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Enforcement & Investigations

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On May 19, 2019, President Trump signed Proclamation 9893 of May 19, 2019 on Adjusting Imports of Aluminum into the United States (published in the Federal Register on May 23, 2019) and Proclamation 9894 of May 19, 2019 on Adjusting Imports of Steel into the United States (published in the Federal Registeron May 21, 2019), which remove the 10% duties on aluminum and 25% duties on steel for goods originating in Canada and Mexico, while…

On May 23, 2019, the Bureau of Industry and Security (BIS) published in the Federal Register a final rule [Docket No. 181129999–8999–01], which revises the Commerce Control List (CCL) to implement certain changes made to the Wassenaar Arrangement List of Dual-Use Goods and Technologies maintained and agreed to by governments participating in the Wassenaar Arrangement on Export Controls for Conventional Arms and Dual-Use Goods and Technologies (Wassenaar Arrangement, or WA) at the December 2018 WA…

Effective May 20, 2019, the US Commerce Department’s Bureau of Industry and Security (BIS) issued a final rule creating a 90-day Temporary General License (TGL) authorizing certain transactions involving the export, reexport, and transfer of items subject to the Export Administration Regulations (EAR) to Chinese-headquartered Huawei Technologies Co. Ltd. (“Huawei”) and its sixty-eight non-US affiliates, which were added to the BIS Entity List effective May 16, 2019 (the “Entity List designation”). The TGL will be effective through August 19,…

On May 20, 2019, the Department of Finance announced that effective today, Canada is lifting its retaliatory countermeasures against the U.S. When the United States imposed unjustified tariffs on Canadian steel and aluminum, the Government of Canada stood up for our country’s steel and aluminum workers, industries, and communities – imposing reciprocal, dollar-for-dollar countermeasures against imports of steel, aluminum, and other products from the U.S., to encourage the full removal of the U.S. tariffs. “Canada stood firm…

On May 20, 2019, the Diario Oficial published a Decree, signed by President López Obrador, which modifies the earlier Decree (published on June 5, 2018) setting the applicable duty rate for goods originating in the United States and the Decree establishing various Sectoral Promotion Programs. The Decree repeals Articles 1, 2 and 9 of the June 5, 2018 Decree and removes the duties imposed by Mexico in retaliation for steel and aluminum tariffs imposed on…

On May 17, 2019, the US Trade Representative’s Office (USTR) published in the Federal Register a notice [Docket Number USTR–2019–0004] that was made available as an advance copy on May 13, beginning the process of imposing additional duties of up to 25% on all remaining imports from China (i.e., List 4). According to the notice, “[i]n light of China’s failure to meaningfully address the acts, policies, and practices that are subject to this investigation and…

On May 17, 2019, President Trump signed a Proclamation Adjusting Imports of Automobiles and Automobile Parts Into the United States under Section 232 the Trade Expansion Act of 1962, as amended (19 U.S.C. 1862). The Proclamation states that the Secretary of Commerce’s (the Secretary) Section 232 report on his investigation into the effects of imports of passenger vehicles (sedans, sport utility vehicles, crossover utility vehicles, minivans, and cargo vans) and light trucks (collectively “automobiles”) and certain…

On May 8, 2019, President Trump issued Executive Order 13871 (the “Iran Metals EO”) imposing sanctions on the iron, steel, aluminum, and cooper sectors of Iran subject to a 90-day wind-down period that will expire on August 6, 2019. Although the sale, supply or transfer to/from Iran of steel and aluminum is already targeted by Section 1245 of the Iran Freedom and Counter-Proliferation Act of 2012, the Iran Metals EO expands upon those sanctions and further targets…

The High Representative of the European Union and the Foreign Ministers of France, Germany and the United Kingdom released a joint statement today (see here for the full statement) following Iran’s announcement yesterday that it would withdraw from certain commitments as agreed as part of the 2015 nuclear agreement (see our post here on this). The statement urged Iran to continue to implement its commitments under the nuclear agreement, stating that Iran’s compliance would be…

President Hassan Rouhani has announced that Iran will withdraw from certain commitments agreed in the 2015 nuclear agreement; this announcement comes a year after the agreement was abandoned by the US, leading to the re-imposition of US sanctions against Iran. In his 8 May 2019 announcement, Hassan Rouhani declared that Iran will stop exporting its surplus enriched uranium. This decision is contrary to the agreement, under which Iran is required to sell its surplus enriched…