On October 26, 2026, the Office of the U.S. Trade Representative (USTR) published in the Federal Register a request for comments to allow for further negotiation with China regarding the acts, policies, and practices at issue and the countermeasures it
Thompson Hine LLP Blogs
Latest from Thompson Hine LLP
Buried Alive? ERISA Claims Exhaustion Isn’t Necessarily Dead After Bolton
The en banc Eleventh Circuit in Bolton v. Inland Fresh Seafood Corporation of America, Inc. overruled Mason v. Continental Group, Inc. “to the extent [Mason and its progeny] hold that ERISA itself requires exhaustion of statutory claims (including those alleging
Treasury Issues Notice of Proposed Rulemaking to Expand Outbound Investment Security Program
On October 26, 2026, the Department of the Treasury (“Treasury”) issued a Notice of Proposed Rulemaking (“NPR”) that would implement Subtitle C of the Comprehensive Outbound Investment National Security Act (“COINS Act”) to expand the coverage of the existing Outbound
President Trump Opts for Negotiations, Not Tariffs, in Section 232 Wind Turbine Investigation
On October 22, 2026, President Donald Trump issued a Proclamation announcing that the investigation into the effects of imports of wind turbines and their parts and components on the national security of the United States under Section 232 of the
U.S. Importer of Canadian Products Challenges Section 338 Tariffs
On October 20, 2026, Gellert Global Group Corp. (Gellert) filed a complaint in in the U.S. Court of International Trade (CIT) challenging the 50% ad valorem tariffs placed on Canadian products by President Donald Trump under Section 338 of the
Shared Savings, Surprise Bills, and Your TPA: What Kreutzmann v. Cigna Means for Self-Funded Group Health Plan Fiduciaries
A newly filed class action against Cigna Health and Life Insurance Company puts a spotlight on a common but often overlooked feature of administrative services only (ASO) agreements: “shared savings” fees that pay the third-party administrator (TPA) a percentage of
CBP Delays Implementation Date of De Minimis Exemption for Mail Shipments
On October 14, 2026, U.S. Customs and Border Protection (CBP) announced the extension of the compliance date for new informal entry procedures for international mail from October 22, 2026, to January 20, 2027. In a press release, CBP states
CIT Certifies IEEPA Tariff Refund Class
On October 8, 2026, the U.S. Court of International Trade (CIT) granted a broad class certification for importers subject to the International Emergency Economic Powers Act (IEEPA) tariff regime, which the Supreme Court of the United States (SCOTUS) invalidated on
Treasury Announces First Enforcement Penalty for Violation of Outbound Investment Security Program
On October 7, 2026, U.S. Department of the Treasury (“Treasury”) announced that it imposed its first civil penalty of $200,000 against U.S. company Amidi LLC (“Amidi”) under the Outbound Investment Security Program (“OISP”). The OISP came into effect on January
OFAC Targets Iran’s Aviation and Rail Sectors for Additional Sanctions
On October 1, 2026, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued new sectoral sanctions determinations targeting Iran’s automotive and rail sectors. These determinations authorize OFAC to sanction any entity or individual operating in these sectors. OFAC stated