US Commerce implements Aluminum Import Monitoring and Analysis System

On December 23, 2020 the International Trade Administration (ITA) at Commerce, published in the Federal Register a final rule [Docket No. 201014-0270] that adopts the Aluminum Import Monitoring and Analysis (AIM) system by promulgating new regulations (19 C.F.R. Part 361) that establish a website for the AIM system that consists of an online aluminum import license application platform and public AIM monitor; require importers, customs brokers or their agents to apply for and obtain an import license for each entry of certain aluminum products into the United States through the AIM system website, etc. The final rule is effective January 25, 2021.


US Government imposes new sanctions on Russia

In the past several days, the US Government has issued a slew of sanctions measures targeting Russia. According to a White House Fact Sheet (see, these measures are stated to be in response to Russia’s “harmful foreign activities,” including efforts to undermine free and fair democratic elections and institutions, malicious cyber activities (including the recent SolarWinds incident), transnational corruption, targeting of dissidents and journalists, undermining national security and violating the territorial integrity of states. The latest measures include: 1. A new Executive Order 14024 (see; 2. The addition of several new parties to the OFAC Specially Designated Nationals and Blocked Persons List (see, and 3. A related new Directive prohibiting US financial institutions from participating in the primary market for certain ruble, as well as non-ruble, denominated Russian sovereign bonds and loans (see

CBP publishes quarterly interest rates

On April 23, 2021, US Customs and Border Protection (CBP) published in the Federal Register a general notice that advises the public that the quarterly Internal Revenue Service interest rates used to calculate interest on overdue accounts (underpayments) and refunds (overpayments) of customs duties will remain the same from the previous quarter. For the calendar quarter beginning April 1, 2021, the interest rates for overpayments will be 2 percent for corporations and 3 percent for non-corporations, and the interest rate for underpayments will be 3 percent for both corporations and non-corporations.


UK imposes sanctions on four individuals and one entity linked to Xinjiang

On 22 March 2021, the UK Government added four individuals and one entity to the Global Human Rights financial sanctions regime, in relation to alleged human rights violations taking place in Xinjiang, China. These measures were announced in coordination with Canada and the United States, and in parallel to EU measures.


US Commerce extends military-intelligence end-use and end user controls to Burma

On April 9, 2021, the US Commerce Department’s Bureau of Industry and Security (BIS) strengthened restrictions targeting Burma by adding Burma to the list of countries subject to the Export Administration Regulations’ (EAR’s) military-intelligence end-use and end-user controls and controls on certain support activities by US persons (“Interim Final Rule“). These controls were first issued on January 15, 2021 (“January Rule“), and became effective March 16, 2021.


BIS adds seven Chinese parties involved in supercomputing to the Entity List

On April 9, 2021, the US Commerce Department’s Bureau of Industry and Security (BIS) published a final rule in the Federal Register to add seven Chinese parties to the Entity List.  The Final Rule took effect on April 8, 2021.  According to the Final Rule and the Commerce Department’s press release, the Designees were added to the Entity List because they have procured US-origin items for use in building supercomputers that are used to support China’s military actors and military activities.


US Treasury Department removes UAE from list of boycotting countries

On April 8, 2021, the US Treasury Department published an updated List of Countries Requiring Cooperation With An International Boycott  (the “Treasury List”). Significantly, Treasury announced that it had removed the UAE from the Treasury List following the UAE’s repeal of its law requiring participation with the Arab League Boycott of Israel and subsequent implementation of the new policy.


US Commerce to delay aluminum licensing requirement again

On March 29, 2021, the Commerce Department announced that it is submitting a notice announcing a delay in the March 29, 2021 effective date of the Aluminum Import Monitoring and Analysis (AIM) system to the Office of the Federal Register. Commerce had published a final rule in the Federal Register on December 23, 2020, adopting the AIM system regulations and establishing an AIM website.  The AIM website consists of an online aluminum import license application platform and public AIM monitor. Under the AIM regulations, all aluminum imports into the United States will require an import license for Customs entry summary. The aluminum import license is an automatic license used for data collection purposes only. The delay means that licenses will not be required for covered aluminum product imports beginning on March 29, 2021 until June 28, 2021.


China imposes sanctions on US, Canadian entities

Beijing announced on March 27 sanctions on US and Canadian individuals and an entity, urging the parties to redress their mistakes and stop political manipulation on Xinjiang-related issues. The Chinese penalties were in response to the two countries’ unilateral sanctions on individuals and entities in the Xinjiang Uygur autonomous region on March 22 based on rumors and disinformation.

According to a statement issued by the Foreign Ministry, the sanctions were placed on three individuals and one entity, namely Chair of the United States Commission on International Religious Freedom Gayle Manchin, Vice-Chair of the USCIRF Tony Perkins, Canadian Member of Parliament Michael Chong, and the Subcommittee on International Human Rights of the Standing Committee on Foreign Affairs and International Development of the House of Commons of Canada. The individuals concerned are prohibited from entering the Chinese mainland and the Hong Kong and Macao special administrative regions, and Chinese citizens and institutions are prohibited from doing business with the individuals and having exchanges with the subcommittee.


USTR terminates Sec. 301 DST investigations for Brazil, the Czech Republic, the EU and Indonesia

On March 26, 2021, the Office of the United States Trade Representative (USTR) posted an advance copy of a Federal Register notice terminating, as of March 26, 2021, the Section 301 investigations of Digital Services Taxes (DSTs) under consideration by Brazil, the Czech Republic, the European Union, and Indonesia because these jurisdictions either have not adopted or not implemented a DST during the period of investigation.