On January 21, 2026, U.S. Customs and Border Protection (“CBP”) announced that its Forced Labor Portal is now live. This new online portal provides a single, centralized platform for importers to submit requests for review when their shipments are detained or excluded due to forced labor enforcement actions. By consolidating what was previously a patchwork
Treasury to Issue All CBP Refunds Electronically Starting in February
The U.S. Department of the Treasury will cease issuing paper checks for all U.S. Customs and Border Protection (“CBP”) refunds starting on February 6, 2026 according to an Interim Final Rule. A recipient may continue to receive paper checks provided that they have an approved waiver in place in accordance with 31 C.F.R. §
Trump Exempts Agricultural Products from IEEPA Reciprocal Tariffs
On November 14, 2025, President Trump signed an executive order modifying the scope of reciprocal tariffs originally imposed under Executive Order 14257 of April 2, 2025, which declared a national emergency based on large and persistent U.S. goods trade deficits. The November 14 order exempts certain agricultural products from the reciprocal tariff regime, effective for
UK Sanctions Lukoil, Rosneft in Major Russia Sanctions Expansion
On October 15, 2025, the UK announced a significant expansion of its Russia-related sanctions regime, designating Lukoil and Rosneft—Russia’s two largest oil companies—as asset freeze targets.
This is the first time Lukoil and Rosneft have been subjected to full asset freezing sanctions by any of the UK, U.S., or EU, and follows earlier UK measures
CIT Vacates CBP Forced Labor Finding Against Aluminum Importer
On September 23, 2025, the U.S. Court of International Trade (CIT) issued an opinion vacating and remanding U.S. Customs and Border Protection’s forced labor Finding against Kingtom Aluminio S.R.L., a Dominican Republic-based aluminum extruder. The court found that CBP’s determination, which prohibited the entry of Kingtom’s aluminum extrusions under Section 307 of the Tariff Act
Client Alert: Impending Deadline for UN Action on Iran: What the “Snapback” of Iran Sanctions Could Mean for Global Business
On August 28, France, Germany, and the UK (the E3) initiated a “snapback” process that will reimpose UN sanctions on Iran on September 27 unless the Security Council acts. On September 19, a resolution to extend sanctions relief failed to receive sufficient votes at the Security Council and was not adopted. If snapback occurs, previously
Department of State Issues Final Rule, Effective Sept. 15, 2025, Updating ITAR and Targeted Revisions to the U.S. Munitions List
On August 27, 2025, the Department of State published a final rule amending the International Traffic in Arms Regulations (“ITAR”) and updating the U.S. Munitions List (“USML”). The rule, effective September 15, 2025, implements changes following public comment and periodic review required under the Arms Export Control Act.
The latest ITAR amendments remove certain items
DHS 2025 UFLPA Update Targets New Industries and Expands Entity List
On August 19, 2025, the Forced Labor Enforcement Task Force, chaired by the Department of Homeland Security and including agencies such as the Department of Labor, released its annual update to the Strategy to Prevent the Importation of Goods Mined, Produced, or Manufactured with Forced Labor in the People’s Republic of China. This update, required
Joint Criminal and Civil Export Controls Enforcement: Lessons from the Cadence Case
On July 28, 2025, Cadence Design Systems Inc., a global electronic design automation technology company based in San Jose, California, agreed to plead guilty to export violations in a settlement with the U.S. Department of Justice’s National Security Division and the U.S. Attorney’s Office for the Northern District of California, and resolved a civil enforcement
De Minimis to be Eliminated July 2027 under Recently Enacted Megabill
As part of the tax and spending provisions included in the “Megabill” signed by Trump into law on July 4, 2025 are provisions that eliminate the de minimis exemption under Section 321 of the Tariff Act of 1930. The de minimis exemption currently allows shipments not exceeding $800 to enter the U.S. duty-free, excluding shipments