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Shelter-in-place or stay at home orders have been prevalent throughout the United States since March 2020 as state and local governments have sought to protect their citizens from the spread of the COVID-19 virus. With the spread appearing to slow, several states are now implementing plans to revise and scale back these orders to re-open their economies. Keeping abreast of the evolving nature of these orders and plans is critical to the functioning of all…

On April 3, 2020, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) re-issued and extended General License No. 13E (“GL 13E”) to continue the validity period for transactions concerning Nynas AB and its subsidiaries (“Nynas”) that otherwise would be prohibited under Executive Order 13850 or Executive Order 13884 given Nynas’s 50% indirect ownership by Petróleos de Venezuela S.A. (“PdVSA”). The authorization was extended through 12:01 am EST on May 14, 2020. In a note accompanying GL 13E’s issuance…

On 3 April 2020, the European Commission issued its Decision granting relief from customs duty and import VAT exemptions for equipment necessary for combating the COVID-19 outbreak, following its announcement of its intention to do so on 20 March 2020 (please see our previous blog post here). Goods will only be exempt from customs duty and import VAT if they: are imported by or on behalf of State organisations, or by or on behalf of organisations approved by…

On October 29, 2019, CBP issued CSMS #40430843 – Additional Duty on Products of the Countries of the European Union Under Large Civil Aircraft Section 301 Trade Remedy Action, which updates guidance provided in CSMS #40281968 on the same subject. It is reproduced below: BACKGROUND The U.S. Trade Representative has determined that the EU and certain member states have denied U.S. rights under the World Trade Organization (WTO) Agreement and have failed to implement WTO…

On October 10, 2019, the US Treasury Department’s Office of Foreign Assets Control (OFAC) designated Ajay Gupta, Atul Gupta, Rajesh Gupta, and Salim Essa of South Africa (“the Guptas”) as Specially Designated Nationals (“SDNs”). The Guptas and their business associate, Essa, were designated in connection with their involvement in corruption under Executive Order 13818 (EO 13818), which implements and expands upon the sanctions authorities set out in the Global Magnitsky Human Rights Accountability Act. The…

On October 23, 2019, the US Treasury Department Office of Foreign Assets Control (OFAC) announced that it had deleted two Turkish ministries and three Turkish individuals from the list of Specially Designated Nationals and Blocked Persons (“SDN List”). These five parties had been designated to the SDN List on October 14, 2019 pursuant to Executive Order 13894 (EO 13894) for contributing to Turkey’s military offensive in northern Syria. Please see our blog post regarding EO 13894 here. OFAC’s…