Voluntary Self-Disclosures

BIS Unveils Enhanced Voluntary Self Disclosure Protocols

By: Adrienne Braumiller, Founder of Braumiller Law Group

On January 16, 2024, the Bureau of Industry and Security (BIS) under Assistant Secretary for Export Enforcement, Matthew Axelrod, disclosed significant enhancements to the process for Voluntary Self-Disclosures (VSDs) related to the Export Administration Regulations (EAR). These adjustments are strategically designed to streamline export control compliance for U.S. governmental bodies, the commercial sector, and academic entities.

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importer registration

Suspensión del Padron de Importadores

Por Brenda Cordova, Mexico Attorney, Braumiller Law Group

Uno de los requisitos más importantes para importar mercancías a México es estar registrado como importador en el registro de importadores mexicanos. Hay 2 tipos de registros para importadores, uno es para importadores generales (Padrón de Importadores) y el otro es para importadores de sectores industriales específicos (Padrón de Importadores de Sectores Específicos) que pueden importar mercancías identificadas por el código arancelario MX (es decir, productos químicos, armas de fuego, puros, calzado, textiles, alcohol, hidrocarburos, siderurgia, automoción, etc.). Generalmente, estos 2 registros son listados con información de personas y entidades autorizadas para importar mercancías a México.

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importer registration

Suspension of Mexican Importer Registration (Padron de Importadores)

By: Brenda Cordova, Mexico Attorney, Braumiller Law Group

One of the most important requirements for importing goods into Mexico is to be registered as an importer under the Mexican importer’s registry. There are 2 types of registries for importers, one is for general importers (Padron de Importadores), and the other is for importers of specific industry sectors (Padron the Importadores de Sectores Especificos) which may import goods identified by the MX tariff code (i.e. chemical products, firearms, cigars, footwear, textiles, alcohol, hydrocarbons, steel, automotive, etc.). Generally, these 2 registries are lists with information of individuals and entities authorized to bring goods into Mexico.

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Free Trade Zones

Maximizing Duty Savings Series Leveraging Bonded Warehouse and Foreign Trade Zones

By: Kerry Wang, Senior Associate, Braumiller Law Group

Consider this scenario: a client faced the challenge of deferring duty payments while managing a significant volume of imports destined for re-exportation from the U.S. Initially considering duty drawbacks, which proved unsuitable for their specific needs, we turned our attention to bonded warehouses and free trade zones. This scenario is not uncommon in the trade world and highlights a critical decision point for many businesses: choosing between a bonded warehouse and a Foreign Trade Zone (FTZ).

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first sale

What is the “First Sale” Rule and How Does it Affect Me?

By Bruce Leeds, Senior Counsel, Braumiller Law Group

The First Sale Rule applies in circumstances such as the example above. A US company places an order with a middleman in the US. The middleman in turn subcontracts to a foreign supplier. The supplier then ships the product either to the middleman or to the original US company that placed the order, meaning either could be the importer of record. The entered value could be the amount on the original purchase order or the price paid by the middleman to the foreign supplier.

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tolkening

Assessing the Benefits and Challenges of Tokenizing Real World Assets

By: James R. Holbein, Of Counsel and Justin Holbein

The world of cryptocurrencies on blockchains and the world of traditional assets in markets have often stood in stark contrast to one another since Bitcoin’s creation in 2008. The lack of a reliable bridge between these two worlds has limited the impact of cryptocurrencies on assets in the real-world outside of on-chain speculation and prevented adoption of the benefits that blockchain technologies can bring to real world processes.

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Taiwan

Taiwan, Invasion & Trade, Part 2

By: Victoria Holmes, Braumiller Law Group
President elect Lai Ching-te’s victory in Taipei ignited tensions across the Taiwan strait and now the geopolitical field waits to see if China will kick off World War Three. I’m only slightly joking, but Beijing has exerted diplomatic pressure on nations maintaining close ties with the island in the past and Taiwan’s decision to remain a democracy will no doubt ramp up China’s reunification process in the coming months. But how will that affect trade relations?

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Federal Register Notice (FR 88 90225)

USTR’s Federal Register Notice (FR 88 90225)

On December 29, 2023, the United States Trade Representative issued Federal Register Notice (FR 88 90225), Extension of Exclusions and Request for Comments: China’s Acts, Policies and Practices Related to Technology Transfer, Intellectual Property and Innovation. The FR Notice indicated that the USTR determined to extend 352 previously reinstated exclusions and 77 COVID related exclusions for five months, through May 31, 2024.

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Forced Labor

Latest Developments with The Uyghur Forced Labor Prevention Act and New Leadership at the Department of Homeland Security Signal Heavier Enforcement is Likely

By Adrienne Braumiller, Partner & Founder

In recent years, the global spotlight has illuminated the grave concerns surrounding human rights violations within China’s Xinjiang region, particularly those impacting the Uyghur population. The Uyghur Forced Labor Prevention Act (UFLPA) stands as a pivotal piece of legislation designed to address these concerns and to ensure that products imported into the United States are devoid of forced labor originating from the Xinjiang region.

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prior notice regulations

Any Comments on FDA’s New Proposed Rule on Prior Notice Regulations?

By: Vicky Wu, Partner, and Brandon French, Associate, Braumiller Law Group

On November 1, 2023, FDA issued a proposed rule that would make changes to its prior notice regulations, if the rule is finalized. These changes include requiring the name of the mail service and a mail tracking number to be provided in prior notice for food articles arriving by international mail. In addition, the FDA proposes that food facility registration information and prior notice be submitted within a specific timeframe after receiving certain notices of refusal or hold (“post-refusal” and “post-hold” submissions).

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antidumping

New Antidumping and Countervailing Duty Investigation Initiated Covering Aluminum Extrusions from 15 Countries

By Paul Fudacz, Partner, Braumiller Law Group

On October 4, 2023, A coalition of 14 U.S. aluminum extrusion producers and labor unions filed petitions before the Department of Commerce, International Trade Administration (Commerce) and the International Trade Commission (ITC) seeking to impose antidumping (AD) and countervailing duties (CVD) on aluminum extrusions produced in 15 countries and exported to the U.S.

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Legal Framework governing IMMEX

Legal Framework Governing IMMEX Operations

Brenda Cordova, Mexico Attorney, Braumiller Law Group

As we have previously explained in other articles, an IMMEX is a duty deferral program from the Mexican federal government created in 2006, which stands for Industria Manufacturera, Maquiladora y de Servicios de Exportación (Manufacturing, Maquiladora and Export Services Industry).

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