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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 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

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

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

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

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.

On October 30, 2024, the Departments of the Treasury, State and Commerce undertook further sanctions against “enablers of Russia’s military-industrial base.” In total, the actions taken by the Office of Foreign Assets Control (OFAC) and the Bureau of Industry and Security (BIS) sanction over 300 individuals and entities involved in supplying Russia with advanced technology

On November 7, 2024, the Committee on Foreign Investment in the United States (CFIUS), in coordination with the Department of Defense (DoD), issued a Final Rule that expanded its ability to review certain real estate transactions by foreign persons near more than 60 military bases and installations across 30 states. In addition, CFIUS’s jurisdiction over

On October 31, 2024, the Department of Homeland Security (DHS) announced that effective November 1, 2024, four textile Chinese entities have been added to the UFLPA Entity List. These entities have been determined by DHS to be facilities and entities that source material from the Xinjiang Uyghur Autonomous Region or from persons working with the

On October 17, 2024, the Commerce Department’s Bureau of Industry and Security (BIS) released three rules—one Final Rule, one Interim Final Rule, and one Proposed Rule—to reduce controls on a variety of less sensitive space-related items, thereby ensuring the U.S. space industrial base remains globally competitive while also bolstering the U.S. international space partnerships. Concurrently

On October 21, 2024, the Department of Commerce’s Bureau of Industry and Security (BIS) issued a Final Rule adding 26 companies to its Entity List for activities contrary to U.S. national security and foreign policy for alleged violations of export controls, involvement in weapons programs of concern, and evasion of U.S. sanctions and export controls