Self-Disclosure, Remedial Measures Yield Declination Decision in FCPA Case

Tuesday, August 28, 2018 Sandler, Travis & Rosenberg Trade Report The Department of Justice has decided to close without prosecution an investigation into charges that an insurance company violated the Foreign Corrupt Practices Act. The DOJ alleged that the company paid approximately $36,000 in bribes to the commerce minister of Barbados in exchange for insurance […]

Enforcement, Trade Up in 2017, Annual ITC Report Finds

Wednesday, August 22, 2018 Sandler, Travis & Rosenberg Trade Report The U.S. increased its trade enforcement activities and saw higher trade values in 2017, according to the International Trade Commission’s annual review of trade-related activities. The Year in Trade 2017 includes information on (a) antidumping, countervailing, safeguard, intellectual property rights infringement, national security, and section 301 cases […]

Rule of Relative Specificity Invoked in Classification Case

Tuesday, August 21, 2018 Sandler, Travis & Rosenberg Trade Report The Court of International Trade has ruled that artichoke antipasto and green olive tapenade are properly classified as sauces under HTSUS 2103.90.90 rather than as other prepared or preserved vegetables under HTSUS 2005.99.80 or HTSUS 2005.99.97. The subject antipasto consists of quartered artichokes, artichoke juice, […]

Section 301 Tariff Exemption for U.S. Goods Returned Narrowed Significantly

Thursday, August 16, 2018 Sandler, Travis & Rosenberg Trade Report Effective Aug. 23, the use of a provision allowing goods assembled abroad from U.S. components to avoid the additional 25 percent tariff imposed on imports from China will be narrowed significantly. This action will affect the $34 billion worth of Chinese products already subject to the tariff […]

Lack of Due Diligence Leads to $155,000 Penalty for Unlicensed Export to Russia

Wednesday, August 15, 2018 Sandler, Travis & Rosenberg Trade Report Inadequate measures to prevent exports to restricted end-users have resulted in a $155,000 civil penalty against a logistics company accused of violating the Export Administration Regulations. The Bureau of Industry and Security alleged that the company aided the export of an item designated EAR99 to […]