Recent Trade Compliance News
On December 14, 2020, the US Government announced Sudan’s removal from the list of State Sponsors of Terrorism (the “SST List”). This rescission of Sudan as an SST follows an agreement in October for Sudan to be removed from the list and the lapse of a 45 day congressional notification period.
See https://www.state.gov/sudans-state-sponsor-of-terrorism-designation-rescinded/
On December 14, 2020, the US Government announced Sudan’s removal from the list of State Sponsors of Terrorism (the “SST List”). This rescission of Sudan as an SST follows an agreement in October for Sudan to be removed from the list and the lapse of a 45 day congressional notification period.
See https://www.state.gov/sudans-state-sponsor-of-terrorism-designation-rescinded/
On December 3, 2020, the Department of Defense announced its third list of “Communist Chinese military companies” operating in the United States, pursuant to Section 1237 of the National Defense Authorization Act for Fiscal Year 1999, as amended (“Section 1237”). The practical impact of the announcement is that these four companies become subject to Executive Order 13959, which restricts US investment in these companies.
On December 3, 2020, the Department of Defense announced its third list of “Communist Chinese military companies” operating in the United States, pursuant to Section 1237 of the National Defense Authorization Act for Fiscal Year 1999, as amended (“Section 1237”). The practical impact of the announcement is that these four companies become subject to Executive Order 13959, which restricts US investment in these companies.
On December 2, 2020, the Department of Homeland Security (DHS) announced that US Customs and Border Protection (CBP) Office of Trade directed the issuance of a Withhold Release Order (WRO) against cotton products originating from the Xinjiang Production and Construction Corps (XPCC).in China based on information that reasonably indicates the use of forced labor, including convict labor. The WRO applies to all cotton and cotton products produced by the XPCC and its subordinate and affiliated entities as well as any products that are made in whole or in part with or derived from that cotton, such as apparel, garments, and textiles.
On December 2, 2020, the Department of Homeland Security (DHS) announced that US Customs and Border Protection (CBP) Office of Trade directed the issuance of a Withhold Release Order (WRO) against cotton products originating from the Xinjiang Production and Construction Corps (XPCC).in China based on information that reasonably indicates the use of forced labor, including convict labor. The WRO applies to all cotton and cotton products produced by the XPCC and its subordinate and affiliated entities as well as any products that are made in whole or in part with or derived from that cotton, such as apparel, garments, and textiles.
On November 25, 2020, the Department of Homeland Security (DHS) published in the Federal Register a notice of two ratification documents regarding a number of previous actions by DHS. The ratifications are intended to provide the public with certainty, by resolving any potential defect in the validity of those actions. : The ratification documents were signed on November 16, 2020 and relate back to the original date of each action ratified.
See https://www.govinfo.gov/content/pkg/FR-2020-11-25/pdf/2020-26060.pdf
On November 17, 2020, the US Treasury Department’s Office of Foreign Asset Control (OFAC) amended General License (“GL”) 8F and re-issued it as General License 8G. GL 8G extends the validity period of certain limited maintenance and wind-down transactions and activities involving Petróleos de Venezuela S.A. (“PdVSA”) until June 3, 2021.
On November 18, 2020, CBP issued CSMS #44905878 – GUIDANCE: Section 301 Tranche 3 – $200B Action Technical Amendment to Product Exclusion from China.
See https://content.govdelivery.com/bulletins/gd/USDHSCBP-2ad3596?wgt_ref=USDHSCBP_WIDGET_2
On November 17, 2020, the US International Trade Commission (ITC) published in the Federal Register a notice of proposed recommendations and solicitation of public comments on Investigation No. 1205-13, Recommended Modifications in the Harmonized Tariff Schedule, 2020, which the ITC instituted on October 1, 2019. The ITC’s proposed recommendations relating to Investigation No. 1205-13 have been posted on the ITC Web site.
See https://www.govinfo.gov/content/pkg/FR-2020-11-17/pdf/2020-25305.pdf