20-0908 Tuesday “Daily Bugle”

20-0908 Tuesday “Daily Bugle”

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[The Daily Bugle was not published yesterday, a U.S. holiday.]
Tuesday, 8 September 2020

(No items of interest posted) 

  1. Items Scheduled for Future Federal Register Edition
  2. Commerce/BIS: (No new postings)
  3. State/DDTC Presents: 9 Sep; “DECCS Tips and Tricks Webinar”
  1. AFR: “China Wants to Decouple from US Tech, Too”
  2. EU Sanctions: “OFAC Investigating Frequency Electronics over Potential Sanctions Breaches”
  1. Baker McKenzie: “DDTC to Begin Accepting Electronic Submissions of Notifications Relating to Mergers, Acquisitions, and Divestitures”
  2. K & L Gates: “Trump Administration Significantly Enhances Export Control Supply Chain Restrictions on Huawei”
  3. Pillsbury: “Sudan Update: OFAC Issues Guidance Clarifying Status of U.S. Sanctions and Export Controls”
  1. Monday List of Ex/Im Job Openings: 55 Jobs Available – 10 New Job Openings This Week
  1. ECS Presents: 21-22 Oct; “3rd Annual ITAR/EAR Symposium and Managing ITAR/EAR Complexities
  2. FCC Academy Presents 3 Webinars: The ABC of FMS | Designing an ICP | Implementing an ICP
  1. Bartlett’s Unfamiliar Quotations 
  2. How to Publish Your Article in the Daily Bugle 
  3. Are Your Copies of Regulations Up to Date? Find the Latest Amendments Here. 
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load to your laptop to keep you updated on the latest amendments, and contain over 800 footnotes of section history, key cases, practice tips & tricks, and extensive Tables of Contents. The ITAR amendments to the ITAR that took effect on 9 March and 25 March are included in the current edition of the BITAR.  Subscribers receive updated editions every time the regulations are amended (usually within 24 hours) so you will always have the current versions of the regulations. Subscribe to the BITAR now to guarantee you have an up-to-date ITAR!    

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[No items of interest posted]

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OGS_a22. Commerce/BIS: (No new postings)

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  Join DDTC’s CIO Karen Wrege and members from the Licensing team for our next DECCS Hot Topics webinar. In this session, we will focus on how to use the DECCS licensing application – including best practices and tips. We will review the best way to contact DDTC’s Response Team and Help Desk – and there will be time for Q&A at the end.
Topics to be discussed:
   – Accessing Licenses
   – Submitting and Signing a License 
   – Types of Licenses available in DECCS
   – Tips for easier submission, processing and License approval
   – Best ways to contact DDTC for support
Login Details:
Date: Wed, 9 Sep (tomorrow!) 
Time: 2:00 pm – 3:00 pm EST
WebEx: Click Here
Important – If password is required when entering WebEx, type ‘census’.
Dial in for audio: 1- 800-857- 5152
Passcode: 4 2 2 9 7 0 5 #

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  Both the US and China have technologies to protect, and economic weapons to do that. But China’s immediate future looks a bit brighter. Decoupling, it turns out, is a two-way street.
  It was perfect ju-jitsu. After weeks of watching US President Donald Trump pressure Chinese tech company ByteDance to sell its social media app TikTok to Microsoft, Beijing struck back, using one of Mr Trump’s own weapons of choice – export controls.
   Chinese authorities expanded the Middle Kingdom’s list of controlled exports to include algorithms, which are of course TikTok’s main asset. …
   But the use of export controls by Beijing to potentially thwart a deal also underscores that it is not just America, but also China, that is moving to decouple its technology industry.
   The Trump administration has tried to offset these efforts by denying Huawei the US-made chips and software it requires for its ambitious global 5G rollout. But no expert that I’ve spoken to on the topic thinks this will prevent China from executing a longer-term decoupling from the US tech ecosystem. If anything, the restrictions have only sped up China’s efforts to develop its own chip industry.
   Meanwhile, the Chinese have been able to access things such as US patents, scientific papers and even American corporate innovations. That includes groundbreaking work on artificial intelligence, some which has been published or developed open-source. This is happening at the same time as China’s own legal protections around things such as intellectual property and patents have been getting stronger by some measures. …
  Now, the US looks like it is heading towards a deeper recession. Perhaps that is why China decided to call Mr Trump’s bluff on TikTok. Both countries have technologies to protect, and the economic weapons to achieve that. But China’s immediate future looks a bit brighter. Decoupling, it turns out, is a two-way street.

(Source: EU Sanctions, 7 Sep 2020) [Excerpts]
  Frequency Electronics, a New York-based satellite communications company, has disclosed in its annual report that OFAC has commenced an investigation into certain sales to and payments from Morion. Morion is a subsidiary of Gazprombank, a Russian state-owned financial institution, which became subject in July 2014 to US sectoral sanctions pursuant to Executive Order (E.O.) 13662.
  Frequency Electronics allowed Morion to delay payments and transfer it funds after Gazprombank’s designation. Such conduct could constitute an extension of credit, which is prohibited under Directive I of the E.O.. The filing says that it cannot yet estimate the possible penalties.


* Principal Author: Bart McMillan, Esq., 1-312-861-2808, Baker McKenzie
  The Directorate of Defense Trade Controls within the US State Department recently issued a number of announcements regarding submissions related to Mergers, Acquisitions, and Divestitures of US businesses regulated under the International Traffic in Arms Regulations.
  The Directorate of Defense Trade Controls (“DDTC“) within the US State Department recently issued a number of announcements regarding submissions related to Mergers, Acquisitions, and Divestitures (“MAD“) of US businesses regulated under the International Traffic in Arms Regulations (“ITAR“).  These changes by DDTC were prompted by the COVID-19 crisis and end the need for parties in MAD transactions involving ITAR-regulated entities to submit hard copies to DDTC.

  By way of background, ITAR Section 122.4(b) requires parties involved in MAD transactions where an ITAR-regulated entity will be owned or controlled by a non-US party to notify DDTC at least 60 days before transaction closing.  Entities involved in manufacturing, exporting, or temporarily importing defense articles or furnishing defense services are required to register with DDTC on an annual basis, and MAD transactions involving such entities may trigger ITAR Section 122.4(b).  This DDTC notification requirement is separate from other licensing or approval requirements under the ITAR as well as transaction-review processes imposed by the Committee on Foreign Investment in the United States.  In addition, ITAR Section 122.4(a) requires entities to update their registrations with DDTC within five days of changes to the information in such filings (e.g., entity name, entity address, ownership or control).  In the MAD context, ITAR Section 122.4(a) is triggered when a transaction closes.  (Similar ITAR notification requirements apply to brokers of defense articles

under ITAR Section 129.8.)

Electronic Submissions of MAD-Related Notifications and MAD-Specific FAQs

  On July 23, 2020, DDTC announced that 5-day notifications of changes to registrations resulting from MAD activities submitted pursuant to ITAR Section 122.4(a) will be accepted via DDTC’s electronic portal  the Defense Export Control and Compliance System.  Previously, the 5-day notifications related to MAD transactions had to be submitted in hard copy.

  On the same day, DDTC also announced that it has established a new mechanism for electronic submission of 60-day advance notifications pursuant to ITAR Section 122.4(b).  Parties submitting such notifications and/or supporting documentation (e.g., organizational charts, ITAR compliance program materials in Microsoft Word format) are encouraged to send such materials via email to PM-DTCC-MAD@state.gov, without corresponding hard-copy submissions.  Letters should be on company letterhead and signed by a

US-person senior officer listed on the submitting entity’s registration with DTCC.
  The 60-day notifications related to MAD transactions previously had to be submitted in hard copy via registered mail/overnight delivery, in addition to sending the materials via email to specific DDTC officials.

  These steps mark DDTC’s transition to full electronic submission of all MAD-related notifications.  To aid registrants in submission of registration-related notifications, DDTC has also updated its Registration FAQs page to include a list of MAD-specific questions and answers under the new subheading titled “Mergers, Acquisitions, and Divestitures.”

Addition of DS-6004 “Other” Type

  On July 16, 2020, DDTC announced that it add an “Other” category to Block 4 of the agency’s DS-6004 Reexport/Retransfer Application.  According to DDTC, industry should select the “Other” category when submitting General Correspondence requests related to MAD transactions, US and Foreign Entity Name/Address Changes or Registration Code Changes, US Persons Providing Defense Services Abroad, End-Use/End-User Change Requests, and Amendments to existing General Correspondence approvals.

  DDTC advised that it will continue to accept paper submissions for these requests but paper submissions may result in extended processing times.  Applicants making paper submissions are advised by DDTC to provide an email address in the transmittal letter so that DDTC can respond through email.

* Principal Author: Steven F.Hill, Esq., 1-202-778-9384, K&L Gates LLP
  The U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) recently adopted measures substantially impacting Huawei-affiliated companies and their non-U.S. supply chains.  Earlier this year, on May 15, 2020, BIS issued a proposed, but immediately effective, amendment to the Foreign Direct Product Rule (hereafter, the “FDPR”) of the Export Administration Regulations (“EAR”; 15 CFR part 730 et seq.) that substantially restricted the supply of certain non-U.S. produced products to Huawei companies on the U.S. Entity List (“Huawei”).  Under the amendment, a non-U.S. produced product that was the direct product of certain designated U.S. software or technology (or produced by plant facilities that were the direct product of such software or technology), was considered “subject to the EAR,” and thereby subject to a U.S. export license requirement, even if transferred from outside the United States, if the non-U.S. product was: (1) designed or produced by Huawei; and (2) being supplied to Huawei (hereafter, the “Huawei Direct Product Rule” or the “Rule”).
  On August 17, BIS adopted the amendment as a final rule, but substantially expanded the scope of the FDPR with respect to Huawei by extending coverage to any subject non-U.S. produced product, even if not designed or produced by Huawei (such as off-the-shelf products), if either: (1) Huawei is a party, in any capacity, to the supply transaction; or (2) the product is supplied with knowledge that the product will be incorporated in a product that will be supplied to Huawei (directly or indirectly) or used in the “production” or “development” of any part, component, or equipment produced, purchased, or ordered by Huawei.  In conjunction with the final adoption of this new Rule, BIS also placed additional Huawei companies on the Entity List and terminated the Temporary General License (“TGL”) which had previously authorized certain activities with Huawei relating to cyber security and product development.

  On May 15, 2020, BIS amended the FDPR (General Prohibition Three of the EAR) as applied to Huawei entities designated on the Entity List.  The FDPR generally provides that any non-U.S. produced item that is produced using national security-controlled U.S. software or technology is considered subject to the EAR and, thereby, to any export license requirement that would be applicable if the product was produced in the United States.  Under the May 15 amendment, an add-on to the FDPR was adopted in connection with the supply of certain items to Huawei companies on the Entity List (this was implemented through a new footnote 1 to the Entity List which applies to all the Huawei companies included on the Entity List).  The new Rule potentially applied to any non-U.S. produced product that: (1) was the direct product, or was produced by a plant (or major equipment of a plant) that was the direct product, of U.S. software or technology enumerated in the new Rule (“subject product”); and (2) was produced or developed by, and being supplied to, Huawei.
Subject Products.  As implemented on May 15, the Rule potentially applied to any non-U.S. produced product that:
  • is the direct product of technology or software subject to the EAR and specified in the following Export Control Classification Numbers (“ECCNs”) of the EAR’s Commerce Control List: 3D001, 3D991, 3E001, 3E002, 3E003, 3E991, 4D001, 4D993, 4D994, 4E001, 4E992, 4E993, 5D001, 5D991, 5E001, or 5E991; or
  • is produced by any non-U.S. plant or major component of a plant that is a direct product of U.S.-origin technology or software subject to the EAR that is specified in ECCNs 3D001, 3D991, 3E001, 3E002, 3E003, 3E991, 4D001, 4D993, 4D994, 4E001, 4E992, 4E993, 5D001, 5D991, 5E001, or 5E991.
  However, as implemented on May 15, a product was subject to the EAR and required a U.S. export license only if it was a product that was produced or developed by Huawei and was being sold to Huawei.


  When adopting the final Huawei Direct Product Rule on August 17, however, BIS implemented amendments to the Rule to further “prevent Huawei’s attempts to circumvent U.S. export controls to obtain electronic components developed or produced using U.S. technology.”  As described by BIS, “[t]his amendment further restricts Huawei from obtaining foreign made chips developed or produced from U.S. software or technology to the same degree as comparable U.S. chips.”  Under the final, amended Rule, although the scope of subject products potentially subject to the new Rule remains the same (the direct product, or a product produced by a plant or major component that is the direct product, of U.S. software or technology specified in the enumerated ECCNs), there is no longer a requirement that the subject product have been produced or developed by Huawei.
  Instead, as finally adopted, the Huawei Direct Product Rule now applies to any subject product when the company exporting, reexporting, or transferring the item (including transfers within the same country) has “knowledge” that either: (1) a Huawei company on the Entity List will be a party to a transaction involving the item (including as a purchaser, consignee, or end-user); or (2) the item will be incorporated into or used in the production or development of any part, component, or equipment produced, purchased, or ordered by Huawei.  “Knowledge” is defined as actual knowledge or reason to know based on the circumstances of a transaction.
  As a result of this revision to the Huawei Direct Product Rule, non-U.S. manufacturers and other suppliers involved in Huawei supply chains must carefully determine which, if any, of their products are within the scope of the Rule and ensure such products are only exported, reexported, or otherwise transferred in compliance with the new Rule.  The changes to the Rule became effective immediately upon its issuance on August 17, 2020.  However, there is a savings clause that allows for shipment without a license of items that are within the scope of the Rule because they are the direct product of covered “plants or major components of plants,” provided: (1) production of those items started by August 17, 2020; and (2) they are exported, reexported, or transferred before midnight (local time) on September 14, 2020.


  Huawei Affiliates Added to Entity List.  The Rule also further expands the scope of Huawei export restrictions by adding 38 additional entities affiliated with Huawei to the Entity List, bringing the total to 153 Huawei companies.  As a result of these designations, companies must obtain a BIS export license before exporting, reexporting, or transferring to these entities any item, software, or technology that is “subject to the EAR.”  This includes any item (commodity, software, or technology) that is: (1) U.S.-origin; (2) located in the United States; (3) non-U.S.-origin but incorporating more than a de minimis percentage of controlled U.S. content; or (4) non-U.S.-origin but subject to the EAR as a result of the direct product rules discussed above.  License applications in this context are subject to a general policy of denial by BIS.
  Export restrictions for the 38 Huawei affiliates added to the Entity List became effective on August 17, 2020, although shipments that were already in transit by August 17 can be delivered without a license.
Temporary General License.  The Rule also expands the Huawei export restrictions by providing for the expiration of a TGL issued originally in May 2019 that authorized certain transactions with Huawei related to cybersecurity research, ongoing support and operations of networks and equipment, and 5G standards conducted by an established standards body.
  The original TGL, which has been renewed and modified over time, expired effective August 17, 2020.  However, BIS has issued a more limited authorization by adding a footnote to the license requirements for designated Huawei entities on the Entity List which authorizes the export, re-export, or transfer of items subject to the EAR, provided it is limited to “information regarding security vulnerabilities in items owned, possessed, or controlled by Huawei or any of its non-U.S. affiliates when related to the process of providing ongoing security research critical to maintaining the integrity and reliability of existing and currently ‘fully operational network’ and equipment.”


  These actions by BIS represent the latest in a series of measures by the U.S. government to cut off Huawei from U.S. commodities, software, and technology, most recently by focusing on preventing reliance on U.S. software and technology in producing products outside the United States for Huawei supply chains.  These measures are intended to send a signal, not only to Huawei’s suppliers who are most directly impacted by the new BIS Rule, but also to Huawei’s customers who are being urged by the United States to develop non-Huawei sources for technology and equipment.
  As Huawei-related and other U.S. export controls evolve, K&L Gates continues to work with our clients to meet the business challenges presented by the new export Rule.  If you have any questions about the Huawei-related export restrictions and what they may mean for your business, please contact a member of the K&L Gates Trade Practice.

* Principal Author: Christopher R. Wall, Esq., 1-202-663-9250, Pillsbury Winthrop Shaw Pittman LLP
  On August 11, 2020, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued a new guidance document, the Sudan Program and Darfur Sanctions Guidance (“Sudan Guidance”), which clarifies the current status of sanctions and export controls that apply to Sudan and the Government of Sudan. The Sudan Guidance confirms the removal of comprehensive sanctions on Sudan, permitting U.S. persons to engage in most economic activity. However, individual sanctions listings in Sudan and South Sudan continue and a U.S. embargo policy remains in place for exports to Sudan.
Removal of Sudan Sanctions Regulations


For two decades, the Sudanese Sanctions Regulations, 31 C.F.R. Part 538 (SSR), implemented a broad and complex sanctions regime that prohibited most economic activity in or with Sudan, its government and its banking sector. This sanctions regime was established pursuant to a series of executive orders and statutes. Sudan also was added to the U.S. State Department’s State Sponsors of Terrorism list in 1993.

  Following negotiations between Sudan and the Obama administration, OFAC published a General License on January 17, 2017 that broadly authorized transactions prohibited under the SSR. The Trump administration continued these policies as the leadership in Sudan changed, removing several government agencies and Sudanese parties from the List of Specially Designated Nationals and Blocked Persons (SDN) in 2017, and rescinding the SSR from the Code of Federal Regulations in 2018.
Continuing Export Controls and Sanctions Designations


Although the economic sanctions that prohibited U.S. persons from engaging in many transactions with Sudan and the Government of Sudan generally have been rescinded, there are still U.S. sanctions designations and export control restrictions that remain in effect.

  A number of SDNs and blocked entities operate in Sudan and northeastern Africa. The South Sudan Sanctions Regulations, 31 C.F.R. Part 558, and Darfur Sanctions Regulations, 31 C.F.R. Part 546, are separate from the SSR. They are still in effect and support multiple SDN designations. In addition, parties in Sudan may be subject to sanctions designations under terrorism-related and human rights regimes.
  The U.S. export control embargo for Sudan, which is distinct from U.S. sanctions, applies to exports and reexport of items subject to the jurisdiction of the Export Administration Regulations (EAR) administered by the U.S. Commerce Department’s Bureau of Industry and Security (BIS). Specifically, the embargo policy for Sudan under Section 742.10 of the EAR prohibits the export and reexport to Sudan of U.S. origin commodities, software and technology, and non-U.S. items subject to the EAR and controlled on the Commerce Control List (CCL), with limited exceptions for reexports. Licenses from BIS are required, and most exports or reexports to Sudan are subject to a policy of denial or case-by-case review. (There is a general policy of approval for licensing applications related to the safety of civil aviation or the safe operation of fixed-winged commercial aircraft and CCL items that are destined for civil railway use.) Items not on the CCL and controlled under EAR99 are not subject to license requirements.
  Finally, the Guidance acknowledges the Terrorism List Governments Sanctions Regulations at 31 C.F.R.§ 596.506 which, although limited in scope, continue to prohibit U.S. persons from engaging in transfers that would constitute a donation from the Government of Sudan to a U.S. person, or which a U.S. person knows or has reason to believe poses a risk of terrorist acts within the United States.
Ongoing Enforcement


The U.S. government continues to enforce Sudan-related sanctions designations and has assessed penalties based on activity that took place before January 2017. This includes penalties that continue to impact past activities in the financial sector that violated the SSR. For example, in September 2019, the British Arab Commercial Bank agreed to a $4 million settlement, which stemmed from 72 transactions processed by the bank between September 2010 and August 2014.


MS_a19. Monday List of Ex/Im Job Openings: 55 Jobs Available — 10 New Job Openings This Week

(Source: Jobs Editor)  

New Jobs
* Albemarle Corporation; Charlotte or Kings Mountain, NC; Trade Compliance Specialist; Contact Details: Bruno.Hennuy@albemarle.com 
* Arrow Electronics; Centennial, COTransportation Import/Export Specialist IIJob ID: 178819; Contact Details: ERIK.EDWARDS@arrow.com 
* BAE Systems Inc.; Falls Church, VA ; Licensing Analyst; Job ID: 63150BR; Contact Details: Tyler Allie, 571-388-8176 tyler.allie@baesystems.com 
* Connection; Wilmington, OH; Export Compliance Specialist 
* Janssen; Spring House, PA; Shipping and Data Systems Associate 
* L3Harris; Anaheim, CA; Procurement Associate; Job ID: MS20200109-50135
* Mercury System; Remote; Audit Program Manager; Job Id: 20-452;
Contact Details: Shawna.Maccario@mrcy.com 
* Peloton; New York, NY; Manager, Trade Compliance; Job ID: 2226183
* ST&R; Washington, DC; Senior Manager, Export Controls; Contact Details:humanresources@strtrade.com 
* Torrent Pharma; Philadelphia, PA; DEA Associate (Coordinator)  
Click here to see the full list. 

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* What: 3rd Annual ITAR/EAR Symposium and Managing ITAR/EAR Complexities 2-Day Webinar
* When: 16-17 Sep moved to 21-22 Oct
* Where: Your Computer
* Sponsor: Export Compliance Solutions & Consulting (ECS)
* ECS and Guest Speakers: Suzanne Palmer, Lisa Bencivenga, Phil Kuhn, Debi Davis, Scott Jackson
* Register: here or write to liz@exportcompliancesolutions.com or call 1-866-238-4018
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The ABC of Foreign Military Sales (FMS)
Tuesday, 29 September 2020

More Info

Designing and Implementing
an ICP
Tuesday, 6 October 2020 More Info
Wednesday, 7 October
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(Source: Jim Bartlett, Daily Bugle Editor)
  Your analysis and commentary on a current trade issue can generate new clients from among the Daily Bugle’s subscribers (over 10,000 world-wide). We receive far more articles every day from law firms and consultants than we can publish, but if you would like have your article published, please contact Jim Bartlett at 1-202-802-0646 or JEBartlett@JEBartlett.com.
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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 


5 Apr 2019: 84 FR 13499:

Civil Monetary Penalty Adjustments for Inflation. 
27 Aug 2020: 85 FR 52898Additions of Entities to the Entity List and Revisions of entries on the Entity List.

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.


29 Jul 2020: 85 FR 45513 Extension to Certain Temporary Suspensions, Modifications, and Exceptions due to Corona Virus.  The latest edition of the BITAR is 29 July 2020.  

DOT FOREIGN ASSETS CONTROL REGULATIONS (OFAC FACR): 31 CFR, Parts 500-599, Embargoes, Sanctions, Executive Orders
Inflation Adjustment of Civil Monetary Penalties Related to Reporting and Recordkeeping.

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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