March 2020

Effective on March 25, 2020, the U.S. Department of State’s Directorate of Defense Trade Controls (DDTC) interim final rule amended the “Encryption Rule” under the International Traffic in Arms Regulations (ITAR) (22 C.F.R. § 120.54) with definitions more clearly explaining activities that are not considered to be exports, reexports, retransfers or temporary imports of secured…

PrimeSource Building Products, Inc., a U.S. importer of various steel derivative products, filed an amended complaint in the U.S. Court of International Trade (CIT) on February 4, 2020, arguing that President Donald Trump’s Proclamation No. 9980 is unlawful and unconstitutional. This proclamation expanded the implementation of steel and aluminum tariffs under Section 232 of the…

The U.S. Trade Representative (USTR) has issued another Federal Register notice exempting Section 301 tariffs for certain List 4A (imports from China with an annual trade value of $300 billion) products. The exemptions cover five entire 10-digit Harmonized Tariff System (HTS) subheadings and seven specially-prepared product descriptions – covering a total of 36 separate exclusion…

As countries around the globe respond to the COVID-19 pandemic, business operations must adapt to changing rules and new restrictions. Many countries have limited business activity and travel, and many have taken actions that impact employee wages and benefits. In addition, several nations have issued economic stimulus measures that may provide companies with opportunities for…

The Department of the Treasury’s Office of Foreign Assets Control (OFAC) has designated 20 Iran- and Iraq-based front companies, senior officials, and business associates for providing support to, or acting on behalf of, the Islamic Revolutionary Guards Corps-Qods Force (IRGC-QF) and for transferring lethal aid to Iranian-backed terrorist militias in Iraq such as Kata’ib Hizballah…

On March 25, 2020, the Department of Commerce’s Bureau of Industry and Security (BIS) extended the deadline to April 22, 2020, for public comment on possibly granting future Huawei Temporary General License (TGL) extensions. As noted in its March 12, 2020 Federal Register notice, BIS is seeking input on the continuing need for, and…

On March 25, 2020, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued amended General License 1A “Official Business of the United States Government” and General License 2A “Authorizing the Wind Down of Transactions Involving the Nicaraguan National Police” to clarify they were also issued under the Nicaraguan Human Rights and…

UPDATED: April 6, 2020 – Major operational changes continue at trade-related U.S. government agencies and courts due to personnel and public safety concerns over the COVID-19 outbreak in the United States. Below is currently available information on their status. Overall, the Office of Personnel Management has announced that as of March 16, 2020, and until…

The Office of the U.S. Trade Representative (USTR) has issued a Federal Register notice exempting Section 301 tariffs for certain List 3 (imports from China with an annual trade value of $200 billion) products. The exemptions cover one 10-digit Harmonized Tariff System (HTS) subheading and 176 specially-prepared product descriptions, which combined cover 202 separately submitted…

The Office of the U.S. Trade Representative (USTR) has issued a Federal Register notice seeking public comment on the possible extension of Section 301 tariff exclusions for certain products that it granted on June 4, 2019, in the ongoing trade dispute with China. These exclusions were in the fifth batch of exclusions granted as part…