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Heightened False Claims Act Enforcement of Customs and Trade Violations

As the Trump administration forges ahead with its trade agenda, including almost weekly new tariffs, and antidumping and countervailing duties orders, heightened False Claims Act (FCA) enforcement is sure to follow. Below, we...more

Frequently Asked Questions: IEEPA and Section 232

On March 21, 2025, U.S. Customs and Border Protection (CBP) updated its Section 232 FAQs to address the recent expansion of the steel and aluminum derivative lists. We note that the additional FAQs added by CBP are under the...more

CBP and DHS Issue Guidance on Implementation of the Uyghur Forced Labor Prevention Act

The week of June 12, 2022, the Department of Homeland Security (DHS) and U.S. Customs and Border Protection (CBP) released two important guidance documents to prepare the public for the implementation of the Uyghur Forced...more

Ahead of New (and Unprecedented) Import Restrictions on Xinjiang-Connected Goods, Biden Administration Seeks Public Comments on...

On January 24, 2022, the Biden administration, as part of the implementation of the newly-signed Uyghur Forced Labor Prevention Act (UFLPA), issued a notice in the Federal Register seeking public comments on “how best to...more

Forced Labor Enforcement: Xinjiang-Based Solar Panel Materials Become the Latest Regulatory Target

In an anticipated move, the Biden administration escalated its forced labor enforcement efforts on June 24 by announcing the issuance of a new withhold/release order (WRO) that blocks the import of certain polysilicon-based...more

Forced Labor Enforcement: CBP’s Latest Seizure Sends “Strong Message” to the Trade Community

On May 4, 2021, U.S. Customs and Border Protection (CBP) announced the seizure of a shipment containing 3.97 million nitrile disposable gloves that, according to CBP, is directly linked to forced labor practices in Malaysia. ...more

Forced Labor Update: CBP Enforcement Actions Appear to Be Just the Start

Since August 2020, U.S. Customs and Border Protection (CBP) has initiated eight separate enforcement actions targeting goods from China’s Xinjiang Uighur Autonomous Region (XUAR) — none more sweeping than a January 13, 2021,...more

'Know Your Supply Chains'— As to Forced Labor Enforcement, the Biden Administration is Picking Up Where the Previous...

In case there was any doubt as to where the Biden administration stands on forced labor enforcement, United States Customs and Border Protection (CBP) stated recently that its “message to the trade community is clear: Know...more

Dialing Up its Forced Labor Enforcement Efforts, CBP Issues Order Barring All Imports of Cotton and Tomato Products from China’s...

On January 13, 2021, United States Customs and Border Protection (CBP) issued an order blocking all imports of cotton and tomato products from China’s Xinjiang Uighur Autonomous Region. The order, intended to address CBP’s...more

CBP Intensifies Focus on Forced Labor Practices in China

On December 2, 2020, U.S. Customs and Border Protection (CBP) issued an order blocking all imports of cotton and cotton products from Xinjiang Production and Construction Corps (XPCC), a Chinese state-owned company operating...more

USMCA Implementation May Require Country of Origin Marking Changes

On July 1, 2020, the United States–Mexico–Canada Agreement (USMCA) entered into force, replacing the North American Free Trade Agreement (NAFTA). The change to USMCA was accompanied by the publication on June 30, 2020, of the...more

FEMA Exempts Additional Shipments From its General Halt of PPE Exports

In the April 21, 2020 Federal Register, the Federal Emergency Management Agency (FEMA) will publish additional exemptions and clarifications to its general halt to exports of personal protective equipment (PPE) from the...more

Administration Halts Exports of Personal Protective Equipment

On April 8, the Federal Emergency Management Administration (FEMA) published a draft Interim Final Rule for the Federal Register that will halt all exports of certain scarce or threatened materials (referred to generally as...more

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