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OFAC Advisory on Sham Transactions and Sanctions Evasion

Seward & Kissel LLP summarizes OFAC's March 2026 advisory on sham transactions and sanctions evasion. The advisory highlights risks where blocked persons attempt to evade sanctions through transfers structured to conceal continuing interests in property. OFAC identifies red flags including commercially unreasonable transactions, transfers to family members or nominees, complex opaque structures, and timing near sanctions designations.

China Enacts Comprehensive Regulations on Industrial and Supply Chain Security

China's State Council published the Regulations on Industrial and Supply Chain Security on April 7, 2026, effective immediately with no transition period. The Regulations create a unified national security–driven framework consolidating export controls and anti-sanctions provisions, monitored by over 15 government agencies including MOFCOM, MIIT, and CAC. Multinational companies face expanded regulatory scrutiny including restrictions on supply chain data collection and potential enforcement for commercial decisions to exit China-related supply chains.

PCT Informed Examination Request Pilot Program

The USPTO announced the PCT Informed Examination Request (PIER) Pilot Program, running from April 9, 2026 through April 9, 2027. The program will select patent applications to participate in examining whether early examination requests improve patent examination efficiency. The USPTO may extend the program or terminate it at its discretion based on workload, resources, public feedback, and program effectiveness.

Final Affirmative Antidumping Duty Determination: Methylene Diphenyl Diisocyanate from China

The U.S. Department of Commerce issued its final affirmative determination in the antidumping duty investigation of Methylene Diphenyl Diisocyanate from China. The investigation established weighted-average dumping margins of 85.11 percent for named exporters Covestro Polymers and Shandong Mingko, and 159.04 percent for the China-wide entity based on adverse facts available. U.S. imports of MDI from China totaled approximately $241 million in 2024, up from $230.8 million in 2023.

OCTG From China Five-Year Review Scheduled

The US International Trade Commission has scheduled expedited five-year (sunset) reviews for antidumping and countervailing duty orders on oil country tubular goods (OCTG) from China under Investigation Nos. 701-TA-463 and 731-TA-1159 (Third Review). The reviews will determine whether removing these trade remedies would likely lead to continuation or recurrence of material injury to the domestic OCTG industry. Domestic producers and importers of OCTG should prepare for the expedited review process.

Silicon Metal From Angola, Laos, and Thailand

The USITC published a notice announcing final determinations in countervailing duty and antidumping duty injury investigations concerning silicon metal from Angola, Laos, and Thailand. Investigation Nos. 701-TA-761, 701-TA-763, 731-TA-1743, and 731-TA-1745 (Final) are covered under citation 91 FR 18004.

Foreign-Trade Zone 136 Florida, reorganization application filed

The Foreign-Trade Zones Board published notice that Canaveral Port Authority submitted an application to expand FTZ 136's service area from Brevard County to include Lake and Osceola Counties, Florida. The application seeks reorganization under the Alternative Site Framework, which allows greater flexibility in designating usage-driven FTZ sites. Public comments on the application are invited through June 8, 2026.

FTZ 39 Dallas/Fort Worth Service Area Expansion Application

The Foreign-Trade Zones Board published notice of an application by the Dallas/Fort Worth International Airport Board to expand Foreign-Trade Zone 39's service area under the Alternative Site Framework. The request would add Parker, Palo Pinto, and Jack Counties to the existing eight-county service area in Texas. Public comments are being accepted through June 8, 2026, with rebuttal comments due June 23, 2026.

Phillips 66 Subzone Application - Billings, Montana

The Foreign-Trade Zones Board published notice of Phillips 66 Company's application for subzone status for a 210-acre facility at 401 South 23rd Street in Billings, Montana. The application, submitted by the City and County of Butte-Silver Bow as grantee of FTZ 274, requests designation under the Foreign-Trade Zones Act. Public comments are invited through May 19, 2026.

Common Alloy Aluminum Sheet from Türkiye - Final CVD Review 2023

The U.S. Department of Commerce issued final results of the countervailing duty administrative review for common alloy aluminum sheet from Türkiye, covering the period January 1, 2023 through December 31, 2023. Commerce determined that countervailable subsidies are being provided to certain producers/exporters of aluminum sheet from Türkiye, with a final subsidy rate of 5.07 percent ad valorem for the reviewed companies.

Steel Rebar from Mexico and Turkey Five-Year Sunset Review Determinations

The US International Trade Commission determined on April 3, 2026, that revocation of the countervailing duty order on steel rebar from Turkey and the antidumping duty order on steel rebar from Mexico would likely lead to continuation or recurrence of material injury to the US industry. The Commission conducted expedited five-year (section 751(c)) sunset reviews and determined these trade remedy orders must remain in place for another review cycle.

OFAC GL 51A, 54, 55 for Venezuela Minerals Sector

Womble Bond Dickinson published an analysis of three OFAC general licenses authorizing transactions in Venezuela's minerals sector. GL 51A permits an established U.S. entity to engage in Venezuelan-origin mineral trade involving the Venezuelan government, Minerven, or Minerven-owned entities under specified conditions. GL 54 authorizes the provision of goods, technology, software, and services for Venezuelan minerals operations. GL 55 permits negotiating and entering contingent contracts for new investment in the sector, contingent on separate OFAC authorization for performance.

Trump Overhauls Section 232 Tariffs on Steel, Aluminum, and Copper

President Trump issued a presidential proclamation adjusting Section 232 tariffs on steel, aluminum, copper, and derivative products. Articles made entirely of these metals now face 50% tariffs based on full commercial value, with a reduced 25% rate for UK-origin products. Derivative articles face 25% tariffs (15% for UK-origin). Products with 15% or less of these metals are exempt. Changes took effect April 6, with some products removed from tariff lists.

U.S. Producer Files New Trade Case Against OCTG Imports from Austria, Taiwan, UAE

U.S. OCTG Manufacturers Association, United States Steel Corporation, and United Steelworkers union filed AD/CVD petitions with the Department of Commerce and ITC against imports of oil country tubular goods from Austria, Taiwan, and UAE. Petitioners allege dumping and unfair subsidization by the Austrian government causing injury to domestic producers.

EU publishes first CBAM certificate price for Q1 2026

The European Commission published the first quarterly CBAM certificate price for Q1 2026, calculated as the average of EU ETS auction clearing prices. The Commission will publish four quarterly prices in 2026 to provide transparency for stakeholders ahead of the certificate purchase obligation beginning in February 2027. From 2027 onwards, prices will be published weekly rather than quarterly.

Treasury Proposes Rule Implementing GENIUS Act Sanctions Compliance for Stablecoin Issuers

The U.S. Department of Treasury's FinCEN and OFAC issued a joint proposed rule on April 8, 2026, to implement provisions of the Guiding and Establishing National Innovation for U.S. Stablecoins (GENIUS) Act. The proposed rule would require permitted payment stablecoin issuers to adopt and maintain effective sanctions compliance programs and AML/CFT programs. The rule aims to mitigate illicit finance risks while encouraging innovation in payment stablecoins.

Section 232 Tariffs Modified: 50% Steel, 25% Derivatives, Effective April 6

President Trump issued a presidential proclamation on April 2, 2026, significantly modifying Section 232 tariffs on steel, aluminum, and copper articles and derivative products. The changes apply tariffs to the full customs value instead of just metal input values, with rates of 50% for primary articles and 25% for derivatives, effective for goods entered on or after April 6, 2026. A reduced 10% rate applies for products made with US-origin metal inputs.

Metals Market Shake-Up: Higher Section 232 Tariffs, Broader Coverage, Narrower Relief

President Trump issued a proclamation under Section 232 substantially increasing tariffs on aluminum, steel, and copper articles. The new two-tier structure applies 50% duties on full customs value for most covered products and 25% for derivative copper wiring and cable products listed in new HTSUS annexes. The changes, effective for entries on or after April 6, 2026, shift from calculating duties on metal content alone to the full customs value of imports.

ITAR Brokering in Foreign Defense Transactions: DS-4294 Approval, Expanding Enforcement, and Hidden Liability Risks

Friling Law analyzes ITAR brokering obligations under 22 C.F.R. Part 129, explaining when intermediaries require DS-4294 approval from DDTC before facilitating foreign defense transactions. The article addresses the extraterritorial reach of ITAR provisions, common misconceptions about brokering activities, and heightened enforcement risk for consultants, deal facilitators, and financial actors.

USTR Section 301 Forced Labor Investigations Create Tariff Risk

USTR initiated Section 301(b) investigations on March 12, 2026, examining whether 60 of the United States' largest trading partners lack or inadequately enforce forced-labor import bans. The investigations target foreign government policies and can result in broad tariff actions across entire product categories or countries. Companies with supply chains in these jurisdictions face layered exposure under Section 301, UFLPA, and CBP enforcement.

IEEPA Tariff Refunds: Who Really Owns the Money?

Following the Supreme Court's invalidation of IEEPA tariffs in Learning Resources, Inc. v. Trump, approximately $166-182 billion in collected tariffs are subject to refund. The Court of International Trade has over 2,100 refund cases pending before Judge Richard K. Eaton, who is overseeing the nationwide refund process. Under current law, CBP must refund tariffs to the importers who paid them, though legislative efforts to redirect refunds to consumers face potential Fifth Amendment constitutional challenges.

Trump Adjusts Section 232 Tariffs on Derivative Steel, Aluminum, Copper

Kelley Drye & Warren LLP analyzes the Trump administration's adjustments to Section 232 tariffs covering derivative steel, aluminum, and copper products. The tariffs now extend to finished and semi-finished derivative goods, affecting importers of pipes, tubes, wire, foil, and related copper products. Companies should monitor ongoing Section 232 tariff refinements as the administration continues to calibrate trade policy.

International Trade Court Broadens IEEPA Tariff Relief for Importers While CBP Continues Refund Process

The U.S. Court of International Trade issued an amended order in Atmus Filtration Inc. v. United States expanding IEEPA tariff refund relief to include finalized (fully liquidated) entries, not just unliquidated entries. CBP is developing the CAPE system to process refund claims, with Phase 1 expected to cover approximately 63% of entries subject to IEEPA duties. Importers with entries dating back to February 2025 may now recover tariffs on previously excluded finalized entries.

Sanctions in a Snap: Developments in Sanctions - March 2026

Hughes Hubbard & Reed LLP published its monthly sanctions update covering March 2026 OFAC developments. Key highlights include unprecedented authorizations involving Russian and Iranian oil, a sanctions advisory outlining factors that will trigger aggressive enforcement, and a $1.1 million civil monetary penalty emphasizing the importance of testing and auditing components within sanctions compliance programs.

Forged Steel Fluid End Blocks: Preliminary Results of Antidumping Duty Administrative Review; 2024

The U.S. Department of Commerce released preliminary results of the 2024 antidumping duty administrative review for forged steel fluid end blocks from Germany, preliminarily finding no dumping by BGH Edelstahl Siegen GmbH during the period of review. Commerce invites interested parties to comment on these preliminary results before issuing final determinations.

U.S. Backs Lindberg for UN World Food Program Executive Director

The U.S. Department of State announced support for USDA Under Secretary Luke J. Lindberg's candidacy for Executive Director of the United Nations World Food Program. Lindberg oversees U.S. food assistance programs including the McGovern-Dole and Food for Progress programs. The announcement reaffirms U.S. commitment to WFP leadership and its humanitarian mission of global food security.

Russia General License 13Q and Venezuela General License Translations

OFAC issued Russia General License 13Q authorizing certain administrative transactions prohibited by Directive 4 under Executive Order 14024, and amended FAQs 999 and 1118. OFAC also published Spanish translations of five Venezuela General Licenses (46B, 47, 48A, 49A, 50A) and 19 associated FAQs covering oil sector operations, diluent sales, and petrochemical products. The translations are informational only and do not alter the English-language terms.

Federal Register Daily Issue - April 8, 2026

Federal Register daily issue, April 8th 2026

NTIA launches frequency coordination portal for spectrum

NTIA launches frequency coordination portal for spectrum

Final anti-dumping determination, certain OCTG, multiple origins

The Canada Border Services Agency made a final determination that certain oil country tubular goods originating in or exported from Mexico, the Philippines, Türkiye (Borusan), South Korea (Hyundai Steel), and the United States (Tenaris) have been dumped and are causing injury to Canadian industry. Anti-dumping duties will apply to imports of affected goods from these countries and exporters.

Update to Open General Licence for AUKUS Nations

The Export Control Joint Unit (ECJU) has published Notice to Exporters 2026/10 announcing an update to the open general licence covering exports to AUKUS Nations (Australia, United Kingdom, United States). The notice advises of changes affecting the export of goods, software, or technology under this licence framework. Exporters utilizing the AUKUS Nations open general licence should review the updated terms to ensure continued compliance.

Fatty Acids from Indonesia and Malaysia; Preliminary Injury Determination

The US International Trade Commission determined there is reasonable indication that the US fatty acids industry is materially injured by reason of less-than-fair-value imports and subsidized imports from Indonesia and Malaysia. The Commission also gave notice of commencement of final phase investigations under the antidumping and countervailing duty statutes. The merchandise at issue includes fatty acids under HTS subheadings 2915.70.01, 2915.90.10, 2916.15.10, 2916.15.51, 3823.11.00, 3823.12.00, 3823.19.20, and 3823.19.40.

Steel Concrete Reinforcing Bar from Mexico and Turkey - Five-Year Review Determination

The US International Trade Commission determined that revocation of countervailing and antidumping duty orders on steel concrete reinforcing bar from Turkey and Mexico would likely lead to continuation or recurrence of material injury to the domestic industry. The orders will remain in effect following completion of this five-year review.

Energy Recovery Inc seeks San Leandro subzone approval

The Foreign-Trade Zones Board published a notice that the City of San Jose (grantee of FTZ 18) has requested subzone status for Energy Recovery, Inc.'s facility at 1717 Doolittle Drive in San Leandro, California. The 1.72-acre facility would be subject to existing activation limits of FTZ 18. Public comments are invited until May 18, 2026, with rebuttal comments accepted through June 2, 2026.

Correction of Period of Review for Taiwan Boltless Steel Shelving AD Administrative Review

The U.S. Department of Commerce's International Trade Administration issued a correction to a February 13, 2026 Federal Register notice regarding rescission of antidumping (AD) and countervailing duty administrative reviews. The correction amends the Period of Review (POR) for Taiwan's boltless steel shelving units prepackaged for sale (A-583-871) from '6/1/2024-5/31/2025' to '11/29/2023-5/31/2025'. This is a ministerial correction with no substantive impact on duty liability.

Cold-Drawn Mechanical Tubing from Switzerland: Rescission of Antidumping Duty Review 2024-2025

The U.S. Department of Commerce rescinded the antidumping duty administrative review for cold-drawn mechanical tubing from Switzerland covering June 1, 2024 through May 31, 2025. Commerce found no reviewable entries of subject merchandise by Benteler Rothrist AG, Mubea Präzisionsstahlrohr, and Mubea Inc during the period of review. The underlying AD order remains in effect.

Citric Acid and Certain Citrate Salts From Colombia: Final Results of Antidumping Duty Administrative Review; 2023-2024

The U.S. Department of Commerce's International Trade Administration has issued final results of its antidumping duty administrative review for citric acid and certain citrate salts from Colombia, covering the period July 1, 2023 through June 30, 2024. Commerce determined that exporters sold citric acid in the United States at less than normal value, confirming dumping margins. The agency tolled deadlines by 68 cumulative days due to a federal government shutdown and document backlog. These final results establish the duty rates applicable to affected Colombian citric acid importers for the review period.

Pacific Cod Trawl Fishing Prohibition - Central Gulf of Alaska

NMFS is prohibiting directed fishing for Pacific cod by catcher vessels using trawl gear in the Central Regulatory Area of the Gulf of Alaska effective April 7 through September 1, 2026. This temporary closure prevents the A season allowance of 5,233 metric tons of Pacific cod allocated to this sector from being exceeded. The directed fishing allowance is set at 4,483 metric tons with 750 metric tons reserved as incidental catch for other groundfish fisheries.

Approved Monitoring Service Providers for Northeast Multispecies Fishery 2026

NMFS has approved nine companies to provide at-sea catch monitoring and electronic monitoring services for the Northeast Multispecies Fishery in fishing year 2026. The approvals are effective May 1, 2026, through April 30, 2027. These approved service providers may be contracted by fishing sectors to meet industry-funded monitoring requirements under the Northeast Multispecies Fishery Management Plan.

SEDAR 94 Florida Hogfish Assessment Webinar IV Public Meeting Notice

NOAA's National Marine Fisheries Service announces the SEDAR 94 Assessment Webinar IV for Florida hogfish, scheduled for April 20, 2026, from 1 p.m. to 4 p.m. Eastern Time. The webinar will be conducted via online platform and is open to the public. Participants will review assessment modeling work to date and provide final recommendations for the hogfish stock status.

North Carolina transfers summer flounder quota to New Jersey

North Carolina transfers summer flounder quota to New Jersey

Canada Sanctions 4 Iranian Officials for Human Rights Violations

Global Affairs Canada announced sanctions against 4 Iranian senior officials under the Special Economic Measures (Iran) Regulations for involvement in gross and systematic human rights violations. The individuals—Mohsen Karimi, Ahmad Kadem Seyedoshohada, Mustafa Mohebbi, and Hassan Akharian—have facilitated and directed repressive policies against protesters and dissidents. This marks Canada's 18th round of sanctions against Iran since October 2022.

Canada imposes additional sanctions against 7 Iranian individuals

Canada has imposed additional sanctions against 7 individuals under the Special Economic Measures (Iran) Regulations. The sanctioned individuals are linked to Iranian state bodies responsible for intimidation, violence, and transnational repression targeting Iranian dissidents and human rights defenders. With these latest measures, Canada has sanctioned 222 Iranian individuals and 256 Iranian entities in total.

Release of American Journalist Shelly Kittleson

Secretary of State Marco Rubio announced the release of American journalist Shelly Kittleson, who was kidnapped by Kata'ib Hizballah near Baghdad, Iraq. The State Department credited collaboration with the FBI, Department of War, Iraqi Supreme Judicial Council, and other agencies for securing her release.

Election of Vietnamese President To Lam and Prime Minister Le Minh Hung

The U.S. Department of State issued a press statement on April 7, 2026, congratulating To Lam on his dual appointment as President of Vietnam and Le Minh Hung on his election as Prime Minister. The statement emphasizes the U.S.-Vietnam Comprehensive Strategic Partnership built on three decades of cooperation in economic prosperity, people-to-people ties, and Indo-Pacific stability. Secretary of State Marco Rubio expressed the United States' commitment to continued collaboration with Vietnam's new leadership.

US Signs Health Cooperation MOU with Tajikistan under America First Strategy

The U.S. Department of State announced the signing of a bilateral health cooperation MOU with Tajikistan on April 6, 2026, under the America First Global Health Strategy. The $78 million agreement provides $38 million in U.S. assistance over five years to support Tajikistan's efforts to combat HIV/AIDS and tuberculosis while strengthening disease surveillance and outbreak response capabilities.

Deputy Secretary Landau's Meeting with North Macedonia Foreign Minister Mucunski

Deputy Secretary of State Christopher Landau met with North Macedonia Foreign Minister Timčo Mucunski in Washington D.C. as part of the second U.S.-North Macedonia Strategic Dialogue. The meeting highlighted the strong and growing partnership between the two countries, emphasizing shared commitments to regional stability, economic cooperation, energy sector development, and NATO burden-sharing.

Rubio and UK Foreign Secretary Cooper discuss Iran and Strait of Hormuz

Secretary of State Marco Rubio spoke with UK Foreign Secretary Yvette Cooper on April 7, 2026, about the Iranian regime's ongoing attacks across the Middle East and the critical importance of restoring freedom of navigation in the Strait of Hormuz. Both officials agreed on the need for international efforts to ensure shipping can move freely and energy supplies can reach global markets.

Section 301 Investigations: Manufacturing Overcapacity and Forced Labor

In March 2026, the Office of the United States Trade Representative (USTR) launched two parallel Section 301 investigations: one targeting manufacturing overcapacity across 16 countries (including China, EU, Japan, India, Mexico, Vietnam, and other major manufacturers), and one targeting forced labor enforcement failures across 60 countries. Crowell & Moring's International Trade team published this advisory addressing the top seven questions clients are asking regarding pending Section 301 comment deadlines and how to address them.

Sunshine Act Meeting Notice - March 23, 2015

The Mississippi River Commission published a Sunshine Act meeting notice announcing a public meeting scheduled for March 23, 2015 at 9:00 a.m. The meeting will address matters under the commission's jurisdiction regarding Mississippi River navigation, flood control, and related water resource issues.