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The Emotional Intelligence Academy was established with the aim to create the most compelling education institution for social science based learning in the world. On November 5, 2019 the Office of Foreign Assets Control OFAC issued two General Licenses GLs authorizing specific transactions involving the Government of Venezuela and categories of persons blocked by Executive Order 13884 E.
O 13884 was intended to increase pressure on the Nicolas Maduro regime by blocking property and property interests of the Government of Venezuela under U.
Treasury Department to sanction additional persons who have assisted 4 supported the Government of Venezuela.
PdVSAany person owned or controlled, directly or indirectly, by the foregoing, and any person who has acted or purported to act directly or indirectly for or on behalf of, any of the foregoing, including as a member of the Maduro regime.
Without authorization from OFAC, U.
The two new GLs make it easier for U.
In particular, General License 35 authorizes U.
Businesses seeking to continue operations in Venezuela should be aware that GL 35 does not authorize transactions that are otherwise prohibited by E.
The reports must include the names and addresses of the entities remitting and receiving payment, the amount of funds paid to the Government of Venezuela, the type and scope of ссылка на подробности activities conducted, and the date of the payments.
OFAC also issued amended General License 34A, which authorizes transactions with certain Government of Venezuela individuals, including U.
In connection with the two new GLs, OFAC also published FAQs related to the GLs.
In the FAQs, OFAC encourages businesses, especially financial institutions, to conduct due diligence on their customers to ensure that the parties with whom they do business are not blocked.
OFAC also warns U.
Finally, as with any General License or specific license, OFAC reserves the right to revoke the authorizations in order to support U.
Now that Canadian PM Justin Trudeau has dissolved Parliament and called for a general election to be held October 21chances of seeing the USMCA ratified by all three member states this year 4 become an increasingly remote possibility.
In fact Andrew Scheer, leader of the Conservative party, has announced that he would support ratification of USMCA if elected Prime Minister, despite the fact that he believes Trudeau was railroaded in negotiations with the U.
Ratification by the U.
Nevertheless, pressure continues to put USMCA to vote in the U.
Last year, President Trump signed into law the Foreign Investment Risk Review Modernization Act of 2018 FIRRMAwhich outlined the expansion of CFIUS jurisdiction to review certain foreign acquisitions and investments in U.
FIRRMA left the specifics to regulations to be passed by the U.
Department of Treasury Treasury.
On September 17, 2019, Treasury issued proposed regulations Wi-Fi Senao EAP-3660 Proposed Rules to implement FIRRMA.
The Proposed Rules are subject to public comment before they become final.
Business where a foreign government holds a substantial interest in the foreign person, and ii critical technology investments under the Pilot Program.
CFIUS 4 review such нажмите чтобы прочитать больше within 30 days of receipt.
The final regulations will go into effect no later than February 13, 2020.
We recommend that all parties who will be affected by FIRRMA review the Proposed Rules and submit comments where appropriate.
For a detailed analysis of the Proposed Rules, click on the link below.
The announcement, which came by way of tweet, provided that Section 301 tariffs on all List 1 through 3 goods would be elevated from 25% to 30% effective October 1.
In addition, the administration announced that tariffs on List 4 goods-the first tranche of which goes into effect at 12:01 am EST on September 1, would be elevated from 10% to 15%.
Though not expressly stated, we expect this increase to be applied against both List 4A and List 4B with List 4B currently being set to go into effect Жмите сюда 15.
With the 2020 presidential election cycle already underway, it is unlikely HTC Vive «Новая реальность» we 4 see much in the way of Chinese effort to reach a resolution with the Trump Administration.
Though the trade war is hitting American 4 and consumers hard, it is also having a significant negative impact on China, who is struggling with a dwindling labor force and slowing of the domestic economy.
Notwithstanding, China may be better positioned to continue the fight and it is highly unlikely that President Xi will back down on key issues, including the Made in China 2025 strategic plan.
Ultimately, we are not seeing indications that this dispute is nearing any resolution in the foreseeable future absent a major policy shift from the US.
Though the USMCA has been ratified by Mexico, the trade agreement still faces a vote in Canada and, perhaps more concerning, the US.
Submission of the implementing legislation operates to start the 90-day clock for Congressional approval.
Accordingly and assuming the implementing bill is submitted as anticipated, passage of the USMCA by the US this 4 year remains an 4 goal.
There are, however, a number of complicating factors.
Although USTR Lighthizer has been working closely with House Democrats for months, a number of Democrats have been quite vocal in opposition to certain provisions of the USMCA—particularly those relating по этому сообщению labor, environmental concerns, prescription drug pricing and the exclusivity period for biologics, and dispute resolution and enforcement.
Whether Congress will press for resolution of these issues in the USMCA text or settle for side agreements with Canada and Mexico on these issues remains to be seen.
Buddy Carter R-Ga has suggested solutions to these disputed issues may not necessarily need to be contained in the agreement itself; although whether this reflects the opinion of a majority of Congress is uncertain and likely doubtful.
Accordingly, Congressional pressure for a renegotiation may spell the end of the USMCA—at least for now.
Notwithstanding the uncertainty in Congress, there has been an outpouring of support for the USMCA by numerous businesses and trade organizations.
Though House Democrats have been vocal in opposition to certain provisions of the agreement, there does appear to be some consensus that NAFTA has become outdated and in need of replacement or revision.
As is typical, however, the devil is proving to be in the details.
In the event the USMCA 4 obtain Congressional approval this year, it may very well find itself a casualty of the upcoming US 4 election.
Pushing a vote into 2020 could further delay ratification of the agreement or, depending on the outcome of the election, kill it entirely.
Conversely, if President Trump is reelected, the USMCA will still need to find its way through the Congressional approval process of the TPA.
In an August 14, 2019U.
CBP reports that each year, approximately 350,000 importers actively engage with CBP through almost 2,100 licensed customs brokers.
Ensuring that each of these importers is a legitimate entity and not, for instance, a shell corporation used to evade customs enforcement or support enemies of the U.
In addition, the information would need to be updated and re-verified on a periodic basis.
Certain of 4 requirements and, in particular the recommendation for in-person verification, may prove impractical given the fast pace of international trade.
Public comments on the proposed rule changes are open until October 15, 2019.
Check back for an updates on any changes to the proposed rules, their effective date, and information on https://booksarchive.ru/100/kontakti-a9n26927-kontakt-avar-isd-dlya-idpn-n-dpn-n-vigi-schneider-electric.html that your clients, brokers, and supply chain are in compliance.
Several products 25 tariff lines in total were removed from the lists following the public comment and hearing process on the basis of health, safety, national security and other factors.
Most significantly, however, is the delayed implementation of tariffs against List 4B articles until December 15.
The List 4B 4 include cell phones, laptop computers, video game consoles, toys, computer monitors, sporting equipment, and certain articles of apparel and footwear.
The list itself, coupled with the December 15 effective date, suggests the move was heavily influenced by a desire not to further burden American consumers and businesses during the busy shopping season leading up to the holidays.
The tariff lines contained in List 4A approximately 3,230 will still face the 10% additional tariff effective September 1.
List 4A goods entered into the US or withdrawn from warehouse for consumption on or after September 1 will be subjected to the additional 10% tariff.
The remaining tariff lines of List 4B approximately 540 will not be subjected to the 10% tariff until December 15.
These actions illustrated a firm commitment by CFIUS to police investments involving certain countries and fields of business.
CFIUS prioritizes critical infrastructure as well, which includes fields such as transportation, healthcare, and financial services.
In its recent decisions, CFIUS has continued to follow the observed trend of criticism towards Chinese investment.
On October 10, 2018, CFIUS cleared the partial acquisition of the US-based data security firm Micro Focus International by Ultimaco, a German cybersecurity firm.
Micro Focus divested its Atalla Hardware Security Module HSM and Enterprise Secure Key Manager ESKM product lines to the German firm, which has also been active in the HSM market for 20 years.
The approval showed that, although foreign investment related to sensitive data will be scrutinized, it will not always be disallowed.
On July 6, 2019, CFIUS issued another clearance that further supports this notion.
According to two people close to the deal, CFIUS approval did not always appear certain, as the interagency committee scrutinized the investment closely.
According to this source, the committee feared that Didi could appropriate vital technology from Cruise through SoftBank.
Taken together with the Ultimaco and SoftBank approvals, the Huatai clearance narrows the apparent disapproval of CFIUS down to any Chinese investment in business sectors specifically involved with sensitive data.
Without the imposition of such conditions, investments may suffer the same fate as those in Grindr and PatientsLikeMe.
It has been almost a year since the first round of Section 301 China tariffs went into effect on July 6, 2018.
Since that time, the Office of the United States Trade Representative USTR has reviewed thousands of product exclusion requests on Lists 1 and 2.
Granted product exclusions are retroactive to the date of the imposition of additional duties under Section 301, and extend for one year after the publication of the exclusion notice in the Federal Register.
This post summarizes guidance issued by the U.
Customs and Border Protection to obtain and preserve rights to refunds on excluded products.
Customs Guidance for Entry of Excluded Products and to Request Refunds To date, there have been five rounds of granted exclusion requests.
For each round of granted exclusions, Customs has issued guidance on how to submit entries of excluded products and the procedures to obtain refunds.
The Customs guidance is linked in the chart below.
Granted Exclusions Federal Register Notice Customs Guidance Round 1 Round 2 Round 3 Round 4 Round 5 Product exclusions granted Norris, Roy, Thomson, Hilary New Ready for FCE TB USTR so far are retroactive to July 6, 2018, for unliquidated entries or entries that are liquidated but not final.
Liquidation is the final assessment of duties owed on an entry, and generally occurs within 314 days of an entry.
However, liquidation may occur faster than the 314-day cycle.
In any event, liquidation must occur within one year of the date of entry unless otherwise extended.
Importers must diligently monitor the liquidation status of entries of excluded products and exclusion requests pending review to protect their rights to refunds.
Once a product exclusion is granted by the USTR, an Importer of Record may request an administrative refund by filing a Post Summary Correction PSC for unliquidated entries that are covered by the exclusion.
If an entry is liquidated prior to the filing of a PSC, a party may file a formal CBP Form 19 protest of the liquidation to obtain a refund.
Form 19 protests must be filed within 180 days of liquidation.
Entries Covered by Pending Product Exclusion Requests Given that liquidation deadlines are fast-approaching for many entries covered by Section 301 if they have not already occurredCustoms recently issued to U.
This guidance applies to importers of products pending exclusion review on Lists 1 and 2.
When filing a protest, the protestant should identify the pending product exclusion decision from USTR as a basis for the protest.
If a protest is filed, CBP will postpone making a determination on protests that include a claim identifying Кассетный кондиционер Daikin FCQG35F / RXS35L pending product exclusion.
For more information about the Section 301 exclusion process, the procedure to obtain refunds, or the submission of extension requests of liquidation, please contact Fox Rothschild attorneysor.
Note: The exclusion process for List 3 products will commence on June 30, 2019.
On November 30, 2018, the United States, Canada and Mexico took the first steps toward a renegotiated North American Free Trade Agreement NAFTA 4 dubbed the United States-Mexico-Canada Agreement USMCA.
However, the USMCA still faces the hurdles of ratification by ссылка respective governments.
In the United States, that means Congressional approval in accordance with the Trade Promotion Authority TPA.
Pursuant to the TPA timeline, the final text of the USMCA was published and a Statement of Administrative Action was submitted by US Trade Representative Robert Lighthizer on May 30, thereby permitting the Administration to formally submit the deal to Congress as soon as July 1.
Whether or not the deal will be submitted this soon remains to be seen, particularly in light of pushback from Democratic leaders.
Once the implementing bill is introduced, the House must vote on the bill within sixty 60 days.
If successful before the House, the bill then moves to the Senate where источник must be voted on within thirty 30 days.
Nevertheless, House approval of the USMCA in its current form remains a lofty hurdle for the Administration.