Trade Compliance Resource Hub

Comment and analysis by Reed Smith lawyers on the latest developments in trade, sanctions and export controls

Effective May 17, the Department of Homeland Security (DHS) is adding 26 China-based cotton traders and warehouse facilities to the Uyghur Forced Labor Prevention Act (UFLPA) Entity List based on the U.S. government’s reasonable cause to believe the entities source or sell cotton from China’s Xinjiang Uyghur Autonomous Region (Xinjiang). These companies will now be

President Biden issued an order requiring a Chinese-owned crypto mining company to vacate and sell certain real property and remove equipment from land in close proximity to Warren Air Force Base (AFB) in Cheyenne, Wyoming.

In June 2022, the crypto mining company acquired 12.06 acres within 1 mile of the Warren AFB, a strategic missile

On May 14, the Office of U.S. Trade Representative (USTR) published its report on the four-year review of the Section 301 tariffs on Chinese-origin goods first imposed in 2018. The report concludes that the tariffs have been effective, but China has not yet eliminated the technology transfer-related acts, policies, and practices at issue in the

On Friday, the Office of Foreign Assets Control (OFAC) published an interim final rule that will amend the Report, Procedures and Penalties Regulations, 31 C.F.R. Part 501, effective August 8, 2024. The updates include:

  • Electronic filing and submission requirements: Filers will generally be required to use the electronic OFAC Reporting System (ORS) to submit (1)

Although aid to Israel, Ukraine, and Taiwan made headlines last month when President Biden signed H.R. 815, the law also significantly expanded the scope of agencies’ enforcement authority under two key national security laws: the International Emergency Economic Powers Act (IEEPA) and the Trading with the Enemy Act (TWEA). Both now have 10-year civil

Last fall, the Bureau of Industry and Security (BIS) paused its issuance of new export licenses involving certain firearms, related “parts,” “components,” and ammunition. On April 30, BIS will publish an interim final rule tightening controls of exports of these items. The interim final rule will take effect on May 30.

The interim final rule

In recent years, the sanctions clause has become a “must have” contractual clause. Any company that engages in activity involving high-risk goods or services, or relating to or in connection with high-risk jurisdictions, should incorporate clear and robust sanctions clauses in its contracts. Businesses face complex issues when interpreting and drafting sanctions clauses, requiring an

To expand the reach of U.S. sanctions, the Bureau of Industry and Security (BIS) amended the Export Administration Regulations (EAR) on March 21 to require a license for the export, reexport, or transfer (in-country) of all items “subject to the EAR” when a party to the transaction is blocked under one of 14 U.S. sanctions

After various delays, on 19 February 2024 the EU Commission issued its FAQ guidance on Article 3q of Council Regulation (EU) No. 833/2014 (as amended). The FAQ document provides some key clarifications sought by the market. However, some uncertainties remain