JD Supra Trade Law

Germany NIS2 Cybersecurity Law Implementation Deadline

Germany's implementation law for the NIS2 Directive, effective December 2025, expands cybersecurity requirements to new sectors including digital services and manufacturing. Covered entities must register with the BSI by March 6, 2026, and comply with new security and incident reporting obligations.

Supreme Court Invalidates Tariffs Imposed Under IEEPA

The U.S. Supreme Court ruled that the International Emergency Economic Powers Act (IEEPA) does not authorize the President to impose tariffs, invalidating recent "reciprocal" tariffs and fentanyl-related country measures. The decision will reshape the tariff landscape, with the Court of International Trade and U.S. Customs and Border Protection expected to establish refund procedures for duties paid.

Importers Can Preserve Rights for IEEPA Tariff Refunds

Following a Supreme Court ruling that the International Emergency Economic Powers Act (IEEPA) does not authorize presidential tariffs, importers can take steps to preserve their rights for refunds of paid duties. The US Court of International Trade is expected to address remedies soon, and importers have options including post summary corrections, protests, or lawsuits.

OCC GENIUS Act Proposal on Stablecoins

The Office of the Comptroller of the Currency (OCC) has issued a Notice of Proposed Rulemaking (NPR) to implement the GENIUS Act concerning stablecoins. The proposal seeks public comment on regulatory frameworks for permitted payment stablecoin issuers, including rules on yield-bearing features and opt-out provisions for state-approved issuers. Comments are due May 1, 2026.

CIT Orders Refunds of IEEPA Tariffs on Unliquidated Entries

The Court of International Trade (CIT) has ordered U.S. Customs and Border Protection (CBP) to refund tariffs collected under the International Emergency Economic Powers Act (IEEPA) on unliquidated and not finally liquidated entries. This ruling benefits all importers who paid these tariffs.

Mideast War Disrupts LNG Contracts and Raises Supply Security Questions

The escalating conflict in the Middle East has disrupted LNG contracts, particularly due to the de facto closure of the Strait of Hormuz and attacks on Qatari facilities. This has led to record-high spot prices and is raising urgent questions about supply security and contractual performance for energy companies.

Supreme Court Rules IEEPA Lacks Authority for Reciprocal Tariffs

The Supreme Court ruled in Learning Resources, Inc. v. Trump that the International Emergency Economic Powers Act (IEEPA) does not grant the President authority to impose reciprocal tariffs. This decision impacts an estimated $175 billion in collected tariff revenues, raising questions about potential refunds.

Court Orders Customs to Refund IEEPA Duties to Importers

The Court of International Trade has ordered U.S. Customs and Border Protection (CBP) to refund International Emergency Economic Powers Act (IEEPA) duties to all importers. CBP must liquidate unliquidated entries and reliquidate final entries without these duties.

USITC Investigates Chinese Biotech State Support and Pricing

The U.S. International Trade Commission (USITC) has launched an investigation into Chinese state support and pricing practices within the biotechnology sector. The investigation aims to assess the impact on U.S. industry competitiveness and market share, with a report due by January 2027.

OFAC Fines Executive $3.77M for Syria Sanctions Violations

The Office of Foreign Assets Control (OFAC) has settled with a real estate executive for $3.77 million for violating U.S. sanctions against Syria. The executive provided managerial services to Syrian real estate companies, which OFAC deemed an 'egregious' violation.