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.
Omaha-based partner Grant Leach appeared last week on an episode of The Justice Insiders podcast to discuss the ever-expanding set of requirements and restrictions placed on U.S. businesses in connection with trade law, including a key change in the statute of limitations—from five years to ten—in connection with the Office of Foreign Assets Control (OFAC)
On May 22, 2024, the U.S. Trade Representative released a draft Federal Register notice containing the list of imported goods for which it proposes to increase Section 301 duty rates. USTR also announced that it was considering an exclusion process by which U.S. manufacturers may request that “particular machinery used in domestic manufacturing be temporarily
On March 22, 2024, the Department of Commerce (“Commerce”) released its anticipated new final countervailing duty regulations authorizing the agency to investigate subsidies provided by third country governments to manufacturers in the country under investigation. From 1997 to the present, Commerce limited its examination of subsidies to those programs and benefits provided by the investigated
On March 28, 2024, CC Metals and Alloys, LLC (“CCMA”) and Ferroglobe USA, Inc.(“Ferroglobe”) (“Petitioners”), filed a petition for the imposition of antidumping and countervailing duties on ferrosilicon from the Federative Republic of Brazil (“Brazil”), the Republic of Kazakhstan (“Kazakhstan”), Malaysia, and the Russian Federation (“Russia”).
SCOPE OF THE INVESTIGATION
The following language describes
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
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
On December 8, 2023, Senators Bill Cassidy and Sheldon Whitehouse introduced a new version of the Customs Modernization bill to amend the Tariff Act of 1930. The new proposal comes over two years after Senator Cassidy initially proposed draft legislation, which we explained in a prior post. The most recent proposed bill aims to
On July 27, 2023, the Department of Commerce’s Bureau of Industry and Security (BIS) announced that U.S. persons reporting boycott-related requests to its Office of Antiboycott Compliance (OAC) must now also disclose the identity of the specific party that made the request. Previously, U.S. persons were required to disclose when they had received a boycott-related
On Wednesday, July 26, the Departments of Commerce, Treasury, and Justice issued a Tri Seal Compliance Note detailing the voluntary self-disclosure of potential violations for export controls, sanctions, and other national security laws. The Compliance Note highlights the new changes made to the Department of Justice’s voluntary self-disclosure policy. The Note also provided an overview