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Ruslan Klafehn

A former attorney in the U.S. Department of Commerce’s Office of the Chief Counsel for Trade Enforcement and Compliance, Ruslan advises clients on U.S. trade law to help maximize commercial opportunity while minimizing regulatory risk and penalties.

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

On August 24, 2026, pursuant to Executive Order 14312, the U.S. Department of State took action to rescind Syria’s designation as a State Sponsor of Terrorism (“SST”).  Additionally, the State Department and U.S. Department of the Treasury concurrently removed Hay’at Tahrir al-Sham’s (“HTS”) designation as a Specially Designated Global Terrorist (“SDGT”) organization and Specially

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.

On June 11, 2026, the U.S. Court of Appeals for the Federal Circuit (CAFC) granted the federal government’s motion for a stay pending appeal, pausing enforcement of a U.S. Court of International Trade (CIT) injunction on the collection of Section 122 duties against the State of Washington and two private businesses – Burlap and Barrel, Inc. and Basic Fun, Inc.

In the latest developments regarding tariffs paid under the International Economic Emergency Powers Act (“IEEPA”), the U.S. Department of Justice (“DOJ”) has formally appealed the U.S. Court of International Trade’s (“CIT”) April 17, 2026, universal injunction ordering refunds to all importers to the U.S. Court of Appeals for the Federal Circuit (“Federal Circuit”).  The DOJ has

On May 20, 2026, the U.S. Court of International Trade (CIT) denied the Government’s request to pause the CIT’s May 7 ruling during the appeals process. For now, Section 122 duties remain unlawful, and U.S. Customs & Border Protection (CBP) cannot collect Section 122 duties from plaintiffs Burlap & Barrel, Basic Fun, and the State of Washington.