News & Analysis as of

Customs and Border Protection China Corporate Counsel

Sheppard Mullin Richter & Hampton LLP

Not What You Think: Some Trump Tariffs Exempt Your Goods from Other Trump Tariffs

Some importers are finding, to their surprise, that the Trump Administration’s 25% tariffs on aluminum and steel create an exemption from the 125% tariffs on Chinese goods. The Trump tariff agenda has been complex, to say...more

Foley & Lardner LLP

What Every Multinational Company Should Know About … The Global and Reciprocal Tariffs Announcement

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On April 2, 2025, President Trump implemented the steepest American tariffs in over a century. The implications for numerous multinational companies — including importers, manufacturers, distributors, and retailers — will be...more

Bass, Berry & Sims PLC

DOJ Settlement Highlights Customs, FCA Risks for Importers

On March 25, 2025, the U.S. Department of Justice (DOJ) announced an $8.1 million settlement in a civil case under the False Claims Act (FCA) related to alleged customs evasion by a California importer of wood flooring. The...more

ArentFox Schiff

DHS’ Second UFLPA Strategy Update: Aluminum, PVC, and Seafood Enter the UFLPA’s Purview for Scrutiny and Enforcement

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Since the inception of the Uyghur Forced Labor Prevention Act (UFLPA), importers globally have started to become acutely aware of potential forced labor risks hidden beneath intricate supply chains....more

ArentFox Schiff

In a Single Action, DHS Adds 26 Entities to the UFLPA Entity List – Importers and Textile Companies Should Expect More Supply...

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In an unprecedented, but anticipated, move last Friday, the US Department of Homeland Security (DHS) expanded the Uyghur Forced Labor Prevention Act (UFLPA) Entity List with the addition of 26 new Chinese textile companies in...more

Skadden, Arps, Slate, Meagher & Flom LLP

Seven Myths About the US Law Banning Imports Made With Forced Labor | Insights

Key Points - - In light of the vigorous enforcement of the Uyghur Forced Labor Prevention Act, boards in their oversight role should ensure that their companies conduct heightened diligence on their supply chains, including...more

Jenner & Block

Ten Questions Answered About Implementation of the Uyghur Forced Labor Prevention Act

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Can you prove the absence of forced labor in your supply chain? As of June 21, 2022, US Customs and Border Protection (CBP) will presume that all goods manufactured in whole or in part in the Xinjiang Uyghur Autonomous Region...more

Wiley Rein LLP

What Companies Need to Know: Uyghur Forced Labor Act Signed Into Law

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After more than a year of debate in the U.S. Congress as to the scope and enforceability, the Uyghur Forced Labor Prevention Act (UFLPA or Act) passed Congress with strong bipartisan support. President Biden has publicly...more

Skadden, Arps, Slate, Meagher & Flom LLP

Legislation Targeting Imports From Xinjiang Region Moves to President Biden’s Desk

On December 16, 2021, the U.S. Congress passed legislation that effectively prohibits imports of goods made either wholly or in part in the Xinjiang Uyghur Autonomous Region (Xinjiang) of China. The prohibition relies on a...more

Morrison & Foerster LLP

OFAC 2020 Year In Review

In too many ways to count, 2020 was an extraordinary year. As we move into 2021 with optimism for an end to the pandemic and better days ahead, we understand that the activity last year of the U.S. Department of the...more

ArentFox Schiff

Wait Is Over: USMCA Border Enforcement Begins

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US tariffs are applied at the time of import and so the elevated role played by US Customs and Border Protection should not be underestimated. While the Customs section begins with the analysis “The Wait Is Over: USMCA Border...more

Pillsbury - Global Trade & Sanctions Law

U.S. Government Moves to Block Imports from Xinjiang, Triggering Due Diligence Challenges for Companies

On September 14, 2020, U.S. Customs and Border Protection (CBP) issued five Withhold Release Orders (WROs) for a range of goods produced in the Xinjiang region of China.  Under 19 U.S.C. § 1307, CBP can initiate enforcement...more

ArentFox Schiff

CBP Gets Tough on Forced Labor: Turning Supply Chain Risks Into Advantages

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Under the TFTEA, CBP has taken an increasingly enforcement-minded posture to prevent and penalize the importation of goods produced using forced labor into the United States. On August 13, 2020, CBP announced that it had...more

Foley Hoag LLP - White Collar Law &...

White Collar Year in Preview: Sanctions/Export Controls Trends in 2020

This is the sixth in our start-of-year series examining important trends in white collar law and investigations in the coming year. Our previous entry discussed enforcement by the Massachusetts Attorney General’s Office in...more

Foley & Lardner LLP

U.S. Customs and the New Trump Administration: Your Top Ten Questions Answered

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During the campaign, U.S. Customs & Border Protection (CBP) was mostly mentioned by President Trump in the context of illegal immigration. Controlling the flow of people, however, is only one of the jobs of CBP, which is part...more

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