On April 28, 2020, the U.S. Commerce Department’s Bureau of Industry and Security (BIS) published two final rules that will eliminate the license exception for civil end users (CIV) in the People’s Republic of China, Russia,...more
On April 19, 2020, the Treasury Department in conjunction with Customs and Border Protection (CBP) released a temporary interim final rule (“Rule”) to provide importers that meet the qualifying criteria with the option of a...more
The COVID-19 pandemic and the resulting economic turmoil have the potential to shake up the U.S. real estate market due to an anticipated influx of real estate investors looking to purchase heavily discounted, distressed...more
TAKEAWAYS - Establishes deadlines for Committee to respond to FCC referrals - Invites Committee review of existing license holders - Resolution of long pending FCC proposed rulemaking expected - On April 4, 2020, the White...more
On April 7, 2020, the Federal Emergency Management Agency (FEMA) released for public inspection a temporary rule that prohibits the export of five types of personal protective equipment (PPE) without explicit approval by...more
TAKEAWAYS -
A transfer of control of a borrower or its business to non-U.S. lenders who exercise remedies under financing documents could trigger CFIUS issues.
CFIUS regulations adopted in February 2020 dramatically...more
On Friday, March 20, 2020, in an effort to fight against the coronavirus pandemic, the U.S. Trade Representative (USTR) announced that it is accepting exclusions requests to remove tariffs imposed on Chinese origin...more
On March 6, 2020, President Trump issued an Executive Order (“EO”) instructing the Chinese company Beijing Shiji Information Technology Co., Ltd. (“Shiji”) to divest its acquisition of StayNTouch, Inc., a U.S.-based software...more
On March 5, 2020, the U.S. Department of the Treasury issued a proposed rule establishing filing fees for parties submitting a voluntary notice to the Committee on Foreign Investment in the United States (CFIUS) for “covered...more
On January 10, 2020, the United States imposed additional sanctions on Iran in the wake of recent tensions between the countries and the continuing broader ‘maximum pressure’ campaign on Iran. ...more
On December 26, 2019, the Department of State published in the Federal Register an interim final rule amending the International Traffic in Arms Regulations (ITAR) to define “activities that are not exports, reexports,...more
On January 13, 2020, the U.S. Department of the Treasury issued two final rules for the Committee on Foreign Investment in the United States (CFIUS) implementing the Foreign Investment Risk Review Modernization Act (FIRRMA),...more
On December 31, 2019, the U.S. District Court for the Northern District of Texas overturned a $2 million fine imposed by the Department of the Treasury’s Office of Foreign Assets Control (OFAC) against ExxonMobil Corp., and...more
Companies anxiously awaiting the release of “emerging technology” export control rules now have an initial interim rule indicating how the Department of Commerce Bureau of Industry and Security (BIS) is likely to proceed....more
On November 27, 2019, the US Commerce Department published a proposed rule implementing regulations following President Trump’s May 15, 2019 Executive Order 13783 (E.O.) on Securing the Information and Communications...more
On September 17, 2019, the U.S. Department of Treasury issued two new proposed rules for the Committee on Foreign Investment in the United States (CFIUS) implementing the Foreign Investment Risk Review Modernization Act...more
Criminal investigations will target businesses profiting from the importation into the United States of goods made using forced labor.
The new criminal enforcement initiative seeks to leverage data about corporate supply...more
8/6/2019
/ Compliance ,
Corporate Counsel ,
Criminal Prosecution ,
Customer Due Diligence (CDD) ,
Customs and Border Protection ,
Department of Homeland Security (DHS) ,
Department of Justice (DOJ) ,
Forced Labor ,
Imports ,
NGOs ,
Strategic Enforcement Plan ,
Supply Chain ,
Tariff Act of 1930 ,
Trafficking Victims Protection Act of 2000
On September 1, a new round of Section 301 duties will be imposed on “List 4” products. President Trump previously announced plans for these duties, but had delayed implementation in June citing progress on the negotiations...more
Recent comments from Bureau of Industry (“BIS”) officials at the BIS Update indicate the U.S. Government is progressing towards more detailed proposed rules with respect to both “emerging” and “foundational” technologies that...more
Third-party petitions seeking to ban the importation of goods made with forced labor may affect global supply chains.
Petitions are being filed with U.S. Custom and Border Protection seeking to ban the importation into the...more
7/26/2019
/ CAATSA ,
Corporate Governance ,
Corporate Liability ,
Corporate Social Responsibility ,
Customs and Border Protection ,
Due Diligence ,
Economic Sanctions ,
Forced Labor ,
Human Trafficking ,
Imports ,
Modern Slavery Act ,
North Korea ,
Office of Foreign Assets Control (OFAC) ,
Risk Management ,
Supply Chain ,
Third-Party ,
Trade Facilitation and Trade Enforcement Act
As trade relations with China continue to evolve, Huawei Technologies Co., Ltd. (“Huawei”) and its foreign affiliates remain subject to broad U.S. export license requirements. ...more
On June 5, 2019, the Department of Commerce Bureau of Industry and Security (BIS) amended an important license exception which generally permitted the temporary sojourn of civil aircraft and vessels to Cuba. ...more
On May 21, the Office of the United States Trade Representative (USTR) established a process through which U.S. stakeholders may exclude products included in List 3 from a 25% tariff imposed pursuant to the investigation of...more
On May 16, 2019, the Bureau of Industry and Security (BIS) of the U.S. Department of Commerce added Huawei Technologies Co., Ltd. (Huawei) and sixty-eight of its non-U.S. affiliates to the Entity List, thereby prohibiting the...more
Further to our prior blog post, on May 13, 2019, at the direction of President Trump, the Office of U.S. Trade Representative (“USTR”) published a proposed tariff list covering approximately $300 billion worth of Chinese...more