On December 23, 2024, the Office of the U.S. Trade Representative (USTR) announced it was initiating an investigation into China’s acts, policies, and practices related to China’s targeting of the semiconductor industry for dominance. The investigation will be conducted under Section 301 of the Trade Act of 1974, and will focus on China’s manufacturing 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.
OFAC Issues General License Allowing Transactions Involving Gazprombank Related to Civil Nuclear Energy
On December 19, 2024, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Russia-related General License 115 to generally authorize transactions involving Gazprombank that are related to civil nuclear energy. After sanctioning Gazprombank in November 2024 in order to further limit Russia’s access the international financial system (see Thompson Hine Update…
BIS Seeks to Further Strengthen Export Controls Targeting China’s Advanced Semiconductor Industry
On December 2, 2024, the Department of Commerce’s Bureau of Industry and Security (BIS) issued two new rulemakings in an ongoing effort to “further impair [China’s] capability to produce advanced-node semiconductors that can be used in the next generation of advanced weapon systems and in artificial intelligence (AI) and advanced computing, which have significant military…
USTR Increases Tariffs Under Section 301 Trade Action on China for Tungsten Products, Wafers, and Polysilicon
On December 11, 2024, the Office of the United States Trade Representative (USTR) announced tariff increases under Section 301 of the Trade Act of 1974 for imports from China of certain tungsten products, wafers, and polysilicon. Beginning on January 1, 2025, the rates for solar wafers and polysilicon will increase to 50%, and the rates…
USTR Initiates Section 301 Investigation into Nicaragua’s Labor Rights and Human Rights Practices
On December 10, 2024, the Office of the U.S. Trade Representative (USTR) announced it was initiating an investigation into Nicaragua’s acts, policies, and practices related to labor rights, human rights, and the rule of law. The investigation will be conducted under Section 301 of the Trade Act of 1974 and is the first under Section…
OFAC Further Expands Sanctions on Iran for Missile Attack on Israel and Renewed Nuclear Escalations
On December 3, 2024, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced that it was “intensifying pressure” on Iran’s petroleum and petrochemical sectors by imposing sanctions on 35 entities and vessels “that play a critical role in transporting illicit Iranian petroleum to foreign markets.” This action identifies and imposes further sanctions…
DHS Updates UFLPA Entity List with Additional Chinese Companies
On November 22, 2024, the Department of Homeland Security (DHS) announced the addition of 29 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 107. The newly identified and listed companies are involved in (i) electronic materials and…
OFAC Sanctions Gazprombank and Further Limits Russia’s Access to International Financial System
On November 21, 2024, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated Gazprombank, more than 50 internationally connected small-to-medium Russian banks, more than 40 Russian securities registrars, and 15 Russian finance officials. Treasury Secretary Janet Yellen stated that these sanctions target “Russia’s largest remaining non-designated bank, as well as dozens of…
Domestic Industry Files AD/CVD Petitions Seeking Relief from Float Glass Imports from China and Malaysia
On November 21, 2024, Vitro Flat Glass, LLC and Vitro Meadville Flat Glass, LLC (“Petitioners”) requested the imposition of antidumping and countervailing duties on float glass imports from China and Malaysia. The Petitioners argue that the “increasing surge of subsidized and dumped float glass products from China and Malaysia is untenable for the American FGP industry…
Final Rule Issued on Outbound U.S. Investments in National Security-Related Technologies in Countries of Concern
The Department of the Treasury has issued a Final Rule to implement Executive Order 14105 of August 9, 2023, “Addressing United States Investments in Certain National Security Technologies and Products in Countries of Concern.” This Final Rule provides the operative regulations and a detailed explanatory discussion regarding the intent and application of these new U.S.
