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Application of the Substantial Transformation Principle in the Context of U.S. Sanctions

The practice of determining an item’s country of origin (“COO”) and utilizing the principal of “substantial transformation” to help make this determination is likely a familiar concept for many U.S. importers in the context...more

Trade Violations Under the False Claims Act

On February 7, 2023, the U.S. Department of Justice (“DOJ”) announced that settlements and judgements under the False Claims Act (“FCA”) exceeded $2 billion for the 2022 fiscal year. The 2022 fiscal year also had the...more

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