Trade Remedy/Enforcement

On June 7, 2019, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned Iran’s largest petrochemical holding group, Persian Gulf Petrochemical Industries Company (PGPIC). In addition to PGPIC, OFAC placed 39 PGPIC subsidiaries and foreign-based sales agents on its Specially Designated Nationals (SDN) List. According to OFAC, PGPIC was sanctioned for having

On June 5, 2019, the Department of Commerce’s Bureau of Industry and Security (BIS) and the Department of the Treasury’s Office of Foreign Assets Control (OFAC) undertook coordinated actions to further restrict travel to Cuba “in order to hold the Cuban regime accountable for its repression of the Cuban people and its support of the

The Office of the U.S. Trade Representative (USTR) has released notice of its fifth batch of China Section 301 product exclusion approvals that will relieve impacted U.S. importers from the 25 percent tariff implemented on certain imports from China July 6, 2018. These approved exclusions cover 464 exclusion requests and are established in two different

The Office of the U.S. Trade Representative (USTR) has announced that it is extending the amount of time certain goods exported from China will have to enter the United States before an additional Section 301 tariff increase from 10 percent to 25 percent is imposed. As we reported on May 9, President Donald Trump

During the month of May while President Donald Trump’s escalating trade war with China was garnering most of the headlines, the Trump administration also continued to apply economic pressure on Venezuela. In May, the Departments of Commerce, State and the Treasury further tightened sanctions and export restrictions on Venezuela.

On May 10, 2019, the Department of State announced that, pursuant to Executive Order 13850, the United States determined persons operating in the defense and security sector of the Venezuelan economy may be subject to economic sanctions. On the same date, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned two companies that operate in the oil sector of the Venezuelan economy, and also sanctioned two vessels, which transported oil from Venezuela to Cuba:

  • Monsoon Navigation Corporation is based in Majuro, Marshall Islands, and is the registered owner of the vessel, Ocean Elegance.
    • Ocean Elegance is a crude oil tanker (IMO: 9038749) that delivered crude oil from Venezuela to Cuba from late 2018 through March 2019.
  • Serenity Maritime Limited is based in Monrovia, Liberia, and is the registered owner of the vessel, Leon Dias.
    • Leon Dias is a chemical and oil tanker (IMO: 9396385) that delivered crude oil from Venezuela to Cuba from late 2018 through March 2019.


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In a proposed rule scheduled for publication in the May 28, 2019 Federal Register, the International Trade Administration (ITA) of the Department of Commerce (Commerce) is proposing to modify two regulations that would clarify how ITA determines the existence of a benefit resulting from a subsidy in the form of currency manipulation and undervaluation and how companies in the traded goods sector of an economy can constitute a group of enterprises for purposes of determining whether a subsidy is specific. In a Commerce press release, Secretary Wilbur Ross stated, “This change puts foreign exporters on notice that the Department of Commerce can countervail currency subsidies that harm U.S. industries … Foreign nations would no longer be able to use currency policies to the disadvantage of American workers and businesses.”

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In a filing with the Office of Management and Budget (OMB) seeking emergency clearance for an information collection and form approval, the Office of the U.S. Trade Representative (USTR) formally indicated that it is “establishing a process by which U.S. stakeholders can request the exclusion of particular products classified within a covered tariff subheading from

On May 20, 2019, the Department of Commerce’s Bureau of Industry and Security (BIS) issued a 90-day temporary general license that partially restored the export licensing requirements under the Export Administration Regulations (EAR) for exports, reexports and transfers (in-country) to Huawei Technologies Co., Ltd. and its 68 affiliates (Huawei), which were added to the Entity List on May 16, 2019 (see Trump and Trade Update of May 17, 2019). The temporary general license permits these activities:

  • Continued Operation of Existing Networks and Equipment, subject to other provisions of the EAR, necessary to maintain and support existing and currently fully operational networks and equipment, including software updates and patches, subject to legally binding contracts and agreements executed between Huawei and third parties on or before May 16, 2019.
  • Support to Existing Handsets, subject to other provisions of the EAR, necessary to provide service and support, including software updates or patches, to existing Huawei handsets that were available to the public on or before May 16, 2019.
  • Cybersecurity Research and Vulnerability Disclosure, subject to other provisions of the EAR, the disclosure to Huawei of information regarding security vulnerabilities in items owned, possessed or controlled by Huawei when related to the process of providing ongoing security research critical to maintaining the integrity and reliability of existing and currently fully operational networks and equipment, as well as handsets.
  • Engagement as Necessary for Development of 5G Standards by a Duly Recognized Standards Body, subject to other provisions of the EAR, engagement with Huawei as necessary for the development of 5G standards as part of a duly recognized international standards body (e.g., Institute of Electrical and Electronics Engineers (IEEE), Internet Engineering TaskForce (IETF), International Organization for Standards (ISO), International Telecommunications Union (ITU), European Telecommunications Standards Institute (ETSI), 3rd Generation Partnership Project (3GPP), Telecommunications Industry Association (TIA), and GSM Association (GSMA or Global System for Mobile Communications)).


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On May 17, 2019, the United States, Canada and Mexico concluded an agreement in which the United States agreed to remove the Section 232 tariffs for steel and aluminum imports from those countries and Canada and Mexico agreed to remove all retaliatory tariffs imposed on U.S. goods. Accordingly, President Donald Trump issued proclamations declaring that

On May 16, 2019, President Donald Trump issued a proclamation reducing Section 232 tariffs on steel imports from Turkey from 50 percent to 25 percent, which had been in effect since August 2018 (see Trump and Trade Update of August 17, 2018). This tariff decrease will become effective May 21, 2019, at 12:01 a.m.