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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 Makes Iran-related Updates to SDN List

The Office of Foreign Assets Control (“OFAC”) took additional actions as part of “Operation Economic Outcast”, the Administration’s sanctions campaign against Iran.  OFAC announced the addition of an Iranian national (Reza Mohammad Taeedi) and a Hong Kong based company (Kameng Trading Limited) to the Specifically Designated Nationals and Blocked

On August 24, 2026, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced numerous actions related to Iran sanctions.  These actions are deemed “Operation Economic Outcast” and are meant to align with changes in the foreign policy of the United States towards Iran.

On the same day, the U.S. Department of

As previously reported, on August 22, 2026, Canadian Prime Minister Mark Carney announced that Canada will impose dollar-for-dollar retaliatory tariffs in response to the Section 338 additional duties that went into effect following the suspension of trade negotiations between the U.S. and Canada. 

On August 25, 2026, the Canadian Government unveiled the finalized list

In the latest development in United States-Canada trade relations, 50% additional duties, announced in three separate proclamations issued on July 20, 2026, took effect as of 12:01 a.m. eastern time on August 22, 2026. President Donald Trump imposed the additional duties pursuant to Section 338 of the Tariff Act of 1930, which empowers the President to impose additional duties (not exceeding 50%) on imports from a foreign country to offset the burden or disadvantage caused by that country’s unequal imposition on or discrimination against U.S. commerce.

The Office of the United States Trade Representative (USTR) has announced the imposition of new Section 301 tariffs under the Trade Act of 1974. Following investigations into global forced labor policies, the USTR has determined that 60 economies have failed to adequately impose or enforce prohibitions on the importation of goods produced with forced labor. The tariffs take effect at 12:01 a.m. Eastern Time beginning July 24, 2026.

On July 15, 2026, the Office of the United States Trade Representative (USTR) concluded its Section 301 investigation into Brazil’s unreasonable acts, policies, and practices by imposing a 25% tariff on most imports from Brazil, effective July 22, 2026. The action follows more than a year of investigation, multiple rounds of negotiations with Brazilian officials, a public comment period that generated over 360 written submissions, and a two-day public hearing held on July 6–7, 2026.

On July 16, 2026, the U.S. Senate confirmed five nominees to serve as Commissioners of the U.S. International Trade Commission (USITC or Commission) by voice vote, restoring the agency to its full six-member panel for the first time in years. The Senate Finance Committee had approved all five nominations with large bipartisan support the day prior.

On July 15, 2026, the Court of International Trade (CIT) issued an order which is the clearest indication of the next steps for addressing the status of finally liquidated entries where IEEPA tariffs were paid. Specifically, the CIT expects U.S. Customs and Border Protection (Customs) to launch Phase 3 of its CAPE platform for tariff refunds. The CIT’s order states that the court will issue case-specific orders in each of the approximately 3,700 individual IEEPA cases that “directs Customs to reliquidate certain finally liquidated entries in accordance with a procedure that will be outlined in the anticipated order.”

On July 15, 2026, U.S. Customs and Border Protection (CBP) issued CSMS #69252300, providing guidance on the new reporting requirements for the countries of smelt and cast for imports of certain copper articles under Proclamation 11021. Beginning July 30, 2026, importers of specified copper wire and cable products will be required to submit smelt and cast country information through the Automated Commercial Environment (ACE).