OFAC

Week Seventeen

CIT Unequivocally Strikes Down IEEPA Tariffs as Invalid

On May 28, 2025, a three-judge panel of the U.S. Court of International Trade (CIT), in a unanimous decision, held tariffs imposed by the Trump Administration pursuant to the International Emergency Economic Powers Act of 1977 (IEEPA) to be unlawful and invalid. The CIT’s order

CBP Issues Facility Requirements for Bonded Warehouses

In a Cargo Systems Messaging Service (“CSMS”) message, U.S. Customs and Border Protection (“CBP”) clarified that bonded warehouses, as defined in 19 C.F.R. § 19.1, do not include container freight stations, inspectional facilities, express consignment facilities, etc., and therefore are not authorized for acceptance of Type 21/22

U.S.-China Trade War Intensifies

On April 8, 2025, President Trump issued an Executive Order raising the reciprocal tariff rate on Chinese imports from 34% to 84%. This move followed his earlier warning that the U.S. would impose a 50% increase unless China withdrew its 34% retaliatory tariffs on American goods.

China swiftly responded by matching

This blog post covers trade developments occurring during the seventh week of the new Trump Administration. It covers events occurring through 12:00 pm Eastern time on Friday, March 7.

Import-Related Developments

IEEPA Tariffs on Canada and Mexico Take Effect March 4 but Modified Two Days Later

The tariffs imposed by President Trump on Canada and

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 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.

On Friday, February 24, 2023, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued new sanctions against individuals and entities operating in Russia and against those assisting with Russia’s war efforts in Ukraine. In combination with OFAC’s additional sanctions, BIS also implemented additional export control measures and added 86 identified supporters of the