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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 August 15, 2024, the Department of State’s Directorate of Defense Trade Controls (DDTC) published a final rule adding two activities to the definition of “activities that are not exports, reexports, retransfers, or temporary imports” in § 120.54 of the International Traffic in Arms Regulations (ITAR). The final rule, which goes into effect September 16

On August 12, 2024, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued General License (GL) 5P, “Authorizing Certain Transactions Related to the Petróleos de Venezuela, S.A. 2020 8.5 Percent Bond on or After November 12, 2024,” which continues to delay U.S. persons’ ability to enforce bondholder rights to the CITGO

On August 8, 2024, the Department of Homeland Security (DHS) announced via a Federal Register notice that effective immediately, five Chinese entities have been added to the UFLPA Entity List. These entities have been determined by DHS to be either: (i) working with the government of the Xinjiang Uyghur Autonomous Region (XUAR) to recruit

In an August 1, 2024 determination totaling 284 pages, the Department of Commerce (Commerce) announced it would continue to classify Vietnam as a non-market economy country in antidumping duty (AD) proceedings, despite praising Vietnam for “impressive reforms and economic growth” over the past 20 years. In a press release issued the day after its determination

On August 2, 2024, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued two revised general licenses regarding conducting financial transactions involving: (i) the Moscow Exchange (MOEX), Russia’s largest public trading markets for equity, fixed income, derivative, foreign exchange, and money market products, as well as Russia’s central securities depository and the

After closing the public docket on June 28, 2024, for comments on proposed tariff increases for certain products subject to the China section 301 investigation, the Office of the United States Trade Representative (USTR) issued a July 30, 2024 press release stating that it received more than 1,100 public comments requiring further review and that

On July 29, 2024, both the Departments of Commerce and State issued separate but complementary proposed rules seeking public comment on enhanced restrictions on exports, reexports, or support to military or intelligence end users and end uses in countries of concern, consistent with the Fiscal Year 2023 National Defense Authorization Act (NDAA). The Department of Commerce’s

The Department of Commerce’s Bureau of Industry and Security (BIS) has issued a Final Rule that redesignates regulations governing the procedures for the review of certain transactions involving information and communications technology and services (ICTS) designed, developed, manufactured, or supplied by persons owned by, controlled by, or subject to the jurisdiction or direction of a

On July 10, 2024, 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 13J, “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