CBP Issues Facility Requirements for Bonded Warehouses
In a Cargo Systems Messaging Service (“CSMS”) message, U.S. Customs and Border Protection (“CBP”) clarified that bonded warehouses, as defined in 19 C.F.R. § 19.1, do not include container freight stations, inspectional facilities, express consignment facilities, etc., and therefore are not authorized for acceptance of Type 21/22 bonded warehouse entries.
Bonded warehouse entries (Entry Type 21/22) require designation of the mandatory data element of the facility’s associated Facilities Information and Resource Management System (“FIRMS”) code, as required by 19 CFR § 144.11(c). Type 21/22 entries submitted without a FIRMS code or with an inaccurate FIRMS code will not be authorized for deposit in any warehouse until the entry is corrected.
CBP Revises List of Energy and Energy Resources of Canada
On May 15, 2025, CBP issued CSMS #65054354 to revise the subheadings included on the list of commodities of energy and energy resources of Canada subject to additional duties. The updated list of energy and energy resources of Canada, as defined by HTS 9903.01.13, is listed here, which fully replaces the list contained in CBP’s CSMS #64514918 issued March 24, 2025.
BIS to Rescind AI Diffusion Rule; Issues Guidance for Exports of AI Chips
On May 13, 2025, the Commerce Department’s Bureau of Industry and Security (“BIS”) issued a press release stating it had “initiated a rescission” of the AI Diffusion Rule previously issued by the Biden Administration in January 2025. The rule was set to take effect May 15, 2025. BIS plans to publish the formal Federal Register notice and will issue a replacement rule in the future.
In its release, BIS also issued a related guidance document covering the following:
- Using Huawei Ascend chips anywhere in the world violates U.S. export controls.
- Warning the public about the potential consequences of allowing U.S. AI chips to be used for training and inference of Chinese AI models.
- How U.S. companies can protect supply chains against diversion tactics.
President Trump Intends to Lift Syria Sanctions
During his trip to the Middle East this week, President Trump announced he would lift all sanctions against Syria. The president also met with Ahmed al-Sharaa, Syria’s interim president. However, as of this writing, neither the Treasury Department’s Office of Foreign Assets Control (“OFAC”), BIS, nor the State Department have taken any official action.
DOJ Adds Sanctions Violations and Customs Fraud to Whistleblower “Priority Areas”
In a May 12, 2025 memorandum on white collar crime, the Department of Justice (“DOJ”) added corporate sanctions offenses, as well as trade, tariff, and customs fraud, to its list of “priority areas” for DOJ investigation and prosecution. Under the DOJ’s Corporate Whistleblower Awards Pilot Program, whistleblowers who provide the DOJ with certain information about corporate misconduct in these and other “priority areas” may be eligible for an award if the information results in a successful prosecution, including criminal or civil forfeiture.
Week Seventeen Sanctions Designations
OFAC and the State Department added several persons and entities to the Specially Designated Nationals and Blocked Persons List (“SDN List”) during Week Seventeen of President Trump’s return to office:
- On May 12, the State Department sanctioned three individuals and one entity for their involvement in activities related to Iranian nuclear-related research with potential military applications (see State press release here).
- On May 13, OFAC sanctioned one individual, two vessels, and fifteen entities as part of an international network facilitating the shipment of millions of barrels of Iranian crude oil to China on behalf of Iran’s Armed Forces General Staff (“AFGS) and its front company, Sepehr Energy Jahan Nama Pars (see OFAC press release here).
- On May 14, OFAC sanctioned six individuals and 12 entities for their involvement in efforts to help the Iran domestically source the manufacturing of critical materials needed for Tehran’s ballistic missile program (see OFAC press release here).
- On May 15, OFAC sanctioned four individuals for their roles in coordinating financial transfers for Hizballah (see OFAC press release here).
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