This Month in International Trade - May 2016
In this issue:
- Customs / Imports / Trade Remedies
- Sanctions / Financial Crime / Anti-Corruption / Export Control
- Trade Agreement and Investment Updates
- Agency Enforcement Actions
- Bureau of Industry and Security (BIS)
- U.S. Customs and Border Protection (CBP)
- Other Agency Actions
- Bureau of Industry and Security (BIS)
- Directorate of Defense Trade Controls (DDTC)
- Office of Foreign Assets Control (OFAC)
- U.S. Customs and Border Protection (CBP)
- Crowell & Moring Speaks
This news bulletin is provided by the International Trade Group of Crowell & Moring. If you have questions or need assistance on trade law matters, please contact John B. Brew or any member of the International Trade Group.
CUSTOMS / IMPORTS / TRADE REMEDIES
President Signs Duty Suspension Bill; Is your Company Ready to Take Advantage?
On May 20, the President signed the Miscellaneous Tariff Bill (MTB), known as the American Manufacturing Competitiveness Act of 2016 (AMCA), into law. The AMCA will reform the long-stalled MTB process by reducing or eliminating tariffs on the importation of products not manufactured in the U.S.
Companies should begin to review their import and purchasing data to identify potential MTB opportunities as the petition period will only be open with the U.S. International Trade Commission (ITC) for sixty days and then will not be open again until 2019.
The ITC can initiate the process at any time, but no later than October 15, 2016.
For detailed information on the MTB, please see Crowell’s client alert.
For more information, contact: John Brew, Frances Hadfield, Jini Koh, Mike Gill
CBP Advises Supply Chain Review for Forced Labor – Third Detention Order Issued
A Detention Order was issued by U.S. Customs and Border Protection (CBP) Commissioner R. Gil Kerlikowske on June 1 for imported stevia extracts (a sweetener) produced by PurceCircle Ltd. of the People’s Republic of China because of allegations that convict labor is used in the production of the product. The ban encompasses all imported stevia extracts and their derivatives.
This is CBP’s third withhold release order since the Trade Facilitation and Trade Enforcement Act of 2015 was signed into law by President Obama on February 24, 2016. The law repealed the “consumptive demand” clause which had allowed importation of certain forced labor-produced goods if the goods were not produced “in such quantities in the U.S. as to meet the consumptive demands of the U.S.”
Under 19 U.S.C. § 1307 it is now illegal to import into the U.S. goods made, in whole or in part, by forced labor, including convict labor, forced child labor, and indentured labor. When information reasonably (but not conclusively) indicates that merchandise of this type is being imported, CBP may issue "withhold release orders" pursuant to 19 C.F.R. § 12.42(e).
Stevia rebaudiana (Bertoni) Bertoni, a plant native to various parts of South America, is commonly used as a low calorie sweetener, and is sold in the U.S.
Commissioner Kerlikowske, in CBP’s press release, advised the trade community to closely examine their supply chains to ensure goods imported into the U.S. are not mined, produced or manufactured, wholly or in part, with prohibited forms of labor, i.e., slave, convict, forced child, or indentured labor.
For more information, contact: Frances Hadfield, Anne Li
Customs Launches Trade Enforcement Task Force Focused on Forced Labor Ban, Trade Remedy Laws
U.S. Customs and Border Protection (CBP) announced on May 2 the establishment of a Trade Enforcement Task Force to “further protect the American economy and domestic industry.” The announcement said the task force is “focused on issues related to enforcement of antidumping and countervailing duty (AD/CVD) laws, and interdiction of imported products using forced labor.”
CBP said the Trade Facilitation and Trade Enforcement Act of 2015 strengthened its enforcement capabilities and methods and enhances its “…efforts to combat the import of counterfeit goods and protect intellectual property rights holders, and eliminates obstacles to preventing imports made with forced or child labor into the U.S.”
For more information, contact: Frances Hadfield
New EU Customs Code Implemented; Firms Advised to Watch for Updated Guidance Docs
The much-heralded entry into force of the Union Customs Code (UCC) on May 1 was notable for the general absence of any disruption to EU trade flows. This confirms that the more difficult work of thoroughly implementing the UCC in ways that will truly affect businesses remains to be done in many respects.
Accordingly, the European Commission has continued to release guidance documents on a variety of key issues concurrently with the UCC’s entry into force. Careful interpretation of these guidance documents will be essential for businesses, especially as these will evolve in light of practice and experience.
First among these is the Guidance on Customs Valuation of April 28, one of the areas likely to have an important impact for many manufacturers and importers. Duty payments may increase as a result of the UCC abolishing the first sale valuation method in favor of the transaction value applicable immediately before the goods are brought into the EU customs territory, with a grandfather clause allowing first sale valuation in certain instances until December 31, 2017. This guidance document thus provides additional explanations and practical examples regarding not only transaction value but also royalties and license fees.
Important definitions have also been elaborated in two recently published documents on the definitions of “exporter” (May 20) and “ship supplies” (April 27). With respect to the former, changes brought about by the UCC cast doubt whether businesses not established in the EU may act as exporters. Thus, the guidance document addresses the meaning of both “established in the customs territory of the Union” under UCC Article 5 and “power of determining that the goods are to be brought outside the customs territory of the Union” under UCC Article 1. It also provides eight different practical examples.
Similarly, a Transit Manual was published on April 27 to promote a better understanding of the transit procedure and the roles of the various participants in the customs process. Among other areas, this detailed guidance document addresses guarantees, the standard transit procedure under the new computerized transit system (NCTS), simplifications, as well as debt and recovery. In addition, another guidance document was published on May 4 on Special Procedures Other Than Transit. This detailed document addresses the full range of (i) storage (including customs warehousing and free zones), (ii) specific use (including temporary admission and end-use), and (iii) both inward and outward processing.
Finally, a useful list of projects related to the development and deployment of the electronic systems supporting and implementing key provisions of the UCC can be found in a recent Commission Implementing Decision establishing the work program in this context. Key deployment dates are provided for seventeen different elements through 2017 and into 2020.
For more information, contact: Ian Laird, Paul Davies, Charles De Jager
G7 Leaders Call for Elimination of Global Excess Steel Capacity
Ahead of the G7 meeting in Japan, steel industry groups from Canada, France, Germany, Italy, Japan, the United Kingdom, and the United States signed a joint statement urging G7 leaders to maintain strong barriers against unfairly traded imports of steel into their countries. Although they refrained from explicitly referring to China, the target of the statement was clear.
As a result, upon conclusion of the meeting in Japan, the G7 Leaders’ Declaration included a statement recognizing that “global excess capacity in industrial sectors, especially steel, is a pressing structural challenge with global implications and this issue needs to be urgently addressed through elimination of market distorting measures and, thereby, enhancement of market function.”
EU foreign affairs ministers also discussed overcapacity in the steel industry before the G7 meeting. They opted not to reinforce the EU trade defense instruments in accordance with ideas presented earlier by the Commission, but called for technical work on these issues to proceed without delay. One idea involves eliminating the lesser duty rule, which limits the level of duties the EU can apply by requiring tariffs be imposed at the lowest level possible to deter dumping. The European Parliament has adopted a resolution urging Member States to scrap the lesser duty rule, but some Member States including the UK argue for other approaches, including accelerating antidumping investigations and triggering investigations based on threat of injury to the domestic industry.
In the U.S., U.S. Steel Corp., on April 26, decided to proceed with a sweeping Section 337 petition targeting imports of Chinese carbon and alloy steels. A supplement to the complaint was filed on May 16. Although Section 337 has been used almost exclusively by U.S. companies to defend their intellectual property rights against infringement by foreign competitors, U.S. Steel’s petition extends beyond claims its trade secrets were stolen to include additional claims traditionally advanced in antidumping and countervailing duty proceedings.
The U.S. International Trade Commission (ITC) published a notice in the Federal Register on June 2 stating it had considered U.S. Steel’s complaint and was proceeding with an investigation. Responses to the complaint and the notice of investigation must be submitted by the named respondents not later than 20 days after the date of service by the ITC of the complaint and the notice of investigation in order to be considered.
U.S. Steel seeks a general exclusion order, which could have significant negative effects on parts on the U.S. economy. As result, commentators suggest U.S. Steel may have filed its petition to accelerate the course of high-level talks on the issue among China, the EU, and the U.S.
For more information, contact: Ian Laird, Paul Davies, Charles De Jager, Benjamin Blase Caryl
New AD/CVD Case Filed on Ammonium Sulfate from China
On May 25, PCI Nitrogen filed antidumping (AD) and countervailing (CVD) petitions for relief from low-priced imports of ammonium sulfate from China. PCI Nitrogen is seeking AD duties ranging from 273 to 475 percent of the price of these fertilizer imports.
The U.S. International Trade Commission (ITC) will hold a preliminary conference on June 15 in Washington, DC, in which interested parties (US producers, importers, purchasers, and foreign producers/exporters) may testify and answer ITC staff questions about the ammonium sulfate industry and market. The U.S. Department of Commerce will then begin an investigation to calculate the proper AD/CVD duties for the largest Chinese exporters of ammonium sulfate.
For more information, contact: Benjamin Blase Caryl
SANCTIONS / FINANCIAL CRIME / ANTI-CORRUPTION / EXPORT CONTROL
Investors See Current Opportunities in Cuba
In the wake of recent relaxations, there are a growing number of examples of commercial relationships between the U.S. and Cuba. The most recent publicly-reported instance is an agreement signed between T-Mobile and ETECSA (Cuba’s government-owned telecom company) allowing T-Mobile to offer services to its clients in Cuba. Non-U.S. companies have also announced recent deals. For example, the Anglo-Dutch multinational Unilever was granted permission to assume a 60 percent ownership interest in a planned $35 million plant to be built in Mariel, one of Cuba’s special development zones.
Although both deals provide evidence that U.S. and non-U.S. multinationals are finding opportunities in Cuba, there remain substantial practical challenges. For instance, despite international press reports to the contrary, Cuba has not yet legalized small and medium enterprises in Cuba. Instead, the Cuban Communist Party (Party) has announced the “legalization” of small and medium enterprises as a future objective for both the economy and the Party, but the plan still requires approval by the Cuban National Assembly. For the moment, the Cuban Government has only approved private sector operations in Cuba in a limited list of vocations, which does not yet include independent professions such as economists, lawyers, or doctors.
Nevertheless, despite these challenges, the recent deals by T-Mobile, Unilever, Starwood and others show that commercial relationships are possible and that the Cuban government is open to the possibility of potential partnerships in certain industries.
For more information, contact: Cari Stinebower, Mariana Pendas, Dj Wolff
U.S. Further Relaxes Burma Sanctions with New and Expanded General Licenses, SDN Removals
In advance of Secretary of State John Kerry’s visit to Burma/Myanmar, the Obama Administration announced further relaxations of financial sanctions against the country on Tuesday, May 17.
This move signals the administration’s support of Burma’s economic growth and recognition of its recent democratic elections, while maintaining some elements of the sanctions to keep pressure on designated individuals to incentivize further reforms.
The further easing of U.S. sanctions against Burma significantly removes barriers to trade that remained after the first waves of sanctions relaxations in 2012 and 2013. Although new opportunities have been created by these revisions, companies seeking to enter the Burmese market nevertheless should continue to carefully evaluate business partners to ensure compliance with U.S. law generally and with anti-corruption/anti-bribery laws specifically.
For more on the changes to the Burmese Sanctions Regulations, please see Crowell’s client alert.
For more information, contact: Carlton Greene, Cari Stinebower, Dj Wolff, Lindsay Denault
President Extended Venezuela Sanctions to 2017, Senate Now Pushing for 2019
On March 3, President Obama issued the “Continuation of the National Emergency With Respect to Venezuela,” extending for one year Executive Order 13692 (Mar. 8, 2015), "Blocking Property and Suspending Entry of Certain Persons Contributing to the Situation in Venezuela."
On April 28, the U.S. Senate passed the Venezuela Defense of Human Rights and Civil Society Extension Act of 2016, extending the sanctions program on Venezuela for three years, until December 31, 2019. Once the bill is approved by the U.S. House of Representatives and signed into law, the U.S. Government will have the authority to continue imposing sanctions on government officials responsible for violations of human rights of anti-government protesters in Venezuela.
To date, the U.S. has imposed sanctions on seven individuals linked with the Venezuelan military, intelligence service, and judiciary.
For more details, please see Crowell's client alert on the Executive Order, as well as Crowell's summary of the legislation.
For more information, contact: Cari Stinebower, Dj Wolff, and Eduardo Mathison
DDTC and BIS Revise Definitions in ITAR and EAR – Effective September 1
On June 3, the Directorate of Defense Trade Controls (DDTC) and the Bureau of Industry and Security (BIS) issued their long awaited revisions to definitions contained in the International Traffic in Arms Regulations (ITAR) and the Export Administration Regulations (EAR), as part of Export Control Reform’s (ECR) continuing effort to harmonize, where appropriate, the two export regimes.
Although both rules are effective on September 1 and represent a milestone in standardizing the ITAR and EAR, additional rules will be required to complete this process. The DDTC revision, for example, is an interim final rule allowing stakeholders the opportunity to provide comments until July 5th. BIS less formally leaves the door open for comments on the revision, stating it welcomes public comments on its rule on a continuing basis, and in places suggests certain comments received in response to the proposed rule will require further rulemaking.
Please see Crowell’s client alert for the key “takeaways” from both rules.
For more information, contact: Alan W.H. Gourley, Christopher Monahan, Lindsay Denault, Jana del-Cerro
Court Dismisses Challenge to FinCEN Section 311 ‘Finding of Primary Money Laundering Concern’ for Banca Privada d’Andorra
On May 18, the U.S. District Court for the District of Columbia granted the U.S. Treasury Department’s Financial Crimes Enforcement Network’s (FinCEN) motion to dismiss a civil action brought by shareholders of an Andorran privately-held bank, Banca Privada d’Andorra (BPA), challenging FinCEN’s issuance of a Notice of Finding (NOF) identifying BPA as a “primary money laundering concern” and Notice of Proposed Rulemaking (NPRM) to impose special measures against BPA pursuant to Section 311 of the USA PATRIOT Act that would prohibit U.S. banks from maintaining correspondent accounts for BPA.
The court ruled that FinCEN’s withdrawal of the notices, following the seizure of the bank by the Andorran financial regulator, rendered the shareholders’ claims moot. This dismissal provides important support for FinCEN’s use of the Section 311 tool, particularly when foreign regulators choose to take action under their own law following the issuance by FinCEN of a finding of primary money laundering concern against a foreign financial institution.
For detailed information on this case, please see Crowell’s client alert.
For more information, contact: Carlton Greene, Cari Stinebower, Jana del-Cerro, J.J. Saulino
FinCEN Final Rule on Beneficial Ownership and the Administration’s New Initiatives on Financial Transparency: What You Need to Know
On May 6, 2016, the Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) released a final rule (the Final Rule) requiring banks, brokers or dealers in securities, mutual funds, futures commission merchants, and introducing brokers in commodities (collectively, covered financial institutions) to obtain and record beneficial ownership information as part of their anti-money laundering (AML) obligations under the Bank Secrecy Act (BSA).
The Final Rule will become effective 60 days after its May 11 publication in the Federal Register; however, covered financial institutions will have a two year implementation period to comply with the new requirements. In conjunction with the release of the Final Rule, the White House announced a series of related legislative and regulatory initiatives aimed at increasing financial transparency and combatting corruption in the wake of the Panama Papers.
For detailed information on this final rule, please see Crowell’s client alert.
For more information, contact: Carlton Greene, Cari Stinebower, Kelly Currie, James Flood, Dalal Hasan, J.J. Saulino
TRADE AGREEMENT AND INVESTMENT UPDATES
Public Procurement in TTIP Remains a Significant EU Concern; EU Member States Urged to Tout Benefits to Citizens
Following the productive thirteenth round of TTIP negotiations in late April, EU and U.S. officials have continued to engage in a variety of areas in which more progress is required. Among these is public procurement, which the EU has identified as one of its most important interests in the negotiations. One exchange of offers has been made by the parties thus far, but the EU deems the U.S. offer inadequate. Elimination or significant modification of the Buy American Act is recognized by EU officials to be impossible in an election year. However, they are hopeful certain exceptions or waivers could be negotiated at the margins, perhaps after the election.
In accordance with the Commission’s practice of conducting sustainability impact assessments of trade agreements under negotiation, a draft of the technical report relating to TTIP was issued in May. The report highlights the opportunities TTIP could generate for people and businesses across Europe. It predicts that EU exports to the U.S. would increase by 27 percent and concludes that all EU Member States’ economies would grow as a result of TTIP. The report also considers TTIP’s likely social and environmental impact, with indicators showing a combined benefit for European and U.S. citizens. Interested stakeholders now have the opportunity to comment on the draft report.
With EU Member States’ politicians like French President François Hollande and German Economic and Trade Minister Sigmar Gabriel recently making public statements distancing themselves from TTIP and casting doubt on its desirability, European Commission President Jean-Claude Junker will reportedly ask EU leaders to reconfirm their commitment to TTIP at the European Council in late June. EU Trade Commissioner Cecilia Malmström has also suggested that despite their professed firm support for TTIP, EU Member States’ foreign affairs ministers could do more to convince their own citizens of its benefits.
In addition, Malmström has noted that progress on TTIP could be slowed by the fact that the U.S. Congress must still ratify the Trans-Pacific Partnership (TPP). As a result, she recently stated at a conference in Stockholm that, although her ambition remains to finalize TTIP this year, failure to meet that deadline does not mean the talks have failed. For his part, U.S. Trade Representative Michael Froman has suggested that if the negotiations are delayed for an unforeseeable period of time, the EU and U.S. might miss their opportunity to help establish global rules reflective of their shared values.
For more information, contact: Ian Laird, Paul Davies, Charles De Jager
ITC Report Released as Obama Administration Continues Push for TPP Vote
On May 18, the U.S. International Trade Commission (ITC) published its long-awaited report – mandated by the Trade Promotion Act - on the economic impact of the Trans Pacific Partnership (TPP). The report forecasts a small increase in U.S. gross domestic product, along with a slight gain in employment over the thirty-year implementation period for the agreement. The impact of TPP would vary by sector, with the manufacturing and energy sectors seeing minor output contractions while the U.S. agriculture and food sectors would see the largest gains.
As the Office of the U.S. Trade Representative (USTR) publicly clarified in the days before the release of the report, the ITC report’s methodology for calculating economic impact only takes into account the reduction or removal of non-tariff barriers for goods and services and intellectual property protections contained in the agreement, along with the reduction or removal of tariff barriers. It does not, however, seek to model economic effects from changes in domestic regulations or the other dynamic impacts of trade liberalization. Other analyses that have sought to incorporate those effects, such as the Peterson Institute, have shown slightly larger gains from TPP.
TPP supporters and opponents both cited the ITC report as validation for their positions. The top Democrat on the Ways and Means Committee, Sander Levin (D-Michigan), who opposes the agreement, said the report confirmed his belief that TPP would weaken the U.S. auto industry. On the other hand, leading Republicans, including both House Ways and Means Chairman Kevin Brady (R-Texas) and Senate Finance Committee Chairman Orrin Hatch (R-Utah), noted the economic benefits described by the report but urged the Obama Administration to address their outstanding substantive concerns on the agreement.
The report arrives in the midst of an ongoing push by the Obama Administration for a congressional vote on TPP this year, to take place during the lame-duck session of Congress following the November election. President Obama, in travel the past month to Vietnam and Japan, spoke to government officials and made public remarks touting the benefits of the agreement.
The Administration also appeared to be close to addressing one of the key substantive concerns Republican leaders have raised regarding the exclusion of the financial services sector from the protections against data localization contained in TPP. In late May, USTR and the Department of the Treasury issued a concept note for industry and Congress on a framework to address data transfer and data localization requirements for the financial services sector in future trade agreements. The framework is not expected to change TPP, nor take the form of side-letters to the agreement.
For more information, contact: Paul Davies, Dj Wolff, Evan Yu
EU-U.S. Data Transfer Turmoil Continues: “Privacy Shield” Needs Improvement
In a May 26, 2016 resolution, the European Parliament (EP) recommended that the European Commission should continue negotiating with the U.S. to improve the draft “EU-U.S. Privacy Shield” (Privacy Shield), the EU-U.S. data transfer mechanism intended to replace the invalidated “U.S.-EU Safe Harbor.”
For detailed information on this important update, please see Crowell’s client alert.
For more information, contact: Jeffrey L. Poston, Emmanuel Plasschaert, Jeane A. Thomas, Evan D. Wolff, Robin B. Campbell, Frederik Van Remoortel, Christopher Hoff, Lisa Weinert
AGENCY ENFORCEMENT ACTIONS
Bureau of Industry and Security (BIS)
- On May 4, BIS announced the denial of export privileges for 10 years to Ali Khanaman Mohammadi, convicted of violating the International Emergency Economic Powers Act (IEEPA). Specifically, Mohammadi knowingly and willfully conspired with others known and unknown to export goods and technology, namely, one Series 446 Rate Integrating Gyroscope, Model LC08, from the U.S. to Iran.
- On May 19, BIS entered into a Settlement Agreement with Unisol International of Miami, Florida, to settle five alleged charges of Acting with Knowledge of a Violation of the Export Administration Regulations (EAR) in connection with the sale and/or transfer of Axis Q1921-E thermal imaging cameras to Ecuador, Venezuela, and Mexico. The company agreed to a civil penalty of $250,000.
U.S. Customs and Border Protection (CBP)
- On May 9, the U.S. government filed a complaint in the U.S. Court of International Trade (CIT) against Kenneth H. Chew, a former customs broker, for allegedly falsifying 275 entries of merchandise entering the U.S. between Oct. 30, 2006, and Sept. 6, 2010, causing CBP a revenue loss of more than $400,000.
- CBP seeks recovery of the revenue loss, as well as a $3.2 million penalty, plus interest and costs.
- The complaint alleges that Mr. Chew routinely falsified information, misstated the value of goods, knowingly misclassified merchandise, and provided CBP with altered invoices. In January 2016, CBP revoked his customs broker’s license.
For more information, contact: Edward Goetz
OTHER AGENCY ACTIONS
Bureau of Industry and Security (BIS)
- On May 12, BIS published a final rule amending the Export Administration Regulations (EAR) to remove the short supply license requirements that, prior to the entry into force of the “Consolidated Appropriations Act, 2016” on December 18, 2015, applied to exports of crude oil from the U.S.
- Specifically, this rule removes the Commerce Control List (CCL) entry and the corresponding short supply provisions in the EAR that required a license from BIS to export crude oil from the U.S.
- This rule also amends certain other EAR provisions to reflect the removal of these short supply license requirements.
- Consistent with the exceptions in the act, exports of crude oil continue to require authorization from BIS to embargoed or sanctioned countries or persons and to persons subject to a denial of export privileges.
- BIS is holding a meeting of the Regulations and Procedures Technical Advisory Committee (RPTAC) on June 14. The RPTAC “advises the Office of the Assistant Secretary for Export Administration on implementation of the Export Administration Regulations (EAR) and provides for continuing review to update the EAR as needed.”
Directorate of Defense Trade Controls (DDTC)
- During May, DDTC posted notices on its website regarding changes to licensing restrictions for Sri Lanka, Cote d’Ivoire, Vietnam, and Liberia.
- In all four cases, DDTC announced it will review applications for licenses to export or temporarily import defense articles and defense services to or from Sri Lanka, Cote d’Ivoire, Vietnam, and Liberia under the International Traffic in Arms Regulations (ITAR) on a case-by-case basis.
- On May 25, DDTC posted a Web Notice concerning its most recent IT Modernization Webinar for Industry, held on May 20.
Office of Foreign Assets Control (OFAC)
- In May and early June, OFAC issued/updated several Kingpin Act General Licenses:
- General License 2, “Authorizing Certain Transactions and Activities to Wind Down Operations for the Hotel Operating at Millennium Plaza, Panama.”
- General License 3A, “Authorizing Certain Transactions and Activities Necessary to Maintain Existing Operations of La Estrella and El Siglo Newspapers."
- General License 4A, “Authorizing Certain Transactions Involving Individuals or Entities Located in the Panamanian Mall and Associated Complex, Soho Panama, S.A. (a.k.a. Soho Mall Panama).”
- General License 5, “Authorizing Certain Transactions and Activities Related to the Panamanian Seizure of Balboa Bank & Trust.”
- General License 6, “Authorizing Certain Transactions and Activities Related to the Intervention by the Superintendency of Securities Markets of Panama in Balboa Securities, Corp.” These General Licenses authorize certain transactions and activities that would otherwise be prohibited pursuant to the Kingpin Act.
- During May, OFAC published or amended five FAQs regarding General Licenses Issued Authorizing Certain Activities Pertaining to Panama.
U.S. Customs and Border Protection (CBP)
- In a pair of Federal Register Notices in May, CBP announced upcoming system changes for processing electronic entries and entry summaries.
- CBP launched a Quarterly Trade Enforcement Bulletin in May. Executive Assistant Commissioner Brenda B. Smith, Office of Trade, said it is designed to highlight “some of the many successes in which U.S. Customs and Border Protection enforces U.S. trade laws at and beyond our nation’s borders through interagency partnership and collaboration.”
For more information, contact: Edward Goetz
CROWELL & MORING SPEAKS
Addie Cliffe and Carlton Greene presented on the International Panel at Crowell & Moring’s Ounce of Prevention Seminar (OOPS) on May 25 in Washington DC. Please click here to view the full conference presentation.
Charles De Jager presented at the International Compliance Association’s (ICPA) EU/UK Conference in Rome on June 7. He was a panelist discussing the latest updates on U.S. and EU economic sanctions.
JOIN US FOR “Venezuela Update: Exchange Controls and Possible International Remedies to Recover Stranded Funds, and OFAC Sanctions”
This free webinar will be held on Wednesday, June 22, 2016 from 11:00 AM – 12:00 PM ET.
Topics will include:
- Venezuela’s exchange controls regime
- New DIPRO and DICOM platforms, and other measures and legal instruments recently adopted by the Venezuelan Government
- Legal protections and potential recovery mechanisms for foreign investors provided in BITs signed by Venezuela
- Time limitations and other implications of pursuing international arbitration against Venezuela
- Settlement strategy and other efforts to seek a negotiated solution with the Venezuelan Government
- Update on U.S. OFAC’s Venezuela sanctions
Presenters include members of Crowell & Moring’s International Dispute Resolution and International Trade teams, and C&M International, based in Washington, D.C., and AraqueReyna’s Corporate and Alternative Dispute Resolution teams based in Caracas, Venezuela.
Please click here for more information about this webinar.
For more information, please contact the professional(s) listed below, or your regular Crowell & Moring contact.