On August 12, CBP confirmed that the recent revocation of Hong Kong’s “special status” and updated China marking requirements would not render goods of Hong Kong origin subject to the additional Section 301 tariffs imposed on most goods of Chinese origin. CBP stated that “the change in marking requirements does not affect country of origin
US Revokes Hong Kong’s “Special Status” – UPDATED 8/24
UPDATE: CBP has extended the compliance period for origin marking for an additional 45 days. In an effort to allow importers ample time to comply with EO requirements for goods produced in Hong Kong to be appropriately marked with the origin of “China”, CBP is extending the transition period through November 9, 2020. Accoringly,
USMCA Certificates of Origin – What you need to know.
The fact that the US-Mexico-Canada Agreement (“USMCA”), which replaced NAFTA on July 1, does not require any particular form Certificate of Origin (“COO”) has left many importers and exporters confused on the proper manner of certifying goods as “originating” under USMCA. The new trade agreement dispensed with the formality of the Form 434 COO under
Apple’s Lesson: Screening Software Alone Won’t Prevent Export Violations
Apple Inc.’s recent settlement with the Treasury Department’s Office of Foreign Assets Control (OFAC) has exposed a potentially costly wrinkle in complying with international trade regulations. While sanctions screening technologies may help a company catch and report errors, this software alone will not absolve faults and shortcomings in a company’s overall export compliance programs.
The
Certain Transactions with the Government of Venezuela are Authorized
On November 5, 2019 the Office of Foreign Assets Control (OFAC) issued two General Licenses (GLs) authorizing specific transactions involving the Government of Venezuela and categories of persons blocked by Executive Order 13884 (E.O. 13884).
E.O. 13884 was signed by President Donald Trump earlier this year on August 5, 2019. E.O 13884 was intended to
USMCA…maybe next year?
Now that Canadian PM Justin Trudeau has dissolved Parliament and called for a general election (to be held October 21), chances of seeing the USMCA ratified by all three member states this year has become an increasingly remote possibility. However, the good news for USMCA supporters is that NAFTA’s replacement continues to enjoy support in
US/China Trade War Escalates
On Friday, August 23, the Trump Administration announced an increase in Section 301 tariffs following China’s announcement of retaliatory tariffs targeting $75 billion of US goods. The announcement, which came by way of tweet, provided that Section 301 tariffs on all List 1 through 3 goods would be elevated from 25% to 30% effective October
Will USMCA become a casualty of the US election?
Though the USMCA has been ratified by Mexico, the trade agreement still faces a vote in Canada and, perhaps more concerning, the US. Under the Trade Promotion Authority (“TPA”), both houses of US Congress must vote in favor of the implementing bill, which is expected to be submitted to Congress after September 1. Submission of
USTR Announces Delays to Portions of Section 301 List 4
On August 13, the Trump Administration announced the “next steps” in implementation of the approximately $300 billion in additional tariffs set to go into effect September 1. This fourth round of Section 301 tariffs (known as “List 4”) was originally announced on May 17; however, the USTR has now modified and separated that list into
Recent CFIUS Enforcement Hints at Its Priority Industries and Concerns
The Committee on Foreign Investment in the United States (CFIUS)* recently cleared several investments and acquisitions involving foreign actors, giving businesses a small glimpse into which investment characteristics the interagency committee may be favoring in its clearance process.
With last year’s passage of the Foreign Investment Risk Review Modernization Act (FIRRMA), the scope of CFIUS’s