On April 14, 2026, U.S. Court of International Trade Senior Judge Richard Eaton held a closed conference in the new lead case, Euro-Notions Florida, Inc. v. U.S. Customs and Border Protection, et al., addressing refunds of duties paid under the International Emergency Economic Powers Act (“IEEPA”). At the conclusion of the conference, the Judge
Francesca M.S. Guerrero
Francesca counsels clients on compliance with export controls, sanctions, import regulations, human rights and forced labor, and the FCPA and antibribery laws. She works closely with companies to develop tailored compliance programs that fit their specific needs, and routinely advises clients on some of their most challenging international transactions, involving dealings in high-risk jurisdictions or with high-risk counterparties. Francesca also counsels companies through all phases of internal investigations of potential trade and antibribery violations and represents companies across industries before related government agencies.
OFAC Amends Russia General Licenses Related to Lukoil
On April 14, 2026, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) amended two general licenses to continue authorizing limited transactions under previous sanctions involving Russia’s Lukoil operations.
Russia-related General License 128C, “Authorizing Certain Transactions Involving Lukoil Retail Service Stations Located Outside of Russia.” This amended general license extends until October 29…
OFAC Issues General Licenses Authorizing Certain Venezuelan Commercial and Banking Transactions
On April 14, 2026, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued two general licenses in the continuing relaxation of certain sanctions involving Venezuela. These new general licenses authorize certain commercial and banking transactions in the country.
Venezuela General License 56, “Authorizing Commercial-Related Negotiations of Contingent Contracts with the Government…
OFAC Issues Russia General License Allowing Delivery and Sale of Russian Crude Oil and Petroleum
On March 12, 2026, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Russia-related General License 134, “Authorizing the Delivery and Sale of Crude Oil and Petroleum Products of Russian Federation Origin Loaded on Vessels as of March 12, 2026.” The general license authorizes transactions “that are ordinarily incident and necessary…
USTR Releases President Trump’s 2026 Trade Policy Agenda and 2025 Annual Report
On March 2, 2026, the Office of the U.S. Trade Representative (USTR) delivered President Donald Trump’s 2026 Trade Policy Agenda and 2025 Annual Report to Congress. This year’s trade agenda seeks to promote U.S. interests abroad and reduce trade deficits by pursuing trade deals with other countries and strengthening domestic manufacturing.
2025 Annual Report
…CIT Suspends Earlier Order Directing IEEPA Tariff Refunds
On March 6, 2026, Judge Richard Eaton of the U.S. Court of International Trade (CIT or Court) held a closed conference in Atmus Filtration, Inc. vs. United States, to continue the Court’s process in determining how the International Economic Emergency Powers Act (IEEPA) tariffs can be refunded to importers of record. At the conclusion of…
CIT Orders Refund of IEEPA Tariffs
On March 4, 2026, in Atmus Filtration, Inc. vs. United States, Judge Richard Eaton of the U.S. Court of International Trade (CIT) issued an order, referencing the U.S. Supreme Court’s February 20, 2026 ruling in Learning Resources, Inc. v. Trump declaring International Emergency Economic Powers Act (IEEPA) tariffs unlawful, that: (1) “[a]ll importers…
After U.S. Supreme Court Invalidates IEEPA Tariffs, Trump Administration Turns to Other Options – What Importers Need to Know
In a 6-3 ruling, the Supreme Court of the United States ruled that the International Emergency Economic Powers Act (IEEPA) does not grant the president power to impose tariffs. In response, President Donald Trump issued a temporary 10% tariff on all imports pursuant to Section 122 of the Trade Act of 1974. Importers of record…
President Trump Implements Temporary Import Duties under Section 122 of the Trade Act of 1974 and Continues the Suspension of Duty-Free De Minimis Exception for International Shipments
On February 20, 2026, President Donald Trump issued a proclamation announcing that he was imposing a temporary import surcharge (i.e., tariff) pursuant to section 122 of the Trade Act of 1974 (19 U.S.C. Section 2132) to address “fundamental international payments problems” that “could impair United States national interests, including economic and national security interests.” Stating…
U.S. Supreme Court Invalidates IEEPA as a Lawful Authority to Impose Tariffs
On February 20, 2026, the U.S. Supreme Court (SCOTUS) in a 6-3 ruling determined that President Donald Trump’s use of the International Economic Emergency Powers Act (IEEPA) to impose tariffs was unlawful. In its decision, the SCOTUS stated: “When Congress grants the power to impose tariffs, it does so clearly and with careful constraints. …
