International Trade

DDTC Provides Updated COVID-19 Measures

Yesterday the Directorate of Defense Trade Controls published an update to its operations as follows:

Compliance/Registration

  • Effective March 13, 2020, a temporary suspension of the requirement in ITAR Parts 122 and 129 to renew registration as a manufacturer, exporter, and/or broker and pay a fee on an annual basis by extending ITAR registrations expiring on February 29, March 31, April 30, May 31, and June 30, 2020 for two months from the original date of expiration.
  • DDTC Compliance is now granting an additional 30 days for responses to its request-for-information letters related to voluntary and directed disclosure matters.  DDTC Compliance is also considering extensions for the submission of full voluntary disclosures on a case-by-case basis.  Extension requests should be sent via email to DTCC-CaseStatus@state.gov on company letterhead in PDF format.
  • DDTC is also pursuing a one-time temporary reduction in registration fees for certain categories of DDTC registrants.  More information on any change will be provided on DDTC’s website.
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This trade bulletin summarizes important developments affecting international trade.

USMCA Interim Implementing Instructions
COVID-19 or not the United States Mexico Canada agreement’s (USMCA) implementation date is fast approaching. The U.S. Customs and Border Protection has issued Interim Implementing Instructions to provide early guidance on the new requirements under the USMCA, including on claiming USMCA preferential treatment for goods. The Final Implementing Instructions will be released prior to the date the USMCA enters into force.

For the Interim Implementing Instructions click here. Don’t hesitate to contact us with questions.

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Importers Facing “Significant Financial Hardship” May Defer Duty Payments for 90 Days

On April 18, 2020, President Trump issued an Executive Order providing authority to the Secretary of the Treasury, under 19 U.S.C. § 1318, to extend the deadline for payments of certain estimated duties, taxes, and fees for importers suffering significant financial hardship during the national emergency created by the COVID-19 novel coronavirus pandemic. Pursuant to the Executive Order, the Department of the Treasury and U.S. Customs and Border Protection (“CBP”) jointly issued a Temporary Postponement of the Time to Deposit Certain Estimated Duties, Taxes, and Fees During the National Emergency Concerning the Novel Coronavirus Disease (COVID19) Outbreak (the “Temporary Final Rule”), which temporarily postpones for 90 days the deadline for importers with a significant financial hardship to deposit certain estimated duties, taxes, and fees that they would ordinarily be obligated to pay as of the date of entry, or withdrawal from warehouse, for consumption.

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Extension of Realisation Period of Export Proceeds

To ease the impact of disruption caused by the Coronavirus/COVID-19 pandemic, the Reserve Bank of India (“RBI”) has provided extension of the period for realisation of the export proceeds as prescribed under the Foreign Exchange Management (Export of Goods & Services) Regulations, 2015 (“FEM Export Regulations”) read with the RBI Master Direction on Export of Goods and Services (“RBI Master Directions on Exports”).

Regulatory Framework:

The export of goods and services in India and the payments to be received for such export of goods and services are regulated by the FEM Regulations, framed under the Foreign Exchange Management Act, 1999, read with the RBI Master Directions on Exports. We discuss hereinbelow certain key provisions of the FEM Export Regulations and the RBI Master Directions on Exports:

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Corporate Governance Reliefs announced in view of COVID-19

The Union Finance & Corporate Affairs Minister, Government of India, Ms. Niramla Sitharaman, in her interactions with the press yesterday, i.e., on March 24, 2020, has announced multiple relaxations to statutory and regulatory compliances under various legislations viz., the Companies Act, 2013 (“CA2013”), Limited Liability Partnership Act, 2008 (“LLP Act”), Insolvency and Bankruptcy Code, 2016 (“IBC”), Income Tax Act, 1961, the Goods and Services Tax legislations, Customs Act, 1962 etc. The complete press release vis-à-vis all measures announced can be accessed at http://pib.nic.in/newsite/PrintRelease.aspx?relid=200639.

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Highlights of Finance Minister’s Press Conference: Reliefs during COVID-19 outbreak

In the midst of the shutdown of businesses all over India to contain the spread of the highly contagious Covid-19 infection, Finance Minister Smt. Nirmala Sitharaman today addressed a press conference on various statutory and regulatory compliance issues and announced a slew of measures for providing relief amid the pandemic outbreak.

The brief highlights of the announcements made by the Finance Minister:

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DDTC and Census COVID-19 Status of Operations

Today the Directorate of Defense Trade Controls published an update to its operations as follows:

  1. Licensing, Commodity Jurisdictions, and General Correspondence: Though longer processing times are expected, DDTC continues to process these submissions and new licenses will be accepted.
  2. Enrollment and Registration: Still operating and being processed via DECCS.
  3. Voluntary Disclosures: Disclosures and related information may be submitted via email to DTCC-CaseStatus@state.gov. Materials should be sent on company letterhead and in PDF format. It is not necessary to send a duplicate hardcopy to DTCC through the mail.

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