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How Do You, Your Suppliers and Customers Fare as Trade Tensions Escalate?

UPDATE: The Tariff Book was updated on May 10, 2019 to reflect an updated action on Section 301 by the Trump Administration that increased tariffs on $200 billion worth of Chinese products (List 3). How To Use The Tariff Book Because there is so much information included in this Tariff Book, we have made the document fully searchable. … Continue Reading

Deadline Approaches for Certain Transitioning USML Category Items to CCL

Due to the Export Control Reform (ECR) that began nearly six years ago, the Department of States’s Directorate of Defense Trade Controls (DDTC) has updated 18 of the 21 categories in the United States Munitions List (USML), and most of these categories had items transition to the Commerce Control List (CCL) of the Export Administration Regulations (EAR) by respective … Continue Reading

DDTC Fines Alleged Violations of ITAR and Failure to Appoint Qualified Empowered Offcial

On February 28, 2019, with a civil penalty of US$400,000, Darling Industries, Inc. of Tucson, Arizona settled allegations for violating six counts of the Arms Export Control Act (AECA), as well as the International Traffic in Arms Regulations (ITAR), in connection with unauthorized exports of defense articles, provisions of defense services and failure to appoint a qualified Empowered Official.… Continue Reading

OFAC Reaches Settlement Agreement With e.l.f. Cosmetics, Inc.

On January 31, 2019, the Department of Treasury’s Office of Foreign Assets Control (OFAC) announced that it has reached a settlement agreement with e.l.f. Cosmetics, Inc. in the amount of US$996,080 for potential civil liability relating to 156 apparent violations of North Korea Sanctions Regulations. The potential violations stem from importation of false eyelash kits from the People’s Republic of … Continue Reading

OFAC Issues New Venezuela-related Executive Order and General Licenses

On January 28, 2019, the Department of Treasury’s Office of Foreign Assets Control (OFAC) announced that it has designated Petroleos de Venezuela, S.A. (PdVSA) following Executive Order (E.O.) 13850, after a determination by Treasury Secretary Steven T. Mnuchin and Secretary of State Michael Pompeo that PdVSA was operating in the Venezuelan oil sector. Additionally, OFAC has amended General License 3 and … Continue Reading

OFAC Issues Venezuela-related General License 6

On January 8, 2019, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Venezuela-related General License 6, which authorizes the winding down of certain specified transactions with Globovision Tele C.A. and Globovision Tele CA, Corp. until January 8, 2020. Additionally, OFAC issued new FAQs for General License 6, and also added several new individuals and entities to … Continue Reading

BIS Announces Former Florida CEO Pleads Guilty to Export Violations

On December 14, 2018, the Bureau of Industry and Security (BIS) announced that Eric Baird, former Chief Executive Officer for a Florida based package consolidation and shipping service, pleaded guilty to a single count of felony smuggling and 166 violations of US export control laws. On December 12, 2018, BIS imposed civil penalties of US$17 million and a five-year denial … Continue Reading

US Government Contracts Quick Hit Briefing: Small Business Runway Extension Act Becomes Law, Yet Implementation Halted by Government Shutdown

On December 17, 2018, President Trump signed into law the Small Business Runway Extension Act of 2018 (HR 6330) (the Act), which modifies the period to measure small business size status from three fiscal years of average annual receipts to five fiscal years.… Continue Reading
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