The latest on Russia sanctions from the International Trade and Supply Chain Team
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The Department of Commerce (“Commerce”) published a notice seeking comments from interested parties on steps Commerce should take to modify its application of a “particular market situation” (“PMS”) analysis in…

Continue Reading Commerce Soliciting Comments on Changes to Particular Market Situation in Antidumping Duty Proceedings

On October 3, 2022, the Department of Commerce (“Commerce”) announced in the Federal Register the opportunity to request an annual administrative review for products that are currently subject to antidumping and countervailing duties and suspension agreements. The products and countries that have been listed in the Federal Register notice are the following:…

Continue Reading Opportunity to Request Administrative Review

Matthew Axelrod, the Assistant Secretary for Export Enforcement at the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”), told a conference held by the Society for International Affairs on May 16, 2022, that his agency is considering major policy changes to its administrative enforcement authorities.  Axelrod said the policy changes, expected to be rolled out in the next few months, are intended to incentivize export compliance by corporations under the Export Administration Regulations (“EAR”).  …
Continue Reading BIS Considers More Public and Expensive Consequences for Companies Violating the EAR

On March 30, 2022, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) modified and expanded a list of aircraft that have flown into Russia in apparent violation of the Export Administration Regulations (“EAR”).  We more thoroughly discussed the implications of this list – which was first published on March 18, 2022 – in our blog post here.  The updated list adds 73 additional Boeing-manufactured aircraft and modifies tail and/or serial number information for 13 aircraft previously listed on March 18, 2022.  The full list of owners/operators include Aeroflot, AirBridge Cargo, Aviastar-TU, Alrosa, Atran, Azur Air, Nordstar, Nordwind, Pegas Fly, Pobeda, Rossiya, Royal Flight, S7 Airlines, and Utair (FC Chelsea owner Roman Abramovich’s private Gulfstream jet is also on the list).
Continue Reading BIS Modifies and Expands List of Russian-Controlled Aircraft Subject to the EAR Known or Suspected to Have Violated the EAR

On February 10, 2022, the Department of Commerce published a Federal Register notice requesting public comments on the Section 232 exclusions process.  The notice follows the agreement reached between the U.S. and the EU related to the tariff rate quotas for steel and aluminum articles from EU member countries and the President’s January 3, 2022 announcement, Adjusting Imports of Steel into the United States (Proclamation 10328).
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Continue Reading Commerce Requesting Public Comments on Section 232 Exclusion Process

The U.S. Department of Commerce (“Commerce”) announced on Friday that it was set to resume trade missions starting as early as March 2022.  Trade missions are government- led programs where members of the trade can meet directly with foreign industries and officials to explore potential business opportunities.  The COVID-19 pandemic brought these missions to a sudden halt in March 2020 and no trade missions have occurred in the past 24 month.  The International Trade Administration (“ITA”) is now preparing to resume in-person trade missions, where possible.
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Continue Reading Commerce Trade Missions Set to Resume in March 2022