In ruling NY N312202 (June 18, 2020), Customs and Border Protection (CBP) discussed the classification of the Plus Bionics POD. It is a composite machine that has several features including facial recognition, temperature reading, disinfection, an LCD display and alarms for high temperature readings. When entering the unit, the user will place their face in front of the facial recognition camera, which identifies the user and displays their information on the LCD display. The device…

On May 29, 2020, President Trump announced his intention to direct his administration to begin the review and removal of Hong Kong’s special treatment for dual-use export controls.  Over the last week, we have seen the U.S. State and Commerce Departments begin to implement these changes through a coordinated series of announcements that, collectively, represent the largest change in Hong Kong’s status under export control laws since the 1997 handover ending British sovereignty. Specifically, on…

New Business Guidance to Address Supply Chain Risks and Considerations The Departments of State, Treasury, Commerce, and Homeland Security issued guidance on July 1, 2020 titled “Risks and Considerations for Businesses with Supply Chain Exposure to Entities Engaged in Forced Labor and other Human Rights Abuses in Xinjiang” (the “advisory”).  The advisory broadly recommends that businesses with potential exposure in their supply chain to the Xinjiang Uyghur Autonomous Region of China (“Xinjiang”) be…

In ruling N312096 (June 22, 2020) CBP discussed a video camera from China. The EYENIMAL Pet Videocam is a small battery-operated camera that is designed to be attached to a pet’s collar.  The subject camera can record videos onto its internal memory. It is waterproof and meant for cats and small dogs. To charge or view the video content the camera is connected to a computer via a USB cable.  The camera cannot capture and…

Only four months after the the United Kingdom’s Office of Financial Sanctions Implementation (OFSI) issued a £20.47 million penalty against Standard Chartered Bank (SCB) for alleged violations of the U.K.’s Ukraine- and Russia-related sanctions (see our alert here), another bank is in the news for regulatory breaches. This time it is the London arm of Commerzbank AG (Commerzbank), which was hit by the United Kingdom’s Financial Conduct Authority (FCA) on 17 June with…

On June 17, 2020, Team Telecom, the multiagency body that reviews certain Federal Communications Commission (FCC) licensing applications for national security and law enforcement concerns, recommended that the FCC deny the portion of the Pacific Light Cable Network (PLCN) submarine cable system application that would have established a direct connection between the U.S. and Hong Kong, citing national security concerns.  Team Telecom recommended that the FCC approve the portions of the application in so far…

In ruling NY N311797 (June 9, 2020) CBP discussed the classification of a zip line kit from China. The products under consideration are five models of zip line kits which are designed to enable children ages 8 years and older to ride a few feet off the ground as they are propelled by gravity to travel from the top to the bottom of the inclined cable while holding on to the freely moving pulley.  Each…