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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.

On May 15, 2020, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) announced two new rules changes directed at Chinese telecommunications giant Huawei Technologies Co., Ltd. (“Huawei”).  As we have previously covered, BIS has named Huawei and 114 of its affiliate companies to its Entity List under the U.S. Export Administration

The Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a Federal Register Notice on May, 19, 2020, inviting comments from interested parties on its investigation regarding the potential expansion of Section 232 tariffs to include imports of steel incorporated into electrical transformers. Comments on the investigation may be submitted on or before June

Sorting through domestic preference requirements applicable to government contracts is no simple task. Different agencies like the DOD, FTA, FAA, FHWA, have their own rules applicable to certain programs. Exceptions from those rules can differ when a small business is making the offer. And the rules are subject to change. With the Court of Appeals

The Department of Justice (“DOJ”) filed comments in the U.S. International Trade Commission’s (“ITC”) investigation on whether imports of mattresses from multiple countries are causing injury to the domestic mattress industry.  The petition was filed on March 31, 2020, and the Commerce Department initiated the investigations on April 22, 2020.  In an unusual step, the

The U.S. Department of State’s Directorate of Defense Trade Controls (“DDTC”) recently announced on its website immediate measures intended to mitigate the impact of the SARS-COV2 pandemic on U.S. businesses and supply chains.  These measures include the following temporary changes to the registration and licensing requirements:

  • Temporary suspension of the requirements set forth in the

On April 29, 2020, the Commerce Department (“Commerce”) published a notice in Federal Register announcing that it is proposing new regulations that would establish an Aluminum Import Monitoring and Analysis System. The program appears to be modeled after the Steel Import Monitoring and Analysis (“SIMA”) System which has been in place since 2005.  Under the

Following an April 10 temporary final rule restricting the export of personal protective equipment (PPE) and an April 21 Notice of Exemptions from the Federal Emergency Management Agency (FEMA), U.S. Customs and Border Protection (CBP) has now issued a set of Frequently Asked Questions (FAQs) regarding the export of PPE.  The FAQs, available here,

As previously reported here, on April 10, 2010, the US Federal Emergency Management Agency (FEMA) issued a temporary final rule restricting the export of certain types of personal protective equipment (PPE).  The temporary rule required FEMA approval before certain kinds of PPE could be exported from the United States.

On April 21, 2020, FEMA

U.S. Supply Chain

The Federal Emergency Management Agency (FEMA) issued a temporary final rule requiring FEMA approval before certain kinds of personal protective equipment (PPE) can be exported from the United States.  The temporary rule is being issued pursuant to, among other authorities, the Defense Production Act of 1950 and a series of Executive Orders.  Based on these

The U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”) recently issued General License 13E (“GL 13E”), authorizing certain activities involving Nynas AB, a Swedish manufacturer of specialty oils owned in part by PDVSA, Venezuela’s state-owned oil company, which would normally be prohibited by Executive Order 13850 (“E.O. 13850”).  The notice issued by OFAC