;

20-0706 Monday “Daily Bugle”

20-0706 Monday “Daily Bugle”

 this copy of the Daily Bugle to others or share 
this subscription link
Monday, 6 July 2020

  1. Justice: “Federal Firearms Licensee Firearms Inventory Theft/Loss Report”
  2. Treasury/OFAC Publishes the Names of One Or More Persons that Have Been Placed on OFAC’s Specially Designated Nationals and Blocked Persons List
  1. Items Scheduled for Future Federal Register Edition
  2. Commerce/BIS: (No new postings)
  3. State/DDTC: (No new postings)
  4. Canada TID: “Canada Takes Action Following Passage Of National Security Legislation for Hong Kong”
  1. Export Compliance Daily: “Industry Should Expect Significant BIS Enforcement of Military Exports Rule, Experts Say”
  1. BakerMcKenzie: “US Suspends EAR License Exceptions and Halts Defense Exports for Hong Kong, Imposes Visa Restrictions in Response to China’s New National Security Law for Hong Kong”
  2. Mayer Brown: “The Hong Kong Autonomy Act”
  3. ST&R Trade Report: “Export Restrictions Imposed on Hong Kong as Chinese Security Measures Advance”
  1. Monday List of Ex/Im Job Openings: 69 Jobs Available -13 New Job Openings This Week
  1. ECTI Presents: Midyear Update on U.S. Export Controls Webinar; 15 Jul
  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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EXIM ITEMS FROM TODAY’S FEDERAL REGISTER

(Source:
Federal Register
) [Excerpts]
 
85 FR 40320
: Notice
 
*
AGENCY:
Bureau of Alcohol, Tobacco, Firearms and Explosives, Department of Justice
*
ACTION:
30-day notice.
*
SUMMARY:
The Department of Justice (DOJ), Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF), will submit the following information collection request to the Office of Management and Budget (OMB) for review and approval in accordance with the Paperwork Reduction Act of 1995.
*
DATES:
Comments are encouraged and will be accepted for an additional 30 days until August 5, 2020.

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

(Source:
Federal Register
) [Excerpts]
 
85 FR 40320
: Notice
 
*
AGENCY:
Bureau of Alcohol, Tobacco, Firearms and Explosives, Department of Justice
*
ACTION:
30-day notice.
*
SUMMARY:
The Department of Justice (DOJ), Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF), will submit the following information collection request to the Office of Management and Budget (OMB) for review and approval in accordance with the Paperwork Reduction Act of 1995.
*
DATES:
Comments are encouraged and will be accepted for an additional 30 days until August 5, 2020.

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

OGS OTHER GOVERNMENT SOURCES

[No relevant items for today]

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

OGS_a24. Commerce/BIS: (No new postings)

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

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

(Source: Canada TID
, 3 Jul 2020
)
 
Statement
July 3, 2020 – Ottawa, Ontario – Global Affairs Canada
The Honourable François-Philippe Champagne, Minister of Foreign Affairs, today issued the following statement:
     “Canada joins the international community in reiterating its serious concern at the passage of national security legislation for Hong Kong by the Standing Committee of the National People’s Congress of China.
     “This legislation was enacted in a secretive process, without the participation of Hong Kong’s legislature, judiciary or people, and in violation of international obligations.
     “This process demonstrated disregard for Hong Kong’s Basic Law and the high degree of autonomy promised for Hong Kong under the ‘one country, two systems’ framework. Hong Kong’s role as a global hub was built on that foundation. Without it, Canada is forced to reassess existing arrangements.
     “Effective immediately, Canada will treat exports of sensitive goods to Hong Kong in the same way as those destined for China. Canada will not permit the export of sensitive military items to Hong Kong.
     “Canada is also suspending the Canada-Hong Kong extradition treaty.
“Finally, we have updated our travel advice for Hong Kong in order to advise Canadians of the potential impacts of the new national security legislation.
“The Government of Canada will continue to work with partners to protect human rights and the rule of law around the world.
     “Canada will continue to support the many meaningful exchanges between Canada and Hong Kong, while standing up for the people of Hong Kong.”

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

COM NEWS

(Source:
Export Compliance Daily
, 6 Jul 2020)
 
Industry should expect the Bureau of Industry and Security to dedicate significant resources to enforcing its new export restrictions on shipments to military end-users and end-uses, export control experts said. Although the rule (see 2004270027), which took effect June 29, increased license restrictions for shipments to China, Russia and Venezuela, companies should expect increased enforcement and monitoring specifically for exports to China as the Trump administration hardens its stance on countering China’s civil-military fusion efforts, the experts said.

COM COMMENTARY

(Source: BakerMcKenzie, 4 Jul 2020)
 
* Principal Author: Alison J. Stafford Powell, Esq.,
1

650

856

5531
,
BakerMcKenzie
 
The US Administration has taken a series of actions in recent days to tighten US export controls for Hong Kong and to sanction Chinese government officials in response to the decision of the Chinese Communist Party (“CCP”) to impose a new national security law for Hong Kong.  Most significantly, these actions put Hong Kong on a par with China with respect to license exception eligibility under the US Export Administration Regulations (“EAR”) by suspending all EAR license exceptions for Hong Kong to the extent different from those available for China. This will increase the need to obtain individual licenses for controlled dual-use exports/reexports to and transfers within Hong Kong. In addition, all defense exports to Hong Kong are being halted on the basis that the US Government “can no longer distinguish between the export of controlled items to Hong Kong or to mainland China.” Finally, visa restrictions will be imposed on certain Chinese government officials determined to be undermining Hong Kong’s autonomy and human rights. These changes mark the most significant step yet in the revocation of Hong Kong’s preferential status under US law.
 
Background
 
(a)
Hong Kong’s Status Under US Law
Under the United States-Hong Kong Policy Act of 1992 (“Hong Kong Policy Act”), Hong Kong is provided “different” treatment by the US government as distinct from the People’s Republic of China, so long as Hong Kong remains “sufficiently autonomous” under the “One Country, Two Systems” principle.  This includes special treatment in areas including but not limited to customs tariffs, export controls, immigration, foreign investment, and extradition.  In May 2020, after Secretary of State Pompeo certified to Congress that Hong Kong is no longer sufficiently autonomous from China to warrant its preferential treatment under US law, the President announced that his Administration would begin reviewing and revoking Hong Kong’s special treatment.  For detailed information on the developments in May 2020, please see our prior blog post here.
 
(b)
The New HK National Security Law
On June 30, 2020, the Standing Committee of the National People’s Congress passed the Law of the People’s Republic of China on Safeguarding National Security in the Hong Kong Special Administrative Region (the “HK National Security Law”). The objectives expressed in the HK National Security Law include safeguarding national security, preventing, stopping and punishing crimes endangering national security, ensuring the implementation of the “One Country, Two Systems” policy, maintaining the prosperity of Hong Kong, and protecting the rights of Hong Kong people.  The HK National Security Law established four crimes: secession, subversion, terrorist activities and collusion with foreign countries or external forces to endanger national security.  The HK National Security Law urges the Hong Kong government to implement further legislation for safeguarding national security as stipulated in the Basic Law of Hong Kong and requires the Hong Kong government to submit an annual report on national security issues to the Central Government of China.  The HK National Security Law also established several governmental bodies to advance, implement, and enforce national security related legislation.  The HK National Security Law, comprising six chapters and 66 articles, has been inserted into Annex III of the Basic Law of Hong Kong, the semi-autonomous region’s mini-constitution.  A summary of the HK National Security Law can be found here.
 
US Government’s Latest Actions and Potential Impact
 
(1)
Suspension of EAR License Exceptions for Hong Kong
On June 29, 2020, US Secretary of Commerce Wilbur Ross announced that China’s heightened security measures on Hong Kong increase the risks that sensitive US technology would be diverted to the People’s Liberation Army or Ministry of State Security.  Following this announcement, on June 30, 2020, the US Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a notice suspending Hong Kong’s eligibility to receive exports, reexports, and transfers of items subject to the EAR under license exceptions that provide differential treatment than those available to China.  
This action was taken pursuant to Section 740.2(b) of the EAR, which provides that all license exceptions are subject to revision, suspension, or revocation, in whole or in part, without notice. Hong Kong’s position in Country Groups A:6 and B on the Country Group chart in Supplement 1 to Part 740 of the EAR has not changed, i.e. Hong Kong has not been moved to Country Group D:1 alongside China.
As a result of the suspension, no items subject to the EAR may be exported/reexported to or transferred within Hong Kong based upon an authorization provided by a license exception, unless the items would otherwise be eligible for a license exception if exported to China; in other words, Hong Kong is now on a parallel footing with China for purposes of determining license exception availability.  Companies that currently rely on EAR license exceptions to make exports/reexports of items subject to US jurisdiction to Hong Kong must carefully review the relevant license exceptions to determine if they remain available for China.  If not, companies must obtain a license before engaging in exports/reexports or in-country transfers involving Hong Kong. Potentially relevant key EAR license exceptions with differential treatment include:  license exceptions LVS, GBS, TSR, APP, GOV, TSU, APR (which an April 28, 2020 proposed rule seeks to remove for China and other D:1 countries), and STA.
While the rule is effective immediately, it provides a savings clause for items that, pursuant to actual orders, were on dock for loading, on lighter, already loaded, or already en route aboard a carrier on June 30, 2020.  
There is also a 60-day transition period for deemed export/reexport transactions involving Hong Kong persons authorized under a license exception prior to June 30, 2020.  Such deemed exports and reexports transactions are authorized until August 28, 2020, so long as proper documentation is maintained showing the Hong Kong person was hired and provided access to technology eligible for Hong Kong before June 30, 2020.
This suspension of EAR license exceptions only affects the availability of license exceptions for Hong Kong; it does not alter the underlying controls for Hong Kong (for example, it does not extend to Hong Kong the recently-expanded military end user and end use controls applicable to China in Part 744.21), nor does it appear to change the license review policies or supporting documentation requirements for Hong Kong in Part 748 of the EAR.
 
(2)
Ending Controlled Defense Exports to Hong Kong
On June 29, 2020, the State Department announced that, effective immediately, it would end exports of US-origin defense equipment to Hong Kong and would take steps toward imposing the same restrictions on US defense and dual-use technologies to Hong Kong as it does for China.  This likely means Hong Kong will be considered as part of China, or be separately added to the list of proscribed destinations, in Section 126.1 of the International Traffic in Arms Regulations (“ITAR”).  Under the ITAR, it is the policy of the United States to deny licenses and other approvals for exports and imports of defense articles and defense services destined for or originating in countries included in Section 126.1 of the ITAR, including China.  Certain other restrictions (e.g., duty to notify of a proposed, final, or actual sale of defense articles or defense services) also apply. 
 
(3)
Visa Restrictions on Chinese Communist Party (“CPP”) Officials  
On June 26, 2020, the State Department announced visa restrictions on CPP officials believed to be “responsible for, or complicit in, undermining Hong Kong’s high degree of autonomy” or “human rights and fundamental freedoms in Hong Kong.”  The visa restrictions apply broadly to “current and former CCP officials,” and potentially to family members of such persons.
 
Hong Kong Strategic Commodities Regulations Circular
The Hong Kong Trade and Industry Department (“TID”) released Strategic Trade Controls Circular No. 5/2020 (“Circular“) on 2 July 2020. Notwithstanding changes to the US rules, the TID emphasized that there would be no change to Hong Kong’s autonomous strategic commodities regime. The Circular also reiterated the announcement by the US BIS that US export authorization (usually in the form of a BIS-issued individual validated license) would now be required for various US-origin items. It also highlighted a non-exhaustive list of Export Control Classification Numbers (“ECCNs”) that require US authorization, including 3A001, 3A002.h, 3B001, 3B002, 3C002.a, 3C005, 3C006, 5A001, and 5B001.
Furthermore, as Hong Kong also independently requires licensing for strategic commodity imports, in-territory transfers and exports (with TID generally requiring demonstration of US authorization before it will grant the Hong Kong license), the Circular also specifically advised that Hong Kong licenses granted on the basis of US Licence Exception GBS will now be unavailable, and that the TID would liaise with relevant Hong Kong licensees for the cancellation of unused licenses.
 
What To Expect Next
In response to the above actions by the US government, the Ministry of Foreign Affairs of China stated that China opposes such actions and will take necessary countermeasures.  Details of such countermeasures are still to come. 
In addition, we may see additional actions against China/Hong Kong from the US government as it calls upon China to “honor its commitments and obligations in the Sino-British Joint Declaration” with respect to Hong Kong. Both State and Commerce have indicated further actions are being evaluated.

(Source:
Mayer Brown
, 4 Jul 2020)
 
* Principal Author:
Duncan A. W. Abate
, Esq.,
852

2843

2203
,
Mayer Brown
 
Background
On July 2, 2020, the US Congress passed the Hong Kong Autonomy Act (HKAA), providing for mandatory sanctions against individuals, entities and financial institutions in response to China’s National Security Law for Hong Kong. The HKAA is the latest in a series of US measures in response to the ongoing disagreement with China regarding China’s obligation to maintain Hong Kong’s autonomous status under the Joint Declaration and the Basic Law. As further detailed in our recent Alerts1, it follows a number of steps taken by the United States, including:-
 
The May 27, 2020 certification by the Secretary of State under the Hong Kong Human Rights and Democracy Act that Hong Kong no longer enjoys sufficient autonomy in order to justify special treatment by the US,
The May 28, 2020 announcement by President Trump that the United States would initiate the process of revoking Hong Kong’s favorable treatment under US law and
The decision by the Chinese Government to introduce a National Security Law for Hong Kong, which took effect on June 30, 2020.
Announcements this week by the State Department of visa restrictions on Chinese government officials, and by the Commerce Department of the elimination of exceptions treating Hong Kong more favourably than China for exports of goods and technology to Hong Kong, and China’s threat of visa restrictions against US officials.
The HKAA was passed by unanimous consent, and therefore with veto-proof support, by the Senate and House of Representatives. It has not yet been signed into law by the President but is expected to be enacted into law in the coming few days.  
 
The Major Provisions of the HKAA
 
Section 3 –
This section lists a number of “findings” by Congress which conclude:-
 
“(16) The ways in which the Government of China, at times with the support of a subservient Government of Hong Kong, has acted in contravention of its obligations under the Joint Declaration and the Basic Law, as set forth in this section, are deeply concerning to the people of Hong Kong, the United States, and members of the international community who support the autonomy of Hong Kong.”
 
Section 5(a) –     
No later than 90 days after the legislation is passed the Secretary of State must submit a report identifying any “foreign person” that is “materially contributing to, has materially contributed to, or attempts to materially contribute to the failure of the Government of China to meet its obligations under the Joint Declaration or the Basic Law” (an Identified Foreign Person)
 
Notes:
The term “foreign person” includes any individual or entity that is not a US person.
References to the Joint Declaration means the Joint Declaration signed between China and the United Kingdom in 1984, which referred to Hong Kong continuing to have a “high degree of autonomy” after the handover of sovereignty in 1997.
References to the Basic Law mean Hong Kong’s mini-constitution.
Section 5(b) –       
Between 30 and 60 days after the submission of the Secretary of State’s report under section 5(a), the Secretary of the Treasury must submit “a report that identifies any foreign financial institution that knowingly conducts a significant transaction with a foreign person identified in [the Secretary of State’s report]” (an Identified FFI).
 
Notes:
The term “financial institution” is very broadly defined to include not only depository institutions but a range of other entities engaged in the business of accepting deposits, making, granting, transferring, holding or brokering loans or credits, or purchasing or selling foreign exchange, securities, commodity futures or options, or procuring purchasers or sellers thereof. A foreign financial institution is therefore very broad also (and includes any financial institution organized under any non-US law).
The term “significant transaction” is not defined in the law. However, we expect it will be interpreted broadly based on the same set of fact-specific and highly discretionary factors used by the Secretary of the Treasury in other sanctions contexts.
Notably, the law defines the term “knowingly” based on an actual knowledge standard, rather than the broader “reason to know” standard used in other sanctions legislation.
 
Section 6 –
The President can (and in certain circumstances shall, subject to possible waiver) impose sanctions (primarily the freezing of assets and associated prohibitions on dealings of any kind) on an Identified Foreign Person.
Section 7(a) –       
The President shall, subject to possible waiver, impose sanctions on an Identified FFI. There are 10 possible sanctions (see below) and, absent a waiver, the law would require the President to impose at least five of them within a year after an Identified FFI is named in the Secretary of the Treasury’s report and then to impose all of these sanctions two years after the FFI is so named.
 
Section 7(b) –

     

The potential sanctions are:-
 
– Refusal of credit from any US institution.
– Prohibition from acting as a primary dealer in US debt.
– Prohibition from acting as an agent of the US government for US public funds.
– Prohibition from participating in foreign-exchange transactions that are subject to US jurisdiction.
– Prohibition on the financial institution from entering into financial transactions with other financial institutions to the extent subject to US jurisdiction (e.g. SWIFT).
– Prohibition on the financial institution from holding, using or dealing with any property which is subject to US jurisdiction.
– Prohibition on the export of commodities or software to the financial institution where such export is subject to US jurisdiction.
– Prohibition on any US person from investing in equity or debt of the financial institution.
– Exclude officers or controlling shareholders from the US.
– Imposition of any sanctions (1) to (8) above on the individual officers of the financial institution.
 
Section 8(a) –

     

The President has the discretion to waive the imposition of sanctions with respect to any foreign person or foreign financial institution where such waiver is in the national security interest of the US. However, the law requires advance notice to Congress before any waiver may be exercised, and establishes a mechanism for Congress to disapprove of and to block the exercise of this waiver authority under the HKAA.  
 
Section 8(b) –

       

The President can remove any foreign person or foreign financial institution from the relevant report where the Secretary of State and the Secretary for the Treasury determine that the relevant person or entity has taken steps to remediate the wrongdoing or that the wrongdoing is unlikely to be repeated.
 
Observations
Status of Legislation. The HKAA is not yet in force. It requires the President’s signature. However, given it passed both the Senate and the House with unanimous consent, and therefore a veto-proof majority, the HKAA will likely be enacted into law soon. The President has 10 days to sign or veto the legislation subject to Congressional override. If the President does nothing, the bill will become law at the end of the 10-day period.
Broad Implementing Discretion. Notwithstanding the mandatory provisions in the legislation, the President retains important discretion in a number of respects regarding the imposition of sanctions against individuals, entities and financial institutions under the law. These discretionary factors will in practice have an important role to play in actual implementation of the law, and an understanding of these considerations could play an important part of a risk mitigation strategy for persons and entities whose activities could expose them to sanctions.
 
(a) Timing. The President does not need to impose any sanctions immediately. The Secretary of State’s report on Identified Foreign Persons (Identified Foreign Persons Report) is due within 90 days of enactment, while the Secretary of the Treasury’s report on Identified FFIs (Identified FFI Report) is due within 30 – 60 days of the Identified Foreign Persons Report. In each case, the President may wait for 12 months from the issuance of those reports to impose sanctions on a person or entity identified therein. The November Presidential elections are bound to play a role in the timing of any sanctions, and the balance of power between the White House and Congress may also have an impact on the political dynamic impacting the implementation of this law.
 
(b) Determination that an Individual has “Materially Contributed” or that an FFI Has “Knowingly Conducted a Significant Transaction”. Moreover, both the Secretary of State and the Secretary of the Treasury have broad discretion in determining who satisfies the criteria for inclusion in the Identified Foreign Persons Report and the Identified FFI Report, respectively. The “material contribution” standard (for Identified Foreign Persons), and the “knowledge” and “significant transaction” standards (for Identified Foreign Financial Institutions) are inherently discretionary and highly fact-specific. While this raises potential risk considerations for institutions and entities considering potential coverage, it also means the Administration will have substantial policy discretion as a practical matter in its determinations regarding whether or not to include entities and individuals who could arguably be covered by the law.
 
(c) Exclusion and Removal Criteria. Even where the facts otherwise support a determination under the criteria above, the HKAA would leave the President discretion to either “exclude” or remove persons and entities from the various reports subject to certain specified criteria. In particular, these criteria require a determination that the relevant activity: (i) is not likely to be repeated in the future, (ii) has been reversed or otherwise mitigated by “positive countermeasures” taken by the foreign person or FFI in question, and (iii) “does not have a significant and lasting negative effect” on China’s obligations with respect to Hong Kong under the Joint Declaration and Basic Law. As this suggests, even where a potentially covered FFI or individual has engaged in activity that could expose it to potential sanctions, it is possible in certain circumstances to take steps to manage and minimize the associated risk, including through engagement and other mitigation measures. Any determination to exclude (or remove) requires notification to Congress.
 
(d) Waiver and Termination. As noted above, the HKAA includes national security waiver authority (subject to Congressional advance notification and blocking mechanisms). The President may also terminate sanctions with respect to any Identified FFI or Identified Foreign Person with respect to which sanctions have been imposed. Notably, the criteria for termination are the same as those for exclusion from the reports as described above.
 
Evaluating Potential Risks for Business. The HKAA has the potential to significantly impact the interests of any FFI entity, and potentially for other businesses, with ties to individuals in China and Hong Kong who could be viewed as making a ‘material contribution’ to actions by the Chinese government that undermine Hong Kong’s autonomy. The designation of such individuals would have direct implications for FFIs to the extent they could be identified as engaging in “significant transactions” with such persons. Moreover, other businesses with investments or other assets in which an Identified Foreign Person has interests could also be impacted by that individual’s designation as a US sanctions target. This is because the imposition of an asset-blocking order would expose all assets in which such a person has interests to an immediate asset freeze, and could severely constrain options for divestment or exit from existing financial relationships. Accordingly, any FFI doing business in Hong Kong or China, as well as investors and other businesses with potential exposure, would be advised to review existing account and asset portfolios to identify any business they are currently undertaking with any politically exposed persons in either jurisdiction who could be targeted under the HKAA in respect of, at least, the promulgation of the Hong Kong National Security Law introduced with effect from June 30, 2020 and related government actions relevant to Hong Kong autonomy.

 
* Contact: 
messages@strtrade.com
, 1-305-894-1035
 
In response to new security measures China has voted to impose on Hong Kong beginning July 1, the U.S. is restricting exports of defense items and dual-use goods and technologies to Hong Kong. U.S. officials said China’s measures will undermine the autonomy of Hong Kong and thereby increase the risk that sensitive U.S. items will be illegally diverted to China’s People’s Liberation Army or Ministry of State Security, Iran, or North Korea.
Effective June 30 the Department of Commerce suspended regulations affording preferential treatment to Hong Kong over China, including the availability of license exceptions for items subject to the Export Administration Regulations. As a result, no items subject to the EAR may be exported to Hong Kong, reexported to Hong Kong, or transferred within Hong Kong based on an authorization provided by a license exception, except for transactions that would otherwise be eligible for a license exception if exported to China. Instead, a license must be sought and obtained whenever a license requirement applies for an export to, a reexport to, or a transfer within Hong Kong.
However, shipments of items that have been removed from eligibility for a license exception as a result of this action and were on dock for loading, on lighter, laden aboard an exporting or transferring carrier, or en route aboard a carrier to a port of export or reexport on June 30 pursuant to actual orders for export to Hong Kong, reexport to Hong Kong, or transfer within Hong Kong may proceed to their destination under the previous license exception eligibility. 
Similarly, deemed export/reexport transactions involving Hong Kong persons authorized under a license exception eligibility prior to June 30 may continue to be authorized under such provision until Aug. 28, after which such transactions will require a license. Exporters, reexporters, or transferors (in-country) availing themselves of this 60-day savings clause must maintain documentation demonstrating that the Hong Kong recipient was hired and provided access to technology eligible for Hong Kong under part 740 prior to June 30.
Separately, the State Department said that as of June 30 it would end exports of U.S.-origin defense equipment to Hong Kong and take steps toward imposing the same restrictions on exports of U.S. defense and dual-use technologies to Hong Kong as it does for such exports to China. Additional measures may also be imposed “to reflect the reality on the ground in Hong Kong.”


TE EX/IM MOVERS & SHAKERS

* Amazon; Austin, TX; Supply Chain Risk Management

 
* Cargolux; Luxembourg; LX;
Deputy Manager Import & Export Control
; Job ID: 563
 
* CMC Electronics Aurora LLC; Sugar Grove, IL; Trade Compliance Manager
 
* ERT; Bristol, PA;
Import/Export Specialist

* John Deere; Milan, IL; Export Shipping Coordinator; Job ID: 66671
 
 
*
Nestlé
; Barcelona, Spain; Import/Export Specialist
* Northrop Group; Falls Church, VA; International Trade Compliance Import Analyst; Job ID:
20018980
; Contact Details:
Patricia.Vives@ngc.com
 
* PepsiCo; Reading, UK; Supply Planner; Job ID:
212299BR
 
 
* Smiths Detection Inc; Edgewood, MD,
Sr. Trade Compliance Specialist
; Job ID:
DETECTIONNA00428
; Contact details: Tina.Seale@smiths-detection.com
 
* Verizon; Irvine, CA;
International Export-Import Compliance Manager
; Job ID:
545024

 
Click here to see all job openings. 

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

TE EX/IM TRAINING EVENTS & CONFERENCES

TE_a1
13.
ECTI Presents: Midyear Update on U.S. Export Controls Webinar; 15 Jul

(Source:
Ashleigh Foor
)
 
* What: Midyear Update on U.S. Export Controls
* When: 15 Jul 2020; 1:00 p.m. (EDT)
* Where: Webinar
* Sponsor: Export Compliance Training Institute (ECTI)
* ECTI Speaker: Scott Gearity
* Register: 
here 
or contact
Ashleigh Foor
, 1-540-433-3977

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

EN EDITOR’S NOTES

EN_a114. Bartlett’s Unfamiliar Quotations

(Source: Editor)
  

* P. T. Barnum
(Phineas Taylor Barnum; 5 Jul 1810 – 7 Apr 1891; was an American showman, politician, and businessman remembered for promoting celebrated hoaxes and for founding the Barnum & Bailey Circus (1871-2017).  He is widely credited with coining the adage “There’s a sucker born every minute,” although no proof can be found that Barnum said this.)
  – “Every crowd has a silver lining.”
  – “Whatever you do, do it with all your might. Work at it, early and late, in season and out of season, not leaving a stone unturned, and never deferring for a single hour that which can be done just as well now.”
 
* Bill Haley
(William John Clifton Haley; 6 Jul 1925 – 9 Feb 1981; was a pioneering American rock and roll musician. He is credited by many with first popularizing this form of music in the early 1950s with his group Bill Haley & His Comets and million-selling hits such as “Rock Around the Clock”, “See You Later, Alligator”, “Shake, Rattle and Roll”, “Rocket 88”, “Skinny Minnie”, and “Razzle Dazzle”, and has sold over 60 million records worldwide.)
 
 
– “See you later, alligator. After a while, crocodile.”
 
Monday is pun day:
* Which country’s capital has the fastest-growing population? Ireland. Every day it’s Dublin.
* I wasn’t originally going to get a brain transplant, but then I changed my mind.
* What do you call the wife of a hippie? A Mississippi. 

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

 

The official versions of the following regulations are published annually in the U.S. Code of Federal Regulations (C.F.R.), but are updated as amended in the Federal Register.  The latest amendments are listed below.
 
Agency 
Regulations 
Latest Update 
DHS CUSTOMS REGULATIONS
: 19 CFR, Ch. 1, Pts. 0-199.

 

5 Apr 2019: 84 FR 13499:

Civil Monetary Penalty Adjustments for Inflation. 
DOC EXPORT ADMINISTRATION REGULATIONS (EAR): 15 CFR Subtit. B, Ch. VII, Pts. 730-774. 
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 NATIONAL INDUSTRIAL SECURITY PROGRAM OPERATING MANUAL (NISPOM)

: DoD 5220.22-M. Implemented by Dep’t of Defense. 

18 May 2016: Change 2: Implement an insider threat program; reporting requirements for Cleared Defense Contractors; alignment with Federal standards for classified information systems; incorporated and cancelled Supp. 1 to the NISPOM (Summary here.)  
DOE ASSISTANCE TO FOREIGN ATOMIC ENERGY ACTIVITIES: 10 CFR Part 810.    23 Feb 2015: 80 FR 9359: comprehensive updating of regulations, updates the activities and technologies subject to specific authorization and DOE reporting requirements. 
DOE EXPORT AND IMPORT OF NUCLEAR EQUIPMENT AND MATERIAL; 10 CFR Part 110.  

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. 
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. 

 
 
 
USITC HARMONIZED TARIFF SCHEDULE OF THE UNITED STATES (HTS, HTSA or HTSUSA), Revision 8.

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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