Client Alerts

New Interpretation of Certain Boycott Language from the UAE

BIS Adds Antiboycott Interpretation Reflecting United Arab Emirates’ Termination of Israel Boycott On June 9, 2021, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) published a final rule adding an Interpretation to the anti-boycott regulations in 15 C.F.R. Part 760 of the Export Administration Regulations (EAR).  See 48 Fed Reg 30,535 (June […]

U.S. Expands Sanctions on Burma

Client Alert

On March 25, 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated two Burmese military holding companies, Myanma Economic Holdings Public Company Limited (MEHL) and Myanmar Economic Corporation Limited (MEC).  As a result of these actions: U.S. companies are prohibited from engaging in any unlicensed business with MEHL, MEC, or […]

U.S. Expands Export Control Restrictions on Russia

Client Alert

On March 2, 2021, the U.S. Department of State announced new Russia-related sanctions and Entity List additions pursuant to the Countering America’s Adversaries Through Sanctions Act (CAATSA) and Chemical and Biological Weapons Act (CBW Act) following a determination that the Russian Government used a chemical weapon against its own nationals. As relevant to forwarders, some of these […]

New COVID Relief Package Grants Many Associations Access to PPP

Client Alert

The massive stimulus package approved by Congress late yesterday includes long awaited relief for many 501(c)(6) organizations. The package makes 501(c)(6) organizations eligible for loans under the Paycheck Protection Program (PPP) if they meet the following requirements: The organization does not receive more than 15% of receipts from lobbying; The lobbying activities do not comprise […]

U.S. Department of State Imposes Sanctions on Turkey’s Presidency of Defense Industries

Client Alert

On December 14, 2020, the U.S. Department of State imposed broad sanctions on Turkey’s Presidency of Defense Industries (also known as SSB) pursuant to Sections 231 and 235 of the Countering America’s Adversaries Through Sanctions Act (CAATSA), including a prohibition on U.S. government agencies from providing U.S. export licenses and authorizations for transfers of goods and technology […]

New FMC Investigation on Demurrage and Detention Practices

Client Alert

On November 19, 2020, the Federal Maritime Commission (FMC) issued a supplemental order expanding the scope of Fact-Finding Investigation No. 29 (FF No. 29). As you may recall, the FMC opened FF No. 29 earlier this year in response to the disruptive effects COVID-19 has had on trade and for the purpose of identifying solutions for some […]

GKG Law Submits Comments To FMC Addressing Shipping Act Violation

Client Alert

GKG Law Principal Ed Greenberg and Associate Kristine Little submitted the below comments to the Federal Maritime Commission (FMC) on behalf of the National Customs Brokers and Forwarders Association of America (NCBFAA) in response to the agency’s Notice of Inquiry (NOI) that was looking into the propriety of steamship line billing practices. In a growing number of instances, […]

Treasury Provides Guidance on Humanitarian Shipments to Iran; Sanctions Shipping Agents in PRC and Hong Kong; and Amends Cuba Sanctions

Client Alert

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has recently provided guidance or taken action on a number of issues relevant to the forwarding industry. Secondary Sanctions on Iranian Financial Institutions On October 8, 2020, the U.S. Department of the Treasury designated eighteen Iranian banks under Executive Order (E.O.) 13902 (2020), […]

BIS Offers Streamlined Process for License Extension Requests / PRC Expands Export Controls

Client Alert

On October 16, 2020, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) implemented a new streamlined procedure for exporters to request six-month extensions of BIS licenses that expire on or before December 31, 2020. These requests for license extensions can be emailed to: LicenseExtensionRequest@bis.doc.gov. BIS estimates that processing will take only two to three […]

Challenging 301 Tariffs in Court to Recover List 3 and 4A Duties

Client Alert

Beginning in September 2020, thousands of companies have challenged the Section 301 China Tariffs under List 3 and 4A in the U.S. Court of International Trade. As part of this challenge, companies are seeking a refund of duties paid under List 3 and 4A, as well as revocation of those tariffs. The lawsuits allege that […]

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