UPDATE: On July 7, 2026, this Iran-related General License X was revoked by OFAC and any activities under this general license must be wound down no later than July 17, 20026. See Thompson Hine Update of July 8, 2026 for additional details.
On June 22, 2026, the Department of the Treasury’s Office of Foreign Assets
On June 3, 2026, President Donald Trump signed an Executive Order, “Strengthening Customs Enforcement,” (Order) directing the U.S. Department of Homeland Security (DHS) and U.S. Customs and Border Protection (CBP) to implement comprehensive reforms targeting importers of record, customs brokers, and international supply chains.
Importer of Record Requirements. Within 180 days
On June 1, 2026, President Donald Trump issued a Proclamation amending the rates, scope, and administration of the Section 232 tariff regimes for aluminum, steel, and copper and their derivative products. Section 232 of the Trade Expansion Act of 1962 authorizes the president to adjust duties on goods imported in quantities or under circumstances that
On June 2, 2026, the Office of the U.S. Trade Representative (USTR) issued its determination under Section 301 of the Trade Act of 1974 that certain acts, policies, and practices of 60 economies related to the failure to impose and effectively enforce a prohibition on the importation of goods produced with forced labor are unreasonable
On June 1, 2026, the Office of the U.S. Trade Representative (USTR) issued its determination that certain of Brazil’s acts, policies, and practices related to (i) digital trade and electronic payment services; (ii) unfair, preferential tariffs; (iii) anti-corruption enforcement; (iv) intellectual property protection; (v) ethanol market access; and (vi) illegal deforestation are unreasonable and burden
On June 1, 2026, the Office of Foreign Assets Control (OFAC), an office of the Department of Treasury, published an “Introduction to the Office of Foreign Assets Control.” OFAC administers and enforces economic sanctions against targeted foreign jurisdictions and regimes, as well as individuals and entities engaging in harmful activity, such as terrorists
On May 29, 2026, the U.S. Trade Representative (USTR) announced that it was launching an investigation of Vietnam under Section 301 of the Trade Act of 1974. The investigation will seek to determine “whether Vietnam’s persistent failure to resolve long-standing concerns about intellectual property (IP) protection and enforcement is unreasonable or discriminatory and burdens or
On May 1, 2026, President Donald Trump issued an Executive Order (EO) titled, “Imposing Sanctions on Those Responsible for Repression in Cuba and for Threats to United States National Security and Foreign Policy.” Pursuant to the EO, the Secretary of State and/or Secretary of Treasury are able to designate for blocking sanctions any foreign person
On April 27, 2026, the Department of Commerce (“Commerce”) published a Federal Register notice adding a duty-free code in the Harmonized Tariff Schedule of the United States (“HTSUS”) with retroactive effect to cover goods subject to the Section 232 aluminum, steel, or copper tariff regimes that do not, in fact, contain these metals. This new
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