Blog

U.S. Suspends Export Privileges of Chinese Tech Giant ZTE

by Melissa Proctor • April 17, 2018

On April 16th, the U.S. Commerce Department’s Bureau of Industry and Security (“BIS”) imposed a denial order against ZTE Corporation and ZTE Kangxun Telecommunications, Ltd. (“ZTE Kangxun”), located in Shenzhen, China, for making false statements in violation of the companies’ settlement of previous violations of the U.S. Export Administration Regulations (“EAR”). As a result, the […]


A Game of Chicken or Chess: The U.S. and China Increase Import Tariffs

by Melissa Proctor • April 10, 2018

Last month, the Trump Administration increased tariffs on certain steel and aluminum products imported into the United States for national security reasons under Section 232 of the Trade Expansion Act of 1962 (19 U.S.C. Ch. 7). Three weeks later, the United States announced that it would also increase tariff rates on additional goods imported from […]


OFAC Adds Russian Oligarchs, Senior Government Officials and Russian-Owned Companies to the Specially Designated Nationals List

by Melissa Proctor • April 10, 2018

On April 6th, pursuant to the Countering America’s Adversaries Through Sanctions Act (CAATSA) and various Executive Orders, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) added 36 parties to the Specially Designated Nationals (“SDN”) List including: 7 Russian oligarchs and the 12 companies that they own or control; 17 senior Russian government officials; and, […]


President Trump Issues Proclamations on Aluminum and Steel Tariffs

by Melissa Proctor • March 11, 2018

President Trump issued two Presidential Proclamations on March 8, 2018 increasing the import tariff on certain articles of steel and aluminum. The proclamations were issued in response to the Section 232 Reports that were submitted by the Commerce Department to the President in January 2018 in accordance with the Trade Expansion Act of 1962, as […]


U.S. State Department Announces Export Policy Shift: South Sudan Is Now an ITAR Proscribed Country

by Melissa Proctor • February 6, 2018

On February 2, 2018, the State Department’s Directorate of Defense Trade Controls (“DDTC”) announced via web notice a significant change in its export policy vis-à-vis South Sudan. Per Section 38(a) of the Arms Export Control Act (“AECA”) (22 U.S.C. 2778), the DDTC has added South Sudan to its list of proscribed countries in Section 126.1 […]


Cheers to Lower Federal Excise Taxes on Imports of Beer, Wine and Distilled Spirits!

by Melissa Proctor • February 6, 2018

On December 22, 2017, “The Craft Beverage Modernization and Tax Reform Act” (“the Act”), was signed into law by President Trump making significant changes to the federal excise tax rates assessed on wines, distilled spirits and beer. The Act formally went into effect on January 1, 2018 and benefits the beer, wine and spirits industries […]


U.S. State Department Increases Maximum Civil Penalty Amounts

by Melissa Proctor • January 10, 2018

As of January 3, 2018, the maximum civil penalty amounts that may be assessed by the U.S. State Department for violations of certain laws and regulations have been adjusted upwards for inflation per the Federal Civil Penalties Inflation Adjustment Act of 1990, as amended. What does this mean for U.S. companies? Briefly, violations of the Arms […]


U.S. Treasury Department Publishes New List of Countries Requiring Cooperation with an International Boycott

by Melissa Proctor • January 10, 2018

Yesterday, the Treasury Department published its quarterly “List of Countries Requiring Cooperation with an International Boycott” (i.e., foreign boycotts that are not sanctioned by the United States). The current list of countries includes: Iraq Kuwait Lebanon Libya Qatar Saudi Arabia Syria United Arab Emirates Yemen Per Section 999 of the Internal Revenue Code of 1986, […]


U.S. Commerce Department to Increase Maximum Civil Penalty Amounts on January 15th  

by Melissa Proctor • January 9, 2018

As announced yesterday in the Federal Register, the maximum civil penalty amounts that may be assessed by the various bureaus, offices and agencies of the Department of Commerce will be adjusted upwards for inflation per the Federal Civil Penalties Inflation Adjustment Act of 1990, as amended. What does this mean for U.S. companies? Briefly, the Final […]


North Korea (Again) Designated by the United States as a State Sponsor of Terrorism

by Melissa Proctor • November 21, 2017

On November 21, 2017, the United States formally re-designated North Korea as a State Sponsor of Terrorism for, among other reasons, conducting six nuclear tests, firing ballistic missiles over Japan, engaging in suspected arms transfers to terrorists, and the assassination of the North Korean dictator’s half-brother in an airport in Malaysia. Although North Korea has […]