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USITC Opens Investigation into Economic Impact of Section 301 and Section 232 Tariffs

The U.S. International Trade Commission (USITC) announced in a notice issued on May 5, 2022, the commencement of a retrospective investigation of the economic impacts of Section 301 and Section 232 tariffs on the most...more

U.S. Department of State Proposes Changes to the ITAR

The U.S. Department of State published a proposed rule on Feb. 2, 2022, that suggests amendments to the International Traffic in Arms Regulations (ITAR). Though some changes are to correct internal inconsistencies and...more

Cambodia in 2022: A New Landscape for U.S. Businesses

Following a series of government agency actions in the final months of 2021, U.S. businesses are advised to evaluate their operations in Cambodia and ensure compliance in the new year. Beginning with the tri-agency Cambodia...more

Department of Commerce Increases Civil Monetary Penalties for 2022

The U.S. Department of Commerce (Commerce) is increasing each civil monetary penalty within Commerce's jurisdiction for 2022 by 6.2 percent. The increases become effective on Jan. 15, 2022. Note that the 2022 adjustments will...more

Treasury Department Mandates Reporting of Foreign Securities Holdings of $200 Million or More

The U.S. Department of the Treasury (Treasury) published a notice to the public on Dec. 8, 2021, that it is commencing a mandatory survey of foreign securities ownership beginning Dec. 31, 2021. The survey is mandatory for...more

USTR Extends Section 301 Exclusions for COVID-19 Related Medical-Care Products

The Office of the U.S. Trade Representative (USTR) published a Notice in the Federal Register on Nov. 16, 2021, extending product exclusions for COVID-19-related products covered by USTR's Section 301 investigation into...more

USTR Considers "Targeted" Reinstatement of Section 301 Exclusions on Certain Chinese Products

The Office of the U.S. Trade Representative (USTR) has published a Federal Register notice seeking public comments on whether to reinstate 549 previously extended tariff exclusions. If reinstated, exclusions will apply...more

Holland & Knight's China Practice Newsletter: September-October 2021

Holland & Knight invites you to read our China Practice Newsletter, in which our authors discuss pertinent Sino-American topics. HIGHLIGHTS: - Non-Fungible Tokens and Intellectual Property Law: Key Considerations...more

GSA Mandates Disclosure of Foreign Ownership/Financing of High-Security Leased Spaces

The General Services Administration (GSA) amended the General Services Administration Acquisition Regulations (GSAR) via an interim rule (Rule) – effective June 30, 2021 – to incorporate disclosure obligations of foreign...more

CBP Issues Withhold Release Order on Silica-Based Products from Chinese Entity

U.S. Customs and Border Protection (CBP) on June 24, 2021, issued a Withhold Release Order (WRO) on silica-based products produced by Hoshine Silicon Industry Co. Ltd. (Hoshine) and its subsidiaries. Hoshine makes...more

Input Sought on Licensing Mechanism for ICTS Transactions Involving "Foreign Adversaries"

The U.S. Department of Commerce (Commerce) recently announced its "apparent" need for public comment on key aspects of a mechanism that would license or preclear certain information and communications technology and services...more

ICTS Investigations: The Commerce Department's New Tool

Back in May 2019, the Trump Administration issued Executive Order 13873, which was meant to police the use of certain information and communications technology and services (ICTS) purchased from "foreign adversaries." Then,...more

BIS Amends Regulations and Loosens Export Restrictions Involving Sudan

The U.S. Department of Commerce Bureau of Industry and Security (BIS) published a final rule on Jan. 19, 2021, amending the Export Administration Regulations (EAR) to implement the rescission of Sudan's designation as a State...more

President Biden Signs Executive Order Strengthening Buy American Rules

President Joe Biden signed an Executive Order on Jan. 25, 2021, "Ensuring the Future is Made in All of America by All of America's Workers" (E.O.), aimed at strengthening Buy American provisions. The E.O. was one of a number...more

BIS Amended the EAR to Treat Hong Kong the Same as China

The U.S. Department of Commerce Bureau of Industry and Security (BIS) on Dec. 23, 2020, amended the Export Administration Regulations (EAR) to remove Hong Kong as a separate destination listed in the EAR....more

Section 301 Litigation: Is It Too Late to Seek Refunds?

The U.S. Court of International Trade's (CIT) docket is brimming these days, all thanks to importers who have initiated more than 3,500 actions to date challenging the Trump Administration's use of Section 301 of the Trade...more

Importers Take Note: Trump Administration's Section 301 Authority Challenged in Court

A lawsuit filed with the U.S. Court of International Trade (CIT) on Sept. 10, 2020, seeks to upend the Trump Administration's authority to levy and collect certain of the tariffs imposed under Section 301 of the Trade Act of...more

FinCEN Warns of Scams Relating to PPE and Other Medical Goods During COVID-19 Pandemic

In struggling to address the evolving COVID-19 pandemic, the United States and many other countries continue to face major shortages of Personal Protective Equipment (PPE), such as N95 masks, gowns and other vital materials...more

U.S. Government to Take Actions Against U.S.-Listed Chinese Companies

President Donald Trump on June 4, 2020, issued the Presidential Memorandum on Protecting United States Investors from Significant Risks from Chinese Companies. It directs the President's Working Group on Financial Markets...more

CBP Issues Detention Order on Top Malaysian Medical Glove Producer Over Forced Labor Concerns

U.S. Customs and Border Protection (CBP) on July 15, 2020, imposed a Withhold Release Order (WRO) – often referred to as a Detention Order – on imports of disposable medical gloves made by Top Glove Sdn Bhd and TG Medical Sdn...more

Rule Banning Chinese Telecommunications Equipment is Released

The U.S. Department of Defense (DoD), General Services Administration (GSA) and National Aeronautics and Space Administration (NASA) released a prepublication version of an interim final rule that will bar contractors from...more

USMCA Replaces NAFTA: An Overview of Key Provisions

After 26 and a half years, the North American Free Trade Agreement (NAFTA) has practically ceased to exist as of July 1, 2020, and has been replaced by United States-Mexico-Canada Agreement (USMCA). Because many of NAFTA's...more

Securing the U.S. Power Grid: President and Commerce Department Sound the Alarm

President Donald Trump signed Executive Order 139201 on May 1, 2020, declaring a national emergency in order to secure the nation's bulk-power system. The president's order explains that such systems are threatened by foreign...more

Comments Sought on Section 301 Exclusions for China Imports Related to COVID-19

The Office of the U.S. Trade Representative (USTR) has issued a call for comments regarding the possible removal of Section 301 tariffs for medical-care products from China. The request for comments on the easing of Section...more

USMCA's Entry into Force Still Pending Amid COVID-19 Uncertainty, But Will Be July 1 or After

In accordance with the text of the United States-Mexico-Canada Agreement (USMCA), once all parties have notified each other in writing of the completion of their internal procedures required for the entry into force of the...more

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