Week Twenty in Trade

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CBP Deploys Portal for Forced Labor Allegations

On June 20, 2025, U.S. Customs and Border Protection (“CBP”) announced it is deploying the Forced Labor Allegation Portal, which allows users to submit forced labor allegations. Submissions may be made anonymously and may include Allegations may be submitted supporting documents related to their submissions.

U.S. Steel and Nippon Steel Finalize Acquisition Agreement

On June 18, 2025, Japan’s Nippon Steel announced it had completed its acquisition of Pittsburgh-based U.S. Steel. Both entities entered into a National Security Agreement (“NSA”) with the U.S. Government as part of the transaction. Some of the key terms include:

• Nippon Steel agreed to approximately $11 billion in new investments in U.S. Steel by 2028.
• Nippon Steel agreed to keep U.S. Steel incorporated in the U.S. and headquartered in Pittsburgh, Pennsylvania.
• U.S. Steel will produce and supply steel to the U.S. market from its U.S. facilities. maintain capacity to produce and supply steel from its U.S. production locations to meet market demand in the U.S.; and
• U.S. Steel’s board of directors will consist of majority U.S. citizens, and the company’s key management and officers will remain U.S. citizens as well.

OFAC Authorizes Certain Transactions Related to Sakhalin-2 Oil Project in Russia

On June 18, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Russia-related General License 55D, “Authorizing Certain Services Related to Sakhalin.” With certain exceptions, the General License authorized transactions relating to the Sakhalin-2 project oil and gas project through December 19, 2025, including certain transactions involving import of the Sakhalin-2 byproduct into Japan and Sakhalin-2-related transactions involving Gazprombank Joint Stock Company.

Week Twenty Sanctions Designations

OFAC also added several persons and entities to its Specially Designated Nationals and Blocked Persons List (“SDN List”) during Week Fifteen of President Trump’s return to office:

• On June 18, OFAC designated five Mexico-based leaders of Cartel de Jalisco Nueva Generacion (“CJNG”) (see OFAC press release here).

• On June 20, OFAC designated one individual and eight entities, and identified one vessel as blocked property, for their involvement in the procurement and transshipment of sensitive machinery for Iran’s defense industry (see OFAC press release here).

• On June 20, OFAC designated four individuals, 12 entities, and two vessels that have imported oil and other illicit goods in support of the Iran-backed Ansarallah, commonly known as the Houthis (see OFAC press release here).

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