Welcome to the July 2025 issue of “As the (Customs and Trade) World Turns,” our monthly newsletter where we compile essential updates from the customs and trade world over the past month. We bring you the most recent and...more
7/15/2025
/ Compliance ,
Cuba ,
Customs and Border Protection ,
Economic Sanctions ,
False Claims Act (FCA) ,
Imports ,
International Emergency Economic Powers Act (IEEPA) ,
International Trade ,
National Security ,
SCOTUS ,
Section 232 ,
Syria ,
Tariffs ,
Trade Agreements ,
Trump Administration ,
US Trade Policies
Welcome to the June 2025 issue of “As the (Customs and Trade) World Turns,” our monthly newsletter where we compile essential updates from the customs and trade world over the past month. We bring you the most recent and...more
On May 23, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Syria General License (GL) 25, “Authorizing Transactions Prohibited by the Syrian Sanctions Regulations or Involving Certain...more
6/3/2025
/ Corporate Counsel ,
Economic Sanctions ,
Executive Orders ,
Export Controls ,
International Trade ,
Office of Foreign Assets Control (OFAC) ,
Publicly-Traded Companies ,
Regulatory Requirements ,
Reporting Requirements ,
Syria ,
U.S. Treasury
Welcome to the April 2025 issue of “As the (Customs and Trade) World Turns,” our monthly newsletter where we compile essential updates from the customs and trade world over the past month. We bring you the most recent and...more
4/11/2025
/ Bureau of Industry and Security (BIS) ,
China ,
Country of Origin ,
Customs and Border Protection ,
Economic Sanctions ,
Enforcement Actions ,
Executive Orders ,
Export Controls ,
False Claims Act (FCA) ,
Forced Labor ,
Harmonized Tariff Schedule of the United States (HTSUS) ,
Imports ,
International Emergency Economic Powers Act (IEEPA) ,
International Trade ,
Supply Chain ,
Tariffs ,
Trade Wars ,
Trump Administration ,
United States-Mexico-Canada Agreement (USMCA) ,
US Trade Policies
Welcome to the January 2025 issue of “As the (Customs and Trade) World Turns,” our monthly newsletter where we compile essential updates from the customs and trade world over the past month. We bring you the most recent and...more
1/17/2025
/ CAFC ,
CFIUS ,
Compliance ,
Customs and Border Protection ,
Forced Labor ,
Harmonized Tariff Schedule of the United States (HTSUS) ,
Imports ,
International Trade Commission (ITC) ,
NGOs ,
Notice of Proposed Rulemaking (NOPR) ,
Office of Foreign Assets Control (OFAC) ,
Oral Argument ,
Popular ,
Section 301 ,
Tariffs ,
USTR ,
Uyghur Forced Labor Prevention Act (UFLPA)
The US government signals careful optimism with a new general license authorizing some previously prohibited transactions, including many (but not all) transactions with Syrian governing institutions, for the next six months....more
1/13/2025
/ Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
Export Administration Regulations (EAR) ,
Export Controls ,
Foreign Policy ,
General Licenses ,
Global Terrorism Sanctions Regulations (GTSR) ,
Office of Foreign Assets Control (OFAC) ,
Prohibited Transactions ,
Sanctions ,
SDN List ,
Syria ,
U.S. Treasury
Three US agencies – the US Department of Commerce, Bureau of Industry and Security (BIS), the US Department of the Treasury, Office of Foreign Assets Control (OFAC), and the US Department of State – took new actions on June...more
6/17/2024
/ Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
Export Administration Regulations (EAR) ,
Export Controls ,
Harmonization Rules ,
Infrastructure ,
Licenses ,
Licensing Rules ,
Mobile Devices ,
Office of Foreign Assets Control (OFAC) ,
Personal Information ,
Popular ,
Russia ,
Savings Clause ,
SDN List ,
Software ,
US State Departments
On May 8, 2022 (aka Mother’s Day), the Biden Administration announced yet another series of export controls and sanctions measures intended to ratchet up the costs on Russia’s economy and limit its ability to continue its war...more
5/11/2022
/ Accounting ,
Belarus ,
Blocking Sanctions ,
Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
Executive Orders ,
Foreign Policy ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Trusts ,
U.S. Treasury ,
Ukraine
On Wednesday, April 6, 2022, the U.S. Government, in concert with the G7 and European Union, took significant additional sanctions actions against Russia “to impose severe and immediate economic costs on the Putin regime for...more
4/8/2022
/ Banking Sector ,
Biden Administration ,
Blocking Sanctions ,
Economic Sanctions ,
Energy Sector ,
EU ,
Executive Orders ,
G7 ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Ukraine
Watch Out, More Things Are Luxury Than You Think!
On March 11, 2022, the President issued Executive Order 14068 (EO 14068) Prohibiting Certain Imports, Exports, and New Investment with Respect to Continued Russian...more
3/15/2022
/ Belarus ,
Economic Sanctions ,
Energy Sector ,
EU ,
Executive Orders ,
Export Administration Regulations (EAR) ,
Exports ,
Imports ,
Most-Favored Nations ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
Trade Restrictions ,
U.S. Treasury ,
Ukraine
ArentFox Schiff sanctions advisors Kay Georgi and Matthew Tuchband talk with WorldSmart co-hosts Hunter Carter and Malcolm McNeil about greatly expanded export controls, blocking sanctions, and banking sanctions in response...more
In a coordinated effort, on March 2, 2022, the White House announced another round of broad trade controls and sanctions against Russia and now Belarus in response to Russia’s military invasion of Ukraine.
The White House...more
3/7/2022
/ Belarus ,
Bureau of Industry and Security (BIS) ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Export Controls ,
Foreign Direct Product Rule ,
Licenses ,
Military End Use ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
U.S. Commerce Department ,
Ukraine
On February 25 and 28, 2022, the US Treasury Department, Office of Foreign Assets Control (OFAC) issued its fifth and sixth actions against Russia, blocking the assets of President Vladimir Putin and three other high-ranking...more
What Are the New US Export Controls on Russia?
On February 24, 2022, the US Department of Commerce, Bureau of Industry and Security (BIS) imposed new export controls intended to restrict access to technologies and other...more
2/28/2022
/ Belarus ,
Bureau of Industry and Security (BIS) ,
ECCNs ,
Economic Sanctions ,
EU ,
Export Administration Regulations (EAR) ,
Export Controls ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Ukraine
Responding to the Russian announcement recognizing the independence of the so-called Donetsk People’s Republic (DNR) and Luhansk People’s Republic (LNR) regions of Ukraine, President Biden signed Executive Order 14065 (the...more
Agency Designates Virtual Currency Exchange and Leaves Insurance Questions Unanswered -
On September 2, 2021, OFAC published an update to their October 2020 Ransomware Advisory. We reported on the original Ransomware...more
In his last days, President Trump takes a swipe against companies identified by the Department of Defense (DoD) as Communist Chinese military companies by prohibiting US persons from investments.
On November 12, 2020,...more
11/18/2020
/ China ,
Department of Defense (DOD) ,
Executive Orders ,
Export Administration Regulations (EAR) ,
Foreign Investment ,
Information and Communication Technology (ICT) ,
International Emergency Economic Powers Act (IEEPA) ,
National Security ,
PCAOB ,
Proposed Rules ,
Securities and Exchange Commission (SEC) ,
Trump Administration ,
U.S. Treasury
The US Government has taken action recently to step up enforcement against forced labor.
As particular regions come under increased media scrutiny, the issue has renewed interest in Congress, which is considering several...more
10/26/2020
/ Child Labor ,
China ,
Customs and Border Protection ,
Department of Homeland Security (DHS) ,
Economic Sanctions ,
Forced Labor ,
International Emergency Economic Powers Act (IEEPA) ,
Securities and Exchange Commission (SEC) ,
Securities Exchange Act ,
Supply Chain ,
Tariff Act of 1930 ,
U.S. Treasury ,
US Department of State ,
Withhold Release Orders (WROs)
On October 1, 2020, the US Department of Treasury’s Office of Foreign Assets Control (OFAC) issued an Advisory highlighting sanctions risks associated with facilitating ransomware payments on behalf of victims targeted by...more
BIS will be looking at items that are controlled only for anti-terrorism, crime control, short supply, United Nations embargoes, or designated as EAR99 in establishing new Foundational Technologies Controls.
Two years...more
8/28/2020
/ Advanced Notice of Proposed Rulemaking (ANPRM) ,
Bureau of Industry and Security (BIS) ,
CFIUS ,
Embargo ,
Export Control Reform Act (ECRA) ,
Exports ,
FIRRMA ,
Interim Final Rules (IFR) ,
Military End Use ,
National Security ,
Rulemaking Process ,
United Nations
There is a risk that garments made from cotton produced by XPCC could be subject to a Customs and Border Protection withhold release orders.
Fashion and luxury goods companies need to be concerned about the recent...more
8/26/2020
/ China ,
Customs and Border Protection ,
Economic Sanctions ,
Entity List ,
Exports ,
Forced Labor ,
Imports ,
Retailers ,
Supply Chain ,
U.S. Commerce Department ,
U.S. Treasury
President Trump signed an Executive Order (EO) (TikTok EO) August 6, 2020, banning “transactions” yet to be identified by the US Department of Commerce (Commerce) related to TikTok and its parent ByteDance Ltd.
Specifically,...more
8/12/2020
/ CFIUS ,
China ,
Data Collection ,
Executive Orders ,
Foreign Policy ,
International Emergency Economic Powers Act (IEEPA) ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Social Media ,
TikTok ,
U.S. Commerce Department ,
U.S. Treasury
As the US technology competition with China continues to intensify, the Trump Administration has taken another step to tighten the screws on China.
In late June, the US Department of Defense (DoD) made public a list of 20...more
8/3/2020
/ China ,
Department of Defense (DOD) ,
Department of Justice (DOJ) ,
Due Diligence ,
Exports ,
FBI ,
Imports ,
International Emergency Economic Powers Act (IEEPA) ,
NDAA ,
Pentagon ,
Trump Administration ,
U.S. Treasury
In four new FAQs issued on June 5, OFAC provides a few surprises in its clarifications of the sector-based sanctions contained in Iran-related Executive Order 13902, which was issued this past January.
The new FAQs confirm...more
Recognizing that COVID-19 is further straining humanitarian needs in sanctioned countries and complicating compliance with economic sanctions, and perhaps also in response to reports that US sanctions are hindering COVID-19...more
4/28/2020
/ Coronavirus/COVID-19 ,
Cuba ,
Economic Sanctions ,
Executive Orders ,
FEMA ,
Humanitarian Assistance ,
Iran ,
North Korea ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Secondary Sanctions ,
Syria ,
Ukraine ,
Venezuela