Registering your robo-advisory firm – where and how?
Thompson Hine LLP Blogs
Latest from Thompson Hine LLP
Department of the Treasury Sanctions Iran’s Persian Gulf Petrochemical Industries Company
On June 7, 2019, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned Iran’s largest petrochemical holding group, Persian Gulf Petrochemical Industries Company (PGPIC). In addition to PGPIC, OFAC placed 39 PGPIC subsidiaries and foreign-based sales agents on its Specially Designated Nationals (SDN) List. According to OFAC, PGPIC was sanctioned for having provided, or attempted to provide, financial, material, technological or other support for, or goods or services to or in support…
Department of Commerce to Launch Special Section 232 Steel and Aluminum Exclusion Request Portal
The Department of Commerce’s Bureau of Industry and Security (BIS) has published an Interim Final Rule in the Federal Register announcing that it has developed a specific portal (i.e., the ‘‘232 Exclusions Portal’’) for persons submitting exclusion requests, objections to exclusion requests, rebuttals and surrebuttals to replace the use of the federal rulemaking portal (http://www.regulations.gov) and “streamline the exclusions process while enhancing data integrity and quality controls.” This interim final rule is effective…
State Department Releases Joint U.S.-Mexico Declaration Removing Threat of Tariffs on Mexico
After a week of uncertainty, the United States and Mexico reached an agreement in which Mexico will work to stem the tide of migration across its southern border and into the United States, while the Trump administration agreed to forgo the implementation of a 5 percent tariff on the import of goods from Mexico. In releasing the Joint U.S.-Mexico Declaration, Secretary of State Mike Pompeo stated that “The United States looks forward to working…
Trump Administration Further Restricts Travel to Cuba
On June 5, 2019, the Department of Commerce’s Bureau of Industry and Security (BIS) and the Department of the Treasury’s Office of Foreign Assets Control (OFAC) undertook coordinated actions to further restrict travel to Cuba “in order to hold the Cuban regime accountable for its repression of the Cuban people and its support of the Maduro regime in Venezuela.” Stating that “Cuba remains communist, and the United States, under the previous administration, made too many…
USTR Releases Notice of Additional China Section 301 Product Exclusions
The Office of the U.S. Trade Representative (USTR) has released notice of its fifth batch of China Section 301 product exclusion approvals that will relieve impacted U.S. importers from the 25 percent tariff implemented on certain imports from China July 6, 2018. These approved exclusions cover 464 exclusion requests and are established in two different formats:
as a full exclusion for one existing 10-digit Harmonized Tariff Schedule of the United States (HTSUS) subheading, 8537.10.8000 (touch-sensitive…
President Trump to Impose a 5 Percent Tariff on All Goods Imported from Mexico
On May 30, 2019, President Donald Trump issued a Statement Regarding Emergency Measures to Address the Border Crisis in which he announced that his administration would be imposing a 5 percent tariff on all goods entering the United States from Mexico beginning on June 10, 2019. Stating that “the United States has suffered the severe and dangerous consequences of illegal immigration” for decades while “Mexico has allowed [illegal immigration] to go on for many years,…
United States to Remove India from List of Beneficiary Developing Countries for Generalized System of Preferences
On November 24, 1975, the United States designated India as a beneficiary developing country (BDC) for the Generalized System of Preferences (GSP), which enabled India over the years to export roughly 2,000 products to the United States duty-free. On March 4, 2019, President Donald Trump announced his intention to terminate India’s BDC designation and its resulting GSP benefits, removing India’s duty-free access to the U.S. market. In a May 31, 2019, presidential proclamation, the…
USTR Announces Delay in Implementing 25% Tariffs on Tranche 3 Products from China
The Office of the U.S. Trade Representative (USTR) has announced that it is extending the amount of time certain goods exported from China will have to enter the United States before an additional Section 301 tariff increase from 10 percent to 25 percent is imposed. As we reported on May 9, President Donald Trump moved to increase Section 301 import tariffs to 25 percent on the third tranche of Chinese products valued at approximately…
Providing Advice in a Digital World: Applying the Suitability Standard to Robo-Advisers
