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Articles by Manasi Venkatesh
New Tri-Seal Compliance Note Highlights Voluntary Self-Disclosure Procedures And Benefits
The U.S. Department of Justice (DOJ), Bureau of Industry and Security (BIS), and Office of Foreign Assets Control (OFAC) published their second Tri-Seal Compliance Note on July 26 summarizing their voluntary self-disclosure procedures for export control and sanctions violations. The Note highlights the potential benefits of self-disclosure, including significant mitigation of civil and criminal liability.
BIS further strengthens antiboycott enforcement efforts
In October, the Bureau of Industry and Security (BIS) strengthened its antiboycott enforcement strategy. Last week, BIS made two additional enhancements to its enforcement strategy: New Boycott Request Reporting Form U.S. persons who receive boycott requests will now be required to identify the requesting party in addition to the country from which the request originated.
New Tri-Seal Compliance Note highlights voluntary self-disclosure procedures and benefits
The U.S. Department of Justice (DOJ), Bureau of Industry and Security (BIS), and Office of Foreign Assets Control (OFAC) published their second Tri-Seal Compliance Note on July 26 summarizing their voluntary self-disclosure procedures for export control and sanctions violations. The Note highlights the potential benefits of self-disclosure, including significant mitigation of civil and criminal liability.
New Tri-Seal Compliance Note highlights voluntary self-disclosure procedures and benefits
The U.S. Department of Justice (DOJ), Bureau of Industry and Security (BIS), and Office of Foreign Assets Control (OFAC) published their second Tri-Seal Compliance Note on July 26 summarizing their voluntary self-disclosure procedures for export control and sanctions violations. The Note highlights the potential benefits of self-disclosure, including significant mitigation of civil and criminal liability.
Tomorrow's Supply Chain - The UFLPA's Reach Extends Beyond China - Export Controls & Trade & Investment Sanctions - Worldwide
After almost a year of enforcement under the Uyghur Forced Labor Prevention Act (UFLPA), U.S. Customs and Border Protection's (CBP) statistics make it clear the UFLPA's reach extends beyond imports from China.
U.S. targets Russian sanctions evasion and expands export controls
In coordination with the G7 and other international partners, the U.S. implemented new Russia-related sanctions and export controls on May 19.
BIS clarifies policies to incentivize voluntary disclosures and whistleblowing
On April 18, the Bureau of Industry and Security (BIS) clarified two enforcement policies in a further attempt to incentivize voluntary self-disclosures and disclosures about others’ possible violations of the Export Administration Regulations (EAR). The announcement follows changes announced last June to strengthen BIS’s administrative enforcement of the EAR.
Court of International Trade rejects challenge to Section 301 tariffs
On March 17, the Court of International Trade upheld the Section 301 tariffs on Chinese-origin goods identified on List 3 and List 4A. The plaintiffs in In re Section 301 Cases previously sought to vacate the tariffs, arguing the U.S. Trade Representative (USTR) violated the Administrative Procedure Act (APA).
New CHIPS and Science Act funding comes with national security limitations
On February 28, 2023, the U.S Department of Commerce, CHIPS Program Office (Commerce) released the first of three expected Notices of Funding Opportunities (NOFO) under the CHIPS and Science Act of 2022, which is intended to develop the domestic semiconductor supply chain, provide jobs and restore the country’s leadership in semiconductor manufacturing, and advance U.S. national and economic security.
Russian petroleum product price cap implemented
Shortly before the 5 February 2023 cut-off date for the provision of maritime services related to the transportation of Russian petroleum products, the UK, EU and U.S. each published the relevant price cap for petroleum products falling under HS/CN Code 2710 that are of Russian origin or consigned or exported from Russia to non-G7 countries (Restricted Petroleum Products).
Bipartisan bill proposes to leverage CFIUS in assessing pharmaceutical supply chain
On June 30, 2020, United States Senators Elizabeth Warren (D-Mass.) and Marco Rubio (R-Fla.) introduced legislation proposing the Committee on Foreign Investment in the United States (CFIUS), an interagency committee authorized to review certain transactions involving foreign investment in the United States for national security concerns, and assist the Federal Trade Commission (FTC) in “conduct[ing] a study on the United States’ overreliance on foreign countries and the impact of foreign...
The USTR responds to French Digital Services Tax with large tariff proposal
In response to France’s Digital Services Tax (DST), the Office of the U.S. Trade Representative (USTR) proposed additional ad valorem duties of up to 100 percent on certain products from France. The USTR issued a Section 301 Investigation Report on the DST, concluding that the DST discriminates against U.S. companies, is inconsistent with prevailing principles of tax policy, and is unusually burdensome for affected U.S. companies.
France’s discriminatory Digital Services Tax prompts hefty tariff proposal from the USTR
On December 2, 2019, the Office of the U.S. Trade Representative (USTR) issued a Section 301 Investigation Report on France’s Digital Services Tax (DST), concluding that France’s DST discriminates against U.S. companies, is inconsistent with prevailing principles of tax policy, and is unusually burdensome for affected U.S. companies. In response, the USTR proposed up to 100 percent tariff on French products.
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