FinCEN Permanently Ends BOI Reporting for U.S. Companies and U.S. Persons Under the Corporate Transparency Act 

On August 11, 2026, the Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a final rule permanently removing the requirement for U.S. companies and U.S. persons to report beneficial ownership information (BOI) under the Corporate Transparency Act (CTA). FinCEN states that U.S. companies are now exempt from BOI reporting requirements and no longer need to file BOI reports. The final rule also relieves U.S. persons from providing BOI to reporting companies and from updating or correcting information previously submitted to obtain a FinCEN identifier. For many domestic businesses, this marks a significant compliance shift—but foreign entities registered to do business in the United States may still have BOI obligations.

What Changed? 

FinCEN’s final rule makes permanent the relief first announced in the March 2025 interim final rule. Under the final rule, U.S. companies are exempt from BOI reporting requirements and therefore are no longer required to file BOI reports. Reporting companies also do not need to report BOI for U.S. person beneficial owners or U.S. person company applicants, and U.S. persons do not need to provide BOI to reporting companies. 

FinCEN also announced that U.S. persons with FinCEN identifiers are not required to update or correct the information they previously submitted to FinCEN. This is important for individuals who filed BOI information before the rule changed and who otherwise may have expected ongoing update obligations.

Who Still Has BOI Reporting Obligations? 

The final rule does not eliminate […]

EAPA Update: CBP Finds Evasion Despite Full Cooperation 

A recent EAPA evasion finding against a solar importer reveals how a single country-of-origin misclassification can trigger steep consequences, even when the importer fully cooperates with CBP.

KEY TAKEAWAYS 

  • CBP issued a Notice of Determination as to Evasion in an EAPA case, finding that a major solar-module importer evaded antidumping AD/CVD orders on crystalline silicon photovoltaic cells. 
  • Report the cell, not the module.  For solar modules assembled in a third country, the AD/CVD-relevant country of origin is where the cell was made, not where the module was assembled. Declaring the assembly country can be a material, false statement under EAPA. 
  • Cooperation does not erase the duty.  The company fully cooperated, but CBP found evasion anyway. 
  • The exposure is severe.  Cash-deposit rates reached up to 271.28% (Vietnam AD) and 238.95% (China-wide AD).
  • If you assemble abroad and import into the U.S., audit your country-of-origin declarations now — before an allegation does it for you. 

The Evasion Case 

On June 23, 2026, U.S. Customs and Border Protection (CBP) issued a Notice of Determination as to Evasion in EAPA Consolidated Case No. 8163, finding substantial evidence that a major solar-module importer evaded antidumping (AD) and countervailing (CVD) duty orders on crystalline silicon photovoltaic cells. The finding reached the Vietnam Circumvention Determination and the Malaysia and Vietnam AD/CVD Orders. 

The […]

Forced Labor Enforcement Just Crossed a Border: What CBP’s Serbia Copper WRO Means for Your Supply Chain

Key Takeaways 

  • CBP continues to chase the company, not just the country. Zijin’s parent was already on the UFLPA Entity List for forced labor in China; this Withhold Release Order (WRO) hits its Serbian copper operation on a separate evidentiary basis. Moving production to a “friendly” country does not move you out of CBP’s reach. 
  • Copper just joined the enforcement map. Forced-labor detentions are no longer concentrated in apparel, solar, and cotton. If you import copper—or anything containing it—your supply chain is now in scope, and most copper-reliant importers have done zero forced-labor due diligence. 
  • The burden is on you, and it lands the moment your shipment is detained. Under a WRO, there is no notice and no grace period. You either prove your goods are clean by detailed documentary evidence, or you export or destroy them. 

On June 16, 2026, U.S. Customs and Border Protection (CBP) issued a Withhold Release Order against copper and copper products manufactured in Serbia by Serbia Zijin Copper D.O.O.—the fourth WRO of Fiscal Year 2026 and the second targeting a Serbian operation in roughly six months. Effective immediately, CBP personnel at every U.S. port of entry will detain shipments of copper and copper products from this company. 

If you read that as another distant enforcement headline, you are missing the part that should concern you. This […]

Bosch Agrees to Pay $36 Million Penalty to BIS for Unauthorized Shipments to Huawei 

Robert Bosch GmbH (Bosch), the German multinational engineering and technology company, has agreed to pay a $36,184,680 penalty to the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) for exporting controlled items to Huawei Technologies Co. and its affiliates without the required U.S. government authorization. 

What Happened 

Between September 2020 and September 2024, Bosch exported approximately $72.4 million worth of Micro-Electro-Mechanical Systems (MEMS) sensor products and automotive software from abroad to Huawei and its affiliates. The exported items were subject to the Export Administration Regulations (EAR) under the Foreign Direct Product Rule, a rule that extends U.S. export controls to certain foreign-produced items that incorporate U.S. technology or are manufactured using U.S. equipment. Because Huawei and its affiliates are listed on BIS’s Entity List, any shipment of items subject to the EAR requires a license from BIS. No such license or authorization was obtained. 

The MEMS sensors at issue are widely used in consumer products, including smartphones, wearable technology, and automobiles. 

The Penalty 

In addition to the $36 million BIS civil penalty, Bosch separately agreed with the Department of Justice to disgorge profits from the transactions, with an actual payment of approximately $3.6 million. BIS suspended approximately $3.6 million of its penalty as credit for the disgorgement, bringing Bosch’s total financial exposure to roughly $39.8 million. 

Bosch filed a Voluntary Self-Disclosure with […]

CBP Just Rewrote the Forced Labor Rulebook: What the New Operational Guidance Means for Importers

Short summary: On June 9, 2026, CBP issued new guidance supplementing its 2022 UFLPA guidance and other resources with a single document covering every forced-labor authority it enforces. The new guidance outlines CBP’s detention and exclusion processes and gives practical guidance on how to respond.


On June 9, 2026, U.S. Customs and Border Protection (CBP) published its new Forced Labor Enforcement Operational Guidance for Importers (Publication No. 5560-0526). It is not a refresh. It updates the June 13, 2022, UFLPA Operational Guidance for Importers and, for the first time, consolidates all forced-labor enforcement authorities CBP wields into a single 89-page reference. 

That consolidation is the story. Until now, importers had to stitch together separate sources to understand how the Uyghur Forced Labor Prevention Act (UFLPA), Withhold Release Orders and Findings under 19 U.S.C. § 1307, and the Countering America’s Adversaries Through Sanctions Act (CAATSA) actually differ in practice. CBP has now mapped all of them — including the exact timelines, the review paths, and the documentation bar — in one place. The practical effect: ignorance of the process is no longer a defensible position. 

The one-line summary every importer needs 

CBP detains or excludes goods it suspects were made, wholly or in part, with forced labor — and the burden is on you to prove they weren’t, on a clock that can […]

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