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
SmarTrade
Timely news and analysis of the latest developments in international trade law
The SmarTrade Blog, published by Thompson Hine LLP, focuses on developments in international trade law and policy. It covers topics such as trade agreements, tariff investigations, trade remedies, national security trade measures, foreign investment regulations, and enforcement actions related to trade practices. The blog discusses government investigations under statutes like Section 301 and Section 232, trade negotiations, and regulatory updates affecting imports and exports. It also addresses issues involving intellectual property protection, supply chain security, and trade compliance. The content is relevant for legal professionals, businesses, and policymakers interested in U.S. and global trade regulatory environments.
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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…
DDTC Issues Proposed Rule to Remove Certain Items from the U.S. Munitions List
On September 30, 2026, the Department of State’s Directorate of Defense Trade Controls (DDTC) issued a proposed rule in the Federal Register that would remove certain items from the U.S. Munitions List (USML). This proposed rule is in furtherance of …
DDTC Removes Syria from ITAR Section 126.1 Policy of Denial
On September 30, 2026, the Department of State’s Directorate of Defense Trade Controls (DDTC) issued a final rule in the Federal Register that, effective October 1, 2026, revises the International Traffic in Arms Regulations (ITAR) to remove Syria from the…
CBP Issues Withhold Release Orders on Two Indonesian Palm Oil Producers
On September 29, 2026, Customs and Border Protection (CBP) issued two Withhold Release Orders (WROs) against palm oil and its derivative products produced by Mitra Aneka Rezeki (MAR) and Hardaya Inti Plantation (HIP) in Indonesia. Both WROs are the result…
OFAC Issues New Cuba Sanctions Regulations and Amends Other Existing Sanctions
On September 30, 2026, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) implemented new sanctions on Cuba and formally amended the existing Cuban Assets Control Regulations (CACR). In May 2026, President Donald Trump issued Executive Order (EO)…
U.S.-China Board of Trade “30-for-30” Identifies Products Recommended for Reduced Tariffs
On September 27, 2026, the White House announced a reciprocal list of U.S. and Chinese imports recommended for reduced tariff treatment (“30-for-30”) as part of the first major outcome of the U.S.-China Board of Trade. The U.S.-China Board of Trade…
CBP Confirms October 6, 2026 Launch of Phase 3 of the IEEPA Tariff Refund Process
On September 15, 2026, U.S. Customs and Border Protection (“CBP”) announced in a declaration filed in the U.S. Court of International Trade (“CIT”) that Phase 3 of the Consolidated Administration and Processing of Entries (“CAPE”), the system for administering refunds…
OFAC Increases the Scope of Sanctions on Iran
On September 8 and 10, 2026, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned multiple companies and persons for supporting Iran’s aviation sector and for enabling Iran to destabilize the Middle East. The aviation-related sanctions include…
CBP Seeks Comments on Implementation of Executive Order 14411
On September 2, 2026, U.S. Customs and Border Protection (CBP) published a notice seeking comments by December 1, 2026, on its implementation of several provisions of Executive Order 14411 (“EO 14411”), which mandates the collection of foreign export documentation, the…