The Biden Administration has taken (at least temporarily) the teeth out of a Trump-era Executive Order that directed the government to “Buy American” for essential drugs and medical devices. President Trump’s August 2020 Executive Order on Ensuring Essential Medicines, Medical Countermeasures, and Critical Inputs Are Made in the United States (Executive Order 13944) aimed to reduce dependence on foreign drugs and devices critical to the U.S. public health sector, in part by requiring that the…

The United States is taking increasingly aggressive actions to prohibit imports from China that may have been produced by forced labor. According to the U.S. Department of Labor, China has arbitrarily detained more than one million Uyghurs and other Muslim minorities in China’s far western Xinjiang Uyghur Autonomous Region (“XUAR”). Muslim minorities there are reportedly subjected to forced labor, torture, and political indoctrination. In response, the United States issued Withhold Release Orders (“WROs”) on certain…

On February 1, 2021, the Myanmar military overthrew the country’s democratically elected government and installed an army general as head of state, with a cadre of military officials and their allies running the government.…

Since President Biden took office and put his national security team in place, we have wondered about the future of the Iran Nuclear Deal. In the past weeks, the Biden Administration has taken formal steps to possibly restore the Joint Comprehensive Plan of Action (i.e., JCPOA or Iran Nuclear Deal).…

On January 19, 2021, the U.S. Department of Commerce (“DOC”) issued an interim final rule governing transactions in Information and Communication Technology or Services (“ICTS”) involving “foreign adversaries.” Although the rule takes effect on March 22, 2021, it allows DOC to review covered transactions initiated, pending, or completed on or after January 19, 2021.…

On January 13, 2021, U.S. Customs and Border Protection (CBP) issued a Withhold Release Order (WRO) on cotton and tomato products produced by entities operating in Xinjiang, China. The order is based on information that indicates the use of forced labor in the production of the goods. If you are sourcing these products from the Xinjiang region, you may want to consider proactive compliance steps to mitigate your risk and prevent disruption in your supply…