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Articles by Eric Dama
Treasury Proposes Expanded Outbound Investment Rules: What Investors in Critical Technologies Need to Know
On October 22, 2026, the US Department of the Treasury (Treasury) issued a Notice of Proposed Rulemaking (NPRM) to implement the Comprehensive Outbound Investment National Security (COINS) Act. As discussed in our prior alert, the COINS Act codified Treasury’s Outbound Investment Security Program (OISP) and required its expansion.
CBP Issues CSMS Guidance on Section 338 Canada Duties
U.S. Customs and Border Protection (CBP) recently issued guidance via the Cargo Systems Messaging Service (CSMS) on filing entries for imports from Canada subject to duties under Section 338 of the Tariff Act of 1930 (Section 338). We previously covered President Trump’s imposition and subsequent modification of these Section 338 tariffs here, here, and here.
New CPSC eFiling Requirement Signals Major Change for Consumer Product Imports
Companies importing consumer products into the United States now face a significant compliance change. As our colleagues on Product Perspective explain, effective July 8th, the U.S. Consumer Product Safety Commission’s (CPSC) new eFiling requirement requires importers to electronically submit product safety certificate information at the time of entry.
New CPSC eFiling Requirement Signals Major Change for Consumer Product Imports
Companies importing consumer products into the United States now face a significant compliance change. As our colleagues on Product Perspective explain, effective July 8th, the U.S. Consumer Product Safety Commission’s (CPSC) new eFiling requirement requires importers to electronically submit product safety certificate information at the time of entry.
President Trump Reduces Section 232 Tariffs on Certain Agricultural, Mobile Industrial, and HVAC Equipment [UPDATED June 5, 2026 with CSMS Instructions]
On June 1, 2026, President Trump issued a proclamation reducing tariff rates on certain agricultural equipment, mobile industrial equipment and machinery, and heating, ventilation and air conditioning (“HVAC”) equipment under Section 232 of the Trade Expansion Act of 1962 (“Section 232”). In the same proclamation, President Trump also added aluminum lithographic plates and steel racks to the list of aluminum and steel derivative products subject to Section 232 tariffs.
Weekly Trade Update: June 1 – 5, 2026
USTR Proposes Section 301 Tariffs on Brazil On June 1, 2026, the United States Trade Representative (“USTR”) proposed under Section 301 of the Trade Act of 1974 (“Section 301”) to impose tariffs on imports of goods from Brazil due to Brazil’s practices involving digital trade and electronic payment services, unfair and preferential tariffs, anti-corruption enforcement, intellectual property protection, ethanol market access, and illegal deforestation.
President Trump Reduces Section 232 Tariffs on Certain Agricultural, Mobile Industrial, and HVAC Equipment [UPDATED June 5, 2026 with CSMS Instructions]
On June 1, 2026, President Trump issued a proclamation reducing tariff rates on certain agricultural equipment, mobile industrial equipment and machinery, and heating, ventilation and air conditioning (“HVAC”) equipment under Section 232 of the Trade Expansion Act of 1962 (“Section 232”). In the same proclamation, President Trump also added aluminum lithographic plates and steel racks to the list of aluminum and steel derivative products subject to Section 232 tariffs.
Weekly Trade Update: June 1 – 5, 2026
USTR Proposes Section 301 Tariffs on Brazil On June 1, 2026, the United States Trade Representative (“USTR”) proposed under Section 301 of the Trade Act of 1974 (“Section 301”) to impose tariffs on imports of goods from Brazil due to Brazil’s practices involving digital trade and electronic payment services, unfair and preferential tariffs, anti-corruption enforcement, intellectual property protection, ethanol market access, and illegal deforestation.
President Trump Issues Executive Order to Bolster U.S. Customs Enforcement
On June 3, 2026, President Trump issued an executive order (“EO”) directing U.S. Customs and Border Protection (“CBP”) to reform many of its enforcement provisions. Titled “Strengthening Customs Enforcement,” the EO targets preventing the importation of unlawful and dangerous goods, tightening eligibility and identification requirements for importers of record (“IORs”), and ensuring compliance with Federal laws and timely collection of duties.
USTR Proposes 301 Tariffs on 60 Countries Following Forced Labor Findings; Requests Comments Before July 7th Hearing
On June 2, 2026, the United States Trade Representative (“USTR”) proposed tariffs under Section 301 of the Trade Act of 1974 (“Section 301”) on imports from 60 countries for their failure to enforce prohibitions related to forced labor. The USTR found that these failures are unreasonable and burden U.S. commerce. The proposed tariffs range from 10% to 12.5%, though they do contain several carveouts.
President Trump Reduces Section 232 Tariffs on Certain Agricultural, Mobile Industrial, and HVAC Equipment
On June 1, 2026, President Trump issued a proclamation reducing tariff rates on certain agricultural equipment, mobile industrial equipment and machinery, and heating, ventilation and air conditioning (“HVAC”) equipment under Section 232 of the Trade Expansion Act of 1962 (“Section 232”). In the same proclamation, President Trump also added aluminum lithographic plates and steel racks to the list of aluminum and steel derivative products subject to Section 232 tariffs.
USTR Initiates Section 301 Investigation on Vietnam’s Intellectual Property Practices
On May 29, 2026, the Office of the U.S. Trade Representative announced it initiated an investigation of Vietnam under Section 301 of the Trade Act of 1974 (“Section 301”) regarding the country’s intellectual property protection and enforcement. The USTR had identified Vietnam as a “Priority Foreign Country” in its April 30, 2026 Special 301 Report. According to that report, Vietnam has failed to resolve long-standing concerns about IP protection and enforcement, which has impacted U.S. innovation.
DOJ to Appeal CIT Order Requiring IEEPA Duty Refunds for Finally Liquidated Entries
On May 29, 2026, the U.S. Department of Justice (“DOJ”) indicated that it will appeal the U.S. Court of International Trade’s (“CIT”) universal injunction ordering U.S. Customs and Border Protection (“CBP”) to reliquidate final entries (entries more than 90 days past liquidation) and refund duties paid under the International Economic Emergency Powers Act (“IEEPA”) by importers who have not themselves filed complaints with the CIT.
CIT Orders Depositions of CBP and BIS in Section 232 Exclusion Challenge
On April 15, 2026, the U.S. Court of International Trade (“CIT”) ordered U.S. Customs and Border Protection (“CBP”) and the Commerce Department’s Bureau of Industry and Security (“BIS”) to sit for depositions in a case filed by an importer seeking refunds of tariffs imposed under Section 232 of the Trade Expansion Act of 1962 (“Section 232”).
Customs IEEPA Refund Portal – CAPE – To Go Live on Monday April 20, 2026
This update covers three key developments this week: (1) U.S. Customs and Border Protection (“CBP”) filed its latest status update in Euro-Notions on April 14, 2025; (2) Judge Eaton thereafter issued another order; and (3) next steps / recommendations for importers. 1. CBP Status Update As a reminder, since the Atmus Filtration case is now dismissed, Euro-Notions is the new IEEPA refund “lead case”.
International Trade & Supply Chain Law: 2025 Year in Review & Outlook for 2026 | JD Supra
A year into Trump’s second term, few areas have undergone major policy shifts within international trade and supply chain. Check out our team’s assessment of what the coming year may bring for trade regulation and enforcement.
BIS Issues New Guidance to Combat Russia Diversion Risks and Highlights Recent Enforcement Actions
Recently, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued new guidance to exporters intended to further assist BIS in its efforts to crack down on third-party diversion to Russia.
BIS Issues New Guidance to Combat Russia Diversion Risks and Highlights Recent Enforcement Actions | JD Supra
*[co-author: Angelina Maleska] Recently, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued new guidance to exporters intended to further assist BIS in its efforts to crack down on third-party diversion to Russia.
Commerce Department Bans Kaspersky Software in First ICTS Prohibition, Signals Increased Risk of Using Certain Foreign Software and Technology | JD Supra
*[co-author: Dakota Nichols] On June 20, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a Final Determination prohibiting the sale of certain cybersecurity products, anti-virus software, and related services to U.S. persons by Kaspersky Lab, Inc. (“Kaspersky”), the U.S. subsidiary of Russian cybersecurity provider AO Kaspersky Lab.
U.S. Government Imposes Over 600 Denied Parties Designations On Second Anniversary Of Russia’s Ukraine | JD Supra
Sanctions Designations and Business Advisory Issued by OFAC and the U.S. State Department On February 23, 2024, the Treasury Department’s Office of Foreign Assets Control (“OFAC”) and Department of State together announced more than 500 sanctions designations targeting government officials, companies, and individuals in Russia and beyond.
U.S. GOVERNMENT IMPOSES OVER 600 DENIED PARTIES DESIGNATIONS ON SECOND ANNIVERSARY OF RUSSIA’S UKRAINE
Sanctions Designations and Business Advisory Issued by OFAC and the U.S. State Department On February 23, 2024, the Treasury Department’s Office of Foreign Assets Control (“OFAC”) and Department of State together announced more than 500 sanctions designations targeting government officials, companies, and individuals in Russia and beyond.
Executive Order Imposes New Russia Sanctions for Foreign Financial Institutions and Prohibits Additional Russian Imports | JD Supra
Executive Order Imposes New Russia Sanctions for Foreign Financial Institutions and Prohibits Additional Russian Imports On December 22, 2023, President Biden issued Executive Order 14114, which amended previous Executive Orders in order to authorize the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) to impose additional Russia-related sanctions on foreign financial institutions and expand the scope of existing import prohibitions for certain Russian goods.
Executive Order Imposes New Russia Sanctions for Foreign Financial Institutions and Prohibits Additional Russian Imports
Executive Order Imposes New Russia Sanctions for Foreign Financial Institutions and Prohibits Additional Russian Imports On December 22, 2023, President Biden issued Executive Order 14114, which amended previous Executive Orders in order to authorize the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) to impose additional Russia-related sanctions on foreign financial institutions and expand the scope of existing import prohibitions for certain Russian goods.
Biden Administration Issues Executive Order to Restrict U.S. Investment in Chinese Technology Sectors
Last week, President Biden issued an Executive Order outlining the long-anticipated proposed restrictions on outbound U.S. investments in entities located in China or otherwise subject to China’s jurisdiction.
Commerce Issues Final Determination on Circumvention of Solar Cells and Modules from Cambodia, Malaysia, Thailand, and Vietnam | JD Supra
On August 18, 2023, the Department of Commerce (“Commerce”) announced its final determination that certain solar cells and modules exported from Cambodia, Malaysia, Thailand, and Vietnam are circumventing the antidumping (“AD”) and countervailing (“CVD”) orders on imports from China after conducting its investigation for over 18 months. Any duties will only go into effect in June 2024, subject to available certifications and exemptions. Commerce’s final determination can be found here.
Commerce Issues Final Determination on Circumvention of Solar Cells and Modules from Cambodia, Malaysia, Thailand, and Vietnam
On August 18, 2023, the Department of Commerce (“Commerce”) announced its final determination that certain solar cells and modules exported from Cambodia, Malaysia, Thailand, and Vietnam are circumventing the antidumping (“AD”) and countervailing (“CVD”) orders on imports from China after conducting its investigation for over 18 months. Any duties will only go into effect in June 2024, subject to available certifications and exemptions. Commerce’s final determination can be found here.
Biden Administration Issues Executive Order to Restrict U.S. Investment in Chinese Technology Sectors | JD Supra
Last week, President Biden issued an Executive Order outlining the long-anticipated proposed restrictions on outbound U.S. investments in entities located in China or otherwise subject to China’s jurisdiction.
BIS Issues New Antiboycott Reporting Requirement Amid Increased Enforcement Efforts | JD Supra
On July 27, 2023, the Department of Commerce’s Bureau of Industry and Security (BIS) announced that U.S. persons reporting boycott-related requests to its Office of Antiboycott Compliance (OAC) must now also disclose the identity of the specific party that made the request. Previously, U.S. persons were required to disclose when they had received a boycott-related request and only the country the request originated from.
BIS Issues New Antiboycott Reporting Requirement Amid Increased Enforcement Efforts
On July 27, 2023, the Department of Commerce’s Bureau of Industry and Security (BIS) announced that U.S. persons reporting boycott-related requests to its Office of Antiboycott Compliance (OAC) must now also disclose the identity of the specific party that made the request. Previously, U.S. persons were required to disclose when they had received a boycott-related request and only the country the request originated from.
OFAC and U.S. Department of State Issue New Sanctions and Designates More Than 300 Russian Federation Individuals and Companies Aiding Russia’s War Efforts | Husch Blackwell LLP - JDSupra
On Friday, May 19, 2023, the U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”) announced the addition of more than 300 Russian Federation individuals and companies as well as other individuals and companies alleged to be aiding Russia’s war efforts to the Specially Designated Nationals and Blocked Persons (“SDN”) List.
BIS Implements Additional Export Controls and Entity List Additions Targeting Russia to Align with Allies and Partners | JD Supra
On May 19, 2023, the Department of Commerce’s Bureau of Industry and Security (“BIS”) announced new export controls and Entity List additions during President Biden’s G7 visit in Japan. In conjunction with the G7 meetings, BIS stated these new restrictions are designed to better align U.S. controls with those of its partner and ally countries, who have committed to further restricting Russia’s ability to obtain items needed to support Russia’s military in its war efforts against Ukraine.
OFAC and U.S. Department of State Issue New Sanctions and Designates More Than 300 Russian Federation Individuals and Companies Aiding Russia’s War Efforts
With a strong investigative background, Eric represents clients in labor and employment litigation and compliance investigations. Eric divides his practice between traditional labor and employment litigation and compliance work.
BIS Implements Additional Export Controls and Entity List Additions Targeting Russia to Align with Allies and Partners
On May 19, 2023, the Department of Commerce’s Bureau of Industry and Security (“BIS”) announced new export controls and Entity List additions during President Biden’s G7 visit in Japan. In conjunction with the G7 meetings, BIS stated these new restrictions are designed to better align U.S. controls with those of its partner and ally countries, who have committed to further restricting Russia’s ability to obtain items needed to support Russia’s military in its war efforts against Ukraine.
BIS Levies Record Penalty for Export Control Violations related to Huawei Shipments | JD Supra
Recently, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) announced the issuance of a $300 million penalty against Seagate Technology LLC and its Singapore affiliate, Seagate Singapore International Headquarters Pte. Ltd., (collectively, “Seagate”) to resolve apparent violations of the Huawei foreign direct product rule (the “Huawei FDP Rule”).
BIS Levies Record Penalty for Export Control Violations related to Huawei Shipments
Recently, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) announced the issuance of a $300 million penalty against Seagate Technology LLC and its Singapore affiliate, Seagate Singapore International Headquarters Pte. Ltd., (collectively, “Seagate”) to resolve apparent violations of the Huawei foreign direct product rule (the “Huawei FDP Rule”).
Recent Actions Illustrate Continued Focus on Export Control Violations | JD Supra
Last week, Deputy Attorney General Lisa Monaco’s statements to the American Bar Association again highlighted the fact that investigating and prosecuting individuals for violating economic sanctions, export controls, and other similar economic crimes is one of the Department of Justice’s highest priorities.
OFAC Issues Sweeping Sanctions to Mark One Year Anniversary of Russia’s Invasion of Ukraine | JD Supra
On Friday, February 24, 2023, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued new sanctions against individuals and entities operating in Russia and against those assisting with Russia’s war efforts in Ukraine. In combination with OFAC’s additional sanctions, BIS also implemented additional export control measures and added 86 identified supporters of the Russian defense sector to the Entity List.
BIS Issues New Export Controls and Entity List Additions Targeting Russia on One-Year Anniversary of Invasion | JD Supra
The Department of Commerce’s Bureau of Industry and Security (“BIS”) announced today new export controls and Entity List additions designed to further restrict Russia’s ability to maintain its continued war against Ukraine. The Biden Administration’s measures come on the one-year anniversary of Russia’s invasion of Ukraine and the first announcement by several Western countries, including the U.S., of initial sanctions in response.
OFAC Issues Sweeping Sanctions to Mark One Year Anniversary of Russia’s Invasion of Ukraine
With a strong investigative background, Eric represents clients in labor and employment litigation and compliance investigations. Eric divides his practice between traditional labor and employment litigation and compliance work.
BIS Issues New Export Controls and Entity List Additions Targeting Russia on One-Year Anniversary of Invasion
The Department of Commerce’s Bureau of Industry and Security (“BIS”) announced today new export controls and Entity List additions designed to further restrict Russia’s ability to maintain its continued war against Ukraine. The Biden Administration’s measures come on the one-year anniversary of Russia’s invasion of Ukraine and the first announcement by several Western countries, including the U.S., of initial sanctions in response.
DOJ Posts Near-Record Year of False Claim Act Settlements and Judgments | JD Supra
Cybersecurity-related FCA cases poised to increase as FCA enforcement ramps up On February 7, 2023, the Department of Justice (DOJ) announced that settlements and judgments under the False Claims Act exceeded $2.2 billion during the 2022 fiscal year and that the government posted its second-highest number of settlements and judgments in a single year.
DOJ Posts Near-Record Year of False Claim Act Settlements and Judgments
Cybersecurity-related FCA cases poised to increase as FCA enforcement ramps up On February 7, 2023, the Department of Justice (DOJ) announced that settlements and judgments under the False Claims Act exceeded $2.2 billion during the 2022 fiscal year and that the government posted its second-highest number of settlements and judgments in a single year.
Export Control Violations Result in Significant Monetary Penalties and Continuing Compliance Training Obligations | JD Supra
In a recent order, the Department of Commerce’s Bureau of Industry and Security (“BIS”) revoked the export privileges for Obaidullah Sayed, an Illinois resident. Sayed was convicted of conspiring to export computers, computer systems, and other related equipment to the Pakistan Atomic Energy Commission without a license. Sayed was sentenced to one year and one day in prison and was required to forfeit $247,000.
Export Control Violations Result in Significant Monetary Penalties and Continuing Compliance Training Obligations
In a recent order, the Department of Commerce’s Bureau of Industry and Security (“BIS”) revoked the export privileges for Obaidullah Sayed, an Illinois resident. Sayed was convicted of conspiring to export computers, computer systems, and other related equipment to the Pakistan Atomic Energy Commission without a license. Sayed was sentenced to one year and one day in prison and was required to forfeit $247,000.
Biden Administration No Longer Approving Export Licenses to Chinese Tech Giant Huawei | JD Supra Original
According to recent reports, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) has stopped granting export licenses to Huawei Technologies Co. Ltd. (“Huawei”). The U.S. government has long sought to restrict Huawei’s access to advanced U.S. computer chips used to power 5G networks and related technological applications.
Biden Administration No Longer Approving Export Licenses to Chinese Tech Giant Huawei
According to recent reports, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) has stopped granting export licenses to Huawei Technologies Co. Ltd. (“Huawei”). The U.S. government has long sought to restrict Huawei’s access to advanced U.S. computer chips used to power 5G networks and related technological applications.
International Trade Law: 2022 Year in Review & Outlook for 2023 | JD Supra
We are pleased to announce that our team’s fourth-annual international trade law year-in-review report was published just before the New Year. In it, we take a detailed look at how 2022 played out and explore how 2023 might develop. Please see full Report below for more information. Download PDF
BIS Adds 35 Chinese Entities to Entity List for Supporting China’s Military Modernization Efforts and Nine Russian Entities for Failure to Complete Satisfactory End-Use Checks | Husch Blackwell LLP - JDSupra
On December 16, 2022, the U.S. Commerce Department’s Bureau of Industry and Security (“BIS”) published a rule adding 35 entities from China and one entity from Japan to the Entity List for supporting China’s military modernization efforts, human rights violations, and risk of diversion.
BIS Adds 35 Chinese Entities to Entity List for Supporting China’s Military Modernization Efforts and Nine Russian Entities for Failure to Complete Satisfactory End-Use Checks
On December 16, 2022, the U.S. Commerce Department’s Bureau of Industry and Security (“BIS”) published a rule adding 35 entities from China and one entity from Japan to the Entity List for supporting China’s military modernization efforts, human rights violations, and risk of diversion.
OFAC Continues to Take Aim at Russia’s Financial Sector with More SDN Designations | JD Supra
December 19, 2022 Eric Dama, Grant Leach, Emily Mikes, Cortney O'Toole Morgan Husch Blackwell LLP + Follow x Following x Following - Unfollow Contact To embed, copy and paste the code into your website or blog: On December 15, 2022, the Office of Foreign Assets Control (“OFAC”) added 18 entities in Russia’s financial services sector to the Specially Designated Nationals and Blocked Persons List (“SDN List”).
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