On September 24, 2021, Office of Foreign Assets Control (OFAC) issued two general licenses (GL) intending to alleviate the impact of U.S. sanctions on civilians in Afghanistan. Specifically, OFAC issued GL 14 “Authorizing Humanitarian Activities in Afghanistan” and GL 15 “Transactions Related to the Exportation or Reexportation of Agricultural Commodities, Medicine, Medical Devices, Replacement Parts…

Ransomware attacks have been increasing, forcing many businesses to choose between paying a ransom and losing access to their confidential and proprietary data or information networks and systems.

On September 21, the Department of the Treasury issued an updated advisory that highlights potential sanctions risks for companies that directly make or otherwise facilitate ransomware payments…

On September 20, 2021, the Department of Commerce (Commerce) published in the Federal Register amended regulations to improve its administration and enforcement of the antidumping (AD) and countervailing duty (CVD) laws. The AD/CVD laws are intended to provide relief to domestic industries, including businesses, workers, farmers and ranchers, from the injurious effects of unfairly traded…

On September 17, 2021, President Biden issued an Executive Order (EO), “Imposing Sanctions on Certain Persons with Respect to the Humanitarian and Human Rights Crisis in Ethiopia,” targeting persons responsible for the conflict in Ethiopia, obstructing humanitarian access and preventing a ceasefire. The White House issued a statement in connection with the new sanctions indicating…

On September 10, 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued General License (GL) 5H, “Authorizing Certain Transactions Related to the Petróleos de Venezuela, S.A. 2020 8.5 Percent Bond on or After January 21, 2022,” which continues to delay U.S. persons’ ability to enforce bondholder rights to the…

On September 8, 2021, the Court of International Trade (CIT) issued an order that revised its July 6, 2021 order granting the plaintiff group’s motion for a preliminary injunction in the ongoing China Section 301 tariff refund litigation. That preliminary injunction suspended liquidation of unliquidated entries from China subject to List 3 and List 4A…

Key Notes:

  • U.S. sanctions regulations require persons subject to U.S. jurisdiction to file initial and annual reports on blocked property and rejected transactions with OFAC.
  • Annual reports of property blocked from July 1, 2020 to June 30, 2021 must be submitted by September 30, 2021.
  • There is no annual reporting requirement for rejected transactions.

On…

Recent additions to the Specially Designated Nationals (SDN) List highlight an increasing enforcement focus on corruption and money laundering. On August 24, 2021, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated three Paraguayan individuals and five associated entities to the SDN List in response to a corruption and money-laundering scheme involving…

The Office of the U.S. Trade Representative (USTR) is seeking public comments on whether to continue exclusions from Section 301 duties for certain medical care imports from China needed to address the COVID-19 pandemic.  These exclusions are set to expire on September 30, 2021 (see Update of March 8, 2021).  The USTR notice…

On August 23, 2021, the plaintiff group led by Transpacific Steel LLC filed a petition with the U.S. Court of Appeals for the Federal Circuit (Federal Circuit) requesting a rehearing by all the Federal Circuit judges of the July 2021 three-judge panel decision reversing the ruling of the U.S. Court of International Trade (CIT) that…