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Substantial Transformation of the FAR Trade Agreements Clause

The Court found the disqualification of an offeror from a pharmaceutical procurement was in error based on a U.S. Customs and Boarder Protection (CBP) interpretation of the Trade Agreements Act of 1979 (TAA)....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

Compliance in 2020 – Key Takeaways from the ITAR Cloud Rule

On December 26, 2019, the Department of State published in the Federal Register an interim final rule amending the International Traffic in Arms Regulations (ITAR) to define “activities that are not exports, reexports,...more

District Court Overturns OFAC Fine Against Exxon

On December 31, 2019, the U.S. District Court for the Northern District of Texas overturned a $2 million fine imposed by the Department of the Treasury’s Office of Foreign Assets Control (OFAC) against ExxonMobil Corp., and...more

Commerce Department Issues New Proposed Rules on Telecommunications Supply Chain

On November 27, 2019, the US Commerce Department published a proposed rule implementing regulations following President Trump’s May 15, 2019 Executive Order 13783 (E.O.) on Securing the Information and Communications...more

U.S. Imposes Sanctions on Turkey – The Economic Fallout from Events in Syria

The U.S. Treasury Department has issued sanctions designations against Turkey’s Ministry of National Defense, Ministry of Energy and Natural Resources, and the Minsters of Defense, Energy and Interior pursuant to a new...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

Cuba Travel Update: U.S. Regulators Amend Key Rules

On June 5, 2019, the Department of Commerce Bureau of Industry and Security (BIS) amended an important license exception which generally permitted the temporary sojourn of civil aircraft and vessels to Cuba.  ...more

The Trump Administration Initiates a Tariff Exclusion Process for Chinese Imports Provided in List 3

On May 21, the Office of the United States Trade Representative (USTR) established a process through which U.S. stakeholders may exclude products included in List 3 from a 25% tariff imposed pursuant to the investigation of...more

Temporary General License Grants Huawei Limited Relief from Restrictions Imposed by Entity List Restrictions

On May 16, 2019, the Bureau of Industry and Security (BIS) of the U.S. Department of Commerce added Huawei Technologies Co., Ltd. (Huawei) and sixty-eight of its non-U.S. affiliates to the Entity List, thereby prohibiting the...more

USTR Issues Proposed Tariff List on Nearly $300 Billion of Chinese Goods

Further to our prior blog post, on May 13, 2019, at the direction of President Trump, the Office of U.S. Trade Representative (“USTR”) published a proposed tariff list covering approximately $300 billion worth of Chinese...more

Further Escalation of Trade War: Trump Administration Raises Tariffs on Chinese Products

On May 9, 2019, the Office of the United States Trade Representative (USTR) issued a Federal Notice indicating that tariffs on $200 billion worth of Chinese imports would be increased from 10% to 25%. ...more

U.S. and EU Propose Steep Tariffs In Connection with Long-Running Parallel Disputes Over Disputed Subsidies to Airbus and Boeing

On April 8, 2019, the United States Trade Representative (USTR) proposed imposing tariffs on $11.2 billion worth of products from the European Union (EU). ...more

U.S. State Department Implements Title III of Helms-Burton Act Permitting Lawsuits Over Seized Properties in Cuba

On April 17, 2019, the Trump Administration announced that it will allow U.S. citizens whose property was seized by the Cuban Government after 1959 to sue foreign companies that “traffic” in their confiscated property....more

“Buy American” Executive Order Expands Potential Reach to Private Recipients of Federal Assistance

President Trump signed an Executive Order on January 31, calling on executive branch departments and agencies to encourage recipients of defined types of new federal awards to use cement, iron, steel, aluminum and certain...more

U.S. Commerce Department Releases Proposed Rulemaking for Export Controls on Emerging Technologies

On November 19, 2018, the US Commerce Department’s Bureau of Industry and Security (BIS) issued a proposed rulemaking seeking public comment on criteria for identifying emerging technologies that are essential to U.S....more

U.S. State Department Adds New Hotels to Cuba Restricted List

On November 15, 2018, the U.S. State Department added several new Cuban hotels to its List of Restricted Entities and Subentities Associated with Cuba (“Cuba Restricted List”). The recent update includes the additional of 16...more

OFAC Announces Sanctions Against Saudi Arabian Government Officials Pursuant to Global Magnitsky Act

On November 15, 2018, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned 17 officials of the Government of Saudi Arabia for their purported role in the killing of journalist Jamal...more

Pillsbury’s Post-Election Outlook

The 2018 Midterm Election played out as most poll forecasters speculated. Although several races have yet to be decided, Republicans have retained control of the Senate, but lost at least 29 seats, allowing the Democrats to...more

Reinstatement of Iran Sanctions

On November 5, 2018, OFAC announced a large number of Iran-related sanctions designations and issued guidance on the end of the 180-day wind down period. ...more

Completing “Snap-Back”

On November 2, 2018, the Department of Treasury’s Office of Foreign Assets Control (“OFAC”) issued a final rule effective Monday, November 5, 2018 that amends the Iranian Transactions and Sanctions Regulations and reinstates...more

CFIUS Announces Pilot Program Requiring Mandatory Declarations for Certain Non-Controlling Investments in Specified Critical...

The U.S. Department of the Treasury issued temporary regulations establishing a partial pilot program implementing two key changes to the jurisdiction and review of transactions by the Committee on Foreign Investment in the...more

U.S. Formalizes Snap-Back of Sanctions with New Executive Order

On August 6, 2018, the Treasury Department’s Office of Foreign Assets Control (OFAC) released a new Executive Order to implement the previously announced re-imposition of U.S. sanctions for Iran. ...more

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