Month: August 2016

Recent AD/CVD Order Country and Product Trends

By: Jennifer Horvath, Senior Associate In the last 12 months, Anti-Dumping/Countervailing Duty (AD/CVD) orders against countries other than China are increasingly on the rise. The U.S. has continued to follow a dramatic five-year trend of involving multiple new countries such as Vietnam, Turkey, and Korea.  China has historically been the country most likely to be

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Changes to CBP’s Entry Reconciliation Program

Come October 1, 2016, CBP’s entry reconciliation program is scheduled to transition to the Automated Commercial Environment (ACE) from the Automated Commercial System (ACS), and with it, there will be an important change to the program. CBP will no longer be applying blanket flags to entry summaries. Under the current process, when an importer applies

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BIS Issues Final Rules on Charging and Penalty Determinations in Settlement of Administrative Enforcement Cases

By: Adrienne Braumiller, Founding Partner On June 22nd, the U.S. Commerce Department Bureau of Industry and Security (BIS) promulgated its final version of the revision of enforcement guidelines (effective July 22, 2016).  BIS proposed its initial revisions in December 2015. Concerns regarding the proposed revisions included the proposed base penalty amounts, mitigation factors, related violations, warning letters,

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U.S. Implementation of WTO ITA Expansion Begins

By: Adrienne Braumiller, Founding Partner In July, the Office of the United States Trade Representative (USTR) announced it has begun the process of implementing the expansion of the World Trade Organization (WTO) Information Technology Agreement (ITA). The process will be completed over the next 3 years. Once fully implemented, American technology exports will be freed

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CBP Signals Change Ahead with New Regulatory Audit Procedure

Trade Alert! CBP SIGNALS CHANGE AHEAD WITH NEW REGULATORY AUDIT PROCEDURE CBP officials with the Office of Regulatory Audit recently discussed changes to their approach to auditing importers for compliance, along with the possibility of issuing penalties for non-compliance, in a meeting with representatives for the Washington D.C., based American Association of Exporters and Importers

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