20-1113 Friday “Daily Bugle”

20-1113 Friday “Daily Bugle”

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Friday, 13 November 2020

  1. Treasury/OFAC: “Blocking or Unblocking of Persons and Properties”
  2. USTR: “Product Exclusion: China’s Acts, Policies, and Practices Related to Technology Transfer, Intellectual Property, and Innovation”
  1. Items Scheduled for Future Federal Register Edition
  2. Commerce/BIS: (No new postings)
  3. State/DDTC: (No new postings)
  4. EU Commission: “Boeing WTO Case: EU Puts in Place Countermeasures against U.S. Exports”
  5. EU Council Implements Regulation (EU) No 267/2012 Concerning Restrictive Measures against Iran”
  6. EU Council Implements Regulation (EU) 2017/2063 concerning Restrictive Measures in view of the Situation in Venezuela”
  1. Defense News: “Britain Moves to Protect its Defense Industry from Foreign Influence”
  2. Export Compliance Daily: “EU Council, Parliament Approve New Export Control Regime”
  1. Baker McKenzie: “UK To Be Added To Eu’s List Of Safe Countries to Export -Dual-Use Items-“
  2. RA Krause: “Export Control is a Matter for the Management in Germany”
  3. Ted Murphy International Trade Updates: “U.S. Trade Issues – Post-Election Thoughts”
  1. ECS Presents: 16-17 Nov; “ITAR/EAR Controls for U.S. & Foreign Companies”
  2. FCC Academy Presents: 1 and 3 Dec; “U.S. Export Controls: ITAR/EAR” and “FMS”
  3. Friday List of Approaching Events: 202 Events Posted This Week, Including 5 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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85 FR 72751: Notice
* AGENCY:Office of Foreign Assets Control, Treasury.
* ACTION:Notice
* SUMMARY:The Department of the Treasury’s Office of Foreign Assets Control (OFAC) is publishing the names of one or more persons that have been placed on OFAC’s Specially Designated Nationals and Blocked Persons List based on OFAC’s determination that one or more applicable legal criteria were satisfied. All property and interests in property subject to U.S. jurisdiction of this person are blocked, and U.S. persons are generally prohibited from engaging in transactions with them.
* DATES:See Supplementary Information section for applicable date(s).
* FOR FURTHER INFORMATION CONTACT:OFAC: Associate Director for Global Targeting, tel.: 202-622-2420; Assistant Director for Sanctions Compliance & Evaluation, tel.: 202-622-2490; Assistant Director for Licensing, tel.: 202-622-2480.

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85 FR 72748: Notice
* AGENCY: Office of the United States Trade Representative.
* ACTION: Notice.
* SUMMARY: Effective September 2018, the U.S. Trade Representative imposed additional duties on goods of China with an annual trade value of approximately $200 billion as part of the action in the Section 301 investigation of China’s acts, policies, and practices related to technology transfer, intellectual property, and innovation. The U.S. Trade Representative initiated a product exclusion process in June 2019, and interested persons have submitted requests for the exclusion of specific products. This notice announces the U.S. Trade Representative’s determination to make one technical amendment to a previously announced exclusion.
* DATES: As stated in the September 20, 2019 notice, product exclusions will apply from September 24, 2018 to August 7, 2020. The amendments announced in this notice are retroactive to the date the original exclusions were published and do not further extend the period for the original exclusions. U.S. Customs and Border Protection will issue instructions on entry guidance and implementation.
* FOR FURTHER INFORMATION CONTACT: For general questions about this notice, contact Associate General Counsel Philip Butler or Megan Grimball, or Director of Industrial Goods Justin Hoffmann at (202) 395-5725. For specific questions on customs classification or implementation of the product exclusions identified in the Annex to this notice, contact traderemedy@cbp.dhs.gov.

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(Source: Federal Register)

* Commerce/BIS; Rules; Identification of Prohibited Transactions to Implement Executive Order 13942 and Address the Threat Posed by TikTok and the National Emergency with Respect to the Information and Communications Technology and Services Supply Chain:
Preliminary Injunction Order by a Federal District Court; [Pub. Date: 17 Nov 2020] (PDF)
* Treasury/OFAC; NoticesBlocking or Unblocking of Persons and Properties; [Pub. Date: 16 Nov 2020] (PDF)
* State/DDTC; Notices; Meetings:Foreign Affairs Policy Board; [Pub. Date: 16 Nov 2020] (PDF)

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OGS_a24. Commerce/BIS: (No new postings)

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The European Commission’s regulation increasing tariffs on U.S. exports into the EU worth $4 billion will be published in the Official Journal of the EU.
The countermeasures have been agreed by EU Member States since the U.S. has not yet provided the basis for a negotiated settlement, which would include an immediate removal of U.S. tariffs on EU exports in the Airbus WTO case. The World Trade Organization (WTO) formally authorised the EU on 26 October to take such countermeasures against illegal U.S. subsidies to aircraft maker Boeing. The measures will take effect as from tomorrow. The European Commission stands ready to work with the U.S. to settle this dispute and also to agree on long-term disciplines on aircraft subsidies.

Executive Vice-President for an Economy that Works for People and Commissioner for Trade Valdis Dombrovskis said: “We have made clear all along that we want to settle this long-running issue. Regrettably, due to lack of progress with the U.S., we had no other choice but to impose these countermeasures. The EU is consequently exercising its legal rights under the WTO’s recent decision. We call on the U.S. to agree to both sides dropping existing countermeasures with immediate effect, so we can quickly put this behind us. Removing these tariffs is a win-win for both sides, especially with the pandemic wreaking havoc on our economies. We now have an opportunity to reboot our transatlantic cooperation and work together towards our shared goals.

The countermeasures bring the EU equal footing with the U.S., with sizeable tariffs on each side based on two WTO decisions related to aircraft subsidies. They include additional tariffs of 15% on aircraft as well as additional tariffs of 25% on a range of agricultural and industrial products imported from the U.S., thereby strictly mirroring the countermeasures imposed by the United States in the context of the WTO case on subsidies to Airbus.
In March 2019, the Appellate Body, the highest WTO instance, confirmed that the U.S. had not taken appropriate action to comply with WTO rules on subsidies, despite the previous rulings. Instead, it continued its illegal support of its aircraft manufacturer Boeing to the detriment of Airbus, the European aerospace industry and its many workers. In its ruling, the Appellate Body:
  • confirmed the Washington State tax programme continues to be a central part of the U.S. unlawful subsidisation of Boeing;
  • found that a number of ongoing instruments, including certain NASA and U.S. Department of Defence procurement contracts constitute subsidies that may cause economic harm to Airbus, and;
  • confirmed that Boeing continues to benefit from an illegal U.S. tax concession that supports exports (the Foreign Sales Corporation and Extraterritorial Income Exclusion).

Today’s decision confirming the EU right to retaliate stems directly from that previous decision. In a parallel case on Airbus, the WTO allowed the United States in October 2019 to take countermeasures against European exports worth up to $7.5 billion. This award was based on an Appellate Body decision of 2018 that had found that the EU and its Member States had not fully complied with the previous WTO rulings with regard to Repayable Launch Investment for the A350 and A380 programmes. The U.S. imposed these additional tariffs on 18 October 2019. The EU Member States concerned have taken in the meantime all necessary steps to ensure full compliance.

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Having regard to the Treaty on the Functioning of the European Union,
Having regard to Council Regulation (EU) No 267/2012 of 23 March 2012 concerning restrictive measures against Iran and repealing Regulation (EU) No 961/2010, and in particular Article 46(2) thereof,
Having regard to the proposal from the High Representative of the Union for Foreign Affairs and Security Policy,
On 23 March 2012 the Council adopted Regulation (EU) No 267/2012.
On 18 June 2020 the Council adopted Regulation (EU) 2020/847.
Following the judgment of the General Court in Case T-490/18, Neda Industrial Group should be removed from the list of persons and entities subject to restrictive measures set out in Annex IX to Regulation (EU) No 267/2012.
Annex IX to Regulation (EU) No 267/2012 should therefore be amended accordingly,
Article 1
Annex IX to Regulation (EU) No 267/2012 is amended in accordance with the Annex to this Regulation.
Article 2
This Regulation shall enter into force on the day following that of its publication in the Official Journal of the European Union.
This Regulation shall be binding in its entirety and directly applicable in all Member States.

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(Source: Official Journal of the European Union, 13 Nov 2020) [Excerpts]
Having regard to the Treaty on the Functioning of the European Union,
Having regard to Council Regulation (EU) 2017/2063 of 13 November 2017 concerning restrictive measures in view of the situation in Venezuela…
In this context, in accordance with Article 17(4) of Regulation (EU) 2017/2063, the Council has reviewed the list set out in Annex IV to Regulation (EU) 2017/2063 and has concluded that the restrictive measures against all persons in the list set out therein should be maintained.
The Council has also concluded that the statement of reasons for fourteen persons should be updated and the family name of all listed persons should be capitalised.
Annex IV to Regulation (EU) 2017/2063 should therefore be amended accordingly,
Article 1
Annex IV to Regulation (EU) 2017/2063 is amended in accordance with the Annex to this Regulation.
Article 2
This Regulation shall enter into force on the date of its publication in the Official Journal of the European Union.
This Regulation shall be binding in its entirety and directly applicable in all Member States.
Done at Brussels, 12 November 2020.

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NWS_a19. Defense News: “Britain Moves to Protect its Defense Industry from Foreign Influence”

(Source: Defense News, 13 Nov 2020) [Excerpts]
Defense and space industries are among nearly twenty sectors named by the British government in the introduction of new legislation Nov. 11 aimed at tightening regulations allowing it to block potentially hostile direct foreign investment.
The government said the National Security and Investment Bill will strengthen its ability to investigate and intervene in mergers, acquisitions and other types of deals potentially posing a threat to British national security.
Artificial intelligence, robotics, military or dual-use technologies, satellite and space technologies, defense and critical suppliers to the government were among 17 industry sectors included in the new legislation.
The new powers allow the government to act against investors from any country, including the United States. …

(Source: Export Compliance Daily, 12 Nov 2020) [Excerpts]
The European Council and the European Parliament agreed to new export control regulations for dual-use goods and sensitive technologies, paving the way for the European Union to soon implement a host of updated export control policies, licensing procedures and enforcement methods. The regulations, which have been discussed for years (see 1911290006 and 1906050039), will lead to more “accountable, competitive and transparent” trade in dual-use items, the council said Nov. 9.


* Author: Sunny Mann, Esq, 44-20-7919-1397, Baker McKenzie
The EU announced last week that the UK would be added to its list of safe countries to export ‘dual-use items’.  Following the UK’s exit from the EU, the UK is no longer a Member State of the EU since 31 January 2020 and the EU law will cease to apply to the UK after the end of a transition period on 31 December 2020. As a result, the export of ‘dual-use items’ from the EU to the UK will require, as of 1 January 2021, an export authorisation. 

This authorisation would need to be issued by the competent national authority of the Member State where the exporter is established and would create a significant administrative burden for the authorities of the Member States and EU exporters, impacting on their competitiveness.
In order to reduce the impact of the UK’s withdrawal from the EU, the UK will be added to Annex IIa of Council Regulation (EC) No 428/2009 (the “Regulation”). Exports to the UK will therefore be eligible under the Union General Export Authorisation EU001. 

In justifying the UK’s addition to the list, the EU gave the following reasons:
  • the UK is party to the relevant international treaties and a member of international non-proliferation regimes and maintains full compliance under these; and
  • the UK applies proportionate and adequate controls effectively addressing considerations about intended end use and the risk of diversion consistent with the provisions and objectives of this Regulation.

The full  proposal for amending the Regulation is available here.  The UK joins the other existing 8 so-called safe countries, namely Australia, Canada, Japan, New Zealand, Norway, Switzerland (including Lichtenstein) and the US.

COM_a212. RA Krause: “Export Control is a Matter for the Management in Germany”  

(Source: RA Krause, 20 Oct 2020)
* Author: A. Krause, Esq., 02131 – 277 119, Geerkens – Frommen – Krause
Every company that exports commodities (goods, software or technology) which are covered by the European or German Commerce Control List must in all cases have named a so-called “Export Officer” (EO) to the Federal Office of Economics and Export Control (BAFA) (hereafter only referred to as the Export Officer (EO)).
The BAFA processes applications for export licences only if the company submitting the application has previously nominated an Export Officer. Furthermore, if the BAFA comes to the conclusion that the Export Officer is unreliable with respect to ensuring that his or her company will comply with the European and German export control regulations, no applications will be processed by this company either (Section 8, paragraph 2 of the German Foreign Trade Act (AWG).
It is imperative that the Export Officer is a member of the Management Board whose business domain also actually covers export control according to the company’s internal allocation of business. Power of attorney alone is not sufficient for the EO to be recognised by the BAFA. The EO is responsible in particular for the organisational, personnel selection and further training obligations with regard to export control. This special responsibility cannot be delegated to others, even if other individuals are charged with its implementation in the day-to-day business of the company. The EO therefore has a key function in the field of export control, which he or she can only fulfil from the point of view of the authorities and courts if he or she continually maintains, monitors and improves a Compliance Management System (CMS) that satisfies the requirements of the associated business. The synonymous designation of the BAFA for such a CMS is Internal Compliance Program (ICP). The contents behind these two designations are fundamentally the same. 
Against the background of this key function of the EO and the requirement for a corresponding CMS/ICP for export control, the previous BAFA announcement “on the Principles of the Federal Government for evaluating the reliability of exporters of war weapons and arms-related goods” has been revised with effect from October 20, 2020 and published in the Federal Gazette on October 19, 2020. The new announcement contains legal information and organisational recommendations to companies which are formulated in a way which is correspondingly clearer and more explicit. At the same time, the forms for the nomination of the EO (Form AV1) and the delegation of his or her signature authority with respect to approval applications to other employees (Form AV2) were also adapted accordingly in line with the revised announcement. A new aspect is that these forms can now also be submitted electronically to the BAFA. There is a transitional period up to January 31, 2021 for the recognition of the declarations submitted before October 20, 2020 on the previous forms.
An EO who has been nominated with the old or new AV1 form is considered as such until his or her nomination is revoked and notified to the BAFA. The BAFA is to be informed without delay if the EO is changed or if he or she leaves the company in the meantime. According to the BAFA, the change of form does not mean that the AV1 has to be renewed for Export Officers who remain in office after the transitional period has expired. In contrast, any delegation of his or her express sole signature authority for export licence applications to other employees (e.g. a so-called Export Control Officer) must be renewed annually to the BAFA using the AV2 form, i.e. without fail with the new AV2 form after the transitional period and the expiry of the one-year validity of the declaration.
The large number of exporting companies which are located in Germany do not have any listed goods that require the formal nomination of an EO in order to apply for export licences. However, depending on the business areas in which they operate, these companies may also be affected by the German and European export control regulations. Certain critical forms of use, such as military purposes, therefore also result in export licensing obligations in critical countries for goods which are not listed (e.g. countries which are subject to arms embargoes). Due to possible violations with respect to non-listed goods or embargo regulations, the entire management is first and foremost the focus of the investigating authorities and courts in such cases. For this reason, such companies are also well advised as a matter of principle to clearly address and organise the question of responsibility within the management team with regard to export controls, even if no EO has to be nominated to the BAFA.
My recommendation regarding this new notification of the BAFA, its background and the accompanying change to the forms is that the employees who are responsible for export control should regularly report on these and similar changes on their own initiative to their respective Export Officers or the entire management team. The old notification that no longer applies can be understood as a kind of “warning” or “wagging finger” with regard to the dutiful fulfilment of the compliance requirements associated with export control. For this reason, this opportunity should be taken at the same time to subject the CMS/ICP system to at least a rough and random review by the EO, Export Control Officers or external experts in an appropriate form.
Insofar as such a review reveals shortcomings (e.g. a lack of employee training, a failure to check the product portfolio against annually modified lists of goods), errors (e.g. a failure to renew AV1 or AV2 in the past), or even infringements (false customs declarations or even unauthorised exports), these must be corrected, made up for or reported accordingly. These processes and decisions should be documented in order that they can be considered a visible element of a functioning CMS/ICP system for export control under the specific personal responsibility of the individual appointed from the management team or the Export Officer as a “matter for the management“.

COM_a313. Ted Murphy International Trade Updates: Trade Issues – Post-Election Thoughts”

* Author: Ted Murphy, Esq.,12027368016, Sidley Austin LLP
As we all catch our breath after an exhausting last week or so, I thought I would jot down some thoughts about U.S. trade issues and what we think folks should be watching for in the coming months.

First, it is important to remember that the Trump administration remains in office until January 20, 2021 (at least, depending on the legal challenges being mounted).  That means that U.S. trade actions initiated by this administration, such as the Section 301 investigation on Vietnam’s currency valuation will continue.  Comments in that investigation are due November 12th, and no hearing is being held, so the U.S. Trade Representative could take action on Vietnam as early as mid-December.  It also means that additional actions could be taken in the Section 301 investigation involving China.  While that is not likely (at least in my view), it is possible that President Trump could order the imposition of duties on List 4B articles (which had previously been suspended), or increase the duty rates applicable to articles on List 1-4A.  Again, while this is not likely, it is possible.  

Second, the prospects for certain trade actions in the ‘lame duck’ session of Congress, which began this week, are less clear now, given that the election results are being contested.  There was hope that issues such as the Miscellaneous Tariff Bill (MTB), renewal of the Generalized System of Preferences (GSP), technical corrections to USMCA and other routine trade issues would be taken up and addressed in the lame duck session.  Given that President Trump is contesting the results of the election, it is now less clear whether Congress will be able to reach agreement on these issues and, even if they can, whether the president will sign any new legislation.  If not, then there may be gaps in both MTB and GSP coverage as of January 1st (which means that importers may need to start paying duties, at least temporarily, as of January 1st). 

Third, assuming that President-Elect Biden is sworn in on January 20, 2021, the additional tariffs imposed under Section 232 and Section 301 are likely to remain in place for some time.  While such duties are not likely to go away immediately (the bad news), they are also not likely to be increased or otherwise expanded (the good news).  Trade tension with China will continue on a variety of issues (e.g., unfair trade issues, human rights/forced labor, technology issues, etc.) and the new administration will likely look to tools other than duties (at least in the first instance) to address them.  That said, other trade issues such as reform of the WTO, trade disputes with the EU, etc. may get addressed. 

Finally, we expect to see increased enforcement on a variety of international trade fronts in 2021.  In particular, we expect that U.S. Customs and Border Protection’s focus will shift from administering the Section 301 duties (i.e., dealing with the imposition of new lists, product exclusions, refunds requests, etc.) to Section 301 enforcement issues.  We expect that questions will focus on changes to tariff classification and country of origin determinations (e.g., what documentation do you have to substantiate your claim that what you are importing is not Chinese-origin?).  We also expect to see even more forced labor enforcement actions.  Forced labor enforcement is an important issue for both Republicans and Democrats in Congress, generally, and it overlaps with other trade concerns related to China.  As a result, additional China-related forced labor actions should be expected.  Finally, we expect to see increased enforcement under USMCA – both from a trade compliance standpoint (i.e., whether a given article originates under the USMCA rules of origin), as well as from a forced labor standpoint.  While CBP has adopted an ‘informed compliance’ period since USMCA went into effect on July 1, 2020, that period is scheduled to expire for all but the auto industry December 31, 2020 (the auto industry reportedly has until July 1, 2021). 

In summary, no one knows exactly how the future will unfold.  It is a safe bet, however, that it will continue to present trade challenges for most companies.  We are not going back to the days of ever increasing globalization any time soon, so companies need to recognize that international trade will involve more nuanced calculations than ever before (e.g., what is the trade risk associated with sourcing from country Z?  how can we mitigate that risk?).  It should be an interesting ride (for all of us)


TE_a114. ECS Presents: 16-17 Nov; “ITAR/EAR Controls for U.S. & Foreign Companies”
(Source: ECS)

*What:  ITAR/EAR Controls for U.S. & ForeignCompanies
*When:  16-17 Nov
*Where:  Your Computer
*Sponsor: Export Compliance Solutions & Consulting (ECS)
*ECS Speakers:  Suzanne Palmer, Marc Binder
*Register: Here or write to phyllis@exportcompliancesolutions.com or call 1-866-238-4018
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U.S. Export Controls: ITAR & EAR from a non-U.S. Perspective (Tuesday, 1 Dec 2020)
Presenters: Jim Bartlett & Marco Crombach
Register or find more information here

The ABC of Foreign Military Sales (FMS) (Thursday, 3 Dec 2020)
Presenters: Mike Farrell & Jim Bartlett
Register or find more information here
* Register for both and take advantage of our discounted price!
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(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;



* 16 Nov: “Developing Technology Control Plans to Meet Export and ITAR Regulatory Requirements“; Strategic Aerospace & Defense Advisors
* 17 Nov: “A Deep Dive into Classification and Origin Challenges“; Global Trade Academy
* 19 Nov: “CMMC – Beyond The Basics“; ComplyZoom
* 1 Dec: “U.S. Export Controls: The ITAR and EAR from a non-U.S. Perspective“; Full Circle Compliance (FCC) Academy; Lecturers: Jim Bartlett and Marco Crombach
* 3 Dec: “The ABC of Foreign Military Sales (FMS)“; Full Circle Compliance (FCC) Academy.  Lecturers: Mike Farrell and Jim Bartlett
* 12 Jan 2021: “Importing Procedures“; Global Training Center
* 13 Jan 2021: “Importing 201“; Global Training Center
* 14 Jan 2021: “Duty Drawback“; Global Training Center
* 22 Jan 2021: “Country of Origin“; Global Training Center
* 4 Feb 2021: “Road to CTPAT“; Global Training Center
* 8 Feb 2021: “Importing Procedures“; Global Training Center
* 9 Feb 2021: “Importing 201“; Global Training Center
* 8 Mar 2021: “Importing Procedures“; Global Training Center
* 9 Mar 2021: “Importing 201“; Global Training Center
* 15 Mar 2021: “Duty Drawback“; Global Training Center
* 25 Mar 2021: “Country of Origin“; Global Training Center
* 8 Apr 2021: “Road to CTPAT“; Global Training Center
* 13 May 2021: “Duty Drawback“; Global Training Center
* 27 May 2021: “Country of Origin“; Global Training Center

* 10 Jun 2021: “Road to CTPAT“; Global Training Center

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EN_a117. Bartlett’s Unfamiliar Quotations

(Source: Editor)

* Robert Louis Stevenson (born Robert Lewis Balfour Stevenson; 13 Nov 1850 – 3 Dec 1894; was a Scottish novelist, poet and travel writer, most noted for Treasure Island, Kidnapped, Strange Case of Dr Jekyll and Mr Hyde, and A Child’s Garden of Verses.)
– “Everyone lives by selling something.”
– “The cruelest lies are often told in silence.”

* Charles Lyell (Sir Charles Lyell; 14 Nov 1797 – 22 Feb 1875; was a Scottish geologist who demonstrated the power of known natural causes in explaining Earth’s history. He is best known as the author of Principles of Geology (1830-33), which presented to a wide public audience the idea that Earth was shaped by the same natural processes still in operation today, operating at similar intensities.)
  – “Never call an accountant a credit to his profession; a good accountant is a debit to his profession.” 

Friday funnies:
* A child asked her mother, “Where did people come from?” So her mother said, “God made Adam and Eve, and they made babies, then their babies grew up and made more babies, and so on until the world was full of people.” The child then went to her father and asked him the same question. He told her, “We were monkeys, then over millions of years, we evolved to become humans.” The child ran back to her mother and said, “Daddy told me we evolved from monkeys!” Her mother replied, “Your father was talking about his side of the family.”
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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)

24 Apr 2018: 83 FR 17749: Foreign Trade Regulations (FTR): Kimberley Process Certificates.  The latest edition of the BAFTR is 
9 Nov 2020.

: 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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