Photo of 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.

On January 14, 2025, the Department of Homeland Security (DHS) announced the addition of 37 companies based in China to the Uyghur Forced Labor Prevention Act (UFLPA) Entity List, bringing the total number of entities on the UFLPA Entity List to nearly 150 entities. 

According to a press release by DHS, the entities added include globally recognized

The Department of the Treasury’s Office of Foreign Asset Controls (OFAC) has issued further sanctions (see also January 15, 2025 Thompson Hine Update) to address Russia’s continued efforts to evade U.S. sanctions.   OFAC noted in a press release that this latest action “targets a sanctions evasion scheme established between actors in Russia and [China]

On January 10, 2025, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) targeted significant entities involved in Russia’s oil production, maritime insurers, maritime oil tankers, and other entities and persons engaged in Russia’s energy sector. According to an OFAC press release, the sanctions block two major Russian oil producers, over 180

On January 10, 2025, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated and placed eight Venezuelan officials on the Specially Designated Nationals (SDN) List for “enabling Nicolas Maduro’s repression and subversion of democracy in Venezuela.” The individuals sanctioned include the president of Petroleos de Venezuela, S.A., (PdVSA), Venezuela’s state-owned oil company

On January 6, 2025, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Syria General License (GL) 24 to expand authorizations for activities and transactions in Syria following the events of December 8, 2024, and the removal of Bashar al-Assad from power.  The intent of the GL is to  ensure that U.S.

On January 7, 2025, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) again extended previous Russia-related General License (GL) 13 by issuing a revised GL 13L, “Authorizing Certain Administrative Transactions Prohibited by Directive 4 under Executive Order 14024,” which states that U.S. persons are authorized to pay taxes, fees, or import

On January 3, 2025, President Joseph Biden issued a Presidential Order blocking an approximately $15 billion proposed acquisition by Nippon Steel Corporation (Nippon Steel) of Japan to purchase Pittsburgh-based United States Steel Corporation (U.S. Steel). Explaining that the proposed acquisition might result in actions that threaten to impair the national security of the United States

The U.S. International Trade Commission released the 2025 Basic Edition of the Harmonized Tariff Schedule of the United States (HTSUS) on January 1, 2025.  The HTSUS sets out the tariff rates and statistical categories for all merchandise imported into the United States and is based on the Harmonized System, which is the global system of

On December 30, 2024, the Department of Commerce’s Bureau of Industry and Security (BIS) released a year-end update of the Boycott Requester List. This list notifies companies, financial institutions, freight forwarders, individuals, and other U.S. persons of potential sources of certain boycott-related requests they may receive during the regular course of business. Introduced in