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Dirty Tricks and Sneaky Tactics: U.S. Issues Advisory on Sanctions Risks Involving North Korea

by Melissa Proctor • July 24, 2018

[July 23, 2018)] On July 23, 2018, the U.S. Departments of State, Treasury and Homeland Security issued an advisory that warns companies of the tactics used by North Korea to evade U.S. and United Nations economic sanctions. Today’s advisory does not impose any new sanctions on North Korea. Rather, the sanctions on North Korea remain […]


Section 301 Tariffs on Chinese-Origin Goods Imported into the United States Are Now in Effect

by Melissa Proctor • July 6, 2018

On July 6th (12:01 a.m.), the Section 301 tariffs on imports of certain Chinese goods into the United States officially went into effect. Goods classified in one of the covered subheadings that are products of China are now subject to a 25% ad valorem rate of duty in addition to the applicable general (Column 1) […]


State and Commerce Departments Publish Long-Awaited Proposed Rules for U.S. Export Controls on Firearms, Ammunition and Related Equipments

by Melissa Proctor • June 12, 2018

On May 24th, the Commerce Department’s Bureau of Industry and Security (“BIS”) and the State Department’s Directorate of Defense Trade Controls (“DDTC”) published the long-awaited proposed rules for the export control of firearms, guns, ammunition and related articles under the Export Administration Regulations (“EAR”) and the International Traffic in Arms Regulations (“ITAR”). These are just […]


Commerce Department and ZTE Reach New Agreement on U.S. Export Violations

by Melissa Proctor • June 12, 2018

On June 7th, the Commerce Department announced that Zhongxing Telecommunications Equipment Corporation and ZTE Kangxun Telecommunications Ltd. (collectively “ZTE”) agreed to additional civil penalties and compliance measures in exchange for their removal from the Bureau of Industry and Security (“BIS”) Denied Persons List, thereby allowing them to regain access to the U.S. market. ZTE, the […]


U.S. Announces Withdrawal from the Iran Nuclear Deal and the Snap-Back of Previously Lifted Sanctions

by Melissa Proctor • May 9, 2018

On May 8, 2018, the President announced that the United States would withdraw from the Joint Comprehensive Plan of Action (“JCPOA”), and begin reimposing the nuclear-related sanctions that were lifted in 2015. He also issued a National Security Presidential Memorandum (“NSPM”) directing the U.S. Treasury Department and other departments and agencies to begin taking 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 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 […]