On April 15, 2021, the United States unveiled a sweeping series of additional sanctions on Russia, marking the first major Russia-related sanctions development of the Biden Administration and the most material such U.S. action in several years. The actions were spearheaded by President Biden’s issuance of an as-yet-unnumbered Executive Order (the “EO”) that grants the
Laurel Saito
BIS Rule on Military Intelligence End User Restrictions Becomes Effective Despite White House Regulatory Review
On January 15, 2021, in the final days of the Trump Administration, BIS published an Interim Final Rule, Expansion of Certain End-Use and End-User Controls and Controls on Specific Activities of U.S. Persons, also referred to as the Military Intelligence End User rule (“MIEU Rule”). It was set to be effective March 16, 2021…
Customs CAATSA Ruling: Apparel Protest Denied over Forced Labor Concerns
On March 5, 2021, U.S. Customs and Border Protection (CBP) denied Dandong Huayang’s protest, which asserted that North Korean nationals did not produce garments that were imported under two separate entries. CBP determined that the materials submitted by the protestant did not establish clear and convincing evidence that Dandong Huayang did not use North Korean…
UPDATE: Export Control Agencies Coordinated Response Target Russia for Prohibited Chemical Weapon Activities
In an update to our prior post published on March 8, the Bureau of Industry and Security (BIS) and State Department published additional actions against Russia in response to the poisoning of Aleksey Navalny on March 18. The new sanctions and export controls are summarized below.
Bureau of Industry and Security
The Secretary of…
CBP Finds Disposable Gloves Made in Malaysia Are Manufactured with Forced Labor
On March 29, 2021, U.S. Customs and Border Protection (CBP) is scheduled to publish a Notice of Finding that certain disposable gloves produced by Top Glove Corporation Bhd (Top Glove) in Malaysia are made with forced labor. Section 307 of the Tariff Act of 1930 prohibits the importation of goods “mined, produced, or manufactured wholly…
U.S. Court of Appeals for the Federal Circuit Asks Trade Attorneys to Simplify Briefs
During a recent panel at Georgetown Law’s annual International Trade Update, two Federal Circuit judges urged trade attorneys to consider their audience and simplify their briefs. Although the U.S. Court of International Trade is specialized, Federal Circuit Judge Todd M. Hughes emphasized how the conversation must change when a trade matter is appealed to the…