• On April 1, 2019, UK Parliament implemented the second phase of its ‘Indicative Votes’ process, which had been devised to find out if there was a UK Parliamentary majority for any one Brexit strategy, following Friday’s third UK Parliamentary defeat of the Withdrawal Agreement that was negotiated between the UK Government and EU.
Chart available at
  • All four alternate Brexit strategies put forward were rejected by UK Parliament. The four proposals put forward were:
    • Customs Union: This plan requires any Brexit deal to include, as a minimum, a commitment to negotiate a “permanent and comprehensive UK-wide customs union with the EU”. This was defeated by the smallest margin, falling just three votes short of an overall majority.
    • Common Market 2.0: This proposes UK membership of the European Free Trade Association and European Economic Area.  It allows continued participation in the single market, and a “comprehensive customs arrangement” with the EU after Brexit – including a “UK say” on future EU trade deals – would remain in place until the agreement of a wider trade deal that guarantees frictionless movement of goods and an open border in Ireland.  This proposal was defeated by 21 votes, but it should be noted that 95 Members of Parliament abstained on the vote, the highest of any of the four options.  Political commentary would suggest that this plan could yet win a majority if there is to be a third round of Indicative Votes.

  • Second Referendum: This plan requires a public vote to confirm any Brexit deal passed by UK Parliament before its ratification. This option polled the highest number of votes – 280 – although it was ultimately defeated by 13 votes.  With relatively few abstentions (66), it has no easy path to an outright Parliamentary majority.
  • Parliamentary Supremacy: This plan entails seeking a long extension to the Brexit process, failing which, the granting of power to UK Parliament to choose between either No-Deal Brexit or No Brexit (via revocation of Article 50, the formal mechanism through which UK withdrawal of the EU is to be effected).  This plan lost by the largest margin – 101 votes – and is not seen as politically palatable to many Members of Parliament.
  • The way forward remains unclear.  The UK Government is thought to be keen on bringing back the Withdrawal Agreement for a fourth vote.  However, its opponents note that three of the proposals detailed above (Customs Union, Common Market 2.0 and Second Referendum) lost by a narrower margin (3, 12 and 21, respectively) than the Withdrawal Agreement (49).  UK Parliament is due to debate all strategies further on Wednesday.



  • As a result, the UK remains in a state of political paralysis, just 10 days away from the default position: No-Deal Brexit.  At the same time, the EU continues to ramp up No-Deal preparations: Michel Barnier, the EU’s chief Brexit negotiator has noted that a No-Deal Brexit is now “more likely”; while Guy Verhofstadt, the European parliament’s Brexit negotiator, has suggested that Wednesday’s debate in UK Parliament marks “a last chance to break the deadlock or face the abyss”.

A federal grand jury returned an indictment on Thursday, March 28, 2019, against two corporate executives for their roles in a scheme involving defective and dangerous consumer products.

The executives were charged with conspiracy to commit wire fraud, failure to furnish information under the Consumer Product Safety Act (CPSA), and to defraud the U.S. Consumer Product Safety Commission (CPSC). In addition to conspiracy, the indictment also alleged one count of wire fraud and one count of failure to furnish information under the CPSA.

According to the indictment, a part owner and the chief administrative officer imported, distributed, and sold to retailers for consumer purchase dehumidifiers that were made in China. The Consumer Product Safety Act requires manufacturers, importers, and distributors of consumer products to report “immediately” to the CPSC information that reasonably supports the conclusion that a product contains a defect that could create a substantial product hazard or creates an unreasonable risk of serious injury or death. This duty also applies to the individual directors, officers, and agents of those companies.

As early as September 2012, the executives at the companies received multiple reports that their imported Chinese dehumidifiers were defective, dangerous, and could catch fire. They also allegedly knew that they were required to report this product safety information to the CPSC immediately. Despite their knowledge of consumer complaints of dehumidifier fires and test results showing problems with the dehumidifiers, the executives failed to disclose their dehumidifiers’ defects and hazards for at least six months while they continued to sell their products to retailers for resale to consumers.

The indictment further alleges that as part of their scheme, the executives deliberately withheld information about the defective and dangerous imported Chinese dehumidifiers from the retail companies that bought the dehumidifiers; the insurance companies that paid for damage caused by the fires resulting from the dehumidifiers; and the CPSC. They continued to sell the Chinese dehumidifiers to retailers with false certifications that the products met safety standards; caused a company employee to solicit materials that would falsely portray to an insurance company that the dehumidifiers were safe and not defective; and sent an untimely report to the CPSC that falsely stated that the dehumidifiers were not defective or hazardous.

The executives and their companies continued to sell the defective and dangerous dehumidifiers through April 2013, and sought to avoid, reduce, and delay the costs of recalling the products. If convicted, they face a term of up to five years in prison for each of the conspiracy and the failure to furnish information counts. They both face up to 20 years’ imprisonment for the wire fraud charge. If convicted, the defendants are also subject to forfeiture and a fine of $250,000 or twice the gross gain or loss for each count.



In September 2013, the CPSC announced a recall of 2.2 million dehumidifiers, including the imported Chinese dehumidifiers sold by the companies between September 2012 and April 2013. The CPSC press release can be found here. For further information regarding importer compliance and obligations under the CPSC please see or contact Cheryl Falvey.


  • The UK Parliament – for the third (and likely final) time – rejected the Withdrawal Agreement that was negotiated over the course of 18 months between the UK Government and EU.
  • As things stand, the UK is therefore on course for a No-Deal Brexit on 12 April 2019.
  • However, per last week’s summit, the EU have said that they will consider a lengthy extension to the Article 50 withdrawal process if, in light of the continuing diminishing authority of the UK Government, the UK Parliament “indicate a way forward” before 12 April “for consideration by the European council”.
  • UK Parliament will meet again on Monday to follow-up on the “indicative” vote process which commenced on Wednesday, where it is expected that some of the more popular of the eight proposals rejected on Wednesday will come to the fore. More focused engagement with the indicative votes process is expected on Monday, given it is likely the UK Government’s Withdrawal Agreement, following today’s rejection, has now been taken off the table for good. Some UK Members of Parliament had abstained from Wednesday’s votes as they waited to see if the Withdrawal Agreement would pass today.
  • Political commentary at this stage would suggest the most popular proposal is the Customs Union option, which would entail a commitment to negotiate a “permanent and comprehensive UK-wide customs union with the EU” in any Brexit deal. However, other options, including the holding of a second referendum or outright revocation of Article 50, cannot be ruled out at this juncture. And, as noted, No-Deal remains the default course of action should Parliament fail to decisively legislate to remove this option.
  • Confusing matters further, there is increasing clamour for a UK General Election to be called to break the Brexit deadlock. This too cannot be ruled out, particularly if no Parliamentary consensus is formed over the course of the ‘indicative votes’ process on Monday.






In Ruling NY N303063, Customs and Border Protection (CBP) reviewed the classification of OREO Cookies & Cream Candy Bar. Ingredients include palm oil, cocoa butter, sweet whey powder, wheat flour, skim milk powder, anhydrous milk fat, palm oil, cocoa, glucose-fructose syrup, wheat starch, soy lecithin, sodium chloride, potassium hydrogen carbonate, ammonium hydrogen carbonate, vanillin, sunflower lecithin. It is available in a king-size variety, with two bars packaged in plastic film with a net weight of 2.88 oz. (82g). It is also available in standard size with a net weight of 1.44 oz. (41g).

CBP ruled that the applicable subheading for the item in question is 1806.31.0049 HTSUS, which provides for Chocolate and other food preparations containing cocoa: Other, in blocks, slabs or bars: Filled: Other. The rate of duty is 5.6% ad valorem.

This HTSUS code is subject to The Public Health Security and Bioterrorism Preparedness and Response Act of 2002 (The Bioterrorism Act) which is regulated by the Food and Drug Administration (FDA).


  • Yesterday, March 27, 2019, saw more major developments within UK Parliament as the UK continues to struggle to formulate a Brexit strategy ahead of the default No-Deal Brexit date of 11 April 2019.

  • Prior to the 8 sets of “indicative” votes that took place March 27, 2019 evening, which were designed to indicate what strategy Members of Parliament would be willing to pursue in order to break the Brexit deadlock, the UK Prime Minister made one final push to get the Withdrawal Agreement her Government negotiated with the EU approved, by announcing to colleagues that she was willing to step down if they voted for her twice-rejected Withdrawal Agreement.

  • The UK Government has subsequently announced today that a vote on the Withdrawal Agreement will indeed take place tomorrow.  It is unclear at this stage whether this announcement will increase the likelihood of her deal being voted through: although some MPs have now said they will switch their vote and approve the Withdrawal Agreement, the Democratic Unionist Party – the Northern Irish party whose members back continued unity with Britain, and whose votes have been key to the UK Government’s ability to pass legislation – have said its 10 MPs will again reject it.

  • On March 27, 2019, UK Parliament rejected eight different proposals on Britain’s withdrawal from the EU.  The proposals can be broadly split into three categories:
  1. Hard Brexit – represented by proposals on No-Deal and a standstill trade deal negotiation.  These were the two least voted-for options.
  2. Soft Brexit – represented by a customs union proposal and two single market models.  The customs union proposal, which requires a commitment to negotiate a “permanent and comprehensive UK-wide customs union with the EU” in any Brexit deal, came closest to securing a Parliamentary majority of any of the eight options.
  3. No Brexit – represented by proposals for a Second Referendum and outright revocation of Article 50, the formal mechanism for the UK’s withdrawal from the EU.  The proposal for a Second Referendum got the most votes of approval of any of the eight options.

Graphic from

  • As regards next steps, on the assumption that the Withdrawal Agreement is again rejected tomorrow, March 29, 2019, UK Parliament will meet again on Monday to follow-up on the “indicative” vote process, where it is expected that some of the more popular of the rejected proposals – including the second referendum option – will again be put forward for another vote.  More focused engagement with the process would be expected, as the UK Government’s Withdrawal Agreement would, by this point, have been taken off the table for good.



  • To date, no substantial progress has been made as to the method and timing of Brexit. All options remain open until 12 April 2019; a softer Brexit, No-Deal Brexit, or no Brexit at all.


Over the last week, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has issued two updated advisories, as well as issued a series of new designations of Specially Designated Nationals (SDNs), highlighting the sanctions-related risks for, and the focus on, the shipping community. Taken together, they provide important guidance for members of the shipping industry—including shipping companies, ship owners, insurance companies, and financial institutions with shipping practices, port operators, and others in the sector—on the scope of OFAC’s prohibitions, red flags for sanctions risks, as well as the types of compliance practices that OFAC expects. We summarize the key takeaways below.

Photo by kinsey on Unsplash;

Advisory One: Updated Guidance on North Korea’s Illicit Shipping Practices

First, on March 21, 2019, OFAC issued an update to its February 23, 2018 North Korea Sanctions Advisory (2018 DPRK Advisory) designed to provide guidance on North Korea’s illicit shipping practices. In particular, OFAC updated the following elements of its guidance:

  • Provided Figures on Illicit Activity: OFAC provided specific figures to identify the scope of the concern regarding North Korean illicit shipping. This included 263 tanker deliveries of refined petroleum in 2018 from UN prohibited ship-to-ship transfers, the resumption of North Korean coal exports in the gulf of Tonkin, specific examples of physical alteration of vessels, and specific identification of illicit shipment locations.
  • Provided Specific Guidance to Maritime Insurance Companies: As part of Annex III, OFAC provided specific guidance to maritime insurance companies to: (1) research the Automatic Identification System (AIS) history of vessels that transport oil and operate in the East China Sea to determine if there is a pattern of AIS disablement or manipulation prior to extending coverage or at presentment of a claim; (2) consider inserting contractual language that states disabling or manipulating the AIS is an indication of potentially prohibited activity and could lead to revocation of services if illicit activity is discovered; and (3) that protection and indemnity (P&I) insurance and reinsurance companies should include an “AIS switch-off clause” for at risk vessels operating in relevant regions.
  • Additional Detail on Ship-To-Ship Transfer Risks: OFAC provided a series of additional data points on the ship-to-ship transfer risk: (1) North Korea expanded its fleet of vessels capable of engaging in ship-to-ship transfers from 24 to 28 capable of transporting refined petroleum products (identified in Annex II of the March 21 update) and 33 capable of transporting coal; (2) OFAC further updated its regional map to identify three additional areas in which such transfers had occurred; (3) OFAC provided a new diagram showing the ports visited before and after ship-to-ship transfers of refined petroleum, identifying major ports in China, Taiwan, South Korea, and Russia.
  • Added Several Recommended Risk Mitigation Steps: In addition to the risk mitigation steps already included in the 2018 DPRK Advisory—which included monitoring for AIS manipulation, conducting research prior to ship-to-ship transfers, reviewing all available shipping documentation, clearly communicating sanctions obligations to international partners, and leveraging all available diligence resources—OFAC added three additional recommended mitigation steps. (1) It recommended that all parties should research a ship’s history to identify regular AIS manipulation, particularly for any parties engaged in refined petroleum or coal trade in the region. (2) OFAC recommended that all parties in the shipping industry, including port operators and shipping associations, should remind oil tankers and coal vessels to maintain AIS broadcasts. (3) Finally, OFAC recommended any companies involved in the petroleum trade should conduct end-use checks to verify that all recipients are not providing oil to North Korea.
  • Identified Additional Vessels Engaged in Deceptive Activity: OFAC expanded its previous annexes in the March 21 update identifying high-risk vessels. First, it added four vessels to Annex II listing North Korean vessels capable of engaging in ship-to-ship transfers of petroleum. Second, it newly identified 18 vessels from six flag jurisdictions (Panama, Republic of Korea, Russia, Sierra Leone, Singapore, and Togo) believed to have engaged in ship-to-ship transfers with North Korean tankers in Annex IV. Finally, in Annex V, OFAC provided a new list of 49 vessels believed to have engaged in the export of North Korean origin coal since 2017.

Advisory Two: Updated Guidance on Risks Related to Petroleum Shipments Involving Iran and Syria

Second, on March 25, 2019, OFAC issued an update to its November 2018 guidance to the maritime petroleum shipping industry to highlight risks associated with petroleum shipments to Syria. In particular, OFAC updated the following elements of its guidance:

  • Added a Deceptive Shipping Practice: OFAC added “Vessel Name Changes” to its list of deceptive shipping practices, noting that it was therefore “essential to research a vessel not only by name but also by its [IMO] number.” This supplements the previous listing of (a) falsifying cargo and vessel documents, (b) ship to ship transfers, and (c) disabling the AIS.
  • Added and Expanded Risk Mitigation Measures: OFAC modified this in three ways. (1) It added the recommended action to “Know Your Customer” (KYC) to its previous list of risk mitigation measures. While KYC is a required element of anti-money laundering (AML) programs for regulated financial institutions, OFAC is expanding this recommendation to all members of the shipping community. Specifically, it recommends that the KYC due diligence include (a) researching companies and individuals in the transactions, (b) vessel owners and operators involved in any contracts or shipments, (c) country-of-origin and destination of goods involved in any underlying shipments, and (d) research on the vessel history by IMO number. (2) OFAC continued the theme of bringing AML concepts into the sanctions space by expanding its previous recommendation to strengthen AML and counter the financing of terrorism (AML/CFT) compliance by adding a recommendation to (a) adopt appropriate due diligence policies and procedures even for “non-financial gatekeepers” and (b) to promote “beneficial ownership transparency for legal entities.” (3) OFAC specifically added a note that there is sanctions risk for underwriting, insurance, or re-insurance for “certain Syrian and Iranian maritime-related persons or activities.”
  • Additional Vessel Listings: Finally, OFAC updated its annexes in several ways in the March 25 update. First, OFAC added 16 vessels to its listing of vessels that delivered oil to Syria between 2016 and 2018 in Annex I. Second, OFAC added a new list of 33 vessels that had engaged in ship-to-ship transfers of petroleum destined for Syria between 2016 and 2019 in Annex II. Finally, OFAC added a new list of two vessels that had had engaged in shipment of petroleum from Syria from 2016 to 2019 in Annex III.

Key Takeaways

Taken together, the two advisories provide a wealth of guidance to the shipping industry. In particular:

  • Current Enforcement Focus: The shipping industry is a primary enforcement focus for OFAC as it seeks to cut off illicit trade with both Syria and North Korea. With two advisories in a week and several recent designations for the same type of activity (e.g.¸ OFAC coupled its North Korea shipping advisory with the designation of two additional Chinese freight forwarding companies for allegedly engaging in deceptive activity in furtherance of North Korea trade), OFAC’s enforcement attention is focused on all of the actors across the shipping industry. In that context, the advisories serve as a double-edged sword. While they provide useful guidance to identify risks, OFAC will now consider industry to be on notice and failure to take the recommended steps is likely to be seen as an aggravating factor in any potential enforcement action.
  • Focus on Non-Banking Industries: In contrast to its typical advisories that focus on financial flows, these two advisories focus particular attention on non-banking actors, reminding the industry that actors in any sector can face sanctions-related risks. Of particular note was the focus in both advisories on the insurance industry, specifically calling out due diligence steps that insurers should be taking to mitigate such risks.
  • Continued Integration of AML and Sanctions Programs: In both advisories, OFAC imports concepts traditionally associated with the AML obligations required of financial isntitutions (e.g., KYC efforts, beneficial ownership research, etc.) as recommended best practices to mitigate sanctions-related risks. This builds on December 2018 remarks in which Treasury Undersecretary, Sigal Mandelkar identified detailed elements that Treasury expects to see in OFAC compliance programs for all companies – such as regular risk assessments, internal controls, periodic, independent testing, and training – which are highly similar to the AML program obligations of financial institutions.
  • Expanded Guidance Efforts: Finally, the updated advisories continue a welcome recent trend of increased guidance from OFAC. Not only has OFAC issued other advisories (e.g., on risks surrounding corruption in the Venezuelan gold sector), but it has also begun adding substantially more detail to its enforcement actions regarding the mitigating or remedial measures that it valued in its consideration.



  • Following negotiations that went well into the night, the EU took control of the Brexit endgame, turning down the UK Prime Minister’s plea to postpone Brexit from 29 March to 30 June, and instead drawing up a “flextension” plan that officially delays Brexit to 12 April 2019 at the earliest.
  • Under the terms of the plan, which was devised by the EU’s 27 heads of state and government and accepted by the UK Prime Minister, the twice-rejected “Withdrawal Agreement” that the UK Government negotiated with the EU will be brought back to the UK Parliament for a vote next week.
  • If the UK Parliament approves the deal, the UK will exit on 22 May 2019, the day before European Parliamentary elections are scheduled to take place.
  • If the UK Parliament rejects the deal – as is expected – the new No-Deal Brexit date of 12 April 2019 will be triggered. However, the UK Government will be able to seek a longer extension from the EU at any point up to 12 April 2019 if it can (i) “indicate a way forward” (which would likely entail UK Parliament wresting control of Brexit proceedings from the UK Government and building some form of UK Parliamentary cross-party consensus for a softer Brexit); and (ii) agree to take part in the European Parliamentary elections on 23 May 2019.
  • In practice, this means that even if the Withdrawal Agreement is rejected once and for all next week by UK Parliament, all options will remain open until 12 April 2019; a softer Brexit, No-Deal Brexit, or no Brexit at all.


  • On 20 March, the UK Prime Minister formally wrote to Donald Tusk, the President of the European Council, requesting that Brexit should be delayed until 30 June 2019 – three months later than the long-envisaged exit date next Friday, 29 March 2019.

    Photo by Robert Tudor on Unsplash;
  • The UK Government’s request will be discussed on 21 March by the EU’s 27 heads of state and government at the European Council summit in Brussels.
  • It is unlikely the EU will unanimously approve the UK’s request, as this would necessitate the UK taking part in European Parliamentary elections on 23 May 2019.
  • The EU’s constitutional lawyers have advised that the UK remaining as a member state without UK Members of European Parliament having been elected could leave the EU’s institutions in paralysis. Guy Verhofstadt, the European Parliament’s Brexit coordinator, has emphatically stated that “it is absolutely not in the interests of the European union for [Brexit] to occur beyond the date of the European elections”.
  • Therefore, it is likely that any extension granted by the EU (a) sets a new Brexit date of no later than 22 May 2019; and (b) is made conditional on the UK Government getting UK Parliamentary approval – at the third time of asking – of the Brexit “Withdrawal Agreement” that the UK Government negotiated with the EU.
  • If the UK Government fails to get approval for the Withdrawal Agreement, senior EU figures have suggested it is likely an emergency EU summit will be convened next week (potentially hours before the 29 March deadline) and the EU may offer either a long extension (potentially to the end of 2019) or a No-Deal Brexit.
  • Simultaneously, UK Parliament will again look to seize control of Brexit proceedings from the UK Government as the window to change the UK’s path forward before what is still the default course of action – No-Deal Brexit on 29 March 2019 – can take effect.

In NY N302853, Customs and Border Protection (CBP) discussed the classification of a product called the “Moby Dick Bath Time Essentials Kit,” which included four items: a kneeler, elbow rest, rinser and spout cover. All of these items are packaged together in a box marketed for retail sale.

  • The kneeler is made of a textile neoprene cover with a foam insert that is cut and sewn in the shape of a whale. The kneeler is used to support parents’ knees during children’s bath time.


  • The elbow rest is made of a textile neoprene fabric cover with a foam insert that is cut and sewn to resemble waves. There is a woven strap sewn on one side and additional foam padding on the top surface area. The elbow rest is placed on the edge of the bath tub to rest elbows and forearms when leaning on the edge of the bath tub during bath time.


  • The rinser is made of molded plastic in the shape of a whale. The “tail” of the whale is shaped into a handle and the “head” is open so that water can be held and poured to rinse children off before getting out of the bath tub.


  • The spout cover is made of molded plastic in the shape of a whale. The “tail,” front and top of the whales “head” all have openings to permit the spout to fit over the faucet and allow the water to flow, and still be able to access the controls of the faucet.

Explanatory Note (EN) X to General Rule of Interpretation (GRI) 3(b) provides: “for the purposes of this Rule, the term ‘goods put up in sets for retail sale’ shall be taken to mean goods which:

(a) consist of at least two different articles which are, prima facie, classifiable in different headings;

(b) consist of products or articles put up together to meet a particular need or carry out a specific activity; and

(c) are put up in a manner suitable for sale directly to end users without repacking (e.g., in boxes or cases or on boards).”

CBP determined that the “Moby Dick Bath Time Essentials Kit” fulfills the requirements listed above. In determining the essential character various factors may be used to determine the component which imparts the essential character to the set. There are two plastic products classified in heading 3926, HTSUS (other articles of plastics) and two textile neoprene products classified in heading 6307, HTSUS (other made up articles of textile). GRI 3(b) states:

“Mixtures, composite goods consisting of different materials or made up of different components, and goods put up in sets for retail sale, which cannot be classified by reference to 3(a), shall be classified as if they consisted of the material or component which gives them their essential character”

In this case, CBP found that the essential character of the overall product could not clearly be attributed to either material. GRI 3(c) states:

When goods cannot be classified by reference to 3(a) or 3(b), they shall be classified under the heading which occurs last in numerical order among those which equally merit consideration”. Heading 6307, HTSUS appears last in the tariff.


CBP determined that the applicable subheading for the “Moby Bath Time Essentials Kit”, will be classified in subheading 6307.90.9889, HTSUS, which provides for other made up textile articles, other. The rate of duty will be 7% ad valorem.

Speaker of the House invokes Parliamentary Protocol from 1604


  • Monday, March 18, 2019, saw the Prime Minister blocked from putting forward the Brexit “Withdrawal Agreement” that the UK Government negotiated with the EU to a third Parliamentary vote. John Bercow, the Speaker of the House of Commons, who in accordance with longstanding UK Parliamentary protocol, decides on whether to allow any vote, told the UK Government that it cannot bring the deal back for a third vote unless substantial changes are made to it.  In making this announcement, he invoked Parliamentary protocol dating back to 1604, which added a constitutional issue to the Brexit proceedings.

    Photo by Dunphasizer on Flickr

  • This latest development puts even more onus on Thursday’s EU Summit in Brussels.  The EU, which per comments from a number of foreign ministers of member states, is displeased with this event. It is expected to formally agree on a new delayed Brexit date on Thursday, March 21, 2019.  It is widely believed that, if EU officials issue a summit communique with legal force (known as “council conclusions”) containing this new Brexit date, this will suffice as a “substantial” change for the Speaker, thereby allowing the Prime Minister to bring the Withdrawal Agreement back to a third vote.


  • It is still unclear whether EU leaders will push for a three-month or nine-month extension to the Article 50 withdrawal process, although political commentary would suggest that the latter remains more likely as this is the preferred option as expressed by senior EU figures.


  • Monday’s developments served to further cloud the Brexit horizon; simultaneously raising new fears of a No-Deal Brexit in 10 days’ time and breathing new life into the Second Referendum campaign.