A Primer on U.S. Sanctions and Export Controls – Part II

By: Devin Sefton, Senior Associate Attorney, Braumiller Law Group The ever-shifting sands of U.S. sanctions and export controls can make it challenging to know the current restrictions that exist with respect to a given country.  With each new administration comes newly imposed restrictions and newly lifted restrictions.  This problem was particularly exacerbated by the 180-degree pivot taken between the Obama and Trump Administrations.  Meanwhile, the Biden Administration has stayed the course on some Trump Administration policy measures, while changing direction on others.   This article aims to provide a simple overview of the current state- of- affairs with respect to some

Read More »

The Quad and International Trade? The U.S., Australia, Japan and India

By: Bob Brewer, Braumiller Law Group When the “Big Bully” is also your best friend, economically speaking, and metaphorically speaking, they are paying for your lunch, but at the same time are slapping you around on the playground…do you hit back, or just take it on the chin? You need your lunch, as you have to eat. You and your three other playground friends, call yourselves The Quad, (The U.S., Australia, India and Japan) which sounds semi-menacing, (superhero capes included) but keep in mind, the rest of the kids on the playground are always watching to see how you deal

Read More »

2022 Harmonized System Nomenclature – Any Significant Changes?

By: Brandon French, Associate Attorney, BLG The new 2022 Harmonized System (HS) nomenclature has been accepted by all parties at the Harmonized System Convention. The HS nomenclature is used as a basis for the classification of goods around the globe. Every six months, the HS Committee of the World Customs Organization (WCO) meets to discuss potential changes in the HS. These changes are often due to advancements in technology, or other important factors such as difficulty classifying items due to their unique features which were not otherwise described in the tariff schedule. All changes are compiled over a five year

Read More »

HTS Classification Mistakes Before Customs Comes Knocking

By: Bob Brewer, Braumiller Law Group & Brad Menard, VP of Braumiller Consulting Group It’s a fact of life in international trade, many shipments, on a daily basis, arrive at ports in the U.S. with the wrong tariff classification code assigned to the product. No big deal? Not quite, and I can tell you this, from the legal side of our 2 companies, (Braumiller Law & Braumiller Consulting) we end up putting out a lot of fires for clients when Customs comes knocking as a result of having discovered this after the entry is filed. In our experience, decades in

Read More »

Fifth Circuit Reverses Office Manager’s Conviction for Failure to Prove Willfulness under Healthcare Fraud and Anti-Kickback Statutes

Attorney Sarah Wirskye,  Wirskye Law Firm, BLG Alliance  In United States v. Nora, 18-31078 (5th Cir. Feb. 24, 2021), the Fifth Circuit reversed a conviction and 40-month sentence in a healthcare fraud case. The jury found Nora guilty of conspiracy to commit healthcare fraud, and conspiracy to violate the anti-kickback statute. Twenty-one defendants were indicted, and five individuals went to trial. The other four trial defendants’ convictions were affirmed. Nora, a high school graduate, earned no more than $60,000 per year as the office manager for Abide Home Health Care Services. His duties were central to the fraud and kickback scheme,

Read More »

A Southern Border Perspective

By: Judy Davis, Senior Trade Advisor, Braumiller Consulting Group Whether you move goods via trucks, trains, planes, or cargo ships, it is essential that you begin to view the shipment of goods in terms of security for the entire journey. Cross-border shipping is on the rise according to Customs and Border Protection (CBP), and adjustments at border bridges are being  managed as fast as they can be approved.  Being a CTPAT (Customs Trade Partnership Against Terrorism) certificated participant is in  large part an advantage to keeping cargo moving smoothly through the ports of entry, in particular along the Southern border.

Read More »

Post-Brexit International Strategy: Freeports EU Series of Articles

By: Joaquin Pampin-Galan, U.S. Customs and International Trade Paralegal/Spain Attorney, Braumiller Law Group Free Trade Zones (“FTZ”) are being introduced into the United Kingdom (“UK”) as part of the post-Brexit landscape. In a measure aimed at developing the UK’s trade strategy, the Government announced the creation of eight new freeport zones in England. The selected locations are East Midlands Airport, Felixstowe & Harwich, Humber, Liverpool City Region, Plymouth, and South Devon, Solent, Teesside, and Thames. These freeports are expected to be fully operational in late 2021. Discussions are also being held between the UK Government and foreign officials to establish further

Read More »

Navigating the Export Controls on Semiconductors

By Bruce Leeds, Senior Counsel, Braumiller Law Group Determining what export controls apply to semiconductor devices can be a challenging task.  Most controls on semiconductor devices are found in Export Commodity Classification Number (ECCN) 3A001 of the Commerce Control List (CCL) in the Export Administration Regulations (EAR).  That ECCN has nearly 16 pages of detailed controls on many types of semiconductors.  Classifying articles in that category and determining what licenses or exceptions may apply is not easy. First things first: Make sure the semiconductors to be exported are not subject to the International Traffic in Arms Regulations (ITAR).  If the

Read More »
Post COVID port issues

A Post COVID Surge, and a Variety of Port Issues

By Bob Brewer, Braumiller Law Group

There are reasons to be optimistic about the economies of the world bouncing back from the pandemic in 2021, and at the same time, the major push to restock the world’s supply of goods has been met with a variety of problems.

Read More »

A Primer on U.S. Sanctions and Export Controls – Part II

By: Devin Sefton, Senior Associate Attorney, Braumiller Law Group The ever-shifting sands of U.S. sanctions and export controls can make it challenging to know the current restrictions that exist with respect to a given country.  With each new administration comes newly imposed restrictions and newly lifted restrictions.  This problem was particularly exacerbated by the 180-degree pivot taken between the Obama and Trump Administrations.  Meanwhile, the Biden Administration has stayed the course on some Trump Administration policy measures, while changing direction on others.   This article aims to provide a simple overview of the current state- of- affairs with respect to some

Read More »

The Quad and International Trade? The U.S., Australia, Japan and India

By: Bob Brewer, Braumiller Law Group When the “Big Bully” is also your best friend, economically speaking, and metaphorically speaking, they are paying for your lunch, but at the same time are slapping you around on the playground…do you hit back, or just take it on the chin? You need your lunch, as you have to eat. You and your three other playground friends, call yourselves The Quad, (The U.S., Australia, India and Japan) which sounds semi-menacing, (superhero capes included) but keep in mind, the rest of the kids on the playground are always watching to see how you deal

Read More »

2022 Harmonized System Nomenclature – Any Significant Changes?

By: Brandon French, Associate Attorney, BLG The new 2022 Harmonized System (HS) nomenclature has been accepted by all parties at the Harmonized System Convention. The HS nomenclature is used as a basis for the classification of goods around the globe. Every six months, the HS Committee of the World Customs Organization (WCO) meets to discuss potential changes in the HS. These changes are often due to advancements in technology, or other important factors such as difficulty classifying items due to their unique features which were not otherwise described in the tariff schedule. All changes are compiled over a five year

Read More »

HTS Classification Mistakes Before Customs Comes Knocking

By: Bob Brewer, Braumiller Law Group & Brad Menard, VP of Braumiller Consulting Group It’s a fact of life in international trade, many shipments, on a daily basis, arrive at ports in the U.S. with the wrong tariff classification code assigned to the product. No big deal? Not quite, and I can tell you this, from the legal side of our 2 companies, (Braumiller Law & Braumiller Consulting) we end up putting out a lot of fires for clients when Customs comes knocking as a result of having discovered this after the entry is filed. In our experience, decades in

Read More »

Fifth Circuit Reverses Office Manager’s Conviction for Failure to Prove Willfulness under Healthcare Fraud and Anti-Kickback Statutes

Attorney Sarah Wirskye,  Wirskye Law Firm, BLG Alliance  In United States v. Nora, 18-31078 (5th Cir. Feb. 24, 2021), the Fifth Circuit reversed a conviction and 40-month sentence in a healthcare fraud case. The jury found Nora guilty of conspiracy to commit healthcare fraud, and conspiracy to violate the anti-kickback statute. Twenty-one defendants were indicted, and five individuals went to trial. The other four trial defendants’ convictions were affirmed. Nora, a high school graduate, earned no more than $60,000 per year as the office manager for Abide Home Health Care Services. His duties were central to the fraud and kickback scheme,

Read More »

A Southern Border Perspective

By: Judy Davis, Senior Trade Advisor, Braumiller Consulting Group Whether you move goods via trucks, trains, planes, or cargo ships, it is essential that you begin to view the shipment of goods in terms of security for the entire journey. Cross-border shipping is on the rise according to Customs and Border Protection (CBP), and adjustments at border bridges are being  managed as fast as they can be approved.  Being a CTPAT (Customs Trade Partnership Against Terrorism) certificated participant is in  large part an advantage to keeping cargo moving smoothly through the ports of entry, in particular along the Southern border.

Read More »

Post-Brexit International Strategy: Freeports EU Series of Articles

By: Joaquin Pampin-Galan, U.S. Customs and International Trade Paralegal/Spain Attorney, Braumiller Law Group Free Trade Zones (“FTZ”) are being introduced into the United Kingdom (“UK”) as part of the post-Brexit landscape. In a measure aimed at developing the UK’s trade strategy, the Government announced the creation of eight new freeport zones in England. The selected locations are East Midlands Airport, Felixstowe & Harwich, Humber, Liverpool City Region, Plymouth, and South Devon, Solent, Teesside, and Thames. These freeports are expected to be fully operational in late 2021. Discussions are also being held between the UK Government and foreign officials to establish further

Read More »

Navigating the Export Controls on Semiconductors

By Bruce Leeds, Senior Counsel, Braumiller Law Group Determining what export controls apply to semiconductor devices can be a challenging task.  Most controls on semiconductor devices are found in Export Commodity Classification Number (ECCN) 3A001 of the Commerce Control List (CCL) in the Export Administration Regulations (EAR).  That ECCN has nearly 16 pages of detailed controls on many types of semiconductors.  Classifying articles in that category and determining what licenses or exceptions may apply is not easy. First things first: Make sure the semiconductors to be exported are not subject to the International Traffic in Arms Regulations (ITAR).  If the

Read More »
Post COVID port issues

A Post COVID Surge, and a Variety of Port Issues

By Bob Brewer, Braumiller Law Group

There are reasons to be optimistic about the economies of the world bouncing back from the pandemic in 2021, and at the same time, the major push to restock the world’s supply of goods has been met with a variety of problems.

Read More »