The U.S. Trade Representative (USTR) has issued another Federal Register notice exempting Section 301 tariffs for certain List 4A (imports from China with an annual trade value of $300 billion) products. The exemptions cover five entire 10-digit Harmonized Tariff System (HTS) subheadings and seven specially-prepared product descriptions – covering a total of 36 separate exclusion requests.

The five excluded HTS subheadings include non-medical items:

  • 0505.10.0050 – Skins and other parts of birds, with their feathers or down, feathers and parts of feathers (whether or not with trimmed edges) and down, not further worked than cleaned, disinfected or treated for preservation; powder and waste of feathers or parts of feathers: Feathers of a kind used for stuffing; down: Feathers.
  • 3926.90.9925 – Other articles of plastics and articles of other materials of headings 3901 to 3914: Other: Other: Reflective triangular warning signs for road use.
  • 6506.10.3045 – Other headgear, whether or not lined or trimmed: Safety headgear: Of reinforced or laminated plastic: Other: Athletic; recreational and sporting headgear.
  • 8512.10.2000 – Electrical lighting or signaling equipment (excluding articles of heading 8539), windshield wipers, defrosters and demisters, of a kind used for cycles or motor vehicles; parts thereof: Lighting or visual signaling equipment of a kind used on bicycles: Lighting equipment.
  • 8528.72.6420 – Monitors and projectors, not incorporating television reception apparatus; reception apparatus for television, whether or not incorporating radio-broadcast receivers or sound or video recording or reproducing apparatus: Other, color: Incomplete or unfinished (including assemblies for television receivers consisting of all the parts specified in additional U.S. note 9 to this chapter plus a power supply), presented without a display device: Other: With a video display diagonal: Not exceeding 75 cm.

The seven specially-prepared product description exemptions all cover medical supplies: certain plastic coverings designed to fit over wounds and forming a protective seal; plastic pouches used with manually operated pill or tablet crushers; plastic refillable dispensers to store and contain bags in a medical setting; sterile urology drain bags; ice bags for treating injuries or soreness; certain identification wristband; and certain apparatus suitable for wearing on wrists having time-display functions and capable of transmitting data.

These exclusions will apply from September 1, 2019, through September 1, 2020. These exclusions apply to any product that satisfies the description in the annex of the Federal Register notice, regardless of whether the company using the exclusion filed the request. Each exclusion is governed by the scope of the HTS heading and the product description appearing in the annex of the exclusion notice; it is not governed by the product description set out in any particular exclusion request. U.S. Customs and Border Protection will soon issue instructions on entry guidance and implementation. The USTR will continue to issue determinations on pending requests on a periodic basis.

As countries around the globe respond to the COVID-19 pandemic, business operations must adapt to changing rules and new restrictions. Many countries have limited business activity and travel, and many have taken actions that impact employee wages and benefits. In addition, several nations have issued economic stimulus measures that may provide companies with opportunities for loans or other support.

Many countries, according to a recent report, have enacted export restrictions on medical supplies and other items needed to treat patients with COVID-19. These restrictions may change quickly. According to a G20 press release, members will “work to ensure the flow of vital medical supplies, critical agricultural products, and other goods and services, and work to resolve disruptions to the global supply chain.”

We have prepared a chart that provides a compilation of reports of economic, employment, safety and export-related emergency measures implemented by countries in response to this crisis. It is not intended as legal advice but as a practical resource for companies adapting to the global pandemic.

The Department of the Treasury’s Office of Foreign Assets Control (OFAC) has designated 20 Iran- and Iraq-based front companies, senior officials, and business associates for providing support to, or acting on behalf of, the Islamic Revolutionary Guards Corps-Qods Force (IRGC-QF) and for transferring lethal aid to Iranian-backed terrorist militias in Iraq such as Kata’ib Hizballah (KH) and Asa’ib Ahl al-Haq (AAH). According to Treasury Secretary Steven Mnuchin, “Iran employs a web of front companies to fund terrorist groups across the region, siphoning resources away from the Iranian people and prioritizing terrorist proxies over the basic needs of its people.” OFAC has sanctioned these entities and persons for a multitude of “malign activities”, including: smuggling; money laundering; selling Iranian oil to the Syrian regime; promoting propaganda efforts in Iraq on behalf of the IRGC-QF; intimidating Iraqi politicians; and illicit use of funds and public donations.

Accordingly, 15 individuals and 5 companies have been placed on OFAC’s Specially Designated Nationals (SDN) List. The five companies are:

  • Reconstruction Organization of the Holy Shrines in Iraq (ROHSI) – an IRGC-QF-controlled organization based in Iran and Iraq. OFAC states that ROHSI, although ostensibly a religious institution, has transferred millions of dollars to the Iraq-based Bahjat al Kawthar Company for Construction and Trading Ltd.
  • Bahjat al Kawthar Company for Construction and Trading Ltd. – also known as Kosar Company, and another Iraq-based entity under the IRGC-QF’s control. OFAC states that the Kosar Company has served as a base for Iranian intelligence activities in Iraq, including the shipment of weapons and ammunition to Iranian-backed terrorist militia groups. Additionally, Kosar Company has received millions of dollars in transfers from the Central Bank of Iran.
  • Al Khamael Maritime Services (AKMS) – an Iraq-based company operating out of Umm Qasr port in which the IRGC-QF has a financial interest. OFAC states, inter alia, that AKMS was involved in the sale of Iranian-origin petroleum products in contravention of U.S. sanctions against the Iranian regime.
  • Mada’in Novin Traders (MNT) – an Iran- and Iraq-based company associated with multiple IRGC-QF officials, including Vali Gholizadeh. OFAC states that Gholizadeh has worked with Saburinezhad for the benefit of both AKMS and MNT.
  • Middle East Saman Chemical Company – an Iran-based company. OFAC states that it maintained an account at Rashed Exchange, an Iran-based exchange house used to convert currency for the IRGC-QF.

As a result of this action, all property and interests in property of these persons that are in the United States or in the possession or control of U.S. persons must be blocked and reported to OFAC. Because U.S. persons are generally prohibited from dealing with entities on the SDN List, persons who engage in certain transactions with these designated persons may themselves be exposed to designation. OFAC has indicated that any foreign financial institution that knowingly facilitates a significant financial transaction or provides significant financial services for these persons could be subject to U.S. correspondent account sanctions or payable-through account sanctions.

On March 25, 2020, the Department of Commerce’s Bureau of Industry and Security (BIS) extended the deadline to April 22, 2020, for public comment on possibly granting future Huawei Temporary General License (TGL) extensions. As noted in its March 12, 2020 Federal Register notice, BIS is seeking input on the continuing need for, and scope of, possible future extensions of the TGL for Huawei Technologies Co. Ltd. and its non-U.S. affiliates on the Entity List. BIS stated that it has received requests from industry to allow for additional time for comments as the original deadline to file comments was March 25, 2020.

The comment period has now been reopened until April 22, and interested parties may file comments in Docket number BIS 2020-0001 or RIN 0694-ZA02 via the Federal eRulemaking portal at www.regulations.gov.

On March 25, 2020, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued amended General License 1A “Official Business of the United States Government” and General License 2A “Authorizing the Wind Down of Transactions Involving the Nicaraguan National Police” to clarify they were also issued under the Nicaraguan Human Rights and Anticorruption Act of 2018, 50 U.S.C. § 1701 (NHRA). Among other things, the NHRA directs the president to impose sanctions on persons engaging in significant acts of violence, human rights violations, significant corruption and acts that undermine democratic processes or institutions in Nicaragua. OFAC has added the Nicaraguan National Police (NNP) and several other entities and individuals to the SDN List pursuant to this authority.

No substantive changes were made to the previous versions of General License 1 and General License 2, but they were superseded and replaced by General Licenses 1A and 2A, respectively. General License 1A authorizes transactions otherwise prohibited by the Nicaraguan Sanctions Regulations, 31 C.F.R. §§ 582.101-.901 (NSR) that constitute official business of the U.S. government. General License 2A authorizes transactions otherwise prohibited by the NSR that are ordinarily incident and necessary to the wind down of transactions involving the Nicaraguan National Police (NNP) or any entity the NNP owns, directly or indirectly, a 50% or greater interest, including the processing of salary payments from the NNP to its employees, through 12:01 a.m. ET, May 6, 2020.

Key Notes:

  • Major operational changes have occurred at trade-related U.S. government agencies and courts due to personnel and public safety concerns over the COVID‑19 outbreak in the United States.
  • The Office of Personnel Management has announced that as of March 17, 2020, and until further notice, federal offices nationwide are open but “maximum telework flexibilities” are in place for all eligible employees “pursuant to direction from agency heads.”
  • Trade-related U.S. government and court websites provide status updates.
  • Helpful website links from the U.S. government, foreign governments and international organizations are regularly updated to keep international trade professionals informed on changes to the business environment caused by the pandemic.

As the novel coronavirus pandemic alters our daily lives, how we interact with each other and how we conduct business, obtaining current and reliable information has become critical, both professionally and personally. This bulletin provides international trade professionals updates on the trade-related government agencies and courts affecting their businesses and helpful website links providing COVID-19 information. The Office of Personnel Management (OPM) has indicated that federal offices nationwide “continue to perform mission critical functions and operations as determined by agency heads” but that maximum telework flexibilities are being provided to all eligible employees.

Trade Agencies and Court Status

U.S. Department of Commerce – While Commerce has published no formal notice of its operating status, meetings with visitors from outside of the agency have been canceled in the past week. Further, the Bureau of Industry and Security (BIS) has canceled its export control forum scheduled for April 2020.

U.S. Department of the Treasury – While Treasury has published no formal notice of its operating status, the “public engagement” schedule for the next several weeks is currently empty, suggesting that all outside meetings have been canceled. The Office of Foreign Assets Control (OFAC) has not indicated yet whether its operations have been affected.

U.S. Department of State – The Directorate of Defense Trade Controls (DDTC) has indicated that its core activities across its Licensing, Compliance, Policy and Management offices continue to function. However, the notice states, “staffing and other adjustments across the Department and interagency are being made” as the agency follows OPM guidance.

  • Licensing Activities – All electronic application systems are currently in normal operational mode, and new licenses continue to be accepted for processing; however, a longer than normal processing time should be expected.
  • Registration, Commodity Jurisdiction Requests and General Correspondence ­– These filings via the Defense Export Control and Compliance System (DECCS) continue and are being processed as they are submitted; responses may be delayed by the current operational environment.

DDTC states that it has established a new option for industry to submit disclosures and related information (e.g., exhibits, extension requests and responses to DTCC inquiries) by allowing submissions via email to DTCC-CaseStatus@state.gov. If a disclosure cannot be submitted via email, DDTC indicates that the continued use of regular U.S. mail is acceptable.

U.S. Trade Representative (USTR) – The Office of the U.S. Trade Representative has offered no update on its operating status.

U.S. International Trade Commission (ITC) – The ITC has stated that it remains open while its employees are teleworking full-time. The Secretary’s Office will accept only electronic filings during this time. Filings must be made through the ITC’s Electronic Document Information System (EDIS) at https://edis.usitc.gov. No in-person, paper-based filings or paper copies of any electronic filings will be accepted until further notice. Visitor access to the building is now closed and will remain so through April 3, 2020.

  • Section 337 Hearings – Administrative law judges (ALJs) have been ordered to postpone any hearings scheduled in the next 60 days. All discovery will continue and any essential outside participation by staff will be decided on a case-by-case basis.
  • Title VII Matters – All antidumping and countervailing duty preliminary phase staff conferences have been cancelled for the next 60 days. All ITC Title VII votes will be conducted by notation; there will be no in-person votes for the next 60 days. Regarding hearings for final phase Title VII investigations, five-year (sunset) reviews, and those held under Section 332 and Section 131, the ITC has decided not to hold in-person hearings and interested parties will be invited instead to answer written questions issued by the ITC with certified written responses.
  • Agency Meetings, Seminars and Briefings – All scheduled in-person meetings with outside persons have been cancelled or postponed for the next 60 days.

U.S. Customs and Border Protection (CBP) – CBP refers users to DHS.gov/coronavirus for information related to the COVID-19 pandemic, where it states that “all air, land and sea Ports of Entry (POEs), CBP Officers (CBPOs) and Border Patrol Agents (BPAs) continue to identify and refer individuals with symptoms of COVID-19 or a travel history to China, Iran, or certain European countries in the past 14 days to CDC or local public health officials for enhanced health screening.” As has been occurring for several weeks, the rerouting of all flights with passengers who have recently been in China, Iran and certain European countries continues through select airports with established resources, procedures and personnel. A February 3, 2020 bulletin explained that “[c]rew, and flights carrying only cargo (i.e., no passengers or non-crew), are excluded” from U.S. Department of Homeland Security’s arrival restrictions imposed on February 2, 2020. It has also been reported that “CBP continues to process cargo at its normal rate as there has been no identified threat as it relates to cargo shipments” and that “vessels or embarked crewmembers or passengers that have recently been in China will have their arrivals fully vetted to safeguard the American public yet facilitate trade. This safety protocol is not anticipated to slow down the movement of cargo.” With decreases in vessel operations, several ports closed and terminal operations suspended, however, the volume of cargo has been reduced.

U.S. Census Bureau – Many U.S. Census Bureau employees are operating remotely via telework. During this time, call centers and email inboxes will remain open to assist customers’ daily trade needs. However, the agency will have limited access to physical mail. For those companies that are submitting a Voluntary Self-Disclosure (VSD) or data request, please make the submission electronically to the Trade Regulations Branch (TRB) in a password-protected file to emd.askregs@census.gov (for VSDs) or Data User & Trade Outreach Branch (DUTOB) to tmd.outreach@census.gov (for data requests). Additionally, such submissions may be sent to the bureau’s secure fax at 301.763.8835.

U.S. Court of International Trade (CIT) – According to its statement of March 12, it appears that there have been no adjustments in CIT operations, except as listed below.

  • People who have traveled to China, Iran, Ireland, South Korea, the United Kingdom, or any of the 26 countries located in the Schengen Area of Europe within the last 14 days; reside or have had close contact with someone who has traveled to one of these areas within the last 14 days; have been asked to self-quarantine by any hospital or health agency; or have been diagnosed with, or have had contact with, anyone who has been diagnosed with COVID-19, must inform the court security officers upon entering the courthouse and will be denied permission to enter. Attorneys who are so affected and scheduled to appear before the CIT must notify the court so that appropriate safeguard measures can be taken. Attorneys may appear via teleconference or videoconference with the approval of the presiding judge. These restrictions will remain in place until further notice.

U.S. Court of Appeals for the Federal Circuit – Per a public advisory notice and an administrative order, the Federal Circuit began restricting public access to the National Courts Building complex on March 16, 2020. On March 19, the Court issued an updated public advisory stating that all cases scheduled for argument during the April 2020 sitting will now be conducted by telephone conference and no in-person hearings will be held. All existing deadlines in cases currently remain in effect. The court has suspended the requirement to file paper copies of all electronic filings but will continue to accept “documents that can only be filed by paper and filings from parties who are not permitted to file electronically.” Such filings should be submitted either by mail or by deposit in the court’s night box. Mail and third-party commercial deliveries will be limited to the lobby. Any other deliveries must be coordinated ahead of time with relevant court staff.

Useful U.S. Government Website Links

The U.S. government has established multiple websites to assist the public:

U.S. Government International Trade-Related Websites:

International Resources

Additional Resources

Thompson Hine has launched a multidisciplinary COVID-19 Task Force to monitor the latest developments and guidance from public health officials and assess the potential impacts on our clients and their businesses. The COVID-19 Task Force page on our website provides a centralized location for recent publications, webinars, articles and resources that you may find helpful.

The Office of the U.S. Trade Representative (USTR) has issued a Federal Register notice exempting Section 301 tariffs for certain List 3 (imports from China with an annual trade value of $200 billion) products. The exemptions cover one 10-digit Harmonized Tariff System (HTS) subheading and 176 specially-prepared product descriptions, which combined cover 202 separately submitted exclusion requests.

The excluded HTS subheading is 7002.10.2000, which covers “Glass in balls (other than microspheres of heading 7018), rods or tubes, unworked: Balls: Other. The exclusions with specially-prepared product descriptions include but are not limited to: certain frozen fish; oyster shells; certain fruit and vegetable seeds; certain synthetic silica gel; multiple different chemicals and materials (CAS numbers are provided); certain parts of fences; certain types of gaskets, hoses, washers, and other seals; certain new tubeless, bias-ply pneumatic and radial pneumatic tires; certain backpacks, tote, duffel bags, and other bags; certain fishing tackle bags; certain surfboard covers; various types of paper products; yarn of cashmere or camel hair; certain polyester fabrics; certain types of bathtubs, sinks, certain faucet and shower parts; certain ceramic articles; types of tempered safety glass; certain types of rear-view mirrors; certain bird feeders; various steel articles covered in Chapter 73 of the HTS; certain kits of bits for woodworking and drilling; certain screen door cross bars; certain pistons and cylinder heads for engines; certain hydraulic and screw jacks; certain bandsaws for working wood; certain camshafts and crankshafts; certain single-phase AC electric motors; certain inductors; certain color TV cameras; certain radiobroadcast receiver kits; various types of printed circuit boards; certain digital sound processing equipment; certain steel or aluminum bumpers for off-road vehicles; certain RV vent insulators; certain aluminum radiators; certain steering gears and other steering cylinder parts for motor vehicles; certain bicycles; certain single-axle trailers with steel or aluminum frames; certain automobile seats and seat covers; certain shelving units and cabinets; and certain lamps, LED lamps and LED backlight modules.

These exclusions will apply from September 24, 2018, through August 7, 2020. These exclusions apply to any product that satisfies the description in the annex of the Federal Register notice, regardless of whether the company using the exclusion filed the request. Each exclusion is governed by the scope of the HTS heading and the product description appearing in the annex of the exclusion notice; it is not governed by the product description set out in any particular exclusion request. U.S. Customs and Border Protection will soon issue instructions on entry guidance and implementation. The USTR will continue to issue determinations on pending requests on a periodic basis.

The Office of the U.S. Trade Representative (USTR) has issued a Federal Register notice seeking public comment on the possible extension of Section 301 tariff exclusions for certain products that it granted on June 4, 2019, in the ongoing trade dispute with China. These exclusions were in the fifth batch of exclusions granted as part of the first round of Section 301 tariffs placed on imports of Chinese goods with an annual trade value of approximately $34 billion (List/Tranche 1 products). These exclusions (see Trump and Trade Update of June 4, 2019) are scheduled to expire on June 4, 2020. This batch of exclusions included one full HTS subheading and 88 partial exclusions under an HTSUS subheading as further defined in specially prepared product descriptions. The USTR is considering a possible extension of up to 12 months for these exclusions and seeks public comment on whether to extend particular ones.

The USTR states that it will evaluate the possible extension of each exclusion on a case-by-case basis. The focus of the evaluation will be “whether, despite the first imposition of these additional duties in July 2018, the particular product remains available only from China.” These issues should be addressed in submitting any comments:

  • Whether the particular product and/or a comparable product is available from sources in the United States and/or in third countries.
  • Any changes in the global supply chain since July 2018 as to the particular product, or any other relevant industry developments.
  • The efforts, if any, the importers or U.S. purchasers have undertaken since July 2018 to source the product from the United States or third countries.
  • The USTR notes that it will continue to consider whether the imposition of additional duties on the products covered by the exclusion will result in severe economic harm to the commenter or other U.S. interests.

Comments will be accepted between April 1 and April 30, 2020. All submissions must be made electronically via the www.regulations.gov portal on Docket Number USTR-2020-0013. The USTR strongly recommends that those wishing to comment complete Exclusion Extension Comment: Form A, which will be posted on the public docket. Importers and purchasers may also submit Exclusion Extension Comment: Form B containing business confidential information via email to 301bcisubmissions@ustr.eop.gov, which will not be made available to the public. If filing a Form B, parties, the USTR notes, must also file a public Form A.

The USTR is considering the possible extension of product exclusions only for those exclusions granted in June 2019; no other extensions under any other product exclusion notices issued by the USTR will be considered.

The Office of the U.S. Trade Representative (USTR) has issued a Notice and Request for Comments seeking comment from members of the public, businesses, and government agencies as to whether further modifications are necessary to the China Section 301 tariffs “to keep current on developments in our national fight against the coronavirus pandemic.” USTR states that throughout the Section 301 process “the United States has prioritized health considerations”, has worked with the Department of Health and Human Services to not “impose tariffs on certain critical products such as ventilators, oxygen masks, and nubilators” and, has “granted exclusions for a large number of health-related products”. Nevertheless, it is taking this additional action to assess whether the removal of duties from additional medical care products is necessary.

Submissions are limited to comments on products subject to the tariff actions and relevant to the medical response to the coronavirus. Comments should be filed using the Federal eRulemaking Portal (www.regulations.gov) on Docket No. USTR-2020-0014. USTR is requesting that comments be submitted “promptly” but no later than June 25, 2020. Once posted, any responses to submitted comments should be submitted within three (3) business days in order to be considered. USTR will review comments on a rolling basis. Each comment must include:

  • The ten-digit HTS subheading applicable to the product;
  • Specifically identify the particular product and “explain precisely how the product relates to the response to the COVID-19 outbreak”;
  • Identify the product in terms of its functionality and physical characteristics (e.g., dimensions, material composition, or other characteristics);

Commenters may also provide information regarding the producer, importer, ultimate consumer, or trademarks or tradenames, but USTR notes that “this is less helpful.” USTR has also clarified that comments may be submitted under this docket number even if the product is subject to a pending or previously denied
exclusion request.

The Department of the Treasury’s Office of Foreign Assets Control (OFAC) has announced its extension of two general licenses related to GAZ Group, Ukraine-related General License No. 13N, “Authorizing Certain Transactions Necessary to Divest or Transfer Debt, Equity, or Other Holdings in GAZ Group” and Ukraine-related General License No. 15H, “Authorizing Certain Activities Necessary to Maintenance or Wind Down of Operations or Existing Contracts with GAZ Group, and Certain Automotive Safety and Environmental Activities.” In addition to extending the expiration dates to July 22, 2020, General License 15H expands the scope of authorized transactions and activities involving GAZ Group.

Effective March 20, 2020, General License 13N supersedes and replaces General License 13M. General License 13N authorizes all transactions and activities otherwise prohibited by Ukraine Related Sanctions Regulations, 31 C.F.R. §§ 589.101-.901 (URSR), that are ordinarily incident and necessary to:

  • Divest or transfer debt, equity or other holdings in GAZ Group or in entities in which GAZ Group owns, directly or indirectly, a 50% or greater interests, to a non-U.S. person; or
  • Facilitate the transfer of debt, equity or other holdings in GAZ Group or in entities in which GAZ Group owns, directly or indirectly, a 50% or greater interests, by a non-U.S. person to another non-U.S. person.

Additionally, General License 13N requires that on or before August 5, 2020, all U.S. persons participating in transactions authorized by this general license file a comprehensive, detailed report with OFAC. The report should include the names and addresses of the parties involved, the type and scope of activities conducted, and the dates on which the activities occurred.

Similarly, effective March 20, 2020, General License 15H supersedes and replaces General License 15G. General License 15H authorizes all transactions and activities otherwise prohibited by the URSR that are ordinarily incident and necessary to:

  • The maintenance or wind down of operations, contracts, or other agreements, including the importation of goods, services, or technology into the United States, involving GAZ Group or any other entity in which GAZ Group owns, directly or indirectly, a 50 percent or greater interest and that were in effect prior to April 6, 2018;
  • Research and development regarding, and the related purchase, manufacture, and installation of, Electronic Stability Program systems and other advanced driver-assistance systems, or components thereof, consistent with applicable automotive safety regulatory requirements, in vehicles produced by GAZ Group or any other entity in which GAZ Group owns, directly or indirectly, a 50 percent or greater interest;
  • Research and development regarding, and the related purchase, manufacture, and installation of, components necessary to implement Euro 5/6 emissions standards in vehicles produced by GAZ Group or any other entity in which GAZ Group owns, directly or indirectly, a 50 percent or greater interest; or
  • The installation of occupant safety systems (including steering wheels, airbags, and seat belts) consistent with applicable automotive safety regulatory requirements in vehicles produced by GAZ Group or any other entity in which GAZ Group owns, directly or indirectly, a 50 percent or greater interest.

Previously, General License 15G was expanded to authorize transactions involving GAZ Group relating to research and development of Electronic Stability Program systems and other advanced driver-assistance system, and Euro 5/6 emissions standards. General License 15H further expands the scope of authorized transactions involving GAZ Group relating to the installation of occupant safety systems consistent with automotive safety regulation requirements.

General License 15H also requires that on or before August 5, 2020, all U.S. persons participating in transactions authorized by this general license file a comprehensive, detailed report with OFAC. The report should include the names and addresses of the parties involved, the type and scope of activities conducted, and the dates on which the activities occurred.

General Licenses 13N and 15H expire on July 22, 2020 at 12:01 a.m. EST.