On February 14, 2019, the Office of Foreign Assets Control (OFAC) announced it had assessed a civil monetary penalty of over $5.5 million dollars against AppliChem GmbH (AppliChem) of Darmstadt, Germany (a company that manufactures chemicals and reagents for the pharmaceutical and chemical industries) for 304 violations of the Cuban Assets Control Regulations, 31 C.F.R. part 515 (CACR). Specifically, OFAC determined that between May 2012 and February 2016, after it had been purchased by a U.S. company and come within the jurisdiction of the U.S. sanctions on Cuba, AppliChem sold chemical reagents to Cuba. 19 C.F.R. § 515.201.

Pedro Szekely

A.The U.S. Company’s Merger and Acquisition Due Diligence Team Successfully Identified the Cuban Sanctions Issue.

On January 1, 2012, Illinois Tool Works, Inc. (ITW), a company based in Glenview, Illinois, acquired AppliChem. In December 2011, during its merger and acquisition due diligence, ITW discovered references to countries subject to U.S. economic and trade sanctions on AppliChem’s website. That same month, ITW told AppliChem it would be required to cease all Cuban transactions after it was acquired. ITW then incorporated AppliChem into its Reagents Division, and allowed AppliChem’s former owners to stay on as manager-employees. On January 12, 2012, the General Manager of ITW’s Reagents Division sent AppliChem’s former owners a memorandum explaining ITW’s guidelines for complying with U.S. sanctions, including the CACR.

B. Willful Evasion by the Non-U.S. Entity and Persons Working for It.

However, despite these warnings, AppliChem continued to complete and collect on existing orders with Cuba under pre-acquisition contracts. Upon discovering AppliChem’s continued Cuban business, ITW’s European legal department sent a third warning to AppliChem’s former owners on April 5, 2012 to immediately cease all sales to Cuba.

In late January, 2016, an anonymous report was made through ITW’s ethics helpline. The call alleged that AppliChem had continued making sales to Cuba through an intermediary company in Berlin, Germany. ITW began a full investigation, which revealed that AppliChem’s former owners had continued AppliChem’s Cuba business by creating a scheme that concealed this business from ITW after having been specifically told by ITW to cease Cuban sales.

Rather than ceasing sales to Cuba as directed by ITW, between February 2012 and April 2012, AppliChem designed and implemented what it called the “Caribbean Procedures” (whereby Cuba was referred to by the code word “Caribbean”), which made sure that no documents mentioning Cuba would be prepared or retained by AppliChem in connection with its continued business with the country. Pursuant to the Caribbean Procedures, AppliChem engaged an external logistics company and an independent hazardous materials consultant to prepare the necessary shipping documents and hazardous materials declarations, which previously had been handled internally.

Once AppliChem implemented the Caribbean Procedures, AppliChem senior management conducted both written and in-person training sessions for AppliChem’s staff, particularly those working in the logistics department, to ensure that Cuba-related sales would be concealed from ITW. The reasons for the implementation of the Caribbean Procedures were “well known to AppliChem staff during this time” and were described by AppliChem staff as an “open secret” at AppliChem. Consequently, between May 2012 and February 2016, AppliChem fulfilled Cuban orders on 304 invoices. The transaction value of the shipments made during this time was €2,833,701 (approximately $3,433,495).

C.  OFAC Investigation and Results

OFAC determined that ITW voluntarily self-disclosed the violations on behalf of AppliChem, and that the violations constituted an egregious case. The statutory maximum civil monetary penalty applicable in this matter was over $20 million dollars. The base civil monetary penalty was over $10 million dollars.

OFAC determined the following to be aggravating factors:

(1) the willful conduct of AppliChem’s management;

(2) the use of written procedures to engage in a pattern of conduct in violation of the CACR;

(3) AppliChem’s sales to Cuba of approximately $3,433,495 in 304 transactions over the course of five years caused significant harm to the sanctions program objective of maintaining a comprehensive embargo on Cuba; and

(4) the size and sophistication of AppliChem, with an average annual revenue of around $23 million between 2012 and 2015, and the fact that it is a subsidiary of ITW, a large international company.

OFAC determined the following to be mitigating factors:

Once ITW discovered ApliChem’s perfidy, it cooperated by filing a thorough voluntary self-disclosure with OFAC, providing prompt responses to requests for information, performing a thorough internal investigation, and signing a tolling agreement on behalf of AppliChem.

This case demonstrates the importance of auditing and verifying foreign subsidiaries. In contrast to previous enforcement actions in which a buyer failed to identify a sanctions exposure, ITW identified the sales and took steps to ensure they ceased. The issue arose because of its new subsidiary’s ability to circumvent those instructions and hide ongoing sales, underscoring the importance of verifying that internal procedures are being followed. Further, U.S. companies with international operations should consider:

(i) implementing risk-based controls, such as regular audits, to ensure subsidiaries are complying with their obligations under OFAC’s sanctions regulations;

(ii) performing follow-up due diligence on acquisitions of foreign persons known to engage in historical transactions with sanctioned persons and jurisdictions; and

(iii) appropriately responding to derogatory information regarding the sanctions compliance efforts of foreign persons subject to the jurisdiction of the United States.

 

 

If you have any questions regarding this penalty decision or any other aspect of U.S. economic sanctions, please do not hesitate to contact our team.

On February 14, 2019, the House of Commons rejected Prime Minister Theresa May’s motion on her approach to Brexit by a majority vote of 303 to 258. While the defeat will have no impact on the March 29th deadline by which time there either needs to be agreement with the EU on the terms for withdrawal or the UK will crash out of the EU with no deal, the loss will make it more difficult for the PM to argue to the EU that she has Commons support for her Brexit strategy. Members of Parliament already voted overwhelmingly against the draft Withdrawal Agreement on January 15, 2019.

Giuseppe Milo

No deal (hard) Brexit would mean that the EU and the UK would be third countries in relation to each other, forcing the UK to automatically fall back on the WTO Most Favored Nation rules unless the UK-EU agreed on a trade deal. Brussels has expressed interest in a plan for a softer Brexit involving a customs union with the EU, but as things currently stand there is no clear or agreed way forward. Time is fast running out for the PM to find a way past the current impasse and any request to delay the exit date would have to be agreed by all 27 EU Member States.

To keep up with the latest in Brexit, please subscribe here.



 


 


 


 


 


 












Updates about the current situation in Venezuela have been coming in rapidly. Recently, we wrote about OFAC adding PdVSA to the SDN list. In this podcast, Crowell & Moring’s Cari Stinebower, Eduardo Mathison, and Mariana Pendás provide an overview of recent developments in Venezuela and explain what U.S. companies need to know about how these developments could impact trade.Compudemano


Click on an option below to access the podcast:


Crowell.com | SoundCloud


 


Crowell & Moring’s Latin America Practice helps clients navigate laws, regulations, and issues by jurisdiction; resolve international disputes and litigation; and assist with both domestic and cross-border corporate and M&A transactions. Additionally, we bring cultural and political sophistication within Latin America to our work and represent clients in both English and Spanish, among other languages. The Crowell & Moring Latin America practice is available to counsel on a wide range of issues. Please click here for contacts and additional information.












In Customs Ruling HQ H290670, the agency discussed a number of issues regarding the country of origin of Ethernet switches, routers, and network cards for purposes of U.S. Government procurement. Notably, the hardware was designed in Taiwan and manufactured in China, later to be provided with software in the United States.


Under the rule of origin set forth under 19 U.S.C. §2518(4)(B):


An article is a product of a country or instrumentality only if (i) it is wholly the growth, product, or manufacture of that country or instrumentality, or (ii) in the case of an article which consists in whole or in part of materials from another country or instrumentality, it has been substantially transformed into a new and different article of commerce with a name, character, or use distinct from that of the article or articles from which it was so transformed.


The company seeking the ruling explained that the assembly process was the same for all the products identified in the ruling. First, metal fabrication was used to create a protective case. This took place in Taiwan. Next, the remaining hardware assembly was done in China, where the country of origin for the individual components of the hardware included various Asian countries, including Singapore, Taiwan, and China. The company explained that the programming done in China was accomplished in order to verify that the product was manufactured correctly. It further explained that the hardware was incapable of performing its intended end function. “[T]herefore, the product enters the United States in a non-functional state.” The final programming on the device and the majority of the programming for the operating system were compiled, downloaded, and completed in the United States. Moreover, the software had to downloaded in order for the products to function as a switch/router.


CBP referenced several rulings that were similar to the company’s routers and switches in reaching its decision. These included HQ H258960 (May 19, 2016), HQ H175415 (Oct. 4, 2011), and HQ H052325 (Mar. 31, 2009). Essentially, the main factor in determining the country of origin for the relevant products is where in the production timeframe was the product ‘finished,’ or became functional as intended. In HQ H258960, CBP considered scenarios wherein in the importer purchased transceivers from Asia, which were then loaded with U.S. developed software in the U.S. Since the transceivers could not function as network devices without the U.S. developed software, the transceivers were substantially transformed as a result of the downloading of the U.S. developed software performed in the U.S. Similarly in HQ H175415, the importer’s Ethernet switches were manufactured wholly in China. Later, they were sent to the United States, where U.S. origin software would be downloaded, giving the hardware the capability of functioning as a local area network device. CBP ruled that the country of origin is the U.S., because without the software, the product could not function as intended.


CBP determined that the company’s non-functioning devices from China were substantially transformed as a result of downloading performed in the U.S., with U.S. developed software. Therefore, CBP the country of origin of the Ethernet switches, routers and network cards for purposes of U.S. Government procurement was the United States.


If you have any questions regarding this ruling please do not hesitate to contact us.


 












The U.S. International Trade Commission (ITC) will be issuing a mandatory questionnaire to companies that benefitted from the Miscellaneous Tariff Bill Act of 2018 (MTB Act). The purpose of the questionnaire is to collect information that will allow the ITC to prepare a report to examine the effect of duty suspensions and reductions contained in the MTB Act on the U.S. economy.


Photo by Guillaume Bolduc on Unsplash;


The MTB Act requires the ITC to solicit and append this report the agency’s recommendations with respect to domestic industry sectors or specific domestic industries that might benefit from permanent duty suspensions and reductions. Once the ITC report is completed, it will be posted at https://www.usitc.gov/mtbeffects for public comment.


Originally announced in the Federal Register on October 9, 2018, the U.S. International Trade Commission (USITC) has also instituted a new fact-finding investigation (Inv. No. 332-565; American Manufacturing Competitiveness Act: Effects of Temporary Duty Suspensions and Reductions on the U.S. Economy) to examine the effects of the newly enacted miscellaneous tariff bill (MTB). However, as a consequence of the Government Shutdown, a yet to be published Federal Register Notice will formally announce new deadlines for filings. These deadlines are:


    

  • Filing requests to appear at the public hearing – March 18 2019;
    • 

  • Filing prehearing briefs and statements – March 21, 2019;
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  • The public hearing is now scheduled for April 8, 2019;
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  • Filing post-hearing briefs – April 15, 2019;
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  • Filing all other written submissions – April 23, 2019; and
    • 

  • The USITC will transmit its report to the House Committee on Ways and Means and the Senate Committee on Finance (Committees) by October 18, 2019.
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All other dates pertaining to this investigation remain the same as in the notice published in the Federal Register on October 9, 2018.


 


 


 












On February 11, 2019, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) amended two General Licenses (GLs) and revised three Frequently Asked Questions (FAQs) relating to the January 28, 2019 designation of Petróleos de Venezuela, S.A. (PdVSA) and the Government of Venezuela.


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The amended GLs provide further guidance on how to navigate the recently-issued sanctions on PdVSA.


Amended GLs:


General License 3C (“GL3C”): replaces GL3B by (a) extending the deadline to wind down financial contracts “involving, or linked to” so-called “GL3C Bonds” from 12:01 AM on March 3 to 12:01 AM on March 11, 2019, and (b) clarifying that the GL only authorizes U.S. Persons to purchase or invest in GL3C Bonds if such purchases or investments are ordinarily incident and necessary to the divestment or transfer of holding in GL3C Bonds.


General License 9B (“GL9B”): replaces GL9A with similar amendments, including by (a) extending the wind-down period to 12:01 AM on March 11, 2019 from March 3, 2019 and (b) clarifying and re-ordering the conditions and exceptions on the granted authorization.


For more information on GL3B and GL9A, please see our recent post.


Updated FAQs:


FAQ 650: addresses the issue of the expected level of due diligence required for the recently amended GLs. It also states that GL3C and GL9B authorize U.S. persons to facilitate the transfer or divestment of securities or bonds to non-U.S. persons.


FAQ 661: provides further explanation on what GL9B authorizes in terms of the PdVSA securities. It states that if a U.S. person decides to sell or transfer any interests in the PdVSA securities, it must be to a non-U.S. person. It also clarifies that U.S. persons may continue to hold their PdVSA securities while still being subject to certain restrictions on the sale in secondary markets.


FAQ 662: explains that GL3C allows U.S. persons to divest, transfer, or facilitate the divestment or transfer of any of GL3C Bonds to any non-U.S. person. Further, it states that U.S. persons may continue to hold their interests in the GL3C Bonds, but are subject to certain restrictions on the sale of those bonds in the secondary market.  Finally, it notes that while non-U.S. persons may continue to deal with the GL3C Bonds, if the transactions involve a U.S. Person or the U.S. financial system, they must comply with the terms of GL3C.


For more information on the PdVSA sanctions and guidance under any Venezuela-related sanction, please contact the Crowell & Moring team.


Crowell & Moring’s Latin America Practice helps clients navigate laws, regulations, and issues by jurisdiction; resolve international disputes and litigation; and assist with both domestic and cross-border corporate and M&A transactions. Additionally, we bring cultural and political sophistication within Latin America to our work and represent clients in both English and Spanish, among other languages. The Crowell & Moring Latin America practice is available to counsel on a wide range of issues. Please click here for contacts and additional information.


 












In less than two months, the United Kingdom may no longer be part of the European Union. Despite that, it is still unclear to what extent U.K. nationals will be able to continue to work in Belgium as they do now. So what can and should you do regarding your U.K. employees or contractors?


Scenario 1 – the main elements of the draft Withdrawal Agreement are adopted


Taken by sabrina-mazzeo unsplash;


In this case, U.K. nationals should encounter no problems in continuing to reside and work in Belgium, provided they are legally resident in Belgium today. The following rules will apply:


    

  • EU law will remain applicable until December 31, 2020 (the implementation period).
    • 

  • Even after this, there will be no change to work and residency rights (they will be ‘subject to the conditions applicable prior to 2021’).
    • 

  • After residing in Belgium for 5 years (starting either before or after the implementation period), they can obtain permanent resident status.
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As importantly, the administrative burden should be manageable. The intention of the Belgian State is to reach out to U.K. nationals holding Belgian residency cards to initiate the process of updating those cards. In practice, the various Belgian communes are likely to contact these U.K. nationals during the implementation inviting them to visit the commune and update their residency cards.


Scenario 2 – No-deal


While employers cannot guarantee that a ‘no-deal scenario’ will have no impact on the work and residency rights of their employees and contractors, they can reassure them that there is a good chance that they will be able to continue to work in Belgium after March 29, at least for the time being.


In principle, a no-deal scenario would deprive all U.K. nationals of their freedom of movement within the EU from March 29, 2019. In principle, U.K. nationals working in Belgium and their employers would require access to a work permit (or, for the self-employed, a professional card).


However, the Belgian government is preparing legislation allowing U.K. nationals lawfully residing in Belgium on March 30, 2019 to continue to live and work in Belgium, at least temporarily. This legislation is currently with of the Council of State for review and advice. We believe that it will be adopted very quickly if it becomes clear that no Withdrawal Agreement will be entered into.


At present, the Belgian authorities are not accepting applications for work permits (or professional cards) for U.K. nationals. So, for the time being therefore, U.K. nationals (and their employers) can only wait and see – and ensure that their residency cards are up to date.


Conclusions


In any likely scenario, the key action point is for all U.K. nationals to make sure they have a valid residency card. Only those with a valid residency card will be contacted by the communes in a Withdrawal Agreement scenario or benefit from any new legislation in a no deal scenario.


Please feel free to contact our Labor & Employment team to answer any questions you may have.


 


 












On January 31 and February 1, 2019, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) amended two General Licenses (GLs) relating to the January 28, 2019 designation of Petróleos de Venezuela, S.A. (PdVSA), amended two Venezuela-related Frequently Asked Questions (FAQs), and issued thirteen new FAQs.


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The new amendments and additions provide additional guidance for navigating the PdVSA sanctions and clarify, to some extent, the scope of authorization in each of the new GLs.


Amended GLs:


    

  • General License 3b (“GL3b”): replaces GL3a by authorizing certain transfers and divestment of funds, provided that they must be to a non-U.S. person. Importantly, it adds a new authorization to enable U.S. persons to engage in transactions necessary to facilitating, clearing, and settling trades of holdings in the bonds specified in the Annex, provided that such trades were placed before February 1, 2019, even if the whole trade was not completed prior to the issuance of the GL. Finally, this GL allows until March 3, 2019, transactions that are necessary to the wind down of financial contracts and other agreements (entered into prior to February 1, 2019).
    • 

  • General License 9a (“GL9a”): replaces GL9 by amending the term, “PdVSA-related debt” to “PdVSA securities,” and authorizing transactions necessary to facilitating, clearing, and settling trades of holdings in the PdVSA securities that were placed before January 28, 2019. GL9a also allows until March 3, 2019, transactions that are necessary to the wind down of financial contracts and other agreements (entered prior to February 1, 2019) linked to PdVSA securities issued prior to August 25, 2017. Lastly, GL9a updates the List of Bonds (Annex) by adding bonds issued by Petrozuata Finance Inc., Cerro Negro Finance Ltd., and La Electricidad de Caracas.
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For more information on the original GL3a and GL9 please see our recent client alert.


Amended FAQs:


In conjunction with the Amended GLs, OFAC issued supplemental guidance in the form of FAQs, as follows:


FAQ 595 was amended to (a) state that GL5 remains in effect despite OFAC’s designation of PdVSA, and (b) include guidance on GL9, which authorizes transactions involving certain PdVSA debt, including the PdVSA 2020 8.5 percent bond.  FAQ 595 states that U.S. persons who are bondholders would be included under this exclusion.​


FAQ 648 defines “maintenance” under GL6 and GL11 to include all transactions that are necessary to continue operations. OFAC further defines the term as including “all transactions and activities ordinarily incident to performing under a contract or agreement in effect prior to the sanctions effective date (in the case of General License 6, January 8, 2019, and in the case of General License 11, January 28, 2019).” It will be key for companies to demonstrate in their transaction history that the transactions it will engage in are consistent and recurring from previous transactions. This FAQ also states that GL6 and GL11 could include renewing contracts if they are ordinarily incident and necessary to contracts in effect prior to the applicable sanctions effective date. However, this FAQ does highlight that U.S. financial institutions may not process transactions that will benefit PdVSA or any entity they possess 50% or more ownership.


NEW FAQs:


The new FAQs provide guidance on the seven newly issued GLs as well as explain the changes and authorizations in the amended GLs:


    

  • Address the expected level of due diligence necessary associated with the transfer of debt under GL9a;
    • 

  • Address bonds issued by PdVSA or any entity in which it owns, directly or indirectly, a 50% or greater interest;
    • 

  • Do not allow funds to be bought, sold, or engaged with any entity that appears in OFAC’s List of Specially Designated Nationals and Blocked Persons (SDN List);
    • 

  • Authorize, with certain exceptions, U.S. person employees of non-U.S. entities located in a country other than the United States or Venezuela to engage in transactions and activities prohibited by E.O. 13850 that are ordinarily incident and necessary to the maintenance or wind down of operations, contracts, or other agreements involving PdVSA or entities owned, directly or indirectly, 50% or more by PdVSA that were in effect prior to January 28, 2019;
    • 

  • State that U.S. persons are allowed to purchase petroleum products from PdVSA as long as funds owed to PdVSA are placed in a blocked, interest-bearing account located in the United States;
    • 

  • State that U.S. persons in Venezuela are allowed to purchase gasoline products from PdVSA as long as it is done in a blocked, interest-bearing account located in the United States;
    • 

  • Address cash transactions with PdVSA;
    • 

  • Address exporting issues, while noting that the GLs do not generally extend to cover transactions with ALBA de Nicaragua (ALBANISA), meaning U.S. persons are generally prohibited from engaging in most transactions with ALBANISA today; and
    • 

  • Explain that the path to sanctions relief for PdVSA is through a bona fide transfer of control of the company to Interim President Juan Guaidó or a subsequent, democratically elected government.
    • 



 


For more information on the PdVSA sanctions and guidance under any Venezuela-related sanction, please contact the Crowell & Moring team.


 


Crowell & Moring’s Latin America Practice helps clients navigate laws, regulations, and issues by jurisdiction; resolve international disputes and litigation; and assist with both domestic and cross-border corporate and M&A transactions. Additionally, we bring cultural and political sophistication within Latin America to our work and represent clients in both English and Spanish, among other languages. The Crowell & Moring Latin America practice is available to counsel on a wide range of issues. Please click here for contacts and additional information.












On January 31, 2019, e.l.f. Cosmetics, Inc. (“ELF”) agreed to pay $996,080 to settle its potential civil liability for 156 apparent violations of the North Korea Sanctions Regulations (NKSR). Elf is a cosmetics company headquartered in Oakland, California.


(Stephan)


ELF appeared to have violated § 510.201(c)1 of the NKSR by importing 156 shipments of false eyelash kits from two suppliers located in the People’s Republic of China (PRC) that contained materials sourced by these suppliers from the Democratic People’s Republic of Korea (DPRK). The total value of the imported shipments equaled $4,427,019.26. The statutory maximum civil monetary penalty amount for the apparent violations was $40,833,633, and the base civil monetary penalty amount for the apparent violations was $2,213,510.


OFAC determined that throughout the time period in which the apparent violations occurred, ELF’s OFAC compliance program was either non-existent or inadequate. The company’s production review efforts focused on quality assurance issues pertaining to the production process, raw materials, and end products of the goods it purchased and/or imported. Until January 2017, ELF’s compliance program and its supplier audits failed to discover that approximately 80 percent of the false eyelash kits supplied by two of ELF’s China-based suppliers contained materials from the DPRK.


OFAC considered the following facts and circumstances pursuant to the General Factors under OFAC’s Economic Sanctions Enforcement Guidelines, 31 C.F.R. Part 501, Appendix A, in reaching the settlement amount. It found the following to be aggravating factors:


    

  • The apparent violations may have resulted in U.S.-origin funds coming under the control of the DPRK government, in direct conflict with the program objectives of the NKSR;
    • 

  • ELF is a large and commercially sophisticated company that engages in a substantial volume of international trade; and
    • 

  • ELF’s OFAC compliance program was either non-existent or inadequate throughout the time period in question.
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OFAC found the following to be mitigating factors in this case:


    

  • ELF’s personnel do not appear to have had actual knowledge of the conduct that led to the apparent violations in this investigation;
    • 

  • ELF has not received a Penalty Notice or Finding of Violation from OFAC in the five years preceding the earliest date of the transactions giving rise to the apparent violations;
    • 

  • The apparent violations do not appear to constitute a significant part of ELF’s business activities; and
    • 

  • ELF cooperated with OFAC by immediately disclosing the apparent violations, signing a tolling agreement, and submitting a complete and satisfactory response to OFAC’s request for additional information.
    • 



ELF then terminated the conduct which led to the apparent violations and has undertaken the following steps to minimize the risk of recurrence of similar conduct in the future:


    

  • Implemented supply chain audits that verify the country of origin of goods and services used in ELF’s products;
    • 

  • Adopted new procedures to require suppliers to sign certificates of compliance stating that they will comply with all U.S. export controls and trade sanctions;
    • 

  • Conducted an enhanced supplier audit that included verification of payment information related to production materials and the review of supplier bank statements;
    • 

  • Engaged outside counsel to provide additional training for key employees in the United States and in China regarding U.S. sanctions regulations and other relevant U.S. laws and regulations; and
    • 

  • Held mandatory training on U.S. sanctions regulations for employees and suppliers in China and implemented additional mandatory trainings for new employees, as well as, regular refresher training for current employees and suppliers based in China.
    • 



The notice from OFAC regarding this enforcement action highlights the risks for companies that do not conduct full-spectrum supply chain due diligence when sourcing products from overseas, particularly in a region in which the DPRK, as well as other comprehensively sanctioned countries or regions, is known to export goods.


OFAC indicated that it encourages companies to develop, implement, and maintain a risk-based approach to sanctions compliance and to implement processes and procedures to identify and mitigate areas of risks. It also explained that such steps could include, but are not limited to, implementing supply chain audits with country-of-origin verification; conducting mandatory OFAC sanctions training for suppliers; and routinely and frequently performing audits of suppliers.


 


For more information and in response to any questions regarding OFAC regulations and supply chain compliance please feel free to contact us.












The U.S. Department of Commerce (Department) posted a generic version of its tolling memorandum extending all deadlines before the Department in all Antidumping and Countervailing Duty (AD/CVD) proceedings active during the partial government shutdown.


A copy of the memorandum can be found here on the International Trade Administration’s Enforcement and Compliance Website.