Publications

New Developments in the Section 232 Tariffs on Imports of Steel and Aluminum Products

by Melissa Proctor • May 4, 2018

The last two weeks ushered in several significant developments relating to the increased tariffs under Section 232 on certain steel and aluminum products. U.S. importers and manufacturers of affected products, raw materials, parts and components should take note of the following key developments and new import filing requirements— A Presidential Proclamation under Section 232 of […]


OFAC Extends Wind-Down and Maintenance Period for United Company RUSAL PLC under the Ukraine/Russia Related Sanctions

by Melissa Proctor • April 24, 2018

On April 23, 2018, the Treasury Department’s Office of Foreign Assets Control (OFAC) extended the wind-down period for United Company RUSAL PLC (hereinafter “RUSAL”), the world’s second largest producer of aluminum and one of the companies added to the Specially Designated Nationals (SDN) List earlier this month with other Russian oligarchs, senior Russian government officials, […]


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, […]


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 […]


Customs and Border Protection Begins Targeting Imported Goods Suspected of Being Made with North Korean Forced Labor

by Melissa Proctor • November 15, 2017

U.S. Customs and Border Protection (“CBP”) has recently begun scrutinizing import shipments suspected of being made with North Korean forced labor, as directed by the recently enacted Countering America’s Adversaries Through Sanctions Act (“CAATSA”). CAATSA gave expanded authority to CBP to enforce economic sanctions against North Korea and prevent the entry of goods made with […]


CBP Implements New Enforcement Policy for Wood Packaging Material Requirements

by Melissa Proctor • November 14, 2017

As of November 1, 2017, U.S. importers and carriers may find themselves subject to civil penalties imposed by Customs and Border Protection (“CBP”) for violations of the wood packaging material requirements. Previously, CBP allowed up to five (5) violations before taking action. That is no longer the case, and civil penalties may be assessed for […]


U.S. State Department Publishes CCATSA Section 231 Entity List and Guidance: Sanctions against U.S. and Foreign Persons Loom on the Horizon in 2018

by Melissa Proctor • November 13, 2017

On October 27, 2017, as required by the Countering America’s Adversaries Through Sanctions Act (“CAATSA”), the U.S. State Department published a list of 39 entities that are part of (or operate on behalf of) Russian defense or intelligence sectors, as well as formal guidance about the forthcoming sanctions anticipated in 2018. Section 231 of the […]