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Aaron focuses his practice on advising clients on compliance with international economic sanctions, export controls, and U.S. import laws and regulations. He is also involved in assisting clients with complex cross-border transactions, anti-dumping and countervailing duty litigation, utilization of international and preferential trade agreements, and customs classifications. Most recently, Aaron has counseled clients navigating requirements under the Export Administration Regulations.

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 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

On April 2, 2026, President Donald Trump issued a proclamation announcing that the United States will impose on July 31, 2026, a 100% Section 232 tariff on imports of certain pharmaceuticals and associated active pharmaceutical ingredients (“APIs”). The tariff will operate as a floating rate: where a covered product is also subject to a non-duty-free

On April 1, 2026, Senior Judge Richard Eaton of the U.S. Court of International Trade (“CIT”) issued an order in Atmus Filtration, Inc. v. United States, the lead case addressing refunds of duties paid under the International Emergency Economic Powers Act (“IEEPA”), concluding that the government “continues to make satisfactory progress” and “is on

On March 27, 2026, Senior Judge Richard Eaton of the U.S. Court of International Trade (“CIT”) issued an order in Atmus Filtration, Inc. v. United States, updating his March 20, 2026 order regarding refunds of duties paid under the International Emergency Economic Powers Act (“IEEPA”). (For background on the March 20, 2026 order, see

On March 20, 2026, Senior Judge Richard Eaton of the U.S. Court of International Trade (CIT) issued another Order in Atmus Filtration Inc. vs. United States regarding refunds of duties paid under the International Emergency Economic Powers Act (IEEPA). In summarizing the CIT’s March 19, 2026 closed conference with plaintiff and government legal counsel, the

On March 17, 2026, Chief Judge Mark Barnett of the U.S. Court of International Trade (“CIT”) issued an order of reassignment transferring cases seeking refunds of duties paid under the International Emergency Economic Powers Act (“IEEPA”) to CIT Senior Judge Richard Eaton.  Chief Judge Barnett’s order effectively ratified Judge Eaton’s March 4, 2026 order in