BIS Update Conference 2012 - Summary of Day 1

July 17, 2012 BIS Update Conference 2012 - Summary of Day 1

Today is the first day of the Bureau of Industry's 25th annual Update Conference on Export Controls and Policy. Here is a summary of our live tweets (twitter.com/tradelawnews) from day 1:
Annual BIS export controls Update starts today in DC. More than 1000 attendees. Will live tweet over next few day. Hashtag #BISUpdate For those not able to attend Update, materials and webcasts are available on BIS's website. See http://t.co/UpJUEu0a for details.First speaker - BIS Undersecretary Hirschhorn stressed need for exporters to stay engaged on export control reform (ECR). As part of Export Control Reform (ECR), first 38(f) notifications on transfer of items from USML to CCL will take place later this year. Future issues to be reviewed by BIS include cloud computing, deemed exports, CCL review, recordkeeping, etc. Next speaker- Asst Secy of State Andrew Shapiro. ECR intended to prioritize controls, not decontrol items. Will lead to better enforcement. Asst Secy Shapiro - "speculation that ECR is stalled is false". Momentum not being lost. Results of hard work on ECR are in reach. Next speaker- Asst Secretary Wolf who has played key role in ECR. While ECR appears to be slow, actually moving quickly when looking at big picture. ECR will make export controls understandable by "Muggles." USML Cat XI (electronics) likely to be published in coming weeks. Here is some information from on the record press briefing by senior BIS and State Dept officials at Update. BIS would like to issue changes to encryption rule in future. Other future changes to regs include cloud computing. Regarding 38(f) process, working closely with Congress and have made changes as a result. Concerned about various amendments to pending legislation on satellites that could have adverse impact on ECR. Hope that satellite legislation can be taken up this year. E2C2 export enforcement coordination center up and running. Update breakout sessions on sanctions, AES, control list changes and end use monitoring. Many of the presentations can be found on the BIS website at http://www.bis.doc.gov/seminarsandtraining/update2012/presentations.htm OFAC participated with BIS on sanctions panel and clarified some points on new Burmese general licenses. Also answered questions on various sanctions programs and licensing issues. OFAC clarified that the new reporting requirement in Burma GL applies to investments greater than $500,000 only and not sales over that amount. OFAC also stated that average processing time for Iran TSRA Ag/Med licenses is 3 months. No real downturn in applications of TSRA applications due to Iran payment issues. also, BIS reiterated importance of reviewing both OFAC and BIS regs due to overlap of jurisdiction in some programs. Regarding press reports re Apple products being denied for Iranians in US, OFAC said that OFAC regs are not discriminatory but that an OFAC license is required when controlled good are exported to Iran. Keynote speaker today is Acting Secretary of Commerce Dr. Rebecca Blank. Acting Secretary of Commerce Blank discussing National Export Initiative and other economic issues relating to exports, including new free trade agreements. Mentioned importance of repealing Jackson-Vanik and permanent MFN for Russia. Promoted current export control reform efforts and reiterated that ECR is not decontrol. Noted herculean efforts made so far in ECR and that no other administration has got this far. Hopes to have some final changes from USML to CCL published by end of year. Export enforcement panel VERY well attended. Discussing IED components concerns and continued focus on enforcement involving China and Iran. Pakistan still an illegal procurer and discussed joint OEE and FBI investigation efforts in procurement networks. Also discussed trends in voluntary self disclosures. Noted only 3% of VSDs led to penalties. Will be 20% increase in enforcement outreach efforts. DDTC and BIS panel discussing details on implementing ECR. All 600 series items must be reported in AES, regardless of value. Post departure AES filing not eligible for 600 series. Special destination statement required for 600 series items. BIS expects 30K increase in licenses. BIS information triage unit is reviewing legitimacy of exports. Enhanced data sharing with DDTC and end use monitoring. DDTC and BIS panel discussing details on implementing ECR. RT @CommerceSec: just finished with my remarks at the Conference on Export Controls Policy, hosted by our Bureau of Industry and Security. Head of DDTC export compliance now discussing enforcement issues related to defense articles. Discussing end use checks, export license due diligence, red flags.  Information and updates on export control reform can be found at http://export.gov/ecrLabels: BIS Update Conference

 

Date of U.S. Customs and Border Protection's 2012 Trade Symposium in Washington, DC Changed to October 29-30, 2012

August 08, 2012 Date of U.S. Customs and Border Protection's 2012 Trade Symposium in Washington, DC Changed to October 29-30, 2012

U.S. Customs and Border Protection (CBP) recently announced that the 2012 East Coast Trade Symposium to be held in Washington, DC has been moved from September 27-29 to October 29–30, 2012.

Further information regarding the Symposium's agenda and online registration will be available on this page on CBP's website and registration is expected to open during mid-August.

A subscription to the live Webcast of the event will also be offered this year for those that cannot attend in person.

Because of the venue's size, CBP will limit attendance to three representatives from the same company.

 

U.S. to "Suspend" Sanctions on Burma

This afternoon Secretary of State Clinton announced that the U.S. is “suspending” the existing financial and investment sanctions on Burma (Myanmar).

However, the details on how the existing sanctions will be suspended are still being worked out and the existing Burmese Sanctions Regulations (31 CFR. Part 537) (BSRs) administered by the Treasury Department's Office of Foreign Assets Control (OFAC) will remain in effect until further notice.

It appears likely that OFAC will issue a general license that will amend the BSRs to enable U.S. companies to enter into contracts relating to the "economic development of resources in Burma" and other investment activities. In addition, the general license will also authorize financial institutions and other parties to provide financial services to Burma.

In today's announcement, Secretary Clinton indicated that U.S. companies doing business in Burma will be expected to implement certain Corporate Social Responsibility measures and U.S. companies will be expected, but not required to "to conduct due diligence to avoid any problems, including human rights abuses . . . create a grievance process that will be accessible to local communities; to demonstrate appropriate treatment of employees, respect for the environment; to be a good corporate citizen; and to promote equitable, sustainable development that will benefit the people."

Senior Administration officials today also reminded U.S. companies of the extensive corruption in Burma. Given the Burmese Government's extensive role in the company's business sector, particularly in the oil and gas sector, U.S. companies will have to take additional steps to ensure compliance with the U.S. Foreign Corrupt Practices Act. 

Existing U.S. Sanctions on Burma

The current U.S. sanctions on Burma are unique and are far less restrictive than the broad sanctions imposed by the U.S. Government on Cuba, Iran, North Sudan, Syria and North Korea. Unlike the other broad-based U.S. sanctions programs, the BSRs generally do not prohibit U.S. companies or U.S. citizens from exporting goods classified as EAR99 to Burma and receiving payment for such goods.

The BSRs currently prohibit U.S. persons and companies from engaging in the following activities involving Burma:

1. Exportation of Financial Services to Burma - No U.S. company or U.S. citizen, wherever located, can make any payment, directly or indirectly, to Burma.

2. New Investment in Burma - No U.S. person or company can enter into any contracts with the Government of Burma or nongovernmental entities in Burma for the "economic development of resources in Burma". The phrase "economic development of resources located in Burma" is defined to mean, among other things, activities pursuant to a contract that involves the development or exploitation of natural resources in Burma, such as contracts conferring rights to explore for, develop, extract or refine petroleum or natural gas in Burma. A "nongovernmental entity in Burma" include most types of business organizations that exist for engaging in economic development of resources in Burma.

3. Facilitation of Prohibited Transactions in Burma - U.S. companies and U.S. citizens are prohibited from approving, aiding or supporting a foreign person’s investment in Burma, if the foreign person’s activity would constitute prohibited new investment if engaged in by a U.S. person. This prohibition does not apply to contracts involving the sale of goods, services or technology to Burma or for use in Burma.

4. Prohibited Importation of Burmese Origin Goods - Most goods of Burmese origin are prohibited from being imported into the U.S.

Existing Export Controls on Burma 

U.S. exports of commercial goods to Burma will remain subject to export control requirements administered by the Commerce Department's Bureau of Industry and Security (BIS). Currently, exports of goods, technology and software on the Commerce Control List (i.e., not classified as EAR99) typically require a BIS export license.

Burma has been subject to a U.S. arms embargo since 1993 and therefore no "defense articles" or "defense services" subject to the jurisdiction of the International Traffic in Arms Regulations can be exported to Burma. Today's announcement will not have any impact on this aspect of U.S. law.

U.S. Securities and Exchange Commission questions answers to frequently asked questions about the Iran reporting requirements

December 05, 2012 U.S. Securities and Exchange Commission Issues Answers to FAQs on Iran Reporting Requirements

The U.S. Securities and Exchange Commission (SEC) yesterday issued some answers to frequently asked questions on the new reporting requirement contained insection 219 of the Iran Threat Reduction and Syria Human Rights Act of 2012(TRA) (H.R. 1905, enacted as Public Law 112-158) that was signed into law on August 10, 2012 and requires ''issuers" to disclose certain activities in Iran starting on February 6, 2013.

Asexpected, the guidance is broad in nature and does not shed too much light on important terms, such as the definition of“affiliate.” As noted below, the SEC has stated that they will use the definition of that term that is currently contained in section 12b-2of the SEC’s regulations, which states:

Affiliate. An “affiliate” of, or a person“affiliated” with, a specified person, is a person that directly, or indirectlythrough one or more intermediaries, controls, or is controlled by, or is undercommon control with, the person specified.
TheFAQs can be found on the SEC's website here and include questions 147.01 through147.07. 
The text of each of the FAQs are reprinted below:Question 147.01Question: Section 219(b) ofthe Iran Threat Reduction and Syria Human Rights Act of 2012, signed into lawon August 10, 2012, specifies that new Section 13(r) of the Exchange Act “shalltake effect with respect to reports required to be filed with the Securitiesand Exchange Commission after the date that is 180 days after the date of theenactment of this Act,” which would be February 6, 2013. If an issuer’speriodic report is required to be filed on a date after February 6, 2013 — suchas, for example, the 2012 Form 10-K for calendar year filers — is the issuerrequired to disclose Iran-related business activities pursuant to Section 13(r)if it files the periodic report on or before February 6, 2013?

Answer: Yes. We interpret“reports required to be filed” to include any periodic report with a due dateafter February 6, 2013, regardless of when the report is actually filed. [Dec.4, 2012]
Question 147.02Question: If an issuer’sannual report is required to be filed after February 6, 2013, must it includedisclosure of activities specified in Section 13(r)(1) that occurred during thefiscal year but prior to enactment of the Iran Threat Reduction and Syria HumanRights Act of 2012 on August 10, 2012?
Answer: Yes. An issuer isrequired to disclose activities specified in Section 13(r)(1) that occurredduring the period covered by the report, which, for a Form 10-K, is the entirefiscal year. For example, an issuer that files an annual report for the fiscalyear ending December 31, 2012 is required to disclose any activities specifiedin Section 13(r)(1) that took place between January 1, 2012 and December 31,2012. [Dec. 4, 2012]
Question 147.03Question: Section 13(r) coversactivities by an issuer “or any affiliate of the issuer.” How is the term“affiliate” defined for purposes of Section 13(r)?
Answer: The term “affiliate”in Section 13(r) is as defined in Exchange Act Rule 12b-2. [Dec. 4, 2012]
Question 147.04Question: If an issuer and itsaffiliates have not engaged in any of the activities specified in Section13(r)(1) during the period covered by the report, must the issuer include astatement to that effect in its periodic report?
Answer: No. Disclosure isrequired only if the issuer or any of its affiliates engaged in any of theactivities specified in Section 13(r)(1) during the period covered by thereport. [Dec. 4, 2012]
Question 147.05Question: Section13(r)(1)(D)(iii) requires disclosure if an issuer or any of its affiliatesknowingly conducts any transaction or dealing with “any person or entityidentified under section 560.304 of title 31, Code of Federal Regulations(relating to the definition of the Government of Iran) without the specificauthorization of a Federal department or agency.” Would this provision allowissuers to omit disclosure of transactions or dealings that have beenspecifically authorized by foreign governmental authorities, but not any U.S.federal department or agency?
Answer: No. A transaction ordealing with any person or entity identified under 31 CFR § 560.304 must bedisclosed unless it was specifically authorized by a U.S. federal department oragency. If a disclosable transaction was specifically authorized by a foreigngovernmental authority, an issuer could disclose that fact in addition to theother information required by Section 13(r)(2) to provide the appropriatecontext for the disclosure. [Dec. 4, 2012]
Question 147.06Question: The Office ofForeign Assets Control (OFAC) of the U.S. Department of the Treasury issuesboth general and specific licenses. A general license authorizes a particulartype of transaction for a class of persons without the need to apply for aspecific license. A specific license is a document issued by OFAC to aparticular person or entity, authorizing a particular transaction in responseto a written license application. See OFAC’s Frequently Asked Questionsand Answers #74, available at http://www.treasury.gov/resource-center/faqs/Sanctions/Pages/answer.aspx#60(explaining the difference between a general license and a specific license).Does a general license issued by OFAC count as a “specific authorization of aFederal department or agency” for purposes of Section 13(r)(1)(D)(iii)?
Answer: Yes. Both general andspecific licenses constitute specific authorization by OFAC to engage in atransaction, provided all conditions of the applicable license are strictlyobserved. [Dec. 4, 2012]
Question 147.07Question: If an issuerincludes disclosure responsive to Section 13(r) in a periodic report filed withthe Commission, will the disclosure become public?
Answer: Yes. All periodicreports filed with the Commission are made public automatically upon filingthrough the Commission’s EDGAR system. [Dec. 4, 2012]

 

U.S. Indicts U.S. and Russian Companies and Individuals Involved in Russian Military Procurement Network and Adds 164 Parties to BIS Entity List

October 03, 2012 U.S. Indicts U.S. and Russian Companies and Individuals Involved in Russian Military Procurement Network and Adds 164 Parties to BIS Entity List

As a result of an investigationinvolving an alleged Russian military procurement network, the U.S. Department of Justice announced today that it had unsealed an indictment against two companies and 11 individualslocated in the U.S. and Russia and executed a number of search warrants at various residences, businesses and banks in the U.S. 

In a coordinated action, the Commerce Department's Bureau of Industry and Security (BIS) also issued a final rule (PDF) amending the Export Administration Regulations (EAR) to add 164 foreign persons and companies to the Entity List who allegedly received, transshipped or facilitated the exports of the items to Russia.

The Indictment
Accordingto the indictment, the defendants were allegedly involved in:  

A surreptitious andsystematic conspiracy to obtain advanced, technologically cutting-edgemicroelectronics from manufacturers and suppliers located within the UnitedStates and to export those high-tech goods to Russia, while carefully evadingthe government licensing system set up to control such exports. Themicroelectronics shipped to Russia included analog-to-digital converters,static random access memory chips, microcontrollers, and microprocessors”that were subject to the jurisdiction of the Export Administration Regulations (EAR) or International Traffic in Arms Regulations (ITAR).

The Justice Department also stated that the defendants:  allegedly exported many of these high-tech goods, frequently throughintermediary procurement firms, to Russian end users, including Russian military and intelligenceagencies. To induce manufacturers and suppliers to sell them these high-tech goods, and to evadeapplicable export controls, the defendants often provided false end user information in connection withthe purchase of the goods, concealed the fact that they were exporters, and falsely classified the goodsthey exported on export records submitted to the Department of Commerce. For example, in order toobtain microelectronics containing controlled, sensitive technologies, Arc claimed to Americansuppliers that, rather than exporting goods to Russia, it merely manufactured benign products such astraffic lights. Arc also falsely claimed to be a traffic light manufacturer on its website. In fact, Arcmanufactured no goods and operated exclusively as an exporter. In addition to the 11 individuals named in the announcement, thetwo companies that were indicted are:Arc Electronics, Inc., Houston, TexasApex System, L.L.C., Moscow, RussiaAddition of 164 Parties to BIS Entity ListThe 164 parties that will be added to the Entity List are located in Belize, Canada, Cyprus, Estonia, Finland, Germany, Greece, Hong Kong, Kazakhstan, Russia (119 of the 164),Sweden, United Kingdom and British Virgin Islands. (There are actually 165entries added, one of which is an alternate address for one party). 
The Entity List, found at Supplement No. 4 to Part 744 of the EAR, includes the names of non-U.S. businesses, research institutions, government organizations and individuals that have been identified as being involved in activities that merit additional scrutiny and licensing requirements. The entries on the Entity List specify the license requirements and license review policy that are applicable to shipments to each listed entity. In some cases, a license will be required to ship items classified as EAR99 to the customer, even when a license would not normally be required. In other cases, all items subject to the Export Administration Regulations will require a license. The export license review policy also varies from entity to entity. In some cases, there is a presumption of approval or denial and, in other cases, the license will be reviewed by BIS on a case-by-case basis. Exporters, freight forwarders and other parties that are involved in shipping items to parties on the Entity List without the required export license are subject to civil penalties of up to $250,000 per violation or twice the value of the underlying transaction.
In this case, theEntity List license requirement for 164 parties is “presumption ofdenial” and applies to “all items subject to the EAR.” As a result, an exportlicense issued by BIS is required before any item subject to the EAR can beexported, reexported or transferred to these persons or companies, andestablishes a presumption that no such license will be granted. In addition, no License Exceptions contained in the EAR can be used for exports, reexports or transfers to any of the 164 named parties.
The export license requirement will go into effect upon publication of the Entity List changes in the Federal Register, whichshould take place early next week. 
While the Entity List announcement contains a "saving clause" authorizing shipments of items to these parties that were en route aboard a carrier to a port of export or reexport, on the date of publication of the notice in the Federal Register, U.S. exporters and non-U.S. exporters of U.S. origin items should review the names to be added to the Entity List to ensure that there are no pending transactions with any of these parties that may be ready to be shipped. 
While restricted partyscreening software vendors will update their restricted party screening list databases to include these 164 new names, some software vendors will not update their databases until the notice is published in the Federal Register next week.
Finally, whileArc Electronics in Houston, Texas is not included on the Entity List since it is located in the U.S., it is recommended that Arc Electronics and the other named U.S. defendants not included on the Entity List be considered as restrictedparties for export compliance purposes pending the outcome of the court proceedings (although it is my understanding that Arc Electronics was shut down today and could be added to the Denied Persons List in the future).  

Request by Law Enforcement for Assistance

In an unusual development, the press release includes the following request by the law enforcement agencies involved in this matter: As a result of this case, there may be victims and witnesses who need to contact the agencies involved in the investigation. If your business has been approached by one of the defendants, or by someone trying to obtain export-protected, sensitive technology who appeared not to be legitimate, please report that information to businessoutreach@leo.gov. The information will remain confidential and will be handled by the appropriate authorities.The leo.gov website is the FBI's Law Enforcement Online (LEO) system that is used to support investigations and other law enforcement communication-related activities. 

Exporters should consider consulting with qualified export controls counsel before submitting information via the LEO website.

 

Office of Defense Trade Controls Compliance Closed Due to Building Fire

March 21, 2012 Office of Defense Trade Controls Compliance Closed Due to Building Fire

The State Department's Directorate of Defense Trade (DDTC) controls announced today that a fire occurred early Tuesday morning, March 20, in a portion of the Washington, DC office complex that includes the Office of Defense Trade Controls Compliance (DTCC).

The fire occurred before normal duty hours and there were no reports of injury. The fire did not impact DTCC, but the office experienced fairly significant water damage. Other offices within the DDTC were not impacted. As a result, DTCC was closed yesterday and remains closed while damage assessment teams survey conditions. While temporary space is being prepared for the compliance staff, this effort is expected to take 2 to 3 days to complete.

DTCC expects to return to a normal level of operation within one week. In the meantime, industry will experience delays in contacting members of the compliance staff and in the issuance of new and renewing registrations.

 

Seasons Greetings and Happy New Year From International Trade Law News and Letter to Santa Regarding Possible Compliance Violations

December 21, 2012 Seasons Greetings and Happy New Year From International Trade Law News and Letter to Santa Regarding Possible Compliance Violations

Season's Greetings and Happy New Year to all of our loyal readers and clients around the world. See you in 2013. 

In the spirit of the holiday season, and back by popular demand, below a letter to Santa regarding a number of alleged violations of import, export and other laws and regulations. 
—Doug Jacobson 
Letter to Mr. Claus from ScroogeMcGrinch  By Dennis Salvey, Trade Compliance Manager of iDirect Inc. (reprinted with permission)

DearMr. Claus,

Weregret to inform you that your annual distribution of toys and gifts will notbe permitted to proceed this year due to multiple Trade Complianceviolations. Each of the below listed “alleged” violations are under reviewand until each is resolved, your gift-giving enterprise is suspended from itsnormal course of surreptitiously sliding up and down chimneys.
1.  The Office of Export Enforcement (OEE) has opened an investigationregarding the potentially illegal exports of toys and gifts from the U.S.without the proper export licenses, customs declarations or documentation. TheExport Administration Regulations (EAR) clearly defines an export as being themovement of goods, services, toys, gifts or technology from the U.S. toany other country by any means including reindeer powered sleighs. Thereis no exception for Magic, as your voluntary disclosure alludes to.
2.   OEE isalso considering placing 2 of your cohorts on the Denied Parties List. Donderand Blitzen are suspected of diverting toys and gifts into embargoed countriesfor the nefarious purpose of bringing joy to the world. Vixen may also be namedas an accomplice. Dancer, Prancer and Comet’s alibi of being contestants onDancing with the Stars during the time of the alleged incident is holding upfor now. Incidentally, Interpol has some questions for you concerning two of yourknown alias’ Father Christmas and Kris Kringle.”
3.   Incorrectapplication of Incoterm© DDP (Delivery Duty Paid) has resulted in millions ofgifts held by Customs agencies around the world as you are not a registeredimporter in any country in which you do business.  Although all of your customers (recipients)wanted to receive those gifts, not one of them was willing to act as theImporter of Record. The exception was little Billy Johnson of Des Moines Iowawho attempted bribing a customs official with a box of candy canes and nowfaces 5 years hard labor in Santa’s workshop on an FCPA charge. The total finesfor storage by the respective Customs agencies are in the gazillions of dollarsand must be paid before the gifts can be returned to the North Pole at yourexpense. Be advised that when paying fines in the currency of board games,only Monopoly and the Christmas Game currencies are acceptable.
4.   TheAirwaybills used on your last 400 delivery episodes issued by “Fairy LandAirlines” is very questionable. It turns out that the dimensional weight versusthe actual weight is impossible to calculate. In addition, the North Pole isnot recognized as a valid Country of Origin.
5.  Speakingof Country of Origin, you claim that all of the material used in the making ofevery gift as well as all of the labor is a direct product of the North Pole.The World Customs Organization cannot verify that the materials needed to makeall of these gifts could conceivably come from the North Pole. The criteria of “Grown,Produced or Manufactured in a specific country” used to determine origin is anabsolute, international law does not recognize “Magic” as part of thesecriteria. They are also looking into unfair labor practices brought before theworld court, by a group known as the International Little Brotherhood of Elves.”
6.   The entered value you have reported on these toys and gifts is too low tohave been manufactured in the North Pole. Your financial records will besubpoenaed unless you can otherwise validate the low value claim before yournext distribution season. If North Pole currency, “The Saint Nickel”, was usedin your valuation methodology, be prepared to show its value against the U.S.dollar, the Euro and the Yen at the time the determination was made as NorthPole currency (the Saint Nickel) is not listed by any of the world’s financialmarkets.  
7.   Weare astonished at the number of paternity suits filing in from all over theworld. These suits all start the same way; “I saw Mommy kissing Santa Clauseunderneath the mistletoe last night.” World courts will act with discretion indetermining the validity of these claims; BUT we cannot guarantee that Mrs.Clause will not become aware of them at some point.
8.   TheEPA and equivalent agencies around the world are investigating complaints ofexcessive reindeer emissions (droppings). The fact that some farmers welcomethis will not be considered a mitigating factor when and if the case goes tocourt.
9.   Your“naughty / nice” list has raised more than a few eyebrows. Servicing those onthe nice list while refusing to do business with those on the naughty list is adirect violation of the U.S. Antiboycott rules as well as violating thediscrimination laws in countries in which you do business. The leagues of “NicePolar Bears” in the North Pole don’t seem to mind too much but the league of“Naughty Penguins” in the South Pole is especially outraged.10. Investigationsinto privacy laws have also been opened concerning the allegation that; “yousee them when their sleeping and know when their awake”. However, all of theseinvestigations will be dropped if you surrender the Intellectual Propertyrights to these methods to the CIA, FBI, Mussed, M5, and the KGB.
11. Finally;the red blinking light on Rudolf’s nose interferes with air traffic control andUFO sightings. The FCC, the FAA and the History Channel are investigating. Youand Rudolf will be summoned to Roswell for a hearing on this issue. My advice;do not arrive at these hearings in the company sled.

Until each of the aboveissues is resolved you are hereby ordered to cease and desist your annual toys and gifts distribution or holiday cheer-spreading, as you refer to it. 

Asan aside (not a Trade Compliance issue) the World Health Organization will berescinding your status as a role model due to your weight and poor diet of milkand cookies at every house. This is not the type of example they expect from aperson that children look up to.

Respectfully, 

Scrooge McGrinch
Bah Humbug Division, office of BIS (Big Important Stuff)