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Customs/Imports

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On February 5, 2021, the Department of State published in the Federal Register a notice [Public Notice: 11347] proposing to extend and amend the Memorandum of Understanding Concerning the Imposition of Import Restrictions on Categories of Archaeological Material of the Arab Republic of Egypt pursuant to 19 U.S.C. § 2602(f)(1). A copy of the Memorandum of Understanding, the Designated List of categories of material restricted from import into the United States, and related information can be…

On January 19, 2021, the US State Department designated Ansarallah, a political movement and militia group in Yemen also known as the Houthis, as a Foreign Terrorist Organization (“FTO”) and Specially Designated Global Terrorist (“SDGT”), and also designated three of its leaders as SDGTs. OFAC designated Ansarallah on the Specially Designated Nationals and Blocked Persons List (“SDN List”) and updated the entries for the same individuals on the SDN List who had already been designated under other…

On January 27, 2021, CBP issued CSMS #45967303 – United Arab Emirates Section 232 Aluminum Absolute Quota limits beginning February 3, 2021, to implement Presidential Proclamation 10139. However, on February 1, 2021, President Biden revoked Proclamation 10139 before it was to take effect and restored the 10% duties for aluminum from the UAE. As a result, CBP issued CSMS #46027083 – United Arab Emirates Section 232 Aluminum Presidential Proclamation 10139 REVOKED February 1, 2021, which…

On January 25, 2021, the Federal Register published Proclamation 10139 of January 19 – Adjusting Imports of Aluminum Into the United States, which modified the terms of Proc. 9704 of March 8, 2018, imposing a 10% additional ad valorem duty on aluminum imports from most countries under section 232 of the Trade Expansion Act of 1962, as amended (19 U.S.C. 1862). Proclamation 10139 added the United Arab Emirates (UAE) to the list of countries exempt…

On January 15, 2021, the Office of Foreign Assets Control (OFAC) published in the Federal Register a final rule adding regulations (31 C.F.R. Part 585) to implement Executive Order (E.O.) 13936 of July 14, 2020. OFAC intends to supplement these regulations with a more comprehensive set of regulations, which may include additional interpretive and definitional guidance, general licenses, and statements of licensing policy. In E.O. 13936, the President determined that, pursuant to section 202 of…

On 31 December 2020, the UK’s Brexit transition period with the EU ended, and the UK became a third country with respect to the EU from a sanctions and export controls perspective. The UK now has its own autonomous sanctions and export control regimes – closely related to the EU’s regimes, but with important differences and complexities that clients need to be aware of. We have written an alert that summarises the key considerations for companies in…

On January 19, 2021, the Commerce Department published an interim final rule to implement President Trump’s 2019 Executive Order 13873 on “Securing the Information and Communications Technology and Services Supply Chain” (“Interim Rule”). The Interim Rule was issued following the closure of the public comment period on January 10, 2021 on the proposed rules issued on November 27, 2019 (“Proposed Rules”) to implement Executive Order 13873. For more information on Executive Order 13873 and the Proposed Rules, please see our blog…

On January 27, 2021, the International Trade Administration, Department of Commerce published in the Federal Register a document delaying the effective date of a final rule and requesting comments [Docket No. 210122-0011; ITA-2021-0001] on the “Aluminum Import Monitoring and Analysis System,” from January 25, 2021 until March 29, 2021. This delay in effective date is necessary to allow the incoming Administration time to review the Final Rule [See 85 FR 83804 (Dec. 23, 2020)], and…

On January 27, 2021, CBP issued CSMS #45967303 – United Arab Emirates Section 232 Aluminum Absolute Quota limits beginning February 3, 2021, which is provided below: The 2021 Section 232 United Arab Emirates Absolute Quota Aluminum threshold is announced on Quota Bulletin QB 21-701A at: https://www.cbp.gov/trade/quota/bulletins. All entries submitted From January 1 through March 31, 2021 will count towards the Q1 quota limit. Entries as of February 3, 2021 must utilize HTS 9903.85.06 through 990385.08…

On December 17, 2020, the US Department of Energy (DOE) issued a “Prohibition Order Securing Critical Defense Facilities“ (the “Prohibition Order”) pursuant to authority granted to the Secretary of Energy by Executive Order 13920 (the “BPS EO“). As of January 16, 2021, the Prohibition Order prohibits certain electric utilities that serve certain defense facilities from acquiring, importing, transferring, or installing identified bulk-power system (“BPS”) equipment and related software produced or supplied by entities subject to…