On September 30, 2026, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) implemented new sanctions on Cuba and formally amended the existing Cuban Assets Control Regulations (CACR). In May 2026, President Donald Trump issued Executive Order (EO) 14404 titled “Imposing Sanctions on Those Responsible for Repression in Cuba and for Threats to
September 2026
U.S.-China Board of Trade “30-for-30” Identifies Products Recommended for Reduced Tariffs
By David M. Schwartz & David Chieng** on
On September 27, 2026, the White House announced a reciprocal list of U.S. and Chinese imports recommended for reduced tariff treatment (“30-for-30”) as part of the first major outcome of the U.S.-China Board of Trade. The U.S.-China Board of Trade was first announced on June 2, 2026, to manage bilateral trade and to identify specific…
CBP Confirms October 6, 2026 Launch of Phase 3 of the IEEPA Tariff Refund Process
On September 15, 2026, U.S. Customs and Border Protection (“CBP”) announced in a declaration filed in the U.S. Court of International Trade (“CIT”) that Phase 3 of the Consolidated Administration and Processing of Entries (“CAPE”), the system for administering refunds of tariffs imposed under the International Emergency Economic Powers Act (“IEEPA”), will deploy on October…
OFAC Increases the Scope of Sanctions on Iran
On September 8 and 10, 2026, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned multiple companies and persons for supporting Iran’s aviation sector and for enabling Iran to destabilize the Middle East. The aviation-related sanctions include covert front companies, foreign intermediaries, and deceptive transshipment routes that Iran relies on to obtain…
CBP Seeks Comments on Implementation of Executive Order 14411
On September 2, 2026, U.S. Customs and Border Protection (CBP) published a notice seeking comments by December 1, 2026, on its implementation of several provisions of Executive Order 14411 (“EO 14411”), which mandates the collection of foreign export documentation, the expansion of the requirements for the Customs Trade Partnership Against Terrorism (CTPAT) program, and the…
President Trump Imposes Import Ban on Certain Canadian Products and Increases Tariffs on Other Products
On September 8, 2026, President Donald Trump issued three proclamations imposing bans on the importation from Canada of certain goods and two other proclamations separately modifying Section 338 tariffs on other Canadian goods imported into the United States. The actions were taken on the same date that Canada implemented its retaliatory tariffs on certain U.S.