Timely news and analysis of the latest developments in international trade law
On December 10, 2021, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned 15 individuals and 10 entities in several countries for their connection to human rights abuse and repression. In addition, OFAC imposed investment restrictions on one Chinese company in connection with the surveillance technology sector
In China, OFAC has placed…
On September 24, 2021, the Department of Commerce’s Bureau of Industry and Security (BIS) issued a notice seeking public comment and input from domestic and foreign semiconductor design firms, semiconductor manufacturers, materials and equipment suppliers, and semiconductor intermediate and end-users regarding ongoing risks in the semiconductor supply chain. The goal of this public comment request…
U.S. Customs and Border Protection (CBP) has issued five Frequently Asked Questions (FAQs) relating to its June 23, 2021 Withhold Release Order (WRO) requiring U.S. ports to detain shipments of silica-based products and materials as well as goods derived from those products manufactured by Hoshine Silicon Industry Co., Ltd. and its subsidiaries (“Hoshine”). Hoshine operates…
On July 14, 2021, the Federal Trade Commission (FTC) published in the Federal Register (86 Fed. Reg. 37022-35) its final rule for “Made in USA” and other “unqualified U.S.-origin claims” on product labels. The final rule is effective on August 13, 2021.
The final rule codifies a longstanding FTC policy and practice that a product…
On June 8, 2021, the White House released its report analyzing the risks associated with supply chains for four key U.S. sectors – semiconductor manufacturing and advanced packaging; large capacity batteries; critical minerals and materials; and pharmaceuticals and advanced pharmaceutical ingredients. The report, Building Resilient Supply Chains, Revitalizing American Manufacturing, and Fostering Broad-Based Growth,…
On June 9, 2021, President Joseph Biden issued an Executive Order (E.O.) to further address the threat posed to the U.S. information and communications technology and services (ICTS) supply chain declared in Executive Order 13873 (the “Telecom Supply Chain E.O.”; see Update of May 16, 2019). The June 9, 2021 E.O. also revoked and…
On May 28, 2021, the U.S. Customs and Border Protection (CBP) issued a press release announcing that the CBP had issued a Withhold Release Order (WRO) for imports of seafood products from Dalian Ocean Fishing Co., Ltd., a Chinese entity, “based on information that reasonably indicates the use of forced labor in the entity’s fishing…
On March 26, 2021, the Department of Commerce’s Bureau of Industry and Security (BIS) announced that it will hold a virtual forum on April 8, 2021 to allow the public to address policy objectives and concerns over President Joseph Biden’s Executive Order 14017, which seeks to address the need for resilient, diverse and secure…
On March 22, 2021, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned two Chinese government officials for “serious human rights abuses” against ethnic minorities in the Xinjiang Uyghur Autonomous Region of China. In a brief press statement, the Director of OFAC stated, “Chinese authorities will continue to face consequences as long…
The Commercial Customs Operations Advisory Committee (COAC) of U.S. Customs and Border Protection (CBP) has indicated that CBP intends to add forced labor to its list of priority trade issues. The COAC issued draft recommendations on how to “ensure a more holistic U.S. government-wide approach to addressing forced labor.” The COAC Forced Labor Working Group…
