20-1104 Wednesday “Daily Bugle”

20-1104 Wednesday “Daily Bugle”

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Wednesday, 4 November 2020

(No items of interest posted) 

  1. Items Scheduled for Future Federal Register Edition
  2. Commerce/BIS: (No new postings)
  3. State/DDTC: (No new postings)
  1. EUS: “72 Countries Issue Statement of Support for ICC & Oppose US Sanctions”
  1. BCLP Law: “Keeping up with the Changes: Has your Compliance Program Been Adapted to Account for Recent Changes to U.S. Export Controls? (Part 1)
  2. Husch Blackwell: “White House Rescinds Sudan’s State Sponsor of Terrorism Designation, Continues National Emergency”
  3. Paul Hastings: “China Enacts New Export Control Law – Global Businesses Take Heed”
  4. Slaughter and May: “Export Control, Trade Wars and Brexit”
  1. FCC Academy Presents: 1 and 3 Dec; “U.S. Export Controls: ITAR/EAR” and “FMS”
  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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[No items of interest posted]

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(Source: Federal Register)
* Commerce/BIS; Notices; Meetings:Materials and Equipment Technical Advisory Committee; [Pub. Date: 5 Nov 2020] (PDF)
* Commerce/BIS; Notices; Order Denying Export Privileges:
Abdul Majid Saidi, Oswaldo Sanchez, Patrick Germain; [Pub. Date: 5 Nov 2020] (PDF) (PDF) (PDF)
* State; Notices; Guidance:Protecting Europe’s Energy Security Act; [Pub. Date: 5 Nov 2020] (PDF)

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OGS_a22. Commerce/BIS: (No new postings)

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Following the International Criminal Court’s (ICC) annual report to the United Nations General Assembly, 72 State Parties to the Rome Statute (which established the ICC) issued a statement confirming their “unwavering support for the Court as an independent and impartial judicial institution”. In light of the US sanctions against 2 ICC senior officials in September 2020 (see post), the statement said that “sanctions are a tool to be used against those responsible for the most serious crimes, not against those seeking justice. Any attempt to undermine the independence of the Court should not be tolerated”.


(Source: BCLP Law, 3 Nov 2020)
* Principal Author: Megan A. Gajewski Barnhill, Esq., 1 202 508 6302, BCLP Law
While the pandemic has slowed down many things this year, it did not impede progress by the Department of Commerce’s Bureau of Industry and Security (“BIS”) in publishing various regulatory changes aimed at addressing national security concerns related to certain countries of interest, including China, Russia and Venezuela.  With significant changes having been introduced this year, it is critical to ensure that your compliance program is keeping up with the changes.  
(1) Expansion of the military end-use/military end-user rule
As of June 29, 2020, BIS amended the military end-use/military end-user rule in § 744.21 of the Export Administration Regulations (“EAR”) to cover additional items and expand the definition of military end-use for transactions destined to China, Russia, and Venezuela.  In addition, the rule restricted transactions to China that are destined to military end-users, which restriction already existed with respect to transactions for Russia and Venezuela.  Companies that engage in exports to China, Russia, or Venezuela should ensure that they have procedures in place to vet end-users and end-uses in connection with the export of any items covered by the rule.  With the expansion of the definition of military end-use – and, in turn, the scope of the definition of military end-user – this vetting will likely require entities to conduct additional diligence related to exports covered by the rule, particularly when such exports involve parties included in the Section 1237 list published by the Department of Defense.  Although the Section 1237 list, which specifies “Communist Chinese military companies” operating directly or indirectly in the United States, is not itself a legal determination that a particular entity is a “military end-user” for purposes of the rule, it is a red flag that additional diligence is warranted.  Note also that this rule expanded the requirement for filing Electronic Export Information to all shipments destined to China, Russia, and Venezuela, except for transactions involving only items designated EAR99.
(2) Expansion of the foreign direct product rule
Effective August 17, 2020, BIS again increased the scope of transactions that would be considered subject to the EAR pursuant to General Prohibition Three of the EAR (often referred to as the “foreign direct product” rule).  The expansion of the foreign direct product rule is particular to certain transactions or activities involving Huawei Technologies Co., Ltd. (“Huawei”) and its affiliates that are listed on the Entity List (“Listed Affiliates”).  In particular, a license is now required under the EAR in order to export, reexport, or transfer (in-country) goods, technology, or software to Huawei or a Listed Affiliate when the foreign-produced item is:

-The direct product of “technology” or “software” subject to the EAR and specified in Export Control Classification Number (“ECCN”) 3D001, 3D991, 3E001, 3E002, 3E003, 3E991, 4D001, 4D993, 4D994, 4E001, 4E992, 4E993, 5D001, 5D991, 5E001 or 5E991 of the Commerce Control List (“CCL”); or


-Produced in a plant outside the United States where “the plant or a major component of the plant, whether made in the US or a foreign country, itself is a direct product of US-origin ‘technology’ or ‘software’ subject to the EAR and specified in ECCN 3D001, 3D991, 3E001, 3E002, 3E003, 3E991, 4D001, 4D993, 4D994, 4E001, 4E992, 4E993, 5D001, 5D991, 5E001 or 5E991.” Footnote 1 in Supplement No. 4 to Part 744 of the EAR. 

These restrictions apply to any transaction in which there is knowledge that:
  • The foreign-produced item will be incorporated into, or will be used in the production or development of any part, component, or equipment produced, purchased, or ordered by Huawei or a Listed Affiliate; or
  • Huawei or a Listed Affiliate is a party to any transaction involving the foreign-produced item (e.g., as a purchaser, intermediate consignee, ultimate consignee, or end-user).   

It is important to note that an item will be considered the direct product of covered technology or software if it is produced in a plant outside the United States in which “the plant or a major component of the plant is a direct product of covered software or technology.  Under the rule, a “major component of a plant located outside the United States” includes any equipment that is essential to the production of an item; this includes testing equipment.  Moreover, foreign-produced items can include foreign-produced wafers, regardless of whether the wafer is finished or unfinished. 

In order to ensure compliance with these changes, companies should ensure they are aware of all transactions that involve Huawei or any of the Listed Affiliates.  Entities both in the United States and outside the United States should consider how their affiliates and business partners outside the United States might interact with Huawei or the Listed Affiliates, particularly to the extent the entity deals in any way with goods, software, or technology classified under Category 3, 4, or 5 of the CCL.  In some cases, entities outside the United States may need more information from their equipment suppliers, for instance, to understand fully whether the equipment might be the direct product of software or technology that is captured by this rule, such that anything produced using that equipment (whether goods, software, or technology) might itself be captured by this expanded foreign direct product rule if there is a nexus to Huawei or any of the Listed Affiliates in the transaction.  Reviewing this information up front is key to mitigating the risks of compliance concerns as business proceeds, especially because a violation of these rules is likely to catch the attention of the enforcement teams given the national security concerns driving the changes in the first place.  
(3) Revision to the license review policy for exports of items controlled for National Security (NS) reasons to China, Russia, or Venezuela
BIS also revised its license review policy for items controlled for National Security (NS) reasons to China, Russia, and Venezuela in a final rule that became effective on October 29, 2020.  Under the rule, BIS will consider whether an export, reexport, or in-country transfer of items controlled for NS reasons will make a material contribution to the weapons systems capability of China, Venezuela, or Russia.  This determination will be based on several factors, including the following:
  • appropriateness of the item for the stated end-use,
  • the significance of the item to the weapons system capabilities of the importing country,
  • whether a party is a military end-user,
  • the reliability of the parties to the transaction,
  • the involvement of any party to the transaction in military activities,
  • government strategies and policies posing a risk of diversion to military end-use, and
  • the effectiveness of export controls in the importing country.
In addition to this review, BIS will also consider the affect that the proposed activity would have on the US defense industrial base. Entities who engage in exports of items controlled for NS reasons to Russia, China, or Venezuela should ensure that they are addressing these considerations when preparing license applications for such exports.

(Source: Husch Blackwell, 3 Nov 2020)
* Principal Author: Beau Jackson, Esq., 1-202-378-2406, Husch Blackwell
On November 2, 2020, the White House released a notice continuing the national emergency with respect to Sudan declared in Executive Order 13067 of 1997.  Secretary of State Mike Pompeo issued a press statement clarifying that the United States is continuing certain Sudan-related sanctions pursuant to obligations to the United Nations (“UN”), but that the notice of continuation “does not reflect negatively on our improved bilateral relationship with Sudan…and does not have any impact on the decision or procedures to rescind Sudan’s State Sponsor of Terrorism (SST) designation.”

On October 26, 2020 the President issued a Certification of Rescission regarding the 1993 determination that the government of Sudan supports acts of international terrorism, following a peace agreement between Sudan and Israel a few days earlier.  The President certified that Sudan has not provided support for acts of terrorism during the last six months, and that Sudan has provided assurances it will not support future acts of terrorism.  The rescission begins the process of normalizing trade relations between the United States and Sudan, which is now governed by a civilian and military government after deposing a thirty-year dictatorship.  According to Section 6(j) of the Export Administration Act of 1979 (“EAA”), it will be at least 45 days, or until December 10, 2020, before Sudan’s State Sponsor of Terrorism designation is officially rescinded.

Currently, because of Sudan’s State Sponsor of Terrorism designation, the U.S. Export Administration Regulations (“EAR”) require a license from the US Commerce Department – Bureau of Industry and Security (“BIS”) to export or reexport almost any item to Sudan that is listed on the EAR’s Commerce Control List.  Once rescinded, some of these licensing requirements will be relaxed, but other export controls and BIS licensing requirements directed at Sudan pursuant to alternative authorities will remain in place.

Additionally, the President issued a certification pursuant to Section 6(e) of the Comprehensive Peace in Sudan Act of 2004 (as amended by the Darfur Peace and Accountability Act of 2006, the “CPSA”).  The certification states that the government of Sudan has “taken demonstrable steps” to meet certain criteria which could serve as a precursor to lifting separate sanctions imposed by the U.S. Department of Treasury – Office of Foreign Assets Control (“OFAC”) against certain Sudanese and Darfuri individuals and entities.  However, many of those OFAC sanctions are imposed under agreements between the U.S. and the UN, and as a result the UN must also agree before OFAC could lift those specific sanctions.  Secretary Pompeo acknowledged this in his press release, stating “In recognition of the important steps that the Sudanese government has taken toward peace in Sudan’s conflict areas, the United States is committed to working with the Sudanese government and our international partners to identify circumstances that could result in lifting sanctions related to the Darfur conflict at the earliest opportunity.  We have already begun consultations at the UN with this objective in mind.”

(Source: Paul Hastings, 2 Nov 2020) [Excerpts]  
* Principal Author: Scott M Flicker, Esq., 1202551-1726, Paul Hastings
In a move that is certain to have broad impacts on cross-border trade, China is preparing to implement a comprehensive new Export Control Law (“ECL”). [FN/1]Many of the requirements, concepts, and mechanisms under the new law-which was announced on October 17, 2020 and is slated to come into effect on December 1, 2020-will be recognized by those familiar with the U.S. Export Administration Regulations (“EAR”). [FN/2] Indeed, a number of the key features of China’s law find direct parallels in the EAR. Among these are:
  • China will be developing a new “Control List” comprised of civil-and-military “dual-use” items, military items, nuclear items, and other goods, technology control over which is deemed important to China’s national security and other policy interests.
  • Persons seeking to export or re-export controlled items may need to obtain specific licenses from the Chinese government, depending on the level of control over the items, the intended destination of export, and the intended end user or end use.
  • “Deemed exports” (transfers of controlled technology to a non-Chinese national, even wholly within China) will be covered and potentially subject to licensing or other restrictions.
  • Chinese authorities will maintain a list of restricted importers and end users that, along with the recent publication of “Regulations on the Unreliable Entity List” by China’s Ministry of Commerce, [FN/3]establishes an analogue to the U.S. Entity List that will trigger a requirement for the Chinese government’s approval for transactions involving listed persons.
  • Violation of the ECL will carry administrative and criminal penalties based in part of the value of the transactions at issue.

Some elements of the ECL, however, find no direct equivalent in the EAR, including the availability of preferential benefits, particularly certain blanket “general licenses,” for companies that establish effective internal compliance systems. The ECL also places an obligation on exporters to acquire approvals before engaging in any transaction where the exporter “knows or should have known” that the export of an item (even one not on any Control List) may “endanger China’s national security and interests”-a potentially unlimited discretionary control that is not found in U.S. law.

It also remains to be seen whether China will implement one of the most controversial features of U.S. export controls: the imposition of extraterritorial restrictions under the EAR on the export of foreign-made items that are comprised of, or are the “direct product” of, controlled U.S. content or technology. The United States has recently expanded these provisions to block foreign chipmakers from supplying semiconductors to leading Chinese companies. Notably, the first draft of the ECL released in June 2017 specified that it would apply to foreign products that “contain a certain proportion of China’s Controlled Items” exported from outside of China to other countries/regions. Later drafts and the final version of the ECL have removed this restriction, but it could still resurface in the form of regulations issued by one of the agencies that will be responsible for administering aspects of the law.
Several aspects of the new law, including the ability of the Chinese government to prohibit exports of entire categories of strategic goods to U.S. persons in China or elsewhere, could be a “game changer” in the U.S.-China trade relationship. One state-run publication went so far as to suggest that rare-earth metals and circuit boards-both of which U.S. technology companies overwhelmingly source from China-could come under government-sanctioned export bans, in a direct response to recent U.S. export control moves directed at China. [FN/4]

One thing is clear: the Chinese government is preparing to impose sweeping new requirements on transactions involving Chinese goods and technology. All companies doing business in or with China must take notice.
Consisting of five chapters and 49 articles, the new ECL provides a comprehensive statutory framework for China to regulate exports. The new law governs the movement of controlled items (discussed below) from the Chinese territory to destinations outside of China (including re-exportation between foreign destinations), as well as the transfer or release of controlled technology by any Chinese individual, legal entity, or any other organization to any foreign individual or entity. [FN/5]

Prior to enactment of the ECL, exports were governed under China’s 2004 Foreign Trade Law for high-level export principles. [FN/6]Several State Council regulations also address transfers of specific controlled items. [FN/7]The ECL remakes China’s export control landscape by consolidating the applicable rules and providing general guidance for administration over the movement of all controlled items. It should be noted, however, that while laws enacted by the National People’s Congress and its Standing Committee, such as the ECL, are superior to State Council regulations, the ECL does not supersede the pre-ECL export control regulations in their entirety. These regulations remain effective unless they conflict with the ECL.

The ECL must be read in conjunction with other recent developments in China’s export control regime, in particular, the Regulations on the Unreliable Entity List issued by the Ministry of Commerce on September 19, 2020. As discussed below, application of aspects of the ECL and the Regulations on Unreliable Entity List intersect, creating similar but independent rules that may apply to transactions with specified foreign entities (see below Key Aspects of the ECL-End-User and End-Use Management).

The ECL has been characterized as China’s response to the increasing tensions over growing restrictions on U.S.-China technology transfers. Commentators note that, combined with the Regulations on the Unreliable Entity List and other relevant rules, the ECL will equip China to react to any U.S. trade measures targeted at its companies and economy. This is evidenced by ECL’s express language that China could take “reciprocal measures” against any country or region that “abuses export control measures to endanger China’s national security and interests.” [FN/8] As such, companies engaging in international trade-especially in both China and the U.S.-should be attuned to the evolving export control regimes of both countries in order to navigate through the political, strategic and regulatory challenges in today’s global trade environment.
Key Aspects of the ECL
Basic Requirements
The ECL regulates the export of certain items (“Controlled Items”), which include civil-and-military “dual-use” items, military items, nuclear items, and other goods, technology, and services identified as necessary to safeguarding China’s national security and interests, and fulfilling international obligations such as non-proliferation of nuclear, chemical, and biological weapons. [FN/9]Controlled Items will also include technology pertaining to controlled commodities, components and software. [FN/10]

The ECL authorizes certain national export control administration authorities, which comprise relevant departments within the State Council and the Central Military Commission (“Export Control Authorities”), to develop, adjust, and publish a control list (“Control List”)[FN/11] specifying the Controlled Items subject to export restrictions. These restrictions may include complete export bans or prohibitions on exports to specific destination countries, regions, organizations, or individuals. [FN/12] Companies seeking to export a Controlled Item must apply for a license from the competent Export Control Authority, [FN/13]which may grant or deny the application based on the following criteria: (i) national security and interests; (ii) international obligations and external commitments; (iii) type of export; (iv) sensitivity of the controlled item; (v) export destination country or region; (vi) end user and end use; (vii) relevant credit records of the export business operator; and (viii) other factors provided by laws and regulations. [FN/14]

The Control List has not yet been issued. On October 22, 2020, following the promulgation of the ECL, the Ministry of Commerce indicated that it would “actively promote the formulation of supporting regulations of the [ECL] to ensure the effective implementation of the various systems established thereby. At the same time, it will further improve and release in due course the [Control List].”[FN/15] While the ultimate Control List is not yet available, it is reasonable to expect that the Control List will encompass the substance of the recently updated Catalogue of Export-Prohibited and Export-Restricted Technologies of China.[FN/16] …
[FN/1] Export Control Law of the People’s Republic of China (Order No. 58 of the President of the People’s Republic of China issued on October 17, 2020 and effective on December 1, 2020, Standing Committee of the National People’s Congress of the People’s Republic of China (available at http://www.npc.gov.cn/npc/c30834/202010/cf4e0455f6424a38b5aecf8001712c43.shtml).
[FN/2]15 C.F.R. Parts 730-774.
[FN/3] Regulations on Unreliable Entity List (Ministry of Commerce Decree No. 4 [2020]) issued and effective on September 19, 2020, Ministry of Commerce of the People’s Republic of China (available 
at http://www.mofcom.gov.cn/article/b/fwzl/202009/20200903002593.shtml); see also Paul Hastings’s post on China’s Regulations on Unreliable Entity List (available at  https://www.paulhastings.com/publications-items/details/?id=cd410e70-2334-6428-811c-ff00004cbded).
[FN/4] Global Times, “China’s export control laws to be used to break U.S. ‘long-arm’ jurisdiction: analyst,” October 18, 2020 (available at https://www.globaltimes.cn/content/1203798.shtml).
[FN/5]ECL, Art. 2(3).
[FN/6] Foreign Trade Law of the People’s Republic of China (Order No. 15 of the President of the People’s Republic of China) issued on April 6, 2004 and effective on July 1, 2004, Standing Committee of the National People’s Congress of the People’s Republic of China (available at http://www.gov.cn/flfg/2005-06/27/content_9851.htm).
[FN/7] These regulations include the Regulations on: (i) Controlled Chemicals (issued 1995), (ii) Administration of Technology Import and Export (issued 2001), (iii) Administration of Arms Export (issued 2002), (iv) Export Control of Missiles and Relevant Items and Technologies (issued 2002), (v) Export Control of Dual-Use Biological Agents and Related Equipment and Technologies (issued 2002), (vi) Control of Nuclear Export (issued 2006), and (vii) Control of Nuclear Dual-Use Items and Related Technologies Export (issued 2007).
[FN/8] ECL, Art. 48.
[FN/9] ECL, Art. 2(1).
[FN/10] ECL, Art. 2(2).
[FN/11] ECL, Arts. 5, 9(1).
[FN/12] ECL, Art. 10.
[FN/13]ECL, Art. 12(2).
[FN/14] ECL, Art. 13.

(Source: Slaughter and May, 1 Nov 2020)
* Author: Ian Ranson, Esq., 44-20-7090-3932, Slaughter and May
Brexit and the US-China trade war are generating significant new developments in the historically quite slow-moving area of export control law.  Businesses operating internationally, particularly in the technology sector, are facing new compliance challenges and some significant uncertainties.

For those unfamiliar with this relatively specialised area, export control laws regulate the export of certain goods and technology with the aim of preventing those items from being used in a way that the exporting country deems harmful.  Export controlled items commonly include weapons, implements of torture, nuclear materials and technology, dangerous chemicals and bio-hazards and “dual-use” items (being items that can have a civil as well as a military use).  The list of items and the availability of a licence to permit an export can depend on the destination country, the identity of the recipient and the intended use of the items.
The category of dual-use items is often the most relevant for technology businesses.  It includes some fairly anachronistic standards around encryption technology, which, subject to various exceptions, means a lot of modern software and hardware is potentially export controlled.  There is also talk, particularly in the US, of export controls being expanded to include new genomics, AI, robotics and facial recognition technologies.

Over the last three years, the US-China trade war has seen the US government use export control laws as means to try to curtail China’s technological advancement and as a tactic in trade negotiations.   
The US government added Huawei and, more recently, China’s largest computer chip fabricator SMIC to its “Entity List”.  This list effectively prevents US businesses, and businesses outside the US looking to trade certain US-sourced technology, from exporting to entities on the list.  Additionally, businesses are reportedly finding it increasingly difficult to obtain export licences for items destined for the PRC.

In retaliation, China’s Ministry of Commerce has issued its own “Unreliable Entity List” and last month the National People’s Congress passed the PRC’s first comprehensive export control regime giving the PRC government broad powers to restrict the export of items for national security or in the national interest.  The law expressly authorises the PRC government to take reciprocal measures against other countries abusing export control measures to endanger the national security or national interests of the PRC.
This escalation is increasing the trade compliance burden for many businesses and the fact that both countries’ laws have significant extraterritorial reach is seeing many UK-based businesses caught in the cross-fire.

Turning to the UK, Brexit is presenting further challenges for businesses in this area.  From the end of the Transition Period on 31 December 2020, the free movement of various export controlled items between the UK and the EU will cease and exports thereafter will require a licence.  Additionally, the UK’s recognition of EU member state export licences (and vice versa) will also cease.  Businesses will need to undertake a trade compliance review to ensure that export controlled items leaving the UK or the EU following the Transition Period are appropriately licensed.

Uncertainty remains as to how a trade agreement between the UK and the EU may change things and how exports and imports will be managed at the border with the Republic of Ireland.  As the UK goes it alone in entering into international treaties and managing its trade relationships with other nations, it remains to be seen how the UK’s export control laws will develop and potentially diverge from those of the EU post-Brexit.


U.S. Export Controls: ITAR & EAR from a non-U.S. Perspective (Tuesday, 1 Dec 2020)
Register or find more information here

The ABC of Foreign Military Sales (FMS) (Thursday, 3 Dec 2020)
Register or find more information here
* Register for both and take advantage of our discounted price!
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EN_a110. Bartlett’s Unfamiliar Quotations

(Source: Editor)

* Will Rogers (William Penn Adair Rogers; 4 Nov 1879 – 15 Aug 1935; was an American stage and film actor, vaudeville performer, cowboy, humorist, newspaper columnist, and social commentator from Oklahoma. He was a Cherokee citizen born in the Cherokee Nation, Indian Territory.  He made 71 films (50 silent films and 21 “talkies”), and wrote more than 4,000 nationally syndicated newspaper columns.)
  – “Last year we said, ‘Things can’t go on like this’, and they didn’t, they got worse.”
  – “Be thankful we’re not getting all the government we’re paying for.”
  – “A fool and his money are soon elected.”
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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
Amendment of Cuban Assets Control 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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