September 2020

On September 25, 2020, the Department of Commerce’s Bureau of Industry and Security (BIS) issued a Federal Register notice reopening the public comment period for its Section 232 national security investigation of imports of vanadium. BIS initially opened the investigation into vanadium imports on June 2, 2020 (see Update of June 3, 2020) as…

On September 24, 2020, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued a Federal Register notice amending the Cuban Assets Control Regulations (CACR) in order “to further implement the President’s foreign policy to deny the Cuban regime sources of revenue.” The changes will restrict: (1) lodging at certain properties in Cuba;…

On September 24, 2020, the U.S. Department of Commerce published a Federal Register notice listing prohibited transactions with ByteDance Ltd. and its subsidiaries including TikTok, Inc., pursuant to President Trump’s August 6, 2020 Executive Order declaring TikTok a national security threat and directing Commerce to define the scope of prohibited “transactions” with TikTok by September…

On September 18, 2020, the U.S. Department of Commerce announced prohibitions on transactions relating to the mobile applications WeChat and TikTok in order to “safeguard the national security of the United States” that were to become effective on September 20 and November 12, 2020. This announcement followed President Trump’s August 6, 2020 executive orders declaring…

On September 19, 2020, the United States announced that virtually all United Nations (UN) sanctions on Iran were being re-imposed. President Donald Trump and Secretary of State Mike Pompeo have taken the position that the United States can trigger the “snapback” provisions of UN sanctions under UN Security Council resolution 2231 pursuant to the Joint…

In a Federal Register notice, the Department of Commerce’s Bureau of Industry and Security (BIS) has announced that effective September 22, 2020, it is adding 47 entities to its Entity List after determining these companies and persons to be acting contrary to the national security or foreign policy interests of the United States. The entities…

The Office of the U.S. Trade Representative (USTR) has issued two Federal Register notices announcing the extension of numerous product exclusions from the Section 301 tariffs for imports from China appearing on List 1 (products from China with an annual trade value of $34 billion) and List 2 (products from China with an annual trade…

On September 15, 2020, a dispute settlement panel of the World Trade Organization (WTO) ruled that President Donald Trump’s tariffs against China violate the General Agreement on Tariffs and Trade (GATT) because they are prima facie inconsistent with Articles I:1 (Most-favored Nation Treatment) and certain of the GATT’s schedules and concessions, and the United States…

On September 15, 2020, the Office of the United States Trade Representative (USTR) issued a statement that it will “modify the terms of the 10% tariff imposed in August on imports of Canadian non-alloyed unwrought aluminum.” The United States will resume duty-free treatment of the Canadian aluminum retroactive to September 1, 2020, based on the…