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
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 Extends Wind Down Authorization for Transactions with Certain Russian Financial Exchanges
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…
USTR Announces Minor Delay in Upcoming Changes to China Section 301 Tariffs
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…
Commerce and State Departments Issue Proposed Rules Addressing Restrictions on U.S. Persons’ Support for Foreign Military, Intelligence, and Security Services and Controls to Protect National Security and Human Rights
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…
Treasury Releases Annual CFIUS Report
On July 23, 2024, the Treasury Department, as the lead agency of the Committee on Foreign Investment in the United States (CFIUS), released a public version of its 2023 Annual Report to Congress regarding foreign direct investment in the United States. The report highlights key indicators of the CFIUS process and provides statistics on transactions…
Regulations Issued to Redesignate BIS as the Authority Administering Rules for Information and Communications Technology and Services Tied to Foreign Adversaries
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…
OFAC Continues to Extend Authorizations Under Russia General License 13
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…
CFIUS Issues Proposed Rule to Expand Coverage of Real Estate Transactions Near Military Installations
On July 8, 2024, the Department of the Treasury’s Office of Investment Security issued a Notice of Proposed Rulemaking seeking to add 59 military installations, across 30 states, to the list of installations around which the Committee on Foreign Investment in the United States (CFIUS) has jurisdiction regarding certain real estate transactions involving foreign persons. …
Two Members of Congress Ask CFIUS to Review Chinese Company’s Purchase of Grain Terminal in Illinois
One week after China’s largest state-run food and agriculture company announced its acquisition of a grain terminal in Cahokia, Illinois, a bipartisan pair of U.S. House members from Illinois urged Treasury Secretary Janet Yellin to conduct “an immediate review of the acquisition to weigh the consequences for America’s national security and the region’s agricultural economy.” …
OFAC Issues General License 40C Continuing to Authorize Certain Transactions Involving the Export of LP Gas to Venezuela
On July 8, 2024, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Venezuela-related General License 40C, “Authorizing Certain Transactions Involving the Exportation or Reexportation of Liquefied Petroleum Gas to Venezuela.” This revised general license continues authorization of all transactions and activities related to the exportation or reexportation, directly or indirectly…
