Comment Submitted by Anonymous (Trade Community Member)

To Customs and Border Patrol: Our comments on CBP’s “Proposed Rule” as published in the Federal Register Vol. 77, No. 158, Wednesday, August 15, 2012. (77 Fed. Reg. 48918). As you must be aware, the following statutes and regulations are already in effect. 31 CFR Part 592; Fed. Reg. Vol. 69, No. 184, Thursday, September 23, 2004. (69 Fed. Reg. 56936). Department of the Treasury, Office of Foreign Assets Control regulations. 31 CFR Section 592.301. 15 CFR Part 30; Fed. Reg. Vol. 70, No. 93, Monday, May 16, 2005. (79 Fed. Reg. 25773). Department of Commerce, Bureau of the Census regulations. 15 CFR Section 30.4. 19 CFR § 161.2. DHS, CBP Regulations. Enforcement for other Agencies. 22 CFR Section 127.4 15 CFR Section 758.7. Title 19 Statutes: 19 U.S.C. §§ 3901-3913. Clean Diamond Trade. 19 U.S.C. § 3905. Additionally, Customs has already published rulings about the Clean Diamond Trade Act and Kimberley process. CBP Rulings N018792, November 8, 2007. H173035, February 23, 2012. And for those interested in enforcement: you will see that both of these rulings work well together to eviscerate any opportunity for effective enforcement that would impact trade in any “not CLEAN,” noncompliant diamonds. The rulings clearly instruct all parties to simply mount the diamonds and they are not subject to the regulatory controls. The subject laws listed above and published in public government documents are already in place and have been for quite a while. Please explain how much CBP employee time and money was spent in processing and publishing the existing regulations under an alleged “PROPOSED” “Notice and Comment” opportunity in the Federal Register. The authority in 19 CFR § 161.2 covers everything CBP has issued as “PROPOSED”. Please respond in dollars and staff hours and staff hour labor costs as the government is spending a lot of taxpayer dollars on work that was already done by others.