On July 8, 2026, on the sidelines of the NATO summit, President Donald Trump announced his intention to remove Syria from the State Sponsor of Terrorism list, a significant move that would assist Syria’s efforts to re-engage in the global political and financial systems and rebuild the country after more than a decade of civil
Aaron C. Mandelbaum
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.
OFAC Reinstates U.S. Sanctions Related to Sales of Iranian Oil
On July 7, 2026, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) revoked Iran-related General License X and issued Iran-related General License X1, for the “Revocation and Wind Down of June 21, 2026 Authorization for the Production, Delivery and Sale of Crude Oil, Petrochemical Products, and Petroleum Products of Iranian Origin.”…
CIT Issues Order Addressing China Section 301 Cases in Light of Supreme Court Denial of Certiorari
On July 6, 2026, the U.S. Court of International Trade (CIT) issued an Order announcing resolution of all pending but stayed China Section 301 cases because of the June 15, 2026 U.S. Supreme Court decision denying the petition for a writ of certiorari in HMTX Industries LLC v. United States. To facilitate resolution of…
CBP Issues Interim Final Rules Indefinitely Suspending the De Minimis Exemption for Imports
On June 24, 2026, Customs and Border Protection (CBP) issued two Interim Final Rules indefinitely suspending the $800 de minimis duty exemption for all modes of importation of goods into the United States and establish a new informal entry and bonding process for international mail shipments. Public comments on these two interim rules are due…
CBP Confirms June 29, 2026 IEEPA Tariff Refund Process Phase 2 Launch
On June 23, 2026, U.S. Customs and Border Protection (“CBP”) published Cargo Systems Messaging Service (“CSMS”) #69035485, confirming that Phase 2 of the process for refunding duties paid by importers of record under the International Emergency Economic Powers Act (“IEEPA”) will be deployed in the Automated Commercial Environment (“ACE”) Portal on June 29, 2026. …
OFAC Temporarily Lifts Certain Oil Sanctions Against Iran
UPDATE: On July 7, 2026, this Iran-related General License X was revoked by OFAC and any activities under this general license must be wound down no later than July 17, 20026. See Thompson Hine Update of July 8, 2026 for additional details.
On June 22, 2026, the Department of the Treasury’s Office of Foreign Assets…
CBP Announces Phases 2 and 3 of the IEEPA Tariff Refund Process
At a show cause hearing before the U.S. Court of International Trade (“CIT”) on June 9, 2026, U.S. Customs and Border Protection (“CBP”) confirmed that it will roll out Phases 2 and 3 of its process for refunding duties paid by importers under the International Emergency Economic Powers Act (“IEEPA”) later this summer, with Phase…
U.S. Supreme Court Declines Review of China Section 301 Tariff Challenge
On June 15, 2026, the U.S. Supreme Court denied without comment the plaintiff group’s petition for certiorari in the test case for the China Section 301 tariff refund litigation (HMTX Industries LLC, et al. v. United States et al.). The petition sought review of the U.S. Court of Appeals for the Federal Circuit…
Trump Administration Appeals CIT’s IEEPA Tariff Refund Order
On June 2, 2026, the U.S. Department of Justice (“DOJ”) on behalf of the Trump administration formally appealed at the U.S. Court of Appeals for the Federal Circuit (“Federal Circuit”) the order of Senior Judge Richard Eaton of the U.S. Court of International Trade (“CIT”) compelling U.S. Customs and Border Protection (“CBP”) to refund importers…
OFAC Publishes Introductory Guide
On June 1, 2026, the Office of Foreign Assets Control (OFAC), an office of the Department of Treasury, published an “Introduction to the Office of Foreign Assets Control.” OFAC administers and enforces economic sanctions against targeted foreign jurisdictions and regimes, as well as individuals and entities engaging in harmful activity, such as terrorists…
