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…

On August 20, 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) implemented additional sanctions on Russia in response to the state-sponsored poisoning of Russian opposition leader Aleksey Navalny in August 2020. Specifically, OFAC has designating nine Russian individuals and two Russian entities found to be involved in Navalny’s poisoning or…

On August 16, 2021, the U.S. Court of International Trade (CIT) once again issued an order revising certain deadlines originally established in its July 6 decision and order granting the plaintiff group’s motion for a preliminary injunction in the ongoing Section 301 tariff refund litigation involving imports of certain Chinese products. The preliminary injunction suspended…

On August 11, 2021, the Department of Commerce’s Bureau of Industry and Security (BIS) and the Department of Treasury’s Office of Foreign Assets Control (OFAC) issued a fact sheet noting existing exemptions and authorizations available for companies, individuals and exporters to provide telecommunications-related goods and services to Cuba. The fact sheet lists OFAC general licenses…

In February 2021, President Joseph Biden’s administration sought a pause in ongoing litigation involving Chinese mobile applications TikTok and WeChat in order to evaluate the record and determine whether there was an actual national security threat as previously determined by former President Donald Trump. On June 9, 2021, President Biden issued a new executive order…