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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

Legal Insights on the Import of PPE and Other Medical Supplies Vital to Fighting COVID-19

The COVID-19 crisis has revealed the extent to which the United States and other countries are dependent upon a well-functioning global supply chain of critical medical supplies, including ventilators and Personal Protective...more

United States Restricts Exports of Critical Personal Protective Equipment

The Federal Emergency Management Agency (FEMA) on April 8, 2020, released an advance copy of a temporary rule banning exportation of five types of Personal Protective Equipment (PPE) from the United States without its...more

Trump Administration Issues New Retaliatory Measures Against EU – and Threatens More

There have been several recent developments in trade disputes involving the Trump Administration and the European Union (EU), including an increase by the U.S. Trade Representative in tariffs on new Airbus aircraft and...more

Bureau of Economic Analysis Ramps Up Data Gathering

The Bureau of Economic Analysis (BEA), an agency of the U.S. Department of Commerce, published 10 notices on Jan. 27, 2020, regarding annual and quarterly surveys that track various types of foreign investment into the United...more

U.S. Considers Expansion of Tariffs in Aircraft Trade Dispute

The U.S. Trade Representative (USTR) published a notification on Dec. 12, 2019, informing the public that it was reviewing the action being taken in the Section 301 investigation involving the enforcement of the United...more

Proposed ICTS Supply Chain Review Regime Raises Procedural Concerns

The U.S. Department of Commerce (Commerce) has proposed a rule implementing the terms of President Donald Trump's Executive Order 13873 (the EO) on securing the United States' information and communications technology and...more

United States Imposes Additional Sanctions on Nicaragua

The Office of Foreign Assets Control (OFAC) on Sept. 4, 2019, promulgated regulations expanding the application of Executive Order 13851 ("Blocking Property of Certain Persons Contributing to the Situation in Nicaragua")...more

Trump Administration Aims to Reform WTO's Developing-Country Status

• The Trump Administration is pushing the World Trade Organization (WTO) to prevent advanced economies such as China from self-declaring as developing countries. • If there is no progress with the WTO, the United States...more

Foreign Gifts to U.S. Educational Institutions Under Increased Scrutiny

• U.S. institutions of higher education are required to report foreign gifts and contracts under Section 117 of the Higher Education Act. • The U.S. Department of Education has launched investigations into at least four...more

USTR Initiates Section 301 Investigation into French Digital Services Tax

• The Office of the U.S. Trade Representative is conducting an investigation under Section 301 of the Trade Act of 1974 with respect to the digital services tax (DST) bill recently approved by the French Parliament. • Under...more

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