On April 20, 2026, U.S. Customs and Border Protection (“Customs”) announced the activation of Phase 1 of the Consolidated Administration and Processing of Entries (“CAPE”) for IEEPA tariff refunds. CAPE Phase 1 is limited only to certain unliquidated entries and certain entries within 80 days of liquidation. For more information about CAPE as well as
On April 15, 2026, the U.S. Court of International Trade (“CIT”) ordered U.S. Customs and Border Protection (“CBP”) and the Commerce Department’s Bureau of Industry and Security (“BIS”) to sit for depositions in a case filed by an importer seeking refunds of tariffs imposed under Section 232 of the Trade Expansion Act of 1962 (“Section 232”).
On April 6, 2026, Atmus Filtration filed a notice of dismissal in its challenge to the IEEPA tariffs. Atmus Filtration v. United States, CIT #26-01259 (“Atmus”) was selected as the lead case by the U.S. Court of International Trade (“CIT”) on March 4, 2026. Atmus became the torch bearer for all IEEPA cases
On April 2, 2026, the Trump Administration issued a proclamation imposing Section 232 tariffs on imports of patented pharmaceutical products and active pharmaceutical ingredients (“APIs”) pursuant to Section 232 of the Trade Expansion Act of 1962 (“Section 232”).
In March 2025, in a similar blog post to this one, Nithya Nagarajan and Robert Romashko forecasted that False Claims Act (“FCA”) enforcement would increase under the current tariff-focused trade policy regime. Sure enough, the Department of Justice (“DOJ”) recently announced two FCA resolutions involving allegations of failure to pay customs duties and evasion of antidumping and countervailing duties.
The Biden Administration’s Forced Labor Enforcement Task Force (FLETF) recently increased enforcement efforts against imports from Chinese entities linked to forced labor in the Xinjiang Uyghur Autonomous Region. Twenty-nine (29) companies were added to the Uyghur Forced Labor Protection Act (UFLPA) Entity List on Friday November 22, 2024, bringing the total number of companies to
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.
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.
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