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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 April 7, 2025, 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 13M, “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

On April 2, 2025, the U.S. Customs and Border Protection (CBP) issued a press release announcing that it had issued a Withhold Release Order (WRO) for imports of sea salt products from Taepyung Salt Farm, a South Korean company, “based on information that reasonably indicates the use of forced labor.” The WRO is effective immediately

On April 3, 2025, the Department of Commerce’s Bureau of Industry and Security (BIS) released its quarterly update to the Boycott Requester List. This list notifies companies, financial institutions, freight forwarders, individuals, and other U.S. persons of potential sources of certain boycott-related requests they may receive during the regular course of business. This resource

On April 2, 2025, President Donald Trump signed an Executive Order (EO) that excludes goods from China (including products of Hong Kong) from entering the United States duty-free under the de minimis exception beginning May 2, 2025. Section 321 of the Tariff Act of 1930, commonly referred to as the “de minimis” rule

UPDATED: This blog post has been updated with additional information and links upon the release of the Annexes to the Executive Order. Readers should note that the breadth and depth of this Executive Order and the implementation of these tariffs is unprecedented, thus the situation regarding interpretation and their implementation remains fluid. It is expected

On April 2, 2025, the Annex to the Presidential Proclamation imposing 25% tariffs under Section 232 of the Trade Expansion Act of 1962 on imports of automobiles and certain automobile parts was released along with U.S. Customs and Border Protection (US-CBP) guidance regarding the fully assembled automobile provisions. As previously reported, see Thompson Hine Update

On March 25, 2025, the Department of Commerce’s Bureau of Industry and Security (BIS) added over 80 companies to its Entity List through two Final Rules.  These are the first listings by BIS under President Donald Trump’s second term and the listings heavily focus on China.  According to BIS, these entities “have been determined by

On March 24, 2025, President Donald Trump signed an Executive Order (EO) declaring that any country purchasing oil from Venezuela, “whether directly from Venezuela or indirectly through third parties,” will pay a 25% tariff on their exports to the United States.  The EO tasks the Secretary of Commerce with determining whether a country buys Venezuelan

On March 24, 2025, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Venezuela General License (GL) 41B extending the expiration date of Venezuela GL 41, which authorized certain transactions related to Chevron Corporation’s joint ventures in Venezuela.  Previously, under GL 41A issued earlier this month, all transactions “ordinarily incident and

The Department of Commerce’s Bureau of Industry and Security (BIS) has issued Federal Register notices announcing that interested parties may submit written comments, data or other information pertinent to these investigations. Comments are due no later than April 1, 2025.

Section 232 National Security Investigation of Imports of Copper

This investigation was initiated on February