By: Adrienne Braumiller, Founder & Partner, Vicky Wu, Senior Associate Attorney and Megan Mohler, Associate Attorney On January 6, 2020, BIS published an interim final rule adding “software specially designed to automate the analysis of geospatial imagery” to the EAR and requiring a license to export and reexport such items to all countries, with the …
By: Vicky Wu, Senior Associate Attorney and Megan Mohler, Associate Attorney, BLG ‘Twas the night before merger and all through the office, not an associate was sleeping not even the bosses. The diligence was due, and the T’s were crossed but (oh no) the I’s were not dotted! One of the biggest concerns for companies in …
Read moreTrade Compliance Best Practices in Mergers and Acquisitions
By: Judy Davis, Senior Trade Advisor, Braumiller Consulting Group It’s a matter of “Much ado about something. . .” Make no mistake – denied party screening applies to you. Don’t gamble with your export privileges by thinking “one size fits all” when it comes to screening. Instead, consider the principle of “screening smart”. Take into …
By: Bob Brewer, Braumiller Law Group As we bring another year in trade to a close obviously the main question one could ask is, will China and the U.S. be able to follow through in 2020 now that Phase 1 has been agreed upon just in time for Christmas. In Phase 1 China has agreed …
Read moreWorld Trade and Moving on to 2020 & South Korea, A Land of Opportunity
By: Brad Menard, VP of Braumiller Consulting Group Known for its kaleidoscope of ever-changing rules and regulations, the international trade landscape certainly surpassed expectations in 2019. Section 232 and 301 duties sent their ripples throughout the global economy. In a speech in September 2019, Cynthia Whittenburg, CBP Deputy Executive Assistant Commissioner, shared that even if …
Read moreTrends in Compliance, and the International Trade Landscape – A Year in Review
By: Adrienne Braumiller, Founding Partner, BLG The long-awaited implementation of the new United States-Mexico-Canada Agreement (USMCA) may be happening just in time for Christmas this year! On 12/10 Speaker Pelosi announced that Democrats had reached an agreement with the Trump administration on moving forward with the USMCA trade agreement. The USMCA will modernize an outdated …
By: Bob Brewer, Braumiller Law Group For anyone in the aerospace, defense, and export control markets, you have undoubtedly been faced with the question on cyber-security compliance. This form of compliance most often surfaces if you’re dealing in the International Traffic in Arms Regulations (“ITAR”), where the certification of compliance is required through systems such …
Read moreNIST 800-171: Cybersecurity, CUI/CDI and NIST 800-171 What does it mean for your business?
By: Brandon French, Associate Attorney, BLG The majority of US businesses have felt increased pressure since the imposition of the Section 301 tariffs. Companies have been forced to find ways to mitigate the impact of the tariff through reclassification, tariff engineering, or re-sourcing outside of China. The following breakdown explains the history of each “List” …
By: Bruce Leeds, Senior Counsel, Braumiller Law Group Section 301 duties on French merchandise? How can that be? Doesn’t Section 301 only apply to China? The answers are yes and no. The US Trade Representative announced that the US was planning to impose up to 100% additional duties on a variety of French origin products …
Read moreSacre Bleu! Section 301 Duties on Nice French Stuff?
By: Bob Brewer, Braumiller Law Group On Friday, October 11th, 2019, President Trump announced a three- phase trade deal with China. The agreement is an outline of a partial trade accord that President Donald Trump said he and Xi Jinping could sign as soon as next month at an upcoming November summit in Chile. To …
Read moreU.S. vs China Trade War, Is There Light at the End of the Tunnel?
By: Adrienne Braumiller, Vicky Wu and Megan Mohler of Braumiller Law Group (Article originally posted on September 26, 2019 and is on the BloombergTax website.) President Trump’s trade war with China continues. What options do businesses importing and exporting have in this period of uncertainty? Adrienne Braumiller, Vicky Wu and Megan Mohler of Braumiller Law Group …
Read moreINSIGHT: Trade Wars—Global Protectionism as a Threat to Cross-Border Transactions
By: Adrienne Braumiller, Founding Partner, Braumiller Law Group On October 2, 2019, the Office of the U.S. Trade Representative announced that the United States has won the largest arbitration award in World Trade Organization (WTO) history in its dispute with the European Union over illegal subsidies to Airbus. This award grew out of an allegation …
Read moreReady for More Section 301 Duties? Here They Come on EU Products!
By: Bob Brewer, Braumiller Law Group This Friday, October 11, the U.S. International Trade Commission (USITC) will open this MTB portal mtbps.usitc.gov. The deadline for submitting MTB petitions is December 10, 2019. More information on the MTB process is available on the USITC’s MTB landing page, usitc.gov. The site includes recordings of webinars on details how …
By: Brandon French, Associate Attorney, Braumiller Law Group The deadline to submit List 3 exclusion requests officially closed on September 30th. While some exclusion requests have already been granted, the majority of submitters must now wait for the United States Trade Representative (USTR) to review their requests. As each request is reviewed, they must progress …
Read moreSection 301 List #3: Current Status of the List 3 Exclusion Process
By: Bob Brewer, Braumiller Law Group It seems like a long time ago, but it really wasn’t, that President Trump withdrew the United States from the TPP (Trans-Pacific Partnership) on his 3rd day in office. Looking back, it was actually the gateway for the implementation of the Section 301 tariff war with China. For a …
By: Bonnie M. Kersch, Sr. Trade Advisor and Incoterms 2020 Certified by the International Chamber of Commerce, Braumiller Consulting Group In June of 2019, I wrote an article about what changes we could expect to see when Incoterms 2020 would be released. I was wrong. Everyone was wrong. Instead of sweeping changes to Incoterms that …
By: Jennifer Horvath, Partner, Braumiller Law Group Either your company, or someone you have spoken with lately, has likely been the recipient of a wood packing notice violation. This is because, especially in the last two years, Customs and Border Protection (CBP) has started strictly enforcing the requirements and regulations related to wood packing material …
Read moreUnderstanding the Ins and Outs of Wood Packing Materials
By: Bruce Leeds, Of Counsel, Braumiller Law Group Section 232? Doesn’t that apply to duties on aluminum and steel? Yes – but it could soon also apply to automobiles and parts. Section 232 of the Trade Expansion Act of 1962 authorizes the President of the United States, through tariffs or other means, to adjust the …
Read moreSection 232 Actions on Automobiles and Parts – What Are They Driving At??
By: Megan Mohler, Associate Attorney, Braumiller Law Group You only have 60 days. The second MTB petition cycle opens October 11, 2019 and closes December 10, 2019. The previous cycle opened in October 2016 and the approved petitions that were signed into law in September 2018 expire December 31, 2020. The MTB petition portal can …
Read more8 Things You Should Know Before Submitting MTB Petitions for the 2019 Cycle
By: Bob Brewer, Braumiller Law Group The trade war between the U.S. and China has dragged on for more than a year now with 25% tariffs currently placed on $200 billion of Chinese goods. On August 1, President Trump announced that the U.S. would move forward with imposing a 10 percent ad valorem tariff on …
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