On November 5, 2026, U.S. Customs and Border Protection (“CBP”) issued its interim final rule that would implement Section 2 of Executive Order 14411 by establishing heightened requirements for foreign importers of record (“IOR”) when making entry, new criteria to qualify as a U.S. IOR, and client verification responsibilities for licensed customs brokers (see…

On November 5, 2026, the Department of Commerce’s Bureau of Industry and Security (BIS) announced that it is extending the suspension of its End-User Controls to Cover Affiliates of Certain Listed Entities rule. The suspension was set to expire on November 9, 2026, but will now be extended through January 10, 2027.

BIS originally issued…

2025 Annual CFIUS Report Released

The Treasury Department, as the lead agency of the Committee on Foreign Investment in the United States (CFIUS), recently released a public version of its 2025 Annual Report to Congress regarding foreign direct investment in the United States. The report highlights key indicators of the CFIUS process and provides…

On October 28, 2026, President Trump issued a proclamation titled “Adjusting Imports of Robotics, Industrial Machinery, and Their Parts and Components into the United States,” directing the Secretary of Commerce and the United States Trade Representative (USTR) to jointly pursue negotiations with trading partners to address the national security threat posed by these imports. Rather…

On October 28, 2026,  the Department of Homeland Security (DHS) announced the addition of three Chinese companies to the Uyghur Forced Labor Prevention Act (UFLPA) Entity List. Effective October 29, 2026, U.S. Customs and Border Protection (CBP) will apply a rebuttable presumption that goods produced in whole or part by these three companies are made…

On October 26, 2026, the Office of the U.S. Trade Representative (USTR) published in the Federal Register a request for comments to allow for further negotiation with China regarding the acts, policies, and practices at issue and the countermeasures it imposed under Section 301 of the Trade Act of 1974, as amended, on Chinese vessels…

On October 26, 2026, the Department of the Treasury (“Treasury”) issued a Notice of Proposed Rulemaking (“NPR”) that would implement Subtitle C of the Comprehensive Outbound Investment National Security Act (“COINS Act”) to expand the coverage of the existing Outbound Investment Security Program (“OISP”) (see Update of October 8, 2026).

The OISP came…

On October 22, 2026, President Donald Trump issued a Proclamation announcing that the investigation into the effects of imports of wind turbines and their parts and components on the national security of the United States under Section 232 of the Trade Expansion Act of 1962 has concluded.  The investigation was initiated in August 2025 by…

On October 20, 2026, Gellert Global Group Corp. (Gellert) filed a complaint in in the U.S. Court of International Trade (CIT) challenging the 50% ad valorem tariffs placed on Canadian products by President Donald Trump under Section 338 of the Tariff Act of 1930, 19 U.S.C. § 1338. The complaint seeks class action status for…

On October 14, 2026, U.S. Customs and Border Protection (CBP) announced the extension of the compliance date for new informal entry procedures for international mail from October 22, 2026, to January 20, 2027. In a press release, CBP states that the 90-day extension “provides importers, brokers, and logistics providers additional time to update their…