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
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
CIT Leaves No Doubt that Ban on Certain Mexican Fish is Effective Immediately
In a recent opinion, the United States Court of International Trade (CIT) upheld its categorical ban of the importation of fish and fish products caught with gillnets in the habitat of the critically endangered vaquita, off the coast of Mexico.
In a July 26, 2018 Order, the CIT granted a preliminary injunction sought by
CBP Holds That Roasting Changes Coffee’s Country of Origin
In a recently issued Final Determination, U.S. Customs and Border Protection (CBP) confirmed that the roasting of coffee beans substantially transforms the beans into a product of the country in which the beans were roasted.
Coffee producer Keurig Green Mountain (“Keurig”) requested the determination as to the country of origin assignment to green coffee