Crowell & Moring’s Derek Hahn and Dj Wolff have co-authored the United States chapter of WorldECR’s Managing Investigations: Best Practice in Government and Internal Investigations. The guide provides information about investigatory authorities in 21 countries responsible for sanctions, export control, anti-corruption, and AML enforcement, and answers questions on related policies, procedures, and best practices in each jurisdiction. The United States chapter covers the American “enforcement landscape, and the key issues faced by those hoping to successfully…

In ruling NY N320523 (August 3, 2021), Customs and Border Protection (CBP) discussed the tariff classification of two hanging kits from China. The first hanging kit, identified as the “Home Lightweight Décor Hanging Kit/Starter Décor Kit,” consists of 43 items. This includes 28 picture hangers made of steel, 6 small poster strips which are rubber tabs with adhesives on both sides, 8 pieces of Velcro, and 1 plastic box that serves as the kit’s package.…

In a string of recent cases following the Supreme Court’s 2019 decision in Food Marketing Institute v. Argus Leader Media, multiple courts have held that a party submitting information to the government need not demonstrate it obtained an assurance of confidentiality from the government in order for the agency to justify withholding that information in response to an information request made under the Freedom of Information Act (FOIA).  (Crowell & Moring previously wrote about the new…

Washington – August 6, 2021: Himamauli Das, senior advisor at Crowell & Moring International, LLC, has been named acting director of the Financial Crimes Enforcement Network, the anti-money-laundering unit of the U.S. Treasury Department. Das assumes the role at a time when FinCEN is moving to implement provisions of the Anti-Money Laundering Act of 2020, which became law in January of 2021 and makes the most sweeping changes to U.S. anti-money laundering laws since…

In ruling NY N320579 (July 27, 2021), Customs and Border Protection (CBP) discussed the tariff classification of an outdoor wooden swing from India. The seat of the swing is 18” in width, 9” in depth, and 2” in thickness. It is made of Meranti wood and has no armrest, backrest, or footrest. The seat is meant to be suspended from a tree or a rafter using a 50” polyester rope with tassels, a pair of 2.25”…

On July 26, 2021, U.S. Customs and Border Protection (CBP) modified its July 1998 Withhold Release Order (WRO) that originally prevented the importation of carpet and hand-knotted wool products from seven Nepalese companies. Specifically, CBP modified the WRO so that carpet and hand-knotted wool products from Annapurna Carpet Industries Pvt. Ltd. (Annapurna Carpet) would be admissible at all U.S. ports of entry. This decision came after a thorough investigation by CBP into Annapurna Carpet indicated…

On July 23, 2021, the U.S. Trade Representative issued a formal determination deciding not to take action against Vietnam in response to their currency practices under Section 301. The investigation, which was initiated in October of 2020 to examine Vietnam’s acts, policies, and practices related to the valuation of their currency, effectively concluded following the announcement of a currency agreement between the U.S. and Vietnam on July 19, 2021. While the investigation found evidence…