A weekly live web event dedicated to issues related to international trade. Materials used throughout the stream include: OWIT Mexico Event | WOMAN EXPORTING MX – October 26-30, 2020 https://mbmapp.com/event/mujerexportamx Assoc. of Cert. Sanction Specialists | Listings, Delistings and Other Developments in the Russian Sphere – Oct. 1, 2020 https://sanctionsassociation.org/20201001upcoming/ Event – Rising Tensions – Increased Trade Controls on Wednesday, October 7 HKT https://email.steptoecommunications.com/120/8358/landing-pages/rsvp-blank.asp?sid=ea292c35-fe3a-42c2-ac19-ea8649c27ee1 Cuba: OFAC’s amendment of Cuban Asset Control Regulations: Qs 837 https://home.treasury.gov/policy-issues/financial-sanctions/faqs/topic/1541 12 Categories of General License: https://cu.usembassy.gov/u-s-citizen-services/local-resources-of-u-s-citizens/traveling-to-cuba/ New Rule for Professional Meetings: https://www.ecfr.gov/cgi-bin/text-idx?SID=cff7b100f3d7279989d2c087a32f83f6&mc=true&node=se31.3.515_1564&rgn=div8 Old Rule for Professional Meetings: https://www.govinfo.gov/content/pkg/CFR-2019-title31-vol3/pdf/CFR-2019-title31-vol3-sec515-564.pdf New Rule for Public Performances: https://www.ecfr.gov/cgi-bin/text-idx?SID=cff7b100f3d7279989d2c087a32f83f6&mc=true&node=se31.3.515_1567&rgn=div8 Old Rule for Public Performances: https://www.govinfo.gov/content/pkg/CFR-2019-title31-vol3/pdf/CFR-2019-title31-vol3-sec515-567.pdf HK Special Administrative Region on SDN – 09/25/2020 OFAC FAQ https://home.treasury.gov/policy-issues/financial-sanctions/faqs/840 Reminder of 08/31/2020 HKSAR Designations: https://home.treasury.gov/news/press-releases/sm1088 Follows Exxon Mobile Case: https://www.govinfo.gov/content/pkg/USCOURTS-txnd-3_17-cv-01930/pdf/USCOURTS-txnd-3_17-cv-01930-2.pdf Xinjiang Production and Construction Corps (XPCC) makes it to Magnitsky List on 09/25/2020 https://home.treasury.gov/policy-issues/financial-sanctions/faqs/835 Note on Magnitsky (https://en.wikipedia.org/wiki/Sergei_Magnitsky): Sergei Magnitsky Rule of Law Accountability Act of 2012 … see pg. 8: https://www.govinfo.gov/content/pkg/BILLS-112hr6156enr/pdf/BILLS-112hr6156enr.pdf New Website for Steel Mill Licenses https://www.federalregister.gov/documents/2020/09/11/2020-19753/steel-import-monitoring-and-analysis-system https://www.trade.gov/us-industry-licensing https://enforcement.trade.gov/steel/license/SMP_byHTS.pdf DOJ News Release on False Claims Act https://www.justice.gov/opa/pr/multinational-industrial-engineering-company-pay-22-million-settle-false-claims-act 09/16/2020 Customs Bulletin at 15: Cyper Power v. US https://www.cbp.gov/sites/default/files/assets/documents/2020-Sep/Vol_54_No_36_Complete_0.pdf Please remember to attend our weekly live stream! Tuesdays at 5:30 p.m. EST…
On April 23, 2014 CBP’s Virginia McPherson advised international trade community that products from Crimea, marked as “Product of Russia,” “Made in Russia,” “Contents Made in Russia” can be subject to additional 10% marking duties due to violation of 19 U.S.C. § 1304. See CSMS #14-000236 (stating “[g]rowth, production, or manufacture of a good in Crimea is growth, production, or manufacture of a good in Ukraine.”). With CSMS #14-000236 CBP joined OFAC’s critique circle that expresses the discontent of our (U.S.) executive branch views over political situation in Crimea. My colleagues done a good analysis on OFAC’s expression of unhappiness with Russia. See e.g. Steptoe’s publication here, or Mr. Burns article here. Here, CBP’s Virginia McPherson statements invite review of the administrative precedent and analysis, as Ms. McPherson’s address offers only conclusive words with very little reasoning. In T.D. 97-16, CBP (then called Customs Service) offered a better reasoning of country of origin marking for products that were made in places of political uncertainties. Case study concerned West Bank and Gaza. Following were the major principles that CBP used for guidance in T.D. 97-16 and 95-25: CBP gives a great deal of deference to the State Department, which “requests” CBP…
Few years back, we published a list of links that U.S. based international trade community should check prior to engaging in a transaction. Time has come to update the list with a Foreign Sanctions Evader List. OFAC’s Specially Designated Nationals List ; OFAC’s Foreign Sanctions Evader List; BIS’s Entity List; BIS’s Denied Persons List; BIS’s Unverified Parties List; ISN’s Nonproliferation Sanctions Lists. DDTC’s Debarred Parties List. Another list maintained by the System for Award Management (SAM) – Excluded Parties List System – may also be relevant in the case of federal contracts.
Read More Websites to check prior to proceeding with U.S. Exports and Imports (Revisited)
