It has been almost a year since the first round of Section 301 China tariffs went into effect on July 6, 2018. Since that time, the Office of the United States Trade Representative (USTR) has reviewed thousands of product exclusion requests on Lists 1 and 2. Granted product exclusions are retroactive to the date of
The USMCA: Where do we stand?
On November 30, 2018, the United States, Canada and Mexico took the first steps toward a renegotiated North American Free Trade Agreement (NAFTA)—now dubbed the United States-Mexico-Canada Agreement (USMCA). However, the USMCA still faces the hurdles of ratification by the respective governments. In the United States, that means Congressional approval in accordance with the Trade
Sanctions Compliance Directly Impacts Executives
In OFAC’s guidance document that was released last week, OFAC made it clear that it will consider using its enforcement authority against the individuals involved in a sanctions violation, not just the entities. OFAC recognized that individual employees, particularly those in supervisory, managerial or executive level positions, have played a crucial role in facilitating or
Updates to the Cuba Restricted List
On April 24, 2019, the U.S. Department of State published an update to its List of Restricted Entities and Subentities Associated with Cuba (Cuba Restricted List) adding five additional entities to the list. 
On June 16, 2017, the President signed the National Security Presidential Memorandum-5 on Strengthening the Policy of the United States Toward Cuba
Treasury Expands Sanctions for Maduro Supporters
In recent weeks, the United Stated Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) expanded the scope of sanctions against current and former Venezuelan government officials who have supported controversial President Nicholas Maduro and his regime of corruption and human rights abuses.
The first sanctions implemented against Venezuelan individuals and entities were authorized
Impact of the Government Shutdown on CFIUS
The government shutdown, which is now in its fourth week, is causing a backlog of cases that will need to be reviewed by the Committee on Foreign Investments (“CFIUS”) once the government reopens.
CFIUS is an interagency committee chaired by the Secretary of the Treasury, which reviews certain transactions involving foreign investment in the Unites
CBP Issues Update on Enforcement of Continuous Bond Amounts
This post is authored by Fox Rothschild associate Rocky Rogers:
As a result of the new Section 232 and Section 301 tariffs on steel, aluminum, and goods imported from China, United States importers and customs brokers relying upon continuous bonds should review their bond amount to ensure it is sufficient to account for these
CIT Rejects Government’s Request to Stay Ban on Mexican Seafood
In a recent decision, the Court of International Trade (CIT) denied the government’s request for a stay of the preliminary injunction that the CIT had implemented in July, banning the importation of certain seafood from Mexico.
In July, the CIT upheld its preliminary order and granted the preliminary injunction sought by conservation groups
Australia to Join the WTO Government Procurement Agreement
Australia will become the newest member of the World Trade Organization (WTO) plurilateral Government Procurement Agreement (GPA). On October 17, 2018, parties to the GPA unanimously approved a decision to welcome Australia as the 48th WTO member to be covered by the GPA.
The GPA is a plurilateral agreement that strives to ensure open, fair
Section 301 Update: USTR Imposes Tariffs on List 3 and Announces Exclusion Process
On September 17, 2018, the Trump Administration finalized tariffs on $200 billion of Chinese imports and announced the final list (List 3) of tariff line items. The additional tariffs became effective on List 3 products on September 24, 2018 in the amount of a 10 percent ad valorem duty. The level of additional tariffs is