On December 5, 2022, the U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”) announced a $60 per barrel price cap on maritime transfers of Russian-origin crude oil. The final cap level is being implemented...more
On December 2, 2020, U.S. Customs and Border Protection (CBP) issued an import detention or Withhold Release Order (WRO) against cotton produced by Xinjiang Production and Construction Corps (XPCC) based on information that...more
Continuing its “maximum pressure” campaign against Iran, the United States has (a) ratcheted up sanctions under Executive Orders that provide for the imposition of secondary sanctions on non-U.S. companies that engage in...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
On January 12, 2018, President Trump issued a statement on the status of the Joint Comprehensive Plan of Action (“Iran nuclear deal”) and the Office of Foreign Assets Control designated 14 individuals and entities in...more
On December 20, 2017, President Trump issued Executive Order 13818 (the “E.O.”) implementing provisions of the Global Magnitsky Human Rights Accountability Act (“Global Magnitsky Act”) (enacted into law in December 2016),...more
Following President Trump’s trip to Asia, sanctions policies for North Korea continue to evolve. The U.S. government has strengthened sanctions through legislation and Presidential Executive Orders. Further, it is enforcing...more