20-1009 Friday “Daily Bugle”

20-1009 Friday “Daily Bugle”

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Friday, 9 October 2020

  1. Commerce/BIS: “Identification and Review of Controls for Certain Foundational Technologies; Correction”
  2. Commerce/BIS: “Revisions to the Unverified List (UVL)”
  1. Items Scheduled for Future Federal Register Edition
  2. Commerce/BIS: (No new postings)
  3. Commerce/Census: “Clarification on the BIS’s Mandatory Filing Requirements related to the 28th of Apr Final Rule”
  4. State/DDTC: (No new postings)
  5. White House: “Statement on Continuation of the National Emergency with Respect to the Situation In and In Relation to Syria”
  6. UK DIT: “UK and Ukraine Sign Political, Free Trade and Strategic Partnership Agreement”
  1. National Law Review: “Sudan Economic Sanctions and Export Controls – A Primer for Aircraft Lessors”
  1. Baker McKenzie: “BIS Amends Licensing Policy for Items Controlled for Crime Control Reasons”
  2. Felice Laird: “A New Landscape for Information Technology Export Controls” (Part I of III)
  3. Hogan Lovells: “OFAC Settles Case Involving Goods with More Than De Minimis Controlled U.S.-Origin Content”
  4. Tuttle Law: “Update on China Section 301 Litigation – History in the Making or a Big Bust?”
  1. Friday List of Approaching Events: 175 Events Posted This Week, Including 13 New Events
  1. Bartlett’s Unfamiliar Quotations 
  2. Are Your Copies of Regulations Up to Date? Find the Latest Amendments Here. 
  3. Weekly Highlights of the Daily Bugle Top Stories 
  4. Submit Your Job Opening and View All Job Openings 
  5. Submit Your Event and View All Approaching Events 

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(Source: Federal Register, 9 Oct 2020) [Excerpts]
85 FR 64078: Proposed Rule
* AGENCY: Bureau of Industry and Security, Commerce.
* ACTION: Advance notice of proposed rulemaking (ANPRM); correction and extension of comment period.
* SUMMARY: On August 27, 2020, the Bureau of Industry and Security (BIS) published the advance notice of proposed rulemaking (ANPRM), Identification and Review of Controls for Certain Foundational Technologies. This document makes a correction to the August 27 ANPRM to clarify that it is permissible to submit confidential business information in response to the August 27 ANPRM, provided the submitter follows the submission requirements included in the ADDRESSES section of this document. The August 27 ANPRM specified that comments must be received on or before October 26, 2020. This document extends the ANPRM’s comment period for fourteen days, so comments must now be received on or before November 9, 2020.
* DATES: The comment period for the ANPRM published at 85 FR 52934 on August 27, 2020, is extended. Submit comments on or before November 9, 2020.
* ADDRESSES: You may submit comments through either of the following:
Federal eRulemaking Portal: http://www.regulations.gov. The identification number for this rulemaking is BIS-2020-0029.
   All filers using the portal should use the name of the person or entity submitting comments as the name of their files, in accordance with the instructions below. Anyone submitting business confidential information should clearly identify the business confidential portion at the time of submission, file a statement justifying nondisclosure and referring to the specific legal authority claimed, and provide a non-confidential version of the submission.
   For comments submitted electronically containing business confidential information, the file name of the business confidential version should begin with the characters “BC.” Any page containing business confidential information must be clearly marked “BUSINESS CONFIDENTIAL” on the top of that page. The corresponding non-confidential version of those comments must be clearly marked “PUBLIC.” The file name of the non-confidential version should begin with the character “P.” The “BC” and “P” should be followed by the name of the person or entity submitting the comments or rebuttal comments. Any submissions with file names that do not begin with a “BC” or “P” will be assumed to be public and will be made publicly available through http://www.regulations.gov.
   Address: By mail or delivery to Regulatory Policy Division, Bureau of Industry and Security, U.S. Department of Commerce, Room 2099B, 14th Street and Pennsylvania Avenue NW, Washington, DC 20230. Refer to RIN 0694-AH80. If you seek to submit business confidential information, you must use the portal. BIS does not accept confidential business information by mail or delivery.

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(Source: Federal Register, 9 Oct 2020) [Excerpts]
85 FR 64014: Rule
* AGENCY: Bureau of Industry and Security, Commerce.
* ACTION: Final rule.
* SUMMARY: The Bureau of Industry and Security (BIS) is amending the Export Administration Regulations (EAR) by removing forty (40) persons from the Unverified List (“UVL”) and adding twenty-six (26) persons to the UVL. The 40 persons are removed from the UVL on the basis that BIS was able to verify their bona fides (i.e., legitimacy and reliability relating to the end use and end user of items subject to the EAR) on the basis of a successful end-use check or because the companies are no longer registered to do business in the country of listing and are no longer involved in U.S. exports. The 26 persons are being added to the UVL on the basis that BIS could not verify their bona fides because an end-use check could not be completed satisfactorily for reasons outside the U.S. Government’s control.
* DATES: This rule is effective October 9, 2020.
* FOR FURTHER INFORMATION CONTACT: Kevin Kurland, Director, Office of Enforcement Analysis, Bureau of Industry and Security, Department of Commerce, Phone: (202) 482-4255 or by email at UVLRequest@bis.doc.gov.

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OGS_a24. Commerce/BIS: (No new postings)

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(Source: Census, 8 Oct 2020)
  On Sunday, September 27, 2020, the Bureau of Industry and Security (BIS) required full compliance with a final rule that expanded the Electronic Export Information (EEI) filing requirement in the Automated Export System (AES) for exports to China, Russia and Venezuela. This rule can be found in its entirety at:  


  The U.S. Census Bureau (Census) has received a number of questions related to BIS’s final rule, specifically the addition to § 758.1(b) of the BIS’s Export Administration Regulations (EAR). This rule added § 758.1(b)(10) of the EAR to require EEI filing for items on the Commerce Control List (CCL) (Part 774 of the EAR) destined to China, Russia, or Venezuela regardless of the value of the shipment, unless the shipment is eligible for License Exception GOV. Most of the questions that Census has received have been related to whether or not ALL exports to China, Russia, and Venezuela require filing.
Census reached out to our partner Commerce agency, BIS, and received the following guidance:
  • “Items on the Commerce Control List” includes any item having an Export Control Classification Number (ECCN), but does not include items that are designated as EAR99.
  • Starting Sunday, September 27, 2020, EEI filing for exports to China, Russia, or Venezuela of items controlled by ECCNs is required regardless of value, unless the shipment is eligible for License Exception GOV.
  • EAR99 items are not subject to BIS’s mandatory filing requirements under § 758.1(b)(10) and an AES exemption from the Foreign Trade Regulations (FTR) may apply.
  • If EEI filing for exports to China, Russia, or Venezuela is required, then the ECCN must be reported in AES.
  For example, an individual is exporting an item valued at $1,000 to China and needs to determine if filing EEI is required. The individual first needs to determine if filing is required under BIS’s mandatory filing requirements in § 758.1(b)(10) of the EAR by determining if the item has an ECCN or is EAR99, as well as any other mandatory filing requirement in § 758.1(b). In this example, the individual determines the item is EAR99. Because the item is EAR99 and destined to China, this export is not subject to the new filing requirement in § 758.1(b)(10). Therefore, an exemption from filing EEI under the FTR would apply, specifically the exemption in Section 30.37(a) of the FTR that applies to goods valued $2,500 or below per Schedule B, provided there are no other mandatory filing requirement in § 758.1(b). The individual in this example is not required to file EEI and the individual would provide the appropriate exemption annotation (i.e., NOEEI 30.37(a)) to the carrier.
Resources and Contact Information: 
  For the entirety of BIS’s final rule, please visit https://www.govinfo.gov/content/pkg/FR-2020-04-28/pdf/2020-07241.pdf
  The BIS issued a FAQ document related to its final rule available here, with information related to filing EEI available on page 8 of the document: 

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  On October 14, 2019, by Executive Order 13894, I declared a national emergency pursuant to the International Emergency Economic Powers Act (50 U.S.C. 1701-1706) to deal with the unusual and extraordinary threat to the national security and foreign policy of the United States constituted by the situation in and in relation to Syria.
  The situation in and in relation to Syria, and in particular the actions by the Government of Turkey to conduct a military offensive into northeast Syria, undermines the campaign to defeat the Islamic State of Iraq and Syria, or ISIS, endangers civilians, and further threatens to undermine the peace, security, and stability in the region, and continues to pose an unusual and extraordinary threat to the national security and foreign policy of the United States. For this reason, the national emergency declared on October 14, 2019, must continue in effect beyond October 14, 2020. Therefore, in accordance with section 202(d) of the National Emergencies Act (50 U.S.C. 1622(d)), I am continuing for 1 year the national emergency declared in Executive Order 13894 with respect to the situation in and in relation to Syria.
  This notice shall be published in the Federal Register and transmitted to the Congress.

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   The UK Prime Minister Boris Johnson today signed an agreement with President Volodymyr Zelenskyy of Ukraine to strengthen the political and trade ties between the two countries.
   Boris Johnson and Volodymyr Zelenskyy have signed the ‘Political, Free Trade and Strategic Partnership Agreement’ to strengthen UK cooperation in political, security and foreign matters with Ukraine, while also securing continued preferential trade for businesses and consumers.
   This agreement, when brought into force, will allow businesses to continue trading as they do now after the end of the Transition Period. It delivers the same level of liberalisation in trade, services and public procurement that businesses currently enjoy under the existing EU-Ukraine Association Agreement. …
Prime Minister Boris Johnson said:
   The UK is Ukraine’s most fervent supporter. … The Strategic Partnership Agreement we signed today signals the next chapter in our relationship. …
Trade between the UK and Ukraine was worth £1.5 billion in 2019. Top UK goods exports to Ukraine were aircraft (£79m), medicinal and pharmaceutical products (£61m) and cars (£52m). The UK imported £177 million of cereals and £182 million of iron and steel in 2019. …
Notes to editors

  • This is the first comprehensive strategic and trade agreement signed by the UK since the creation of the Foreign, Commonwealth and Development Office (FCDO).
  • The agreement provides for broad cooperation in a number of areas, including commitments to cooperate on peaceful conflict resolution, defence and security, climate change, human rights and people-to-people links.
  • This agreement is designed to take effect when the EU-Ukraine agreement ceases to apply to the UK at the end of the transition period. The agreement will be subject to the domestic parliamentary procedures in both the UK and Ukraine before it is brought into force.
  • Statistics source: ONS UK total trade: all countries, non-seasonally adjusted January to March 2020.
  • The UK has now signed or agreed in principle trade agreements with 50 countries. This includes the UK-Japan Comprehensive Economic Partnership Agreement which was agreed in principle on 11 September 2020. Total UK trade with these countries was worth £144 billion in 2019.

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(Source: National Law Review, 9 Oct 2020) [Excerpts]
   The status of Sudan often arises for aircraft and jet engine lessors that require their lessees to comply with U.S. economic sanctions and export control programs. As the Office of Foreign Assets Control (“OFAC”) of the U.S. Department of the Treasury has recently issued guidance on the Sudan program, this is an opportune time to review the current status of Sudan insofar as the existing programs are concerned.
   Many civil aircraft and jet engine leases contain provisions that prohibit the lessee and its allowed sublessees from operating the aircraft or engine to, from or within “prohibited” or “restricted” countries and regions, i.e., those countries and regions that are subject to comprehensive trade embargoes. From the standpoint of U.S. law, such countries and regions currently include Cuba, Iran, Syria, North Korea and the Crimea region of the Ukraine. …
   In October 2017, as a result of improving conditions, the United States began taking down existing trade sanctions against Sudan. Under Executive Orders signed by Presidents Obama and Trump, prior Executive Orders were revoked, in whole and in part, and dozens of Sudanese individuals and companies were removed from OFAC’s SDN list. In June 2018, the then-existing Sudanese Sanctions Regulations were removed, thereby opening the door for U.S. persons to re-engage in previously prohibited transactions with Sudan and the Government of Sudan. As a result of these actions, new aircraft and jet engine leases that were entered into after June 2018 often blue penciled Sudan from the list of restricted or prohibited countries.
   The Guidance recently published by OFAC reminds us, however, that the sanctions book on Sudan did not end there.
   For starters, the “national emergency” with respect to Sudan, first declared by President Clinton in 1997 pursuant to the International Emergency Economic Powers Act (“IEEPA”), has never been terminated and, in fact, has been expanded over the years. The declaration of a national emergency was last continued by President Trump on October 31, 2019 on grounds that, despite “positive developments” in Sudan, “the crisis constituted by the actions and policies of the Government of Sudan that led to the declaration of a national emergency” was then unresolved.
   Although seemingly odd that a national emergency still exists with respect to Sudan after 23 years, the fact that it does makes the return of sanctions against Sudan by executive fiat that much easier. Under IEEPA, the President may exercise broad sanctions powers “to deal with any unusual and extraordinary threat, which has its source in whole or substantial part outside the United States, to the national security, foreign policy, or economy of the United States, if the President declares a national emergency with respect to such threat.” Thus, the continuing existence of a national emergency involving Sudan under IEEPA allows the President to reimpose sanctions authorities against Sudan without Congressional direction or authorization. …
   In the meantime, Sudan remains a State Sponsor of Terrorism, a designation that continues to have important implications for the export and re-export of items subject to the EAR, including civil aircraft of U.S. origin and foreign-built aircraft incorporating more than a de minimis amount of U.S. controlled content. These implications flow from Section 1754(c) of the recently enacted Export Control Act of 2018, which states that a license is required for the “export, re-export, or in-country transfer” of controlled items to any country whose government has been found to repeatedly provide “support for acts of international terrorism.”
   Because Sudan remains on the list of State Sponsors of Terrorism, exports and re-exports to Sudan are controlled for anti-terrorism (“AT”) purposes and those controls will likely remain in place until a deal is reached to remove the country from the list. AT controls affect the export and re-export of civil aviation aircraft and related gas engines, parts and components under ECCN 9A991, which means that Sudan will be subject to AT controls under 15 C.F.R. §742.10 and a general licensing policy of denial if an appropriate license exception is not otherwise available under 15 C.F.R. §740. The most common license exception used in connection with civil aircraft is the one that applies to aircraft, vessels and spacecraft (AVS) – commonly referred to as the temporary sojourn license exception. The application of AVS is subject to detailed requirements that must be strictly followed.
   The OFAC Guidance provides a valuable reminder to U.S. aircraft lessors that Sudan remains a special case. Although no longer subject to a comprehensive trade embargo administered by OFAC, Sudan is still subject to a national emergency declaration under IEEPA and is still listed as a State Sponsor of Terrorism, a designation which triggers AT export controls. Aircraft and jet engine lessors whose lessees fly to Sudan should be mindful of that country’s status and should ensure that their leases require compliance with sanctions and export controls otherwise applicable to the leased aircraft and engines.


* Author: Stuart P. Seidel, Esq., 1-202-452-7088, Baker McKenzie
  On October 6, 2020, the Bureau of Industry and Security (BIS) published in the Federal Register a final rule [Docket No. 200624-0168] amending the Export Administration Regulations (EAR) by revising, in part, the licensing policy for items controlled for crime control (CC) reasons, which is designed to promote respect for human rights throughout the world. BIS also is amending the EAR to provide that, except for items controlled for short supply reasons, it will consider human rights concerns when reviewing license applications for items controlled for reasons other than CC. This revision is necessary to clarify to the exporting community that licensing decisions are based in part upon US Government assessments of whether items may be used to engage in, or enable violations or abuses of, human rights including those involving censorship, surveillance, detention, or excessive use of force. 

* Author: Felice Laird, Export Strategies LLC [Part II and III coming soon]
   2020 has brought in a new wave of U.S. export controls and other significant actions that have an effect on global trade in telecommunications and information security products.  New export controls on hardware, software and related technical data have been imposed as part of efforts to identify and restrict “emerging technologies” in the telecom space.  By and large, these controls result from group decisions made by the US and many European countries, while others reflect the United States’ unusual use of executive powers.  For example, while the export ban to Huawei and its many subsidiaries was done by the Bureau of Industry and Security (BIS) primarily using its authorities under the Export Control Reform Act (ECRA), the various US government procurement bans on equipment produced by Huawei has been done under various Executive Orders issued under the International Economic Emergency Powers Act (IEEPA).  The recent Executive Orders banning the use of TikTok and WeChat cited IEEPA, were intended to force the major app distribution platforms run by US companies to stop allowing downloads of the apps in the US.
   For the trade compliance professional, it’s important to be able to tell what is a classic “export  control” on hardware, software and technical data and what may look like an export control but is really an effort to manage domestic supply chain concerns, or to further human rights in particular countries.  For example, the US government alleges that the TikTok and WeChat apps have been used to collect personal data on US citizens, and to track the movements and activities of people worldwide, which is a human rights concern.   Yet the entities owning the apps have not been identified on the various government “restricted” parties list and to date there are no transaction related limits on doing business with the companies involved.  The attempt to restrict transactions via Executive Order/IEEPA in this case has led to judicial proceedings, citing the lack of due process.   In the case of Huawei, the US Government has alleged that Huawei supplies countries like Iran with their telecommunications equipment, makes and sells network infrastructure equipment used by US telephone, mobile phone and wired service providers that may contain illegal “back doors”, and manufactures cellphones loaded with apps that can track users. 
   For the purposes of this article series, we will focus on changes to the Export Administration Regulations (EAR) that were published in September and /October 2020 as they pertain to telecommunications and information security.  Export controls on “dual use” telecommunications and information security technologies appear in Category 5 of the Commerce Control List (CCL).  This Category is regularly reviewed by the US and its partners in the Wassenaar Arrangement.  The 2020 changes have been published as Final Rules, and thus were not subject to prior industry consultations.  Concurrently, the Commerce Department has implemented a comprehensive ban on direct and indirect trade with Huawei companies affecting both US and non-US companies. The ban has taken the form of an Entity List designation, and a carefully crafted expansion of the Foreign Direct Product Rule.  (To be continued in Part II and Part III.) 

* Principal Author: Aleksandar Dukic, Esq., Hogan Lovells LLP
   On 24 September 2020, the U.S. Department of Treasury’s Office of Foreign Asset Control (OFAC) announced a $473,157 settlement with Keysight Technologies, Inc. (Keysight) for sanctions violations committed by its former subsidiary, Anite Finland OY (Anite). Anite reexported goods to Iran that incorporated 10 percent or more controlled U.S.-origin content. This appears to be the first public settlement announced by OFAC that is based on violations involving the reexport of goods that incorporated greater than a de minimis amount of U.S.-origin controlled content in contravention of section 560.205 of the Iranian Transactions and Sanctions Regulations (ITSR).
The Settlement
   OFAC settled with Keysight, a company based in Santa Rosa, CA, for potential U.S. export control violations committed by its former Finnish subsidiary, Anite. Keysight has agreed to pay US$473,157 for its potential civil liabilities. In addition, as part of the settlement agreement, Keysight made a five year commitment to numerous compliance measures.
The Facts
   Keysight acquired Anite in August 2015. After the acquisition, Anite sold goods containing 10 percent or more U.S.-origin controlled content to Iran. Anite designed and sold test and measurement instruments, and related software, to the wireless industry. Anite fulfilled six orders to Iran between January 2016 and June 2016 that totalled US$331,089 in value. The export of those goods required a license pursuant to the ITSR. The ITSR requires a license for the reexport to Iran of goods containing 10 percent or more U.S.-origin controlled content. At the time the violations occurred, a general license (General License H) had been in place between 16 January 2016 and 27 June 2018 that permitted certain transactions between foreign entities owned or controlled by U.S. persons, but General License H did not authorize the reexport from third countries of any goods that were prohibited by section 560.205 of the ITSR.
   After Keysight’s acquisition of Anite and Anite’s integration into Keysight, Keysight directed Anite to cease all business with sanctioned countries. Despite that direction from management, employees at Anite continued to do business with entities in Iran. Those employees also took steps to conceal their activities from others at Keysight.
   Upon discovery of the violations, Keysight conducted an internal investigation and submitted a voluntary self-disclosure to OFAC and in its Securities and Exchange Commission filings. Mitigating factors – particularly actions taken by Keysight during the course of its internal investigation and after the voluntary self-disclosure – brought the penalty amount down from the statutory maximum of US$2,102,920 to US$473,157.
Next steps
   Companies that have acquired, or are looking to acquire, foreign entities should assess their potential sanctions exposure associated with the proposed transaction. This case highlights the need to assess exposure through the supply chain, as violations of U.S. sanctions can be triggered by the export, reexport, or transfer of goods with incorporated U.S.-origin content. Once a company acquires a new entity, the purchaser should ensure that its newly acquired entity adopts a robust sanctions compliance program.


(Sources: Event sponsors)  

Submit your event in the Submission section at the end of this newsletter.  
[Editor’s note:  This Daily Bugle Event List has grown so large that we have run out of space to display it, so we are displaying here only the new events in the Daily Bugle, while maintaining a LINK HERE to the full list.]

Published every Friday or last publication day of the week. Send events to events@fullcirclecompliance.eu, composed in the below format:
# * Date: (Location;) “Event Title”; <Weblink>” Event Sponsor;

* 13 Oct: “Can you get your 301/China duties back?“; Foreign Trade Association
* 14 Oct: “U.S. Food and Drug Administration (FDA) Virtual Workshop“; Women in Trade – Northern California Chapter & CBFANC
* 30 Oct: “Methods of Payment & Letters of Credit Course“; Chamber International
* 22 Oct, 1-5 pm Eastern: DDTC’s Defense Trade Advisory Group (DTAG) plenary virtual meeting.  Send name, email address, and phone number to Neal Kringel, DTAG@state.gov, by COB  21 Oct. 
* 10 – 12 Nov: “ITAR for the Empowered Official and Compliance Personnel“; FD Associates
* 26 Nov: “The ABC of Foreign Military Sales (FMS) “; Full Circle Compliance (FCC) Academy
On Location:

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EN_a115. Bartlett’s Unfamiliar Quotations

(Source: Editor)

Lewis Cass (9 Oct 1782 – 17 Jun 1866; was an American military officer, politician, and statesman.)
  – “People may doubt what you say, but they will believe what you do.”

Friday funnies:
* There’s a scary split second when you lose your balance in the shower and think “Oh darn. They’re gonna find me naked.”
* The quickest way to double your money is to fold it over and put it back in your pocket.
* And finally – Can we all agree that in 2015 not a single person got the answer correct to the question, “Where do you see yourself 5 years from now”.
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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. 
9 Oct 2020: 85 FR 64014:  Revisions to the Unverified List (UVL).

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.


28 Sep 2020: 85 FR 60874: Temporary Amendment for Republic of Cyprus. The latest edition of the BITAR is 28 Sep 2020. 

DOT FOREIGN ASSETS CONTROL REGULATIONS (OFAC FACR): 31 CFR, Parts 500-599, Embargoes, Sanctions, Executive Orders
International Criminal Court-Related 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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