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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 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

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

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

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

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

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

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

  • 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
  • A new Executive Order prohibits U.S. investments in semiconductors and microelectronics, quantum information technologies, and artificial intelligence capabilities in China and other countries of concern and imposes certain notification requirements.
  • Certain passive and similar investments will be excepted from the restrictions.
  • An Advanced Notice of Public Rulemaking seeks public comment on the scope
  • The May 2023 FinCEN/BIS Joint Alert supplements the Joint Alert published by FinCEN and BIS in June 2022.
  • The Supplemental Joint Alert offers financial institutions new and updated information on export control restrictions imposed by BIS related to Russia.
  • Included is a list of certain “high priority” items organized according to their Harmonized