PrimeSource Building Products, Inc., a U.S. importer of various steel derivative products, filed an amended complaint in the U.S. Court of International Trade (CIT) on February 4, 2020, arguing that President Donald Trump’s Proclamation No. 9980 is unlawful and unconstitutional. This proclamation expanded the implementation of steel and aluminum tariffs under Section 232 of the
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 Issues Additional China Section 301 Tariff Exclusions, Including Exemptions for Certain Medical Supplies
The U.S. Trade Representative (USTR) has issued another Federal Register notice exempting Section 301 tariffs for certain List 4A (imports from China with an annual trade value of $300 billion) products. The exemptions cover five entire 10-digit Harmonized Tariff System (HTS) subheadings and seven specially-prepared product descriptions – covering a total of 36 separate exclusion…
OFAC Sanctions 20 Iran- and Iraq-Based Front Companies Supporting Islamic Revolutionary Guards Corps-Qods Force
The Department of the Treasury’s Office of Foreign Assets Control (OFAC) has designated 20 Iran- and Iraq-based front companies, senior officials, and business associates for providing support to, or acting on behalf of, the Islamic Revolutionary Guards Corps-Qods Force (IRGC-QF) and for transferring lethal aid to Iranian-backed terrorist militias in Iraq such as Kata’ib Hizballah…
Commerce Extends Deadline for Filing Comments on Future Extensions of Temporary General License for Huawei
On March 25, 2020, the Department of Commerce’s Bureau of Industry and Security (BIS) extended the deadline to April 22, 2020, for public comment on possibly granting future Huawei Temporary General License (TGL) extensions. As noted in its March 12, 2020 Federal Register notice, BIS is seeking input on the continuing need for, and…
OFAC Issues Amended Nicaragua-Related General Licenses
On March 25, 2020, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued amended General License 1A “Official Business of the United States Government” and General License 2A “Authorizing the Wind Down of Transactions Involving the Nicaraguan National Police” to clarify they were also issued under the Nicaraguan Human Rights and…
USTR Issues Additional China Section 301 Tariff Exclusions for List/Tranche 3 Products
The Office of the U.S. Trade Representative (USTR) has issued a Federal Register notice exempting Section 301 tariffs for certain List 3 (imports from China with an annual trade value of $200 billion) products. The exemptions cover one 10-digit Harmonized Tariff System (HTS) subheading and 176 specially-prepared product descriptions, which combined cover 202 separately submitted…
USTR Seeks Public Comment on Possible Extension of June 2019 Section 301 Tariff Exclusions for Chinese Products on List/Tranche 1
The Office of the U.S. Trade Representative (USTR) has issued a Federal Register notice seeking public comment on the possible extension of Section 301 tariff exclusions for certain products that it granted on June 4, 2019, in the ongoing trade dispute with China. These exclusions were in the fifth batch of exclusions granted as part…
USTR Seeks Comments on Possible Modifications to China Section 301 Tariffs in Response to COVID-19
The Office of the U.S. Trade Representative (USTR) has issued a Notice and Request for Comments seeking comment from members of the public, businesses, and government agencies as to whether further modifications are necessary to the China Section 301 tariffs “to keep current on developments in our national fight against the coronavirus pandemic.” USTR states…
OFAC Issues Amended Ukraine-Related General Licenses Involving GAZ Group
The Department of the Treasury’s Office of Foreign Assets Control (OFAC) has announced its extension of two general licenses related to GAZ Group, Ukraine-related General License No. 13N, “Authorizing Certain Transactions Necessary to Divest or Transfer Debt, Equity, or Other Holdings in GAZ Group” and Ukraine-related General License No. 15H, “Authorizing Certain Activities…
OFAC Sanctions Companies for Facilitating Iran’s Petroleum Sales; BIS Places Iranian Entities on Entity List
In its continuing effort to tighten economic sanctions on Iran, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) has sanctioned five United Arab Emirates (UAE)-based companies that facilitate the Iranian regime’s petroleum and petrochemical sales. According to OFAC, these companies in 2019 “collectively purchased hundreds of thousands of metric tons of petroleum…
