The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has launched a Reconsideration Portal for the submission of requests by persons or entities seeking to be removed from an OFAC sanctions list. The portal provides an overview
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Trump Accounts Get an ERISA Pass: Practical Implications of the DOL’s New Guidance
DOL’s guidance gives employers room to fund or facilitate Trump Account contributions without creating an ERISA plan.
When Congress created Trump accounts under the One Big Beautiful Bill Act, one of the questions employers quickly focused on is whether providing
CBP Issues Interim Final Rules Indefinitely Suspending the De Minimis Exemption for Imports
On June 24, 2026, Customs and Border Protection (CBP) issued two Interim Final Rules indefinitely suspending the $800 de minimis duty exemption for all modes of importation of goods into the United States and establish a new informal entry and
CBP Confirms June 29, 2026 IEEPA Tariff Refund Process Phase 2 Launch
On June 23, 2026, U.S. Customs and Border Protection (“CBP”) published Cargo Systems Messaging Service (“CSMS”) #69035485, confirming that Phase 2 of the process for refunding duties paid by importers of record under the International Emergency Economic Powers Act
OFAC Temporarily Lifts Certain Oil Sanctions Against Iran
UPDATE: On July 7, 2026, this Iran-related General License X was revoked by OFAC and any activities under this general license must be wound down no later than July 17, 2026. See Thompson Hine Update of July 8, 2026 for
USTR Launches Section 301 Investigation into Germany’s Underpayment for Pharmaceutical Products
On June 18, 2026, the Office of the U.S. Trade Representative (USTR) announced that it was launching an investigation of Germany under Section 301 of the Trade Act of 1974. The investigation will seek to determine “whether persistent underpayment for
State Regulators Step into the Breach: What Broker-Dealers and Investment Advisors Need to Know
As federal regulators scale back enforcement and staffing, state securities regulators are positioned to fill the gap. In a recent CRC Oyster Consulting webinar, titled “Navigating the Evolution of States Securities Regulations,” Bill Riley, Director at CRC Oyster and
CBP Announces Phases 2 and 3 of the IEEPA Tariff Refund Process
At a show cause hearing before the U.S. Court of International Trade (“CIT”) on June 9, 2026, U.S. Customs and Border Protection (“CBP”) confirmed that it will roll out Phases 2 and 3 of its process for refunding duties paid
U.S. Supreme Court Declines Review of China Section 301 Tariff Challenge
On June 15, 2026, the U.S. Supreme Court denied without comment the plaintiff group’s petition for certiorari in the test case for the China Section 301 tariff refund litigation (HMTX Industries LLC, et al. v. United States et al.). The
President Trump Modifies Section 232 Tariffs on Aluminum, Copper and Steel Imports
On June 1, 2026, President Donald Trump issued a Proclamation amending the rates, scope, and administration of the Section 232 tariff regimes for aluminum, steel, and copper and their derivative products. Section 232 of the Trade Expansion Act of 1962