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President Trump: “When It Comes to Leverage, Tariffs Are King” – What You Need to Know

Since taking office in January 2017, President Trump has made use of several provisions of US law – including Section 301, targeting unfair trade practices, and Section 232, targeting threats to national security – to bring trading partners to the negotiating table. Major developments over the last two weeks could impact global supply chains across a wide range … Continue Reading

US Commerce Department Offers Huawei and Affiliated Suppliers Interim Reprieve by Granting Temporary General License Until August 2019

On May 22, 2019, the US Department of Commerce, Bureau of Industry and Security (BIS) is expected to publish in the Federal Register a Final Rule creating a 90-day Temporary General License (TGL) for Huawei Technologies Co., Ltd. (Huawei) and the 68 affiliated Huawei entities (collectively, the “Huawei Listed Companies”) that were added to the … Continue Reading

US Changes Policy on Helms-Burton Act – Litigation Strategy for Companies Active in Cuba

On May 2, the Trump Administration ceased waiving Title III of the Helms-Burton Act, thus allowing US individuals and companies to file lawsuits against companies that are operating in Cuba and “trafficking” in (meaning, using or profiting from) property in Cuba which was confiscated from them by the government of Cuba. (For additional details, read our earlier publication.) The … Continue Reading

Trump Secures US Telecom Supply Chain with Executive Order; Related Huawei Actions

On May 15, 2019, President Donald Trump issued an Executive Order (EO) titled “Securing the Information and Communications Technology and Services Supply Chain.” The long-awaited EO addresses the use in US communications networks of technologies from certain types of foreign companies.… Continue Reading

US Adds Huawei and Affiliates to the Department of Commerce Entity List – What to Expect From the Final Rule

On May 21, 2019 the US Commerce Department, Bureau of Industry and Security (BIS) is expected to publish in the Federal Register a Final Rule designating Huawei Technologies Co., Ltd. (Huawei) and 68 affiliated Huawei entities located in 26 countries (collectively, the “Huawei Listed Companies”) to the Entity List. … Continue Reading

Webinar: US-Russia: Anti-corruption, Sanctions and Counter-sanctions and Compliance for Companies Doing Business Between the US and Russia – Presentation Material Now Available

UPDATE:  The presentation slides for the this webinar is now available in the Learning Center section of this blog.  Please contact the presenters noted in the materials with any questions. Our webinar with Lexology to discuss the evolving anti-corruption, sanctions landscapes with respect to the US and Russia and resources for companies to strengthen compliance is set … Continue Reading

Export Controls & Technology Transfers Conference – June 19-20, 2019 | Washington DC

We are once again joining forces with marcus evans® for this year’s export controls and technology transfers conference (June 19-20 in Washington DC) as Knowledge Partner. George Grammas will chair day one of the conference, which aims to provide information on fortifying export control practices through strengthened compliance and adaptation to reoccurring updates and evolving … Continue Reading

The Real Significance of OFAC’s Sanctions Compliance Guidance | Sanctions Webinar on May 16, 2019

On May 2, 2019, the US Department of Treasury’s Office of Foreign Assets Control (OFAC) released guidance on effective sanctions compliance programs. While this is the first document of this kind from OFAC, similar guidance documents by the US Department of Justice (DOJ) and the Securities and Exchange Commission (SEC) have been on the books … Continue Reading

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
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