In multiple petitions filed on January 18, 2023, Cleveland-Cliffs Inc. and the United Steel, Paper and Forestry, Rubber, Manufacturing, Energy, Allied Industrial and Service Workers International Union (collectively, “the Petitioners”) requested the imposition of antidumping duties on U.S. imports of certain tin- and chromium-coated steel sheet products (“tin mill products”) from Canada, China, Germany, Netherlands
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.
Panel Concludes Automakers May Continue Core Parts “Roll-up” to Meet USMCA’s RVC Passenger Vehicle and Light Truck Requirements
A United States-Mexico-Canada Agreement (USMCA) Chapter 31 Dispute Resolution Panel concluded that automakers may continue to use the longstanding practice of “roll-up” when calculating the percentage of North American-originating materials used in the production of core automotive parts (e.g., engines) that is subsequently factored into the computation for determining the total amount of originating content…
OFAC Publishes Preliminary Guidance on Price Cap to Be Placed on Petroleum Products of Russian Origin
On December 30, 2022, the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) published preliminary guidance on how the United States will implement a price cap policy on petroleum products of Russian origin. OFAC notes that with this preliminary guidance the agency will likely “take a similar approach for Russian petroleum products as…
OFAC Publishes First Set of Sanctions Against Foreign Persons Involved in the Global Illicit Drug Trade
On December 19, 2022, the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) introduced the first set of regulations to be issued under the new Illicit Drug Trade Sanctions (to be codified at 31 CFR part 599). The regulations will go into effect on December 20 pursuant to Executive Order (“E.O.”) 14059 (December…
Treasury Sanctions Network of Chinese Fishing Vessels for Serious Human Rights Abuses
On December 9, 2022, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned two Chinese individuals and a vast network fishing vessels they control, including Pingtan Marine Enterprise Ltd. (PME) and Dalian Ocean Fishing Co., Ltd. (Dalian), for perpetrating serious human rights abuses and corruption via illegal, unreported, and unregulated (IUU) fishing. Although…
Treasury Announces Price Cap on Russian Oil
On December 2, 2022, the Department of the Treasury (“Treasury”) issued a Determination pursuant to Executive Order 14071 of April 6, 2022 imposing a price cap of $60 per barrel on seaborne crude oil of Russian origin, effective December 5, 2022. Thus, companies can purchase and/or provide services related to the maritime transport of Russian-origin…
CBP Issues WRO on Sugar Produced by Central Romana in the Dominican Republic Following Forced Labor Investigation
On November 23, 2022, Customs and Border Protection (CBP) issued a Withhold Release Order (WRO) that mandates CBP personnel at all U.S. ports of entry detain raw sugar and sugar-based products produced in the Dominican Republic by Central Romana Corporation Limited (Central Romana). This WRO followed an investigation that reasonably indicated Central Romana uses forced…
Commerce Downgrades Russia’s Status in Antidumping Proceedings from Market Economy to Non-Market Economy
On November 10, 2022, the Department of Commerce’s International Trade Administration (ITA) announced that it was revoking Russia’s status as a market economy (ME) and reclassifying the country as a non-market economy (NME) for any antidumping (AD) proceeding. In announcing this determination, the ITA noted that Russia’s market-oriented economic reforms “have notably and significantly backtracked.”…
U.S. Paper File Folder Industry Files Petition Alleging Injury from Dumped Imports from China, India and Vietnam and Subsidized Imports from India
In an October 12, 2022 petition, the Coalition of Domestic Folder Manufacturers (“Coalition”) alleged that paper file folder imports from China, India and Vietnam are being sold in the United States at less than fair market value with dumping rates as high as 236% and that paper file folder imports from India are benefitting from…
OFAC Expands Russia Sanctions Following Putin’s Illegal Annexation of Four Ukrainian Regions
On September 30, 2022, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated hundreds of Russian individuals and entities and placed them on the Specially Designated Nationals (SDN) List in response to Russia’s illegal annexation of additional Ukrainian territories.
The new designations target 14 suppliers connected to the country’s military-industrial complex, including…
