On January 18, 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 13H, “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
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.
Annual and Semi-Annual Encryption Reports Due to BIS by February 1, 2024
As a reminder to our readers, the annual encryption self-classification report and semi-annual sales report for certain encryption items are due to be filed by February 1, 2024.
Annual Self-Classification Report
The self-classification report covers less sensitive items described under the Department of Commerce’s Bureau of Industry and Security (BIS) License Exception ENC (b)(1) (i.e., …
OFAC Continues to Extend Venezuela General License Delaying PdVSA 2020 8.5% Bond-Related Authorizations
On January 16, 2024, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued General License (GL) 5N, “Authorizing Certain Transactions Related to the Petróleos de Venezuela, S.A. 2020 8.5 Percent Bond on or After April 16, 2024,” which continues to delay U.S. persons’ ability to enforce bondholder rights to the CITGO…
U.S. International Trade Commission Releases 2024 Harmonized Tariff Schedule Basic Edition
The U.S. International Trade Commission released the 2024 Basic Edition of the Harmonized Tariff Schedule of the United States (HTSUS) on January 1, 2024.
The HTSUS sets out the tariff rates and statistical categories for all merchandise imported into the United States and is based on the international Harmonized System, which is the global system…
OFAC Updates its Guidance on the Price Caps on Russian Oil and Russian Petroleum Products
On December 20, 2023, nearly eleven months after publishing its finalized guidance on the implementation of the twin price caps on Russian oil and Russian petroleum products, the Department of the Treasury (“Treasury”) published a revised Guidance on Implementation of the Price Cap Policy for Crude Oil and Petroleum Products of Russian Federation Origin. …
President Biden Authorizes Secondary Sanctions on Foreign Financial Institutions Facilitating Certain Transactions Involving Russia
On December 22, 2023, President Joseph Biden issued Executive Order 14114 (EO) amending EO 14024 by authorizing the imposition of U.S. sanctions on foreign financial institutions that are either facilitating significant transactions on behalf of persons designated for operating in certain key sectors of the Russian economy, or facilitating significant transactions or providing services involving Russia’s…
President Biden Expands U.S. Sanctions on Russia by Authorizing Additional Prohibitions on Imports of Russian Seafood and Diamonds
On December 22, 2023, President Joseph Biden amended, among other things, Executive Order (EO) 14068, by additionally authorizing the prohibition on the importation and entry into the United States, including a foreign trade zone located in the United States, of the following products of Russian Federation origin: fish, seafood, and preparations thereof, as well…
EU Suspends Retaliatory Tariffs on U.S. Imports and U.S. Extends TRQs on Imports of EU Steel and Aluminum as Bilateral Negotiations Continue
The temporary trade truce between the United States and European Union (EU) will continue after the EU issued a press release on December 19, 2023 announcing the customs union would suspend the reimposition of certain retaliatory tariffs on U.S. imports until March 31, 2025. The EU’s retaliatory tariffs, which were scheduled to resume January 1…
USTR Again Extends Certain China Section 301 Product Exclusions
On December 29, 2023, the Office of the U.S. Trade Representative (USTR) issued a Federal Register notice further extending certain China-related Section 301 product exclusions through May 31, 2024. This action extends 352 exclusions previously reinstated in December 2022 through September 30, 2023, and 77 COVID-related exclusions previously extended in May 2023 through September 30…
Commerce Issues Further Export Controls Targeting China’s Semiconductor Manufacturing and Advanced Computing Capabilities
- These two Interim Final Rules reinforce the October 7, 2022, controls appended to the EAR to restrict China’s ability to both purchase and manufacture certain high-end chips critical for military advantage.
- The rules impose controls on additional types of semiconductor manufacturing equipment, adjust the parameters that determine whether an advanced computing chip is
