Author: Adrienne Braumiller


Should You File a Prior Disclosure in 2023?

By Adrienne Braumiller and Harold Jackson

2023 is more than a brand-new year – it is an opportunity for your company to prioritize supply chain and customs compliance. For some companies, this means filing a prior disclosure with U.S. Customs and Border Protection (CBP). Companies that are frequent importers are seriously considering disclosing entry violations under the condition that Customs will not issue civil penalties against them.

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The U.S. and China are in a trade war

Doing Business with China Continues to Get More Difficult for U.S. Companies

By: Bruce Leeds, Senior Counsel and Adrienne Braumiller, Partner & Founder

The U.S. and China are not only in a trade war but there is also an effort by the U.S. to (1) prevent development of supercomputers, semiconductors and related products and technologies, and (2) prevent use of forced labor – especially involving the Uyghur minority in the Xinjiang region. U.S. companies planning to export to China are facing a new or revised set of restrictions that may make their business more challenging.

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Customs Broker Regulations

New Rules for Customs Brokers – Bringing Your Brokerage into Compliance with the Modernized Part 111

By: Adrienne Braumiller Founding Partner and Bruce Leeds, Senior Counsel

After several years of review by U.S. Customs and Border Protection (“CBP”), the Customs Broker community, and the Commercial Customs Operations Advisory Council, CBP unveiled the new Customs Broker Regulations under 19 C.F.R. Part 111. On October 18, 2022, CBP published the final rules, Modernization of the Customs Broker Regulations, 87 FR 63267, and Elimination of Customs Broker District Permit Fee, 87 FR 63262, which go into effect on Monday, December 19, 2022.

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China Tariffs

Section 301 Update: Four-Year Review, Exclusions, Litigation, and the Future of China Tariffs

By: Adrienne Braumiller, Partner & Founder, Braumiller Law Group

China Tariffs are here to stay – for now. The Biden Administration continues to defend the Trump-era tariffs on goods from China with little guidance as domestic inflation climbs steadily. Meanwhile, 2022 has been a busy year for the Office of the U.S. Trade Representative (“USTR”). The agency was instructed by the Court of International Trade to provide further written justification for the Section 301 Actions for Lists 3 and 4a in the wake of the agency’s obligatory four-year review of each tariff action.

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Uyghur Forced Labor Prevention Act

Forced Labor Due Diligence – Supply Chain Tracing Requirements to Comply with UFLPA, Withhold Release Orders, and More

By: Adrienne Braumiller, Partner & Founder, Braumiller Law Group

We can all agree that goods made from forced labor, indentured labor or child labor should not be introduced into the U.S. market. Indeed, U.S. law prohibits the entry of goods made from forced labor. The Uyghur Forced Labor Prevention Act (“UFLPA”) which went into effect as of June 21, 2022, expands on this prohibition by placing a ban on goods from the Xinjiang Uyghur Autonomous Region (“XUAR”) where ethnic minorities are being exploited or certain specified entities that are involved in using forced labor

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Primer on Forced Labor Enforcement

Primer on Forced Labor Enforcement for U.S. Importers

By: Adrienne Braumiller, Partner & Founder, Braumiller Law Group and Harold Jackson, Associate

This Primer provides introductory guidance to complying with U.S. forced labor laws for importers, and includes an introductory overview to forced labor laws, U.S. Customs and Border Protection’s (CBP) authority to enforce forced labor laws, outlines importer requirements under The Uyghur Forced Labor Prevention Act, describes the detention processes for imported goods made with forced labor, lists key recommended compliance actions for adhering to U.S. forced labor laws, and provides helpful resources for complying with U.S. forced labor laws.

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Indo-Pacific-Economic-Framework IPEF

U.S. Initiates Indo-Pacific Economic Framework in the South Pacific

By: Adrienne Braumiller, Partner & Founder, Braumiller Law Group

On May 23 in Tokyo, Japan, the U.S., and other countries in the Pacific region launched the Indo-Pacific Economic Framework for Prosperity (“IPEF”). The countries included are Australia, Brunei, India, Indonesia, Japan, South Korea, Malaysia, New Zealand, the Philippines, Singapore, Thailand, and Vietnam.

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Uyghur-Forced-Labor-Prevention-Act UFLPA

CBP Releases Guidance related to Complying with the Uyghur Forced Labor Prevention Act

By: Adrienne Braumiller, Partner & Founder, Braumiller Law Group

U.S. Customs and Border Protection (“CBP”) released its first set of guidance relating to the Uyghur Forced Labor Prevention Act (“UFLPA”), which is set to take effect on June 21, 2022. CBP’s guidance takes the form of a website that is a homepage for UFLPA-related guidance, FAQs, webinars, graphics, and CBP contact information. This essential UFLPA homepage can be accessed at:

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Russian Sanctions OFAC

Russian Sanction Updates and Reporting Requirements: What are your Responsibilities under OFAC?

By: Adrienne Braumiller, Partner & Founder, Braumiller Law Group

In response to the Russian Federations’ (“Russia”) invasion of Ukraine, the U.S. Government has recently announced expansive economic sanctions against Russia and its economy. The U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) imposed sanctions against multiple parties in Russia to deplete Russian resources for purposes of ending the war.

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trump tariffs

Trump-Era Tariffs – Any Relief On The Horizon?

By: Adrienne Braumiller, Partner & Founder, Braumiller Law Group

The costly Trump-Era tariffs and trade policies have largely remained in effect nearly a year into the Biden Administration. Now more than ever, importers are looking for ways to avoid or mitigate duty exposure. Below is the lowdown of present relief from the Trump tariffs and a forecast of further relief to come.

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forced labor

Forced Labor in Xinjiang: What you need to know

By: Adrienne Braumiller, Founder & Partner, Braumiller Law Group

Human rights violations run rampant within China’s Uyghur Autonomous Region (Xinjiang), targeting ethnic and religious minority groups such as Uyghurs, ethnic Kazakhs, and ethnic Kyrgyz. The PRC government in Xinjiang has unjustly imprisoned more than one million individuals from these minority groups since 2017.

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origin rules

Non-Preferential Origin Rules – Which Do You Prefer?

By: By Adrienne Braumiller, Partner & Founder, Braumiller Law Group

There are two basic sets of country of origin rules that may apply to imports: (1) The preferential origin rules for articles considered “originating” under a free trade agreement; and (2) the non-preferential rules for articles not qualifying under a free trade agreement. 

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art of deal making

The Art of Deal Making: Using External Expertise Effectively​

By Adrienne Braumiller and Bob Brewer, Braumiller Law Group

Adrienne Braumiller is the founder of Braumiller Law Group PLLC and an innovative force in international trade law. With more than 25 years of experience, she is widely recognized as a leading authority in Customs, import, export, foreign-trade zones, free trade agreements and ITAR compliance.

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