As the International Longshoreman’s Association (ILA) strike commenced yesterday morning, our team received word from a source with knowledge of operations at the Port of New York and New Jersey (NYNJ) that, one by one, NYNJ terminals decided to “freeze the clock” on detention and demurrage (D&D) charges for the duration of the ILA strike.
Cortney Morgan
An experienced attorney in the area of international trade and supply chain issues, Cortney advises foreign and domestic clients on all aspects of international trade regulation, planning and compliance, including import (customs), export controls, economic sanctions, embargoes, international trade agreements and preference programs.
OFAC Issues Guidance Extending Statute of Limitations to 10 Years
On April 24, 2024, President Biden signed into law the 21st Century Peace through Strength Act, Pub. L. No. 118-50, div. D. Part of the Act included a provision extending the statute of limitations for civil and criminal violations of the International Emergency Economic Powers Act (IEEPA) and the Trading with the Enemy Act (TWEA) from five years to 10 years. The new statute of limitations took effect on the date of the President’s signature.
BIS Issues New Guidance to Combat Russia Diversion Risks and Highlights Recent Enforcement Actions
Recently, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued new guidance to exporters intended to further assist BIS in its efforts to crack down on third-party diversion to Russia.
Specifically, BIS’s recent guidance outlines the various mechanisms it has employed—outside of its usual public screening lists (i.e., the Unverified List…
Commerce Department Bans Kaspersky Software in First ICTS Prohibition, Signals Increased Risk of Using Certain Foreign Software and Technology
On June 20, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a Final Determination prohibiting the sale of certain cybersecurity products, anti-virus software, and related services to U.S. persons by Kaspersky Lab, Inc. (“Kaspersky”), the U.S. subsidiary of Russian cybersecurity provider AO Kaspersky Lab.
This Final Determination represents the first…
FLETF Identifies New High-Priority Sectors in Updated UFLPA Strategy: Polyvinyl Chloride (PVC), Aluminum, and Seafood
On July 9, 2024, the Forced Labor Enforcement Task Force (FLETF) issued its annual update to its guidelines enforcing the Uyghur Forced Labor Prevention Act (“UFLPA”) in a Report to Congress titled “2024 Updates to the Strategy to Prevent the Importation of Goods Mined, Produced, or Manufactured with Forced Labor in the People’s Republic of…
USTR Issues List of Proposed Section 301 Tariff Increases in Strategic Sectors, Invites Public Comment, Suggests Possible Exclusions for Equipment Used in Domestic Manufacturing, and Remains Silent on Fate of Existing Exclusions
On May 22, 2024, the U.S. Trade Representative released a draft Federal Register notice containing the list of imported goods for which it proposes to increase Section 301 duty rates. USTR also announced that it was considering an exclusion process by which U.S. manufacturers may request that “particular machinery used in domestic manufacturing be temporarily…
U.S. Trade Representative Releases Section 301 Review, Announces Increases in Section 301 Duties for Select Products, and Indicates that Existing Exclusions are Scheduled to Expire on May 31
As previewed over the course of the last month, the Biden Administration has announced that intends to increase Section 301 tariff rates for a host of products, including critical minerals used in battery production, and solar cells and modules. Today’s announcement comes in the context of the U.S. Trade Representative completing its four-year review of…
U.S. GOVERNMENT IMPOSES OVER 600 DENIED PARTIES DESIGNATIONS ON SECOND ANNIVERSARY OF RUSSIA’S UKRAINE
Sanctions Designations and Business Advisory Issued by OFAC and the U.S. State Department
On February 23, 2024, the Treasury Department’s Office of Foreign Assets Control (“OFAC”) and Department of State together announced more than 500 sanctions designations targeting government officials, companies, and individuals in Russia and beyond. The sanctions, which the U.S. stated were intended…
Executive Order Imposes New Russia Sanctions for Foreign Financial Institutions and Prohibits Additional Russian Imports
Executive Order Imposes New Russia Sanctions for Foreign Financial Institutions and Prohibits Additional Russian Imports
On December 22, 2023, President Biden issued Executive Order 14114, which amended previous Executive Orders in order to authorize the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) to impose additional Russia-related sanctions on foreign financial institutions and…
Legal Insights for Manufacturing: International Trade & Supply Chain
Husch Blackwell’s Technology, Manufacturing & Transportation group has published its second-annual Legal Insights for Manufacturing report, covering the top challenges facing U.S.-based manufacturers and including a section on international trade and supply chain concerns. In particular, our team takes a closer look at the elevated importance of know-your-customer/business (KCY/B) practices and how they are…