The Electronic Export Information (EEI) filing requirement for items subject to Supplement No. 2 to Part 744 destined for China, Russia, and Venezuela will become effective on June 29, 2020.  Review Supplement No. 2 to Part 744:https://www.govinfo.gov/content/pkg/FR-2020-04-28/pdf/2020-07241.pdf#page=6
  • EEI filing for exports to China, Russia, or Venezuela of items controlled by Export Control Classification Numbers (ECCNs) not listed in Supplement No. 2 to Part 744 will not be required until Sunday, September 27, 2020.  
Background on the EEI filing Requirement to China, Russia, Venezuela
   This rule expands Electronic Export Information (EEI) filing requirements in the Automated Export System (AES) for exports to China, Russia, or Venezuela. Existing provisions exempt exporters from both filing EEI for many shipments valued under $2,500 (unless an export license is required) and from entering the ECCN in the EEI when the reason for control is only anti-terrorism (AT).
To promote transparency with respect to shipments to these destinations, this rule revises § 758.1 of the EAR to require filing for items on the Commerce Control List (CCL) destined to China, Russia, or Venezuela regardless of the value of the shipment, unless the shipment is eligible for License Exception GOV.
  In addition, even if no license is required to ship a CCL item to those destinations, the EEI filing must include the correct ECCN regardless of reason for control. Certain exemptions from filing found in both the EAR and Foreign Trade Regulations (see § 758.1(c) of the EAR), such as for personally-owned baggage, are retained in this rule.
   For the entirety of the rule, visit
   For general questions regarding AES, contact the Economic Management Division (EMD) at the Bureau of the Census at 1-800-549-0595, option 1.
  A complete list of all of the AES License Type codes and reporting instructions for these types can be found at
   For questions regarding these upcoming AES changes, contact the Bureau of Industry and Security at:  
   – Outreach and Educational Services Division (located in Washington, DC) (202) 482-4811
   – Office of Technology Evaluation (located in Washington, DC): (202) 482-4933
   – Western Regional Office (located in Irvine, CA) (949) 660-0144
   – Northern California branch (located in San Jose, CA) (408) 998-8806

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EU Sanctions, 26 Jun 2020) [Excerpts]
   The UN Panel of Experts on the Democratic Republic of Congo has issued its 2020
final report. It says that “several countries offered military training and delivered significant quantities of arms, ammunition, equipment and military vehicles to armed forces” without notifying the UNSC Sanctions Committee, as is required under
resolution 1533 (2004).

The DRC Sanctions Committee also expressed concern about the volume of gold being illicitly exported from the DRC, and said such activities are benefitting armed groups. The
press release
calls on member states to ensure compliance with the due diligence obligations in
resolution 1952 (2010)
by strengthening company management systems, identifying and responding to risks within supply chains, and conducting independent audits.

The Wall Street Journal, 26 Jun 2020) [Excerpts]

  The U.S. Senate passed by unanimous consent a bipartisan bill that would put sanctions on Chinese officials who erode Hong Kong’s limited autonomy from Beijing, as well as the banks and firms that do business with them.

  Because it sets mandatory sanctions, the legislation has drawn objections from Trump administration officials concerned it could hobble their ability to conduct diplomacy with China and give Congress too much power over foreign relations, according to congressional, administration and industry officials. …


COM_a110. GRV&R: “CBP Proposes To Deputize Customs Brokers”

* Principle Author: Oscar Gonzalez, Esq., Gonzalez, Rolon, Valdespino, & Rodriguez, LLC;
214-720-7720 or
   CBP is about to overhaul the way customs brokers conduct business.  The proposed regulations are far-reaching, but they are not yet final. If you want to submit a written comment to CBP, you have until August 4, 2020. The proposed amendments and the instructions for submitting comments can be found in the Federal Register Notice of June 5, 2020. See
  My law firm will be hosting a free webinar on July 14, 2020 explaining the new regulations (see internationaltrade.law), but perhaps the most pivotal change, and it is barely mentioned in the proposed regulations, is that CBP is effectively deputizing customs brokers. Custom brokers will be required to turn in to CBP any client who, in the broker’s estimation, is attempting to defraud or otherwise commit any criminal act against the U.S. Government. Is misclassification an “attempt to defraud?” How about exploring with an importer legal methods to decrease the amount of antidumping duties that the importer pays? The relationship between importers and customs brokers is already tense when potential violations arise. Forcing customs brokers to snitch on their clients will certainly complicate the relationship further.

Here are more changes that CBP is proposing:

  • Eliminate district permits and allow a national permit holder to conduct any type of customs business within the customs territory of the United States.
  • Any applicant who obtains a passing grade on the examination for an individual broker’s license may apply for a national permit. The national permit application may be submitted concurrently with or after the submission of an application for a broker’s license.
  • Increase the broker license application from a base of $200 to $300 for individuals and $500 for business entities. 
  • Customs broker must designate a recordkeeping contact who must be a knowledgeable employee who will serve as the party responsible for broker-wide financial and recordkeeping requirements.
  • Customs broker must employ a sufficient number of licensed brokers relative to the job complexity, similarity of subordinate tasks, physical proximity of subordinates, abilities and skills of employees, and abilities and skills of the managers.
  • Simply maintaining current editions of the relevant laws and regulations does not indicate responsible supervision and control, ensuring access to these documents, whether hard copy or electronic, is more important in determining responsible supervision and control.

COM_a211. Midwest Trade Law: “What’s the Deal on Dealing with Huawei?”

Midwest Trade Law, 25 June 2020)


* Author:
Valentin. A Povarchuk, Esq., 1-651-237-2173,
Midwest Trade Law 
  In the wake of multiple rounds of increasing restrictions by the U.S. government on trade with the Chinese telecommunications giant Huawei and its subsidiaries, your company may be led to believe that any transaction with Huawei or participation in the Huawei supply chain is now prohibited.  In fact, that is not so.  Indeed, the United States government regards Huawei as a serious geopolitical and national security threat to U.S. interests and severely restricts the ability of U.S. businesses to deal with Huawei.  Moreover, there appears to be a bipartisan consensus on this policy direction in Washington, which means the United States is unlikely to back off this policy any time soon.  Nevertheless, the restrictions on dealing with Huawei at this time are not all-encompassing.  It is important for industry actors to understand that certain activities are still permitted.
  So what is restricted, and what is still permitted in dealing with Huawei?  Reader, please bear with me.
Buying Huawei equipment
  Strictly speaking, pursuant to the Federal Acquisition Regulations rule published on August 13, 2019, the ban on buying Huawei telecommunications equipment (as well as the equipment of ZTE, Hytera Communications Corporation, Hangzhou Hikvision Digital Technology Company, and Dahua Technology Company), applies only in connection with the performance of U.S. government contracts.  U.S. government agencies may grant waivers from this prohibition where network security is not at issue through August 13, 2021.
Does this mean that private sector companies remain free to buy Huawei equipment for installations not related to U.S. government contracts?  (This is quite pertinent, since the Rural Wireless Association estimates that about 25 percent of rural wireless carriers use Huawei equipment).
   Not so fast.  In May 2019 President Trump signed Executive Order 13873, which prohibits “any acquisition, importation, transfer, installation, dealing in, or use of any information and communications technology or service (transaction) by any person . . . subject to the jurisdiction of the United States” if such a transaction involves telecommunications technology developed by a foreign person subject to the jurisdiction of a “foreign adversary.”  On November 27, 2019, the U.S. Department of Commerce published a proposed rule on “Securing the Information and Communications Technology and Services Supply Chain” to implement Executive Order 13873.  The regulation, if it is adopted in its current form (which seems likely), will give the Secretary of Commerce sweeping powers to prohibit or require mitigation of transactions involving the acquisition, installation, and even “use” of telecommunications equipment and services provided by a company subject to the jurisdiction of a “foreign adversary.”  The official designation of a “foreign adversary” has not been made as of yet, but there is little doubt that this regulation aims squarely at China and at Huawei.
   In addition, on March 12, 2020, President Trump signed into law the bipartisan Secured and Trusted Communications Networks Act of 2019, which prohibits the use of federal subsidies in connection with the acquisition, rent or lease of telecommunications products and services from companies that present an unacceptable risk to the national security of the United States (again, read “Huawei”).
  Thus, while, technically speaking, acquisition, installation, and use of Huawei telecommunications equipment and services by the private sector currently is not prohibited, there is a high risk that such transactions postdating May 15, 2019 will be determined to be prohibited by the Department of Commerce when its regulation comes into force.  Buying from Huawei is also becoming impracticable for suppliers of rural telecommunications due to the prohibition on federal subsidies to finance such purchases.
Providing U.S. items to Huawei
   The main thrust of the U.S. offensive against Huawei’s ambitions to dominate the global telecommunications market originally consisted of the listing of Huawei and its subsidiaries worldwide on the Entity List on May 16, 2019.  As a result of this listing, “items subject to the EAR,” including any commodity, technology, or software, may not be provided to Huawei without an export license from the Bureau of Industry and Security (“BIS”).  This includes not only items within the possession or control of U.S. persons, but any items “subject to the EAR,” wherever located.
  The rub, of course, is in what items are “subject to the EAR,” or what items are within the jurisdiction of the BIS under the Export Administration Regulations.  This clearly includes any item that has ever been exported from the U.S. territory.  In addition, under the BIS regulations it includes foreign-produced items that contain 25 percent or more of export-controlled U.S. content.
  The term “items subject to the EAR,” however, does not include foreign-produced items (that is, items that undergo a substantial transformation through a manufacturing process such that they acquire origin of a foreign country) that contain less than 25 percent of controlled U.S. content.  In theory, a foreign-produced item may contain even more than 25 percent of of U.S. content, and still not become “subject to the EAR,” if that U.S. content is not export-controlled.
  Thus, providing items to Huawei without a BIS export license (which would be denied) is clearly prohibited if those items were exported from the U.S.  However, it is not necessarily prohibited to supply to Huawei foreign-manufactured items that contain some U.S. content.
Providing foreign items made with U.S. technology
   Historically, under the Foreign Direct Product rule, section 736.2(b)(3) of the EAR (General Prohibition Three), the term “item subject to the EAR” also included foreign-produced items that would be exported to certain higher-risk countries, and were the direct product of a U.S. technology or software controlled for national security reasons and requiring written assurances to support the license application.  This was a fairly limited basis for extending BIS jurisdiction over foreign-produced items, because technology or software controlled for national security reasons and requiring written assurances were but a small subset of export controlled technology and software, and most manufacturing technology and software are not controlled.
Recently, however, BIS significantly expanded General Prohibition Three to include a wider swath of U.S. technology and software that would create BIS jurisdiction for the purposes of dealing with Huawei and its affiliates. The Amendments to General Prohibition Three (Foreign-Produced Direct Product Rule), published on May 15, 2020, will have significant and lasting impacts on semiconductor supply chains.  
   Under the convoluted new rules, which entered force immediately on May 15, a foreign-produced item is now also “subject to the EAR” if it is controlled by the newly-created footnote 1 to the Entity List, and there is knowledge that the item is destined to an entity with a footnote 1 designation (Huawei entities).  The new footnote 1 to the Entity List controls the following:
   (a) Direct products of technology or software

(i)  Foreign-produced item is produced or developed by Huawei or its affiliates, 

(ii) Is a direct product of  ”technology” or ”software” subject to the EAR and specified in ECCN 3E001, 3E002, 3E003, 4E001, 5E001, 3D001, 4D001, or 5D001; of ”technology” subject to the EAR and specified in ECCN 3E991, 4E992, 4E993, or 5E991; or of ”software” subject to the EAR and specified in ECCN 3D991, 4D993, 4D994, or 5D991 (“designated technology”)
(b) Direct product of a plant or major component of a plant
(i) The foreign-produced item is produced by a plant or a major component (which means equipment essential for the production) of a non-U.S. plant, where the plant or its major component itself is a direct product of U.S.-origin designated technology;
(ii) The foreign-produced item is a direct product of software or technology produced or developed by Huawei or its affiliates.
The new rules are designed to target Huawei production that depends on sensitive U.S. technologies, and production of components by third parties for Huawei with the use of equipment that is based on sensitive U.S. technologies.  They may have a much more disruptive impact on the Huawei supply chain than the original designation of Huawei and its affiliates on the Entity List.
Selling into the supply chains that feed Huawei
   Nevertheless, for many players in the electronics and semiconductor industry, it still may be possible to sell their products into the supply chains that ultimately feed Huawei.  These supply chains can be very complex and include many tiers of production.  
   Consider the following scenario:  A U.S. Company A is selling its product X to a non-U.S. manufacturer B.  B uses X to make a new product, Y, which it sells to a non-U.S. manufacturer C.  C conducts further manufacturing on Y, creating a new product Z.  Z is sold to multiple original equipment manufacturers (“OEMs”), including Huawei, which uses it to make the finished product.  If products X, Y, and Z do not have controlled U.S. content, if they are are not direct products of designated controlled U.S. technologies or software, and if manufacturers B and C do not use equipment that is a direct products of designed controlled U.S. technologies or software, then Z is unlikely to be subject to the EAR.  U.S. Company A cannot be charged with exporting product X to Huawei, considering that X undergoes multiple substantial transformations before some of it ends up in Huawei’s finished product.
   Of course, it is necessary to carefully analyze each case of a product that is supplied into the supply chain connected to Huawei.  Among other considerations, legal counsel should review whether U.S. products would be exported abroad for genuine substantial transformations, or in an effort to evade or circumvent U.S. Entity List restrictions.  Yet, as things currently stand, in many cases it will still be possible to conclude that the fact that downstream items that include U.S. content reach Huawei, does not mean that the export of U.S. items violates U.S. law.
Important exceptions from restrictions
   Considering the global scale and market position of Huawei, and the level of integration between certain Huawei products and U.S.-origin products, technology, and software, cutting off Huawei from its U.S. suppliers is a very disruptive and difficult process.  And when it comes to sharing of U.S. technology with Huawei in the context of the work of international standard-setting bodies, it would be folly to completely cut off technology sharing, because it would force U.S. technology companies to cede international standard-setting to Huawei.   With some recognition of that, the U.S. government has allowed for certain exceptions from its rules prohibiting provision of U.S. items to Huawei.
   First, soon after designating Huawei and its affiliates on the Entity List, BIS published a Temporary General License authorizing the continuation of certain transfers to Huawei in derogation of the Entity List.  This Temporary General License is found in Supplement No. 7 to Part 744 of the EAR.  It authorizes:
(1) certain transactions necessary to maintain and support existing and current fully ‘operational network’ and equipment,
(2) Support to existing ‘personal consumer electronic devices’ and ‘Customer Premises Equipment (CPE)’, and
(3) Disclosures for cybersecurity research and vulnerabilities.
Using this TGL requires fulfilling certain certification requirements, including obtaining certifications from Huawei or its affiliated companies.  Recently, the date of expiration of the TGL was extended from May 15, 2020, to August 13, 2020.
  Second, last week BIS revised the Entity List designations for Huawei and its affiliates once again, to permit sharing of technical information for “technology subject to the EAR that is designated as EAR99, or controlled on the Commerce Control List for anti-terrorism reasons only, when released to members of a ‘standards organization’ (see §
772.1) for the purpose of contributing to the revision or development of a ‘standard’ (see §
772.1).”  This revision is intended to allow U.S. companies and persons to share technology in the context of international standard-setting organizations in which Huawei participates.  Given that Huawei has become a key and often the dominant player in the development of 5G network technology and associated standards, this concession will help U.S. companies to keep their seats at the table of standard-setting, rather than help Huawei.
   Huawei and certain other Chinese telecommunications and high tech companies are seen as geopolitical, industrial, and national security threats by many in the U.S. government and in other governments around the world.  Accordingly, U.S. policymakers are tightening restrictions, and continuing trade and technology transactions entails substantial risk.  Nevertheless, it is a fact of life that Huawei plays a key and sometimes dominant role in the development of modern telecommunications networks, and dealing with Huawei is sometimes unavoidable for many market players.  In many cases, it is still possible and legal.  Even for activities that are subject to restrictions, certain exceptions and phaseout periods exist.
   The United States government could make restrictions on dealing with Huawei more comprehensive by designating it as a restricted person subject to Office of Foreign Assets Control (“OFAC”) sanctions.  If that happens, virtually every transaction by a U.S. person ultimately destined to benefit Huawei, directly or indirectly, would likely be prohibited.  There are signs that many in the U.S. government wish to move in this direction.  But we are not there yet, and there are many in the industry who would oppose such comprehensive sanctions on Huawei.


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

*Presenter: Suzanne Palmer, Mal Zerden

 or by calling
866-238-4018 or email 

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

(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, so we are displaying here only the new events in the Daily Bugle, while maintaining a 
LINK HERE to the full list.]


* 29 Jun: “
CBP USMCA Webinar Q&A Follow-up
; Customs and Border Protection

* 30 Jun : “
USMCA: Launching a New Phase of Prosperity in North America
“; Wilson
Center’s Mexico Institute and Canada Institute
* 30 Jun: “
Managing Conflicts in Laws and Enforcement Risk
“; Baker McKenzie
* 9 Jul: “
Customs Brokerage in 2020 – New Regulations and Best Practices
“; Sandler, Travis & Rosenberg
* 14 Jul: “
Antidumping 101: Minimizing Risk, Maximizing Compliance
“; Sandler, Travis & Rosenberg
* 16 Jul: “
CBMA: How to Properly File Claims
“; CBP
* 21 Jul: “
The Latest Issues in OFAC and EAR Enforcement
“; Export Compliance Training Institute (ECTI)
* 26 Aug: “
Import 101 for Aerospace Professionals
“; Export Compliance Training Institute (ECTI)
* 1 Sep: “
Methods of Payment & Letters of Credit
“; Chamber International

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EN_a114. Bartlett’s Unfamiliar Quotations

(Source: Editor)

* Lord Kelvin (William Thomson, 1st Baron Kelvin, OM, GCVO, PC, PRS, FRSE (26 June 1824 – 17 December 1907) was a British mathematical physicist and engineer.  He did important work in the mathematical analysis of electricity and formulation of the first and second laws of thermodynamics, and did much to unify the emerging discipline of physics in its modern form.  Absolute temperatures are stated in units of kelvin in his honor.)
– “Heavier-than-air flying machines are impossible.”
 – “In science there is only physics; all the rest is stamp collecting.”
Friday funnies:
A middle-aged man sat alone at a bar, glumly staring at his drink. A young Hell’s Angel biker stepped next to him, grabbed his beer, and grinning, gulped it down. The small man started crying. The biker says, “Come on man, I was just joking. Here, I’ll buy you another beer! I can’t stand to see a grown man cry!” “No, I don’t want another beer,” said the man. “I’m crying because today is the worst of my life! First, I was late to work because I had a doctor’s appointment and found out I have colon cancer. When I got to work my boss fired me for being late again, refusing to even listen to why I was late. When I left the building, I found out my car had been stolen, and I don’t have theft insurance. I hitched a ride home, but I left my wallet with all my separation pay in the car I rode home in. And when I walked in the house to tell my wife about my horrible day, I find a note from her saying she has run off with the gardener. So I leave home, come to this bar, and order a beer. And just when I was about to end my miserable life, you show up and drink all my poison!”

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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. 
DOC FOREIGN TRADE REGULATIONS (FTR): 15 CFR Part 30.   24 Apr 2018: 83 FR 17749: Foreign Trade Regulations (FTR): Clarification on the Collection and Confidentiality of Kimberley Process Certificates.  

: 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. 

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

5 Jun 2020:
85 FR 84510:

Syria 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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