In a 2-1 decision on May 7, 2026, a three-judge U.S. Court of International Trade (“CIT”) panel struck down the Trump administration’s implementation of Section 122 tariffs (see Update of February 23, 2026).

The 10% tariff on a wide range of imported goods, the panel reasoned, extended beyond President Trump’s power to address…

On May 6, 2026, the U.S. Trade Representative (USTR) issued a notice initiating its second statutory four-year review of Section 301 tariffs on imports of certain Chinese products initially implemented by the Trump administration in its 2018 investigation of China’s Acts, Policies, and Practices Related to Technology Transfer, Intellectual Property, and Innovation. The first step…

On May 1, 2026, President Donald Trump issued an Executive Order (EO) titled, “Imposing Sanctions on Those Responsible for Repression in Cuba and for Threats to United States National Security and Foreign Policy.”  Pursuant to the EO, the Secretary of State and/or Secretary of Treasury are able to designate for blocking sanctions any foreign person…

On April 27, 2026, the Department of Commerce (“Commerce”) published a Federal Register notice adding a duty-free code in the Harmonized Tariff Schedule of the United States (“HTSUS”) with retroactive effect to cover goods subject to the Section 232 aluminum, steel, or copper tariff regimes that do not, in fact, contain these metals.  This new…

On April 14, 2026, U.S. Court of International Trade Senior Judge Richard Eaton held a closed conference in the new lead case, Euro-Notions Florida, Inc. v. U.S. Customs and Border Protection, et al., addressing refunds of duties paid under the International Emergency Economic Powers Act (“IEEPA”).  At the conclusion of the conference, the Judge…

On April 14, 2026, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) amended two general licenses to continue authorizing limited transactions under previous sanctions involving Russia’s Lukoil operations.

Russia-related General License 128C, “Authorizing Certain Transactions Involving Lukoil Retail Service Stations Located Outside of Russia.” This amended general license extends until October 29…

On April 14, 2026, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued two general licenses in the continuing relaxation of certain sanctions involving Venezuela.  These new general licenses authorize certain commercial and banking transactions in the country.

Venezuela General License 56, “Authorizing Commercial-Related Negotiations of Contingent Contracts with the Government…

On April 10, 2026, U.S. Customs and Border Protection (“CBP”) published Cargo Systems Messaging Service (“CSMS”) #68315804, confirming that Phase 1 of the process to refund duties paid by importers under the International Emergency Economic Powers Act (“IEEPA”) will launch on April 20, 2026.  Known as the Consolidated Administration and Processing of Entries (“CAPE”)…

On April 6, 2026, Senior Judge Richard Eaton of the U.S. Court of International Trade (CIT) granted the Notice of Dismissal filed by counsel for Atmus Filtration, Inc. in Atmus Filtration Inc. vs. United States, the lead case seeking refunds of tariffs paid under the International Emergency Economic Powers Act (IEEPA). Subsequently, he issued…

On April 2, 2026, President Donald Trump issued a proclamation amending the rates, scope, and administration of the Section 232 tariff regimes for aluminum, steel, and copper and their derivative products. Section 232 of the Trade Expansion Act of 1962 authorizes the president to adjust duties on goods imported in quantities or under circumstances that…