On December 2, 2024, the Department of Commerce’s Bureau of Industry and Security (BIS) issued two new rulemakings in an ongoing effort to “further impair [China’s] capability to produce advanced-node semiconductors that can be used in the next generation of advanced weapon systems and in artificial intelligence (AI) and advanced computing, which have significant military
Scott E. Diamond**
Scott is a senior policy advisor with more than 25 years' experience with the legislative and regulatory processes involved in international trade policy, remedies and enforcement. This includes working with clients on matters involving export controls, economic sanctions, human rights and forced labor compliance, corporate anti-boycott and antibribery compliance, national security investigations, and foreign direct investment in the United States.
**Not licensed to practice law.
USTR Increases Tariffs Under Section 301 Trade Action on China for Tungsten Products, Wafers, and Polysilicon
On December 11, 2024, the Office of the United States Trade Representative (USTR) announced tariff increases under Section 301 of the Trade Act of 1974 for imports from China of certain tungsten products, wafers, and polysilicon. Beginning on January 1, 2025, the rates for solar wafers and polysilicon will increase to 50%, and the rates…
USTR Initiates Section 301 Investigation into Nicaragua’s Labor Rights and Human Rights Practices
On December 10, 2024, the Office of the U.S. Trade Representative (USTR) announced it was initiating an investigation into Nicaragua’s acts, policies, and practices related to labor rights, human rights, and the rule of law. The investigation will be conducted under Section 301 of the Trade Act of 1974 and is the first under Section…
CBP Issues Forced Labor Finding Concerning Aluminum Products Made by Chinese-owned Company in Dominican Republic
On December 4, 2024, U.S. Customs and Border Protection (CBP) released a forced labor finding concerning aluminum extrusions and profile products produced wholly or in part by Kingtom Aluminio S.R.L. (“Kingtom”), a Chinese-owned aluminum extruder in the Dominican Republic. Effective December 4, CBP will seize any articles that are covered by CBP’s forced labor finding…
OFAC Further Expands Sanctions on Iran for Missile Attack on Israel and Renewed Nuclear Escalations
On December 3, 2024, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced that it was “intensifying pressure” on Iran’s petroleum and petrochemical sectors by imposing sanctions on 35 entities and vessels “that play a critical role in transporting illicit Iranian petroleum to foreign markets.” This action identifies and imposes further sanctions…
BIS Announces New Controls on Exports to Pakistan
On November 25, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) announced new export controls targeting Pakistan to address concerns about the diversion of certain items to unauthorized end uses or end users, particularly those on the Entity List. The final rule, effective November 25, 2024, imposes new licensing requirements…
DHS Updates UFLPA Entity List with Additional Chinese Companies
On November 22, 2024, the Department of Homeland Security (DHS) announced the addition of 29 companies based in China to the Uyghur Forced Labor Prevention Act (UFLPA) Entity List, bringing the total number of entities on the UFLPA Entity List to 107. The newly identified and listed companies are involved in (i) electronic materials and…
OFAC Sanctions Gazprombank and Further Limits Russia’s Access to International Financial System
On November 21, 2024, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated Gazprombank, more than 50 internationally connected small-to-medium Russian banks, more than 40 Russian securities registrars, and 15 Russian finance officials. Treasury Secretary Janet Yellen stated that these sanctions target “Russia’s largest remaining non-designated bank, as well as dozens of…
Domestic Industry Files AD/CVD Petitions Seeking Relief from Float Glass Imports from China and Malaysia
On November 21, 2024, Vitro Flat Glass, LLC and Vitro Meadville Flat Glass, LLC (“Petitioners”) requested the imposition of antidumping and countervailing duties on float glass imports from China and Malaysia. The Petitioners argue that the “increasing surge of subsidized and dumped float glass products from China and Malaysia is untenable for the American FGP industry…
CFIUS Issues Final Rule Enhancing Enforcement and Penalty Regulations
On November 18, 2024, the Department of the Treasury (Treasury), as Chair of the interagency Committee on Foreign Investment in the United States (CFIUS), issued a final rule to enhance certain CFIUS procedures and sharpen its penalty and enforcement authorities. It revises certain provisions of the CFIUS regulations, 31 C.F.R. Parts 800 and 802, pertaining…
