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USTR Section 301 Shipbuilding Reprised

The Notice also proposes new tariffs on Chinese origin ship-to-shore (STS) cranes and cranes and parts containing Chinese components. Interested parties may submit comments in response to these proposed measures before May...more

DOJ Releases Its Data Security Program Compliance Guide

The guide outlines the requirements of a newly implemented Data Security Program designed to prevent China, Russia and other foreign adversaries designated by the U.S. Department of Justice from accessing American’s sensitive...more

Breaking Ground: The Trump Administration Invokes Emergency Powers in New Executive Order to Boost U.S. Critical Mineral...

On March 20, 2025, the Trump administration invoked emergency powers in an Executive Order (EO) entitled Immediate Measures to Increase American Mineral Production, aiming to accelerate domestic mineral mining and processing....more

Beyond the Executive Orders: Legislative Proposals to Strengthen the U.S. Critical Minerals Supply Chain

Critical minerals are the backbone of modern technologies and national security, powering everything from advanced semiconductors and electric vehicle batteries to missile guidance systems and renewable energy infrastructure....more

U.S. Tariffs on Non-USMCA-Compliant Products Take Effect; Increased Tariff Rate on China Imposed

Between March 4, 2025, and March 6, 2025, U.S. trade policy in North America changed course multiple times as the Trump administration initially implemented previously paused tariffs on imports from Canada and Mexico, and two...more

The Battle of the Shipyards: USTR Proposals Would Require U.S.-Flagged and U.S.-Built Vessels, Impose Fees on Operators of Chinese...

On February 21, 2025, the Office of the U.S. Trade Representative (USTR) announced a proposal to: (i) require that exporters of U.S. goods use U.S.-flagged and U.S.-built vessels for an increasing percentage of their exports;...more

The Trump Administration Reinstates and Expands Section 232 Tariffs on Steel and Aluminum

On February 10, 2025, President Trump issued two Presidential Proclamations reimposing and expanding tariffs on all steel and aluminum imports into the United States pursuant to Section 232 of the Trade Adjustment Act of...more

Implementing the Russian Oil Price Cap – Most Recent U.S. Guidance

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

CBP’s Region-Wide WRO Escalates Pressure in China’s Xinjiang Region

On January 13, 2021, U.S. Customs and Border Protection (CBP) issued a withhold-release order (WRO) on all cotton and tomato products from China’s Xinjiang Uyghur Autonomous Region (XUAR) based on information that reasonably...more

U.S. Expands WROs in Xinjiang, Targeting Major Cotton Producer with Implications for Global Supply Chains

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

U.S. Government Issues Human Rights Policy for Export Licensing and Guidance to Prevent Misuse of Surveillance Tools

Over the course of the Obama and Trump administrations, U.S. officials have found new ways to incorporate human rights concerns into sanctions and export control policies. Recent announcements by the Commerce and State...more

U.S. Steps Up Pressure on Iran With Sanctions on Additional Financial Institutions and Continuation of Arms Embargo

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

World Trade Organization Panel Finds Section 301 Tariffs on Chinese Products Violate WTO Rules, but Decision Unlikely to Have...

On September 15, 2020, a World Trade Organization (“WTO”) panel found that the Trump Administration’s unilateral tariffs imposed on Chinese products violated WTO rules regarding nondiscrimination and import tariff rates...more

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

The USMCA’s Rapid Response Mechanism for Labor Complaints: What to Expect Starting July 1, 2020

On July 1, 2020, the United-States-Mexico-Canada Agreement (USMCA) entered into force, replacing the 26-year-old North American Free Trade Agreement (NAFTA). The U.S. government has taken several steps toward implementation...more

DoD Bans Use of Russian-Sourced Energy at U.S. Military Bases in Europe

In an effort to curb the potential risk associated with reliance upon the Russian Federation for energy, the Department of Defense issued a class deviation that prohibits contractors from using any Russian-sourced energy to...more

The United States No Longer Considers Hong Kong Autonomous from China, Setting the Stage for Rule Changes that Could Disrupt Trade...

Since the handover of Hong Kong by the United Kingdom to China in 1997, Hong Kong has enjoyed separate treatment from the mainland by the United States, other countries and international organizations pursuant to the “one...more

6/1/2020  /  China , Export Controls , Hong Kong , Imports

Treasury and CBP Temporary Rule on 90-Day Deferment for Payment of Certain Duties

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

Temporary FEMA Rule: Export Approvals Required for Certain Personal Protective Equipment

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

USTR Launches New Exclusion Request Procedure to Address COVID-19

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

Department of Commerce Publishes Regulations Allowing it to Impose Punitive Duties on Products from Countries with Undervalued...

On February 3, 2020, the Department of Commerce published a final rule that amends the regulations for countervailing duty investigations to allow the imposition of duties on countries that undervalue their currencies....more

The United States Updates Sanctions to Combat Terrorism with New Focus on Non-U.S. Banks

As it targets terrorist groups and their finances, the U.S. Government announces potent secondary sanctions that can impede correspondent banking relationships of non-U.S. banks. A new U.S. Executive Order updates the...more

DHS’s New Criminal Enforcement Initiative to Prosecute Corporations for Forced Labor

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

Trump Administration To Impose Tariffs on List 4 Products

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

Update on U.S. Government Review of “Emerging and Foundational” Technologies

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

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