On May 7, 2026, the United States Court of International Trade (“CIT” or “Court”) invalidated Proclamation No. 11012 in The State of Oregon, et al. v. United States, et al. and Burlap and Barrel, Inc., et al. v. United States, et al., holding that the President exceeded his statutory authority in imposing a temporary
CBP Issues Guidance on Technical Corrections to Section 232 Duties for Aluminum, Steel, and Copper Imports
U.S. Customs and Border Protection (“CBP”) has issued new guidance addressing technical corrections to recently imposed Section 232 duties on imports of aluminum, steel and copper. Following a Notice of Technical Corrections issued by the Department of Commerce on April 29, 2026, CBP, on May 6, 2026, released CSMS #68554727 clarifying the application of these
CBP Issues Entry Filing and Reporting Guidance on Section 232 Duties for USMCA‑Qualifying Medium and Heavy‑Duty Vehicles
On May 6, 2026, U.S. Customs and Border Protection (“CBP”) released new guidance via CSMS #68559236 regarding the application of 25% Section 232 duties for Medium and Heavy-Duty Vehicles (“MHDVs”) that qualify for preferential treatment under the United States-Mexico-Canada Agreement (“USMCA”). Pursuant to Presidential Proclamation 10984, the Secretary of Commerce may approve eligible MHDVs to
OFAC Issues Guidance on Sham Transactions and Sanctions Evasion
On March 31, 2026, the Office of Foreign Assets Control (“OFAC”) issued an advisory (the “Advisory”) regarding sham transactions and their use in evading US sanctions. OFAC described sham transactions as occurring when “blocked persons, often operating through proxies or other intermediaries, effectuate transfers or establish arrangements that conceal–rather than genuinely extinguish–a continuing interest in property.”
Trump NSPM Proposes Changes to CFIUS Process and Outbound Investment Rules
On Friday, February 21, 2025, President Trump issued a National Security Presidential Memorandum (“NSPM”) titled “America First Investment Policy” which directed multiple federal agencies to take action to further restrict foreign adversaries’ ability to invest in sensitive United States businesses and to further restrict United States outbound investments into China. The Trump Administration also issued a Fact Sheet to accompany the NSPM.
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
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
OFAC and U.S. Department of State Issue New Sanctions and Designates More Than 300 Russian Federation Individuals and Companies Aiding Russia’s War Efforts
On Friday, May 19, 2023, the U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”) announced the addition of more than 300 Russian Federation individuals and companies as well as other individuals and companies alleged to be aiding Russia’s war efforts to the Specially Designated Nationals and Blocked Persons (“SDN”) List. Simultaneously, the U.S.