20-0714 Tuesday “Daily Bugle”

20-0714 Tuesday “Daily Bugle”

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Tuesday, 14 July 2020

  1. Justice/ATF Requests eComments on Extension Without Change of a Currently Approved Collection Federal Firearms License (FFL) RENEWAL Application
  1. Items Scheduled for Future Federal Register Edition
  2. Commerce/BIS:(No new postings)
  3. State/DDTC:(No new postings)
  4. Canada TID: “Export of items listed on the Export Control List to Hong Kong”
  5. UK DIT: “Negotiations on the UK’s Future Trading Relationship with Australia – Update”
  1. EU Sanctions: “UK Post Brexit Guidance on Export Licences and Certificates”
  2. Reuters: “China Says to Sanction Lockheed Martin over Taiwan Arms Sale”
  1. Mayer Brown: “UK Government Resumes Issue of Saudi Export Licences”
  2. MSK: “Customs Broker Regulations Update – What Was CBP Thinking?”
  3. Nicholas Turner: “Sanctions Top-5 for the Week Ending 10 July”
  1. ECS Presents: 15-16 Oct; Toronto, CA; “ITAR/EAR Controls for Non-US Companies”
  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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EXIM_a11. Justice/ATF Requests eComments on Extension Without Change of a Currently Approved Collection Federal Firearms License (FFL) RENEWAL Application-ATF Form 8 (5310.11) Part II

Federal Register
, 14 Jul 2020)
85 FR 42432: Notice
* AGENCY: Bureau of Alcohol, Tobacco, Firearms and Explosives, Department of Justice.
* ACTION: 60-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. The proposed information collection (IC) is also being published to obtain comments from the public and affected agencies.
* DATES: Comments are encouraged and will be accepted for 60 days until September 14, 2020.
* FOR FURTHER INFORMATION CONTACT: If you have additional comments, regarding the estimated public burden or associated response time, suggestions, or need a copy of the proposed information collection instrument with instructions, or additional information, please contact: Tracey Robertson, Federal Firearms Licensing Center, either by mail at 244 Needy Road, Martinsburg, WV 25405, by email at Tracey.Robertson@atf.gov, or by telephone at 304-260-3643

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


(Source: Federal Register)
* Treasury/OFAC: NOTICES: Blocking or Unblocking of Persons and Properties [Pub. Date: 15 Jul 2020] (PDF)

* USTR: NOTICES: Product Exclusion Amendments:  China’s Acts, Policies, and Practices Related to Technology Transfer, Intellectual Property, and Innovation [Pub. Date: 15 Jul 2020] (PDF) and (PDF)  

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OGS_a23. Commerce/BIS: (No new postings)

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  Canada is deeply concerned by 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.
  Accordingly, the Minister of Foreign Affairs announced that, effective July 3, 2020: “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.”
  In order to ensure that sensitive items are not exported to Hong Kong, Global Affairs Canada will closely scrutinize all export permit applications for items to Hong Kong, and will deny permits that are not in line with Canada’s domestic and international legal obligations, foreign policy or security interests.
  Global Affairs Canada will continue to monitor the evolving situation and may reassess the above decision in light of changes on the ground.
Exporters will be advised of any new developments with respect to export permits to Hong Kong.

For further information, please contact the Export Controls Division at Global Affairs Canada by phone or email: 613-996-2387 / tie.reception@international.gc.ca.

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

   Trade negotiators from the UK and Australia held the first round of negotiations for a UK-Australia Free Trade Agreement (FTA) between 29 June and 10 July 2020.
   We are now one step closer to an ambitious, wide-ranging free trade agreement with one of our oldest friends. An FTA with Australia can bring investment, better jobs, higher wages and lower prices just when we need them the most.
   Both teams of negotiators recognised the unprecedented circumstances we find ourselves in and reiterated that more global trade is essential to support post-Covid economic recovery.
   Negotiations were conducted virtually and covered discussions on all areas of a comprehensive trade agreement. The discussions covered the following areas …

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EU Sanctions
, 13 Jul 2020) [Excerpts]

   The UK has published 
on certain goods which will require licences or certificates for export to the EU from 1 January 2021, when the Brexit transition period comes to an end. The guidance provides specific information on the export procedure of animals/plants/food/agricultural products, chemicals and waste, controlled goods (i.e. military or dual-use items), and diamonds. It reminds exporters also to check whether goods will be controlled by UK sanctions after the transition period, see 

   The guidance is part of a collection on how to prepare to export goods from the UK to the EU after 1 January 2021, which includes information on how to declare goods, checking new rules, getting an EORI number, and VAT. 

, 14 Jul 2020) [Excerpts]
   China will put sanctions on Lockheed Martin (LMT.N) for involvement in the latest U.S. arms sale to Chinese-claimed Taiwan, China said on Tuesday, adding tension to its troubled relationship with the United States.
The U.S. weapons maker is the main contractor for a $620 million upgrade package for Taiwan’s Patriot surface-to-air missiles, which the U.S. government approved last week.
   Chinese foreign ministry spokesman Zhao Lijian called on the United States to stop selling weapons to Taiwan to “avoid further harming Sino-U.S. ties and peace and stability in the Taiwan Strait”.
   “In order to safeguard the country’s interests, China has decided to take necessary steps, and put sanctions on the main contractor for this sale, Lockheed Martin,” Zhao told reporters, without giving details. …
   China has announced similar sanctions before on U.S. companies for Taiwan arms sales, though it is unclear what form they have taken.
   The United States has long had an arms embargo on China.
   The government in Taiwan has welcomed the missile upgrade. It is bolstering its defences for what it sees as increasingly threatening moves by Beijing, such as its regular air force and naval exercises near Taiwan. …


Mayer Brown
, 10 Jul 2020)

* Principal Author:
Jason Hungerford
, 44-20-3130-3084,
Mayer Brown

   We have previously reported1 on the Court of Appeal’s (CoA) decision in June 2019 to uphold an appeal by the Campaign Against Arms Trade (CAAT) against the UK Secretary of State for International Trade (the Secretary), concerning military exports to Saudi Arabia which might be used in the conflict in Yemen. The Secretary was directed by the CoA to review his previous decisions to issue licences and, in particular, to determine if there had been a pattern of breaches of international humanitarian law (IHL) by Saudi Arabia and its coalition partners. During this review, the Government announced that it would not grant any new licences for exports to Saudi Arabia and its coalition partners that might be used in the conflict in Yemen.
   On 7 July 2020, the (new) Secretary informed2 Parliament that the Government had completed its review and had not identified a historic pattern of IHL breaches, with the result that the previous licensing decisions presumably remained unaffected. Moreover, the Government would begin the process of clearing the backlog of applications that had formed since the CoA’s judgment.3
Review of decisions to issue existing licences
   The key issue in the CoA case was Criterion 2c of the Consolidated EU and National Arms Export Licensing Criteria, which the Government uses to assess export licence applications. Criterion 2c states that a licence will not be granted “if there is a clear risk that the items might be used in the commission of a serious violation of international humanitarian law“.
  In this context, the CoA found that the Secretary had failed to determine whether there had been a historic pattern of breaches of IHL by Saudi Arabia and its coalition partners. As a result, the license decision-making process was irrational and therefore unlawful. The Secretary had been directed to reconsider the licensing decisions in accordance with the correct legal approach. 
   The Secretary’s statement on 7 July 2020 states that, in order to address the CoA’s judgment, the Government had reviewed its licensing decisions using a revised methodology to assess alleged breaches of IHL. This methodology involved two elements:
  • First, where an allegation relating specifically to fixed-wing aircraft had been made, the Government conducted a detailed analysis of the allegation and evaluated whether it possibly constituted a breach of IHL. The focus on fixed-wing aircraft was intended to reflect “the factual circumstances that the court proceedings concerned” – to wit, CAAT’s evidence focussed on airstrikes by Saudi Arabia. Importantly, a “possible” breach was regarded by the Government as a breach for the purposes of its review. The Government then sought to determine whether any breaches were indicative of: (i) any patterns of non-compliance; (ii) a lack of commitment on the part of Saudi Arabia to comply with IHL; and/or (iii) a lack of capacity or systemic weaknesses which might give rise to a clear risk of IHL breaches.
  • Second, the Government also looked for patterns across incidents which had been assessed as unlikely to be IHL breaches, and also those for which there was insufficient information to make an assessment.
   On the basis of this methodology, the Government did not identify any patterns, trends or systemic weaknesses relating to IHL breaches, concluding that the incidents which it had assessed as being possible violations of IHL were “isolated incidents“. It further concluded that, despite these isolated incidents, “Saudi Arabia has a genuine intent and the capacity to comply with IHL“, and therefore, for the purpose of Criterion 2c, there was not a clear risk that arms or military equipment exported to Saudi Arabia might be used in the commission of serious IHL violations. Therefore the original decisions to issue existing licences were presumably unaffected (although this is not expressly stated in Secretary’s statement).
Existing licence applications
   Following the CoA’s decision last June, the Government gave an undertaking to the CoA that it would not grant any new licences for the export of arms or military equipment to Saudi Arabia for possible use in Yemen, pending completion of its review. It then gave a broader commitment to Parliament that it would not grant such licences for exports to Saudi Arabia’s coalition partners (UAE, Kuwait, Bahrain and Egypt).
   The Government also stopped new registrations for six new Open General Export Licences (OGEL)4 . In July, it published revised versions of these OGELs which did not permit exports to Saudi Arabia and its coalition partners5 . In September 2019, the Secretary informed Parliament of certain breaches of the abovementioned undertaking and commitment.6 Subsequently in December the Government again made changes to certain OGELs, and also issued new OGELs and Open General Trade Control Licences (OGTCL), which reflected restrictions on exports and brokering to Saudi Arabia and a wider range of coalition partners: Bahrain, Egypt, Jordan, Kuwait, Sudan and UAE.7
   The Secretary’s statement on 7 July states that, since the Government has complied with the CoA’s decision, the Government’s undertaking and broader commitment to Parliament have both fallen away. The Government will now therefore begin the process of clearing the backlog of licence applications that has built up since the CoA’s judgment. Notably, the Secretary’s statement did not refer to the OGELs and OGTCLs that have been affected by the undertaking and commitment, but presumably these will again be revised in the near future to permit (in some degree) exports and brokering to Saudi Arabia and its coalition partners.
Practical implications

   The Government has advised that it may take some months to work through the backlog of existing licence applications, and this process may cause delays in processing new applications. This will effect both UK exporters, and non-UK companies that have UK exporters in their supply chains. As noted above, we anticipate that affected OGELs and OGTCLs will be revised to permit (to some degree) exports and brokering to Saudi Arabia and coalition partners, which may give UK exporters some more options. Meanwhile, restrictions on exports to Saudi Arabia remain in place in other countries: Germany, for example, recently extended its export restrictions on Saudi Arabia until 31 December 2020.8 Exports to Saudi Arabia will therefore continue to pose challenges for many defence and aerospace players. 

, 13 Jul 2020)

* Author:
Susan Kohn Ross
, 1-310-312-3206,
Mitchell Silberberg & Knupp LLP

   For many months, the customs brokerage community has been expecting to see updates to the existing regulations. They finally came out in the Federal Register on June 5, 2020, see
here. Comments are due on or before August 4, 2020. While much of what is in the proposed revisions is not controversial and fits nicely into CBP’s stated purpose to “modernize” the regulations, one update is totally out of line – and CBP should know better! For all the positive steps forward these revisions accomplish, CBP has yet again failed to comprehend the role of the customs broker. The way the proposed language is written, CBP is again trying to turn customs broker into Junior G-Men. As worded, brokers would be turned into investigators and enforcers for CBP, and that attempt alone totally undermines all the good which is otherwise accomplished, AND fails to understand the role of the customs broker in international trade!

   There is a little concern about all brokers having a national permit and being regulated at the Center of Excellence and Expertise level. Increasing the filing and processing fees is also understandable as is the preference for electronic data filing. At the same time, what is particularly notable (beyond the attempt at making brokers into Junior G-Men) is the lack of anything remotely approaching the topic of continuing education. For months this was a hot topic with lots engagement between CBP and the brokerage community – and now nothing!
   One change CBP made really just underscores what has been a long-standing requirement. However, now that so many brokerage operations are part of multi-country forwarding, courier and/or 3PL operations, the long standing concern by CBP that individuals outside the U.S. are making decisions about classification and value has again been vocalized. To address this point of concern, the new regulations make clear that “customs business” must be conducted in the U.S., which includes entry and admissibility determinations, so classification, value, etc., and, of course, entry filing.
   The elimination of all but national permits is certainly reasonable, but allowing someone to apply for the national permit simply because they are a licensed broker flies in the face of basic corporate law, which requires the person acting on behalf of the company to have “apparent” authority. To eliminate any doubt that the applicant had that authority, the old rule was the person filing the application had to be a corporate officer. CBP is doing away with that requirement. Perhaps CBP thinks having a license provides apparent authority, but many individual brokers would tell you they are part of a larger team which makes joint decisions, meaning simply having the license is not the determining factor.
   Another topic on which CBP may have created mischief has to do with who may request records from a broker. The current law is found at 19 C.F.R. 111.24 and states, the broker is not to release the importer’s confidential information except to the importer, the relevant surety/ies, the Regulatory Audit Field Director, the Special Agent in Charge, the Port Director and “other duly accredited officers or agents of the United States, except on subpoena by a court of competent jurisdiction.” The potential challenge is the proposed change eliminates the various titles and instead allows “representatives of the Department of Homeland Security (DHS), or other duly accredited officers or agents of the United States, except on subpoena or court order by a court of competent jurisdiction, or when authorized in writing by the client.” Now, in principle, this change seems relatively tame. Perhaps, but given history, there remains the potential that someone at DHS who is not familiar with what brokers do or the regulatory framework in which they operate (and most have no idea) will simply demand records orally or in an overly broad or otherwise objectionable manner. The good news is this does not now happen often, but that is due in large measure to the fact that brokers have taken to heart the need to have such requests made in writing. How many more DHS staffers might need to be educated under this proposed change?
   CBP has also expanded the definition of responsible supervision and control, the corollary to the importer’s reasonable care standard. Reasonable care appears at 19 U.S.C. 1484(a)(1) and has been defined by CBP as the importer’s obligation to make sure the classification and value declared at time of entry are accurate and that any admissibility requirements have been met. Responsible supervision and control has long be defined by regulation at 19 C.F.R. 111.1 to include: “… While the determination of what is necessary to perform and maintain responsible supervision and control will vary depending upon the circumstances in each instance, factors which CBP will consider include, but are not limited to: 
1) training, 
2) instructions and guidelines to employees; 
3) volume and type of business; 
4) reject rate; 
5) maintenance of the proper reference materials; 
6) frequent interaction between the individually licensed broker and the other employees; 
7) the frequency of visits by the licensed broker to the branch offices where no license holder is present; 
8) the frequency of audits and reviews by the licensed broker; 
9) how involved is the licensed broker in the overall brokerage operation; and 
10) anything else which “indicates” the licensed broker has a “real interest in the operations” of the broker.
   Under the proposed revisions, first, it will no longer be necessary to have a licensed broker in each office, which is certainly a welcome change. Instead, the standard becomes that the 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.” Admitting what is required varies, CBP goes on to expand the list of factors it will consider by adding: 
(11) The timeliness of processing entries and payment of duty, tax, or other debt or obligation owing to the Government whether owed by the broker or where the broker is transmitting payment on behalf of the importer; 
(12) Communications between CBP and the broker; 
(13) The broker’s responsiveness and action to communications, direction, and notices from CBP; 
(14) Communications between the broker and its officer(s); and, 
(15) The broker’s responsiveness and action to communications and direction from its officer(s). 
What one quickly comes to realize is this continues to be a somewhat subjective determination. What is clear is if you fail to pay your bills or timely submit funds paid by importers, and/or ignore instructions from CBP, you are in trouble with the agency. Otherwise, it is difficult to see any clarity. This need for clarity is, of course, driven home by the case brought at one of the southern border ports a few years ago against a local customs broker by CBP in circumstances where the ultimate outcome was CBP wrote and filed the motion to dismiss!
   Another change worthy of note has to do with the dealings between brokers and unlicensed parties. Typically, what causes CBP concern is the importer’s relationship is with the freight forwarder, not the broker. The forwarder hires the broker and directs what is to be done. The current regulation can be found at 19 C.F.R. 111.36(c)(3) and makes clear the forwarder cannot bar the broker from having direct contact with the importer, although for relationship reasons some may still foolishly try to do so. Seeking to drive the point home more forcefully, CBP will now bar the importer from issuing a power of attorney to the forwarder that allows the forwarder to issue the power of attorney to the broker. Any power of attorney provided to the broker must come directly from the importer. CBP states this step is needed to deal with identity theft, supply chain security, fee transparency and “help ensure that unlicensed persons are not benefiting from the customs business conducted.” While that sounds reasonable at first, why not just revoke the ruling which allows this practice? Also, from all the audits conducted, CBP should have learned long ago, there are ways to bill charges which include the brokerage fee which are compliant with the regulations, in letter and spirit!
   Growing up, all of us learned there are boundaries to our actions, and consequences when we cross those boundaries. For years, CBP has tried to fashion a way that it could gain the means to have brokers help it enforce the law against importers CBP thinks are bad guys. If the importer is a truly bad apple, the only brokers who might want to deal with them are often co-conspirators. Otherwise, the standard has been if the importer will not follow the broker’s advice regarding compliance, the broker fires the importer as their customer. CBP has been repeatedly reminded that it cannot and should not turn brokers into informants for two very important reasons: 1) the identity of the broker will come out in any trial which follows (and likely earlier in the process); and 2) the broker as the agent owes a duty of loyalty to its principal – the importer. CBP knows this is the state of the law and yet it has crossed the line – and done so unabashedly!
   Where CBP has gone overboard, and by a very large margin, is when comes to making brokers into Junior G-Men! It has long been the case (see 19 C.F.R. 111.32) that, brokers are not to file or assist in the filing of false claims or documents. Frankly, it seems all would agree that is a no-brainer! The regulations goes on to say the broker should not give false or misleading advice, again, a no-brainer. If the new provision stopped here, everything would be fine. However, the next sentence is basically outrageous. It reads: “…A broker also must document and report to CBP when the broker separates from or cancels representation of a client as a result of determining the client is intentionally attempting to use the broker to defraud or otherwise commit any criminal act against the U.S. Government.”
   What CBP has basically said with this ill-advised proposal is the broker is now an investigator and enforcer for CBP –
report the impropriety to CBP or else!
In short, fink on your importer or you are in trouble with the agency! This is a total breach of the duty of loyalty the broker owes to the importer. It is equally a breach of the obligation of the broker-agent to act without conflict of interest on behalf of his importer-principal. Making matters worse, the first time a broker does rat out his importer and this becomes public knowledge (and you know it will), that brokerage operation will be quickly out of business. No importer wants to work with a broker that is so unprofessional that it informs on the importer to CBP rather that find an earlier point in time to cut ties with that importer. Frankly, prudent brokers can be expected to fire questionable importers long before they have actual knowledge the importer is acting intentionally. Every other professional does the same thing. Brokers should not be put in a compromising position.
   Did CBP really forget about the basic principal-agency and good judgment rule: fire clients when they do things you consider improper, but keep your mouth shut so you don’t get sued! The role of the broker is to help the importer become compliant. The broker is not a Junior G-Man, and shame on CBP for ignoring the difference!

Medium, 14 Jul 2020)

* Author: 
Nicholas Turner
, Esq., 852-5998-7559, 
Steptoe & Johnson HK 
  Here are five things that happened this week in the world of economic sanctions that I think you should know about:
   (1) The UK
announced asset freezes and travel bans against a total of 49 individuals and entities
in Myanmar, North Korea, Russia, and Saudi Arabia under the new
Global Human Rights Sanctions Regulations 2020
. The “
” sanctions, which target perpetrators of serious human rights abuses, will form part of the UK’s evolving post-Brexit sanctions regime.
   (2) The US Office of Foreign Assets Control (OFAC)
named four Chinese government officials and one state entity as Specially Designated Nationals 
(SDNs) under the Global Magnitsky Sanctions program for their roles in human rights abuses in the Xinjiang Uyghur Autonomous Region (XUAR). Meanwhile, the US State Department
announced travel bans against three Chinese officials and their immediate family members
under Section 7031(c) of the FY 2020 Department of State, Foreign Operations, and Related Programs Appropriations Act.
   (3) In related news, the US State Department
announced visa restrictions against unnamed Chinese officials

substantially involved in the formulation or execution of policies related to access for foreigners to Tibetan areas
,” under the
Reciprocal Access to Tibet Act of 2018
According to the State Department news release
, China has restricted access to Tibet by US officials, journalists, and tourists.
   (4) OFAC
announced a modest USD 134,523 settlement
with a US-based online retailer for a slew of apparent violations caused by automated name screening deficiencies. The company also missed a deadline for reporting transactions under a Crimea-related general license, thereby “
” the license with respect to those transactions,
according to the OFAC settlement notice
   (5) OFAC
removed Eritrean presidential advisor Yemane Gebreab
from the SDN List. OFAC
sanctioned Gebreab in April 2010
under the Somalia sanctions program for his alleged role in supporting destabilizing activities in Somalia.
   You may have noticed that OFAC’s XUAR-related designations were not made under the recently adopted 
Uyghur Human Rights Policy Act of 2020
. The Act, which became law on 17 June 2020, gives the President 180 days to submit a report to Congress identifying persons determined to be responsible for human rights abuses in the XUAR, with sanctions to follow. Why wait when the Magnitsky Sanctions can be used at any time? Interestingly, Axios 
reported a few weeks ago 
that Donald Trump said he avoided using the Magnitsky sanctions in relation to the XUAR to avoid upsetting the US-China trade deal. If the White House had acted earlier, would Congress have needed to pass a bill?


* 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 Spea
ker: Scott Gearity

* Register: 
or contact
Ashleigh Foor
, 1-540-433-3977

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


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


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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