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
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.
BIS Announces the Opportunity to Submit Comments in the Section 232 Investigation on Imports of Steel for Electrical Transformers
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…
An Update on Trade Agreements Act Compliance and What “Manufacture” Means
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…
DOJ Takes Unusual Step to Submit Comments in Antidumping and Countervailing Duty Investigation on Mattresses from Vietnam, Thailand, Turkey, Serbia, Malaysia, Indonesia, and Cambodia, and China
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…
DDTC Announces New COVID-Related Measures Covering Registration and Licensing
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
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Commerce Department Proposes New Aluminum Import Licensing System
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…
U.S. Customs and Border Protection Issues FAQ Guidance on PPE Exports
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,…
FEMA Issues Notification of Additional Exemptions to the Export Restrictions on PPE
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…
FEMA Issues Temporary Final Rule Restricting Export of Certain PPE
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…
OFAC Extends General License for Companies Doing Business with PDVSA Affiliate Nynas AB
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…

