International Trade & Supply Chain

cargo shipOn November 8, the Federal Maritime Commission (FMC) issued a Notice for Proposed Rulemaking regarding modifications to NVOCC Service Arrangements (NSAs) and Negotiated Rate Arrangements (NRAs).

NSAs:

NSAs will continue to serve as basic agreements between NVOCCS and their customers for comprehensive longer-termed ocean transport agreements with provisions similar to those included in ocean carrier service contracts, with two basic differences: Continue Reading Federal Maritime Commission NVOCC Deregulation More Imminent

Globe showing AsiaThe U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC) has amended its Global Terrorism Sanctions Regulations (GTSR) in order to impose additional sanctions on Iran’s Islamic Revolutionary Guard Corps (IRGC) within the timeline required by the Countering America’s Adversaries Through Sanctions Act (CAATSA). Effective October 31, 2017, persons and entities that OFAC has designated as officials, agents, or affiliates of the IRGC remain subject to secondary blocking sanctions which continue to prohibit them from engaging in activity with US and non-US persons and, in addition, these amendments to the GTSR now impose new sanctions to prohibit the designated IRGC affiliates from receiving humanitarian donations and other forms of assistance. OFAC has provided a list of the IRGC affiliates subject to these amendments here. Continue Reading OFAC and State Department Update Iran and Russia Sanctions Under Countering America’s Adversaries Through Sanctions Act

After undertaking a broader review of the United States’ policies with regard to Iran, President Donald Trump announced today that he will not certify the Iran nuclear deal, more commonly referred as the Joint Comprehensive Plan of Action (“JCPOA”). This move stops short of unraveling the deal but allows Congress to consider the agreement for the next 60 days on an expedited basis in order to decide whether to re-impose sanctions lifted under the terms of the agreement. Continue Reading President Trump Declines Certification of Iran Nuclear Deal: What Does This Mean?

White HouseOn October, 6, the U.S. Department of State announced it will issue a report to President Donald Trump which will express the Department’s conclusion that the Government of Sudan (“GOS”) has sustained the positive actions necessary in order to repeal the majority of current U.S. economic sanctions against Sudan. The Department of State will formally publish a copy of this report in the Federal Register on Thursday, October 12, 2017, but has provided an advance copy on their website.

Continue Reading State Department and OFAC Announce Repeal of Sudan Sanctions

bankOn Tuesday, September 26, the Office of Foreign Assets Control at the Treasury Department announced new sanctions on banks and representatives linked to North Korean financial networks. These sanctions come as a response to North Korea’s violations of UN resolutions and attempts to develop nuclear weapons.

OFAC identified 26 North Korean nationals working in China, Russia, Libya, and the UAE as representatives of North Korean banks. In addition, eight financial institutions were added to the Specially Designated Nationals list, several of which have branches in China.

Continue Reading OFAC Implements New Sanctions on North Korean Banking

shipping containersOn September 26, 2017, DAK Americas LLC, Nan Ya Plastics Corporation, America, Indorama Ventures USA Inc., and M&G Polymers USA, LLC filed a petition for the imposition of antidumping duties on imports of Polyethylene Terephthalate (“PET”) Resin from Brazil, Indonesia, Korea, Pakistan, and Taiwan.

Continue Reading Petition Summary: Polyethylene Terephthalate (“PET”) Resin from Brazil, Indonesia, Korea, Pakistan, and Taiwan

International flagsOn September 22, 2017, the U.S. International Trade Commission (“ITC”) voted in the affirmative and found that U.S. producers are being seriously injured or are threatened with serious injury by imports of silicon photovoltaic cells and modules. This case was brought under section 201 of the Trade Act of 1974. Section 201 cases have two main parts: (1) the case is filed at the ITC which determines if there is such serious injury by imports, and if there is, then recommends a remedy, and (2) if there is a finding of such serious injury, the case goes to the President of the United States for final review and decision on the remedy. The President may modify or agree with the recommendation of the ITC on remedy.

Continue Reading ITC Votes Affirmatively on Injury on Trade Case on Crystalline Silicon Photovoltaic Cells and Modules

White HouseOn Thursday, September 21, 2017, President Trump signed an executive order imposing new sanctions on North Korea designed to curb its nuclear weapons program. President Trump, along with Japanese Prime Minister Shinzo Abe and South Korean President Moon Jae-in, announced the sanctions at a United Nations luncheon.

The President said he had authorized the U.S. Department of Treasury to “target any individual or entity that conducts trade in goods, services or technology” with North Korea. The sanctions are also intended to disrupt shipping from North Korea by prohibiting aircraft and vessels that have been to North Korea within 180 days to call at a port or land in the United States.

Continue Reading Trump Announces New Sanctions on North Korea