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,
Canadian Aluminum to Again Face 10% Tariff
On August 6 the Trump Administration announced that it would reimpose the 10% aluminum tariff on imports of Canadian “non-alloy unwrought aluminum” classified under HTS subheading 7601.10. The move has not garnered widespread support from industry or the US Chamber of Commerce, who called it “a step in the wrong direction.” The Administration’s proclamation claims
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
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
Section 301 (China) Product Exclusions Update: Customs Guidance for U.S. Importers
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
Bloomberg Law Features Nevena Simidjiyska’s Piece on CFIUS Grindr Determination
A Chinese company was recently forced to sell California-based Grindr, the world’s largest gay dating app, after the Committee on Foreign Investment in the United States (CFIUS) determined that its ownership constituted a national security risk.
To explain the issue to readers, Bloomberg Law featured an article by Partner Nevena Simidjiyska, co-chair of the