- Russia-related General License 124B, “Authorizing Petroleum Services and Other Transactions Related to the
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.
USTR Announces One-Year Suspension of Section 301 Countermeasures Targeting China’s Maritime, Logistics, and Shipbuilding Sectors
On November 13, 2025, the Office of the U.S. Trade Representative (“USTR”) published a notice in the Federal Register announcing a nearly one-year suspension—until November 10, 2026—of countermeasures it imposed under Section 301 of the Trade Act of 1974, as amended, on Chinese vessels and maritime transport operations. Section 301 authorizes the USTR to investigate…
Trump’s Emergency Tariffs Face Scrutiny—and Skepticism—at the Supreme Court
On November 5, 2025, the U.S. Supreme Court heard oral arguments in a high-profile consolidated appeal challenging whether President Donald Trump lawfully invoked the International Emergency Economic Powers Act (“IEEPA”) to impose tariffs. The cases challenge two sets of tariffs Trump implemented earlier this year: (1) tariffs against Canada, China, and Mexico in response to…
White House Announces One-Year Suspension of the BIS “Affiliates Rule”
On November 1, 2025, the White House published a Fact Sheet announcing that the Department of Commerce’s Bureau of Industry and Security (“BIS”) will suspend the new “50% Rule”—also known as the “Affiliates Rule”—for one year, beginning November 10, 2025. The suspension was among several concessions reached during trade negotiations between the United States and…
United States and China Reach Deal to Ease Trade Tensions
- China
Customs Broker Pleads Guilty to Conspiracy Charge in Latest FCPA Prosecution Following DOJ’s Recent Enforcement Restart
On October 23, 2025, a customs broker operating in both the United States and Mexico pleaded guilty to conspiring to violate the Foreign Corrupt Practices Act (FCPA) before a magistrate judge in the U.S. District Court for the Western District of Texas. Although the plea agreement remains under seal, it was approved and adopted the…
OFAC Sanctions Russia’s Two Largest Oil Companies
On October 22, 2025, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) placed Russia’s two largest oil companies on its Specially Designated Nationals (SDN) List. This action was taken by the Treasury Department to “increase pressure on Russia’s energy sector and degrade the Kremlin’s ability to raise revenue for its war machine…
President Trump Announces New Section 232 Tariffs on Medium- and Heavy-Duty Trucks, Their Parts, and Buses Starting November 1, 2025
On October 17, 2025, President Donald Trump issued Proclamation 10984 announcing that, effective November 1, 2025, the United States will begin levying a 25% tariff on medium- and heavy-duty vehicles (“MHDVs”), a 25% tariff on medium- and heavy-duty vehicle parts (“MHDVPs”), and a 10% tariff on buses pursuant to Section 232 of the Trade Expansion…
Status of Trade-Related Agency Operations During Government Shutdown
As of October 1, 2025, federal funding lapsed for numerous U.S. government agencies, including those engaged in sanctions, export control, and customs compliance and enforcement. Due to the lack of funding, export licensing functions have been significantly curtailed. Below is an overview of the status of key operations at OFAC, DDTC, BIS, and CBP.
Department
…BIS Expands Entity List End-User Controls to Cover Affiliates of Listed Entities
On September 30, 2025, the Department of Commerce’s Bureau of Industry and Security (BIS) issued an Interim Final Rule that expands the export control restrictions of its Entity List to cover any affiliates that are at least 50% owned by one (or more) entities on the Entity List or the Military End-User (MEU) List. Previously…
