LinkedInFacebookInstagramXYouTube
305-456-3830|info@diaztradelaw.com

Export

Call 305-456-3830 or email info@diaztradelaw.com.

ICYMI: Tri-Seal Advisory: Sanctions and Export Controls Relief for Syria

On November 7, 2025, the Office of Foreign Assets Control (OFAC), alongside the U.S. Department of State and the U.S. Department of Commerce, issued a Tri-Seal Advisory: Sanctions and Export Controls Relief for Syria. 

The Advisory follows President Trump’s Executive Order on June 30, 2025, formally removing U.S. sanctions on Syria and directing agencies to take additional measures to encourage U.S. private sector and foreign partner reengagement in Syria.

New Opportunities & Remaining Restrictions

The Advisory outlines what business with Syria is now permissible as well as what restrictions remain.

Permissible Business:

  • The United States no longer imposes comprehensive sanctions on Syria. 
  • The Caesar Act is suspended, except for sanctionable transactions with Russia and Iran.
  • The transfer of most basic civilian use U.S.-origin goods, as well as software and technology, to or within Syria is permitted without a license. 

Remaining Restrictions:

  • Sanctions remain on “the worst of the worst:” Bashar al-Assad and his associates, human rights abusers, drug traffickers, and other destabilizing regional actors.
  • The U.S. Government continues to review Syria’s State Sponsor of Terrorism (SST) designation. 
  • Most Commerce Control List items going to Syria still require a U.S. export license.

What Exporters Should Do

The removal of Syria sanctions and the easing of […]

By |2025-11-24T11:18:20-05:00November 24, 2025|Export, International Trade, U.S. Bureau of Industry and Security (BIS), U.S. Department of Commerce (DOC), U.S. Department of State (DOS), U.S. Office of Foreign Assets Control (OFAC)|0 Comments
Read More

Tariff Updates: Heavy Trucks, Timber & Lumber, Vessel Fees

Over the past several weeks, there has been a flurry of tariff updates affecting importers across multiple industries. From tariffs on heavy-duty vehicles and timber to 232 exclusions and vessel fees, the trade landscape is moving fast, and staying compliant is more challenging than ever. To help you keep up, we’ve summarized recent key tariff developments you need to know. For a full list of tariffs and trade deals, visit our tracker here.

Heavy-Duty Vehicles and Vehicle Parts

On September 25, 2025, President Trump, via Truth Social, announced his intention to impose a 25% tariff on heavy trucks. On October 17, 2025, he issued a Presidential Proclamation formalizing and clarifying these tariffs. The proclamation imposes a 25% tariff on imports of medium- and heavy-duty trucks and truck parts. This includes Class 3 to Class 8 vehicles, like large pick-up trucks, moving trucks, cargo trucks, dump trucks, and tractors for eighteen-wheelers. 

The Proclamation also imposes a 10% tariff on imports of buses, including school buses, transit buses, and motor coaches. The tariffs are set to take effect on November 1, 2025.

President Trump is imposing the new tariffs under section 232 of the Trade Expansion Act of 1962, citing national security concerns.

If medium and heavy-duty vehicles qualify for USMCA treatment, the importer may submit documentation to identify the amount of U.S. content, and, after the Department of Commerce’s […]

By |2025-10-24T10:50:49-04:00October 24, 2025|Enforcement, International Trade, U.S. Bureau of Industry and Security (BIS), U.S. Customs and Border Protection (CBP), U.S. Department of Commerce (DOC)|0 Comments
Read More

ICYMI: BIS Imposes New Affiliates Rule

[Update November 10, 2025]: BIS imposed a one-year suspension of the interim final rule. The suspension is set to end November 9, 2026, absent a future extension.

On September 30, 2025, the Bureau of Industry and Security (BIS) released an interim rule regarding “Affiliates.” Under the rule, any entity that is at least 50% owned by one or more entities on the Entity List or the Military End-User (MEU) List will itself automatically be subject to Entity List/MEU restrictions. This is a significant change from the current standard, which excludes entities that are not specifically included on the Entity List or MEU List, regardless of any affiliation with Entity List or MEU List organizations. 

This rule is effective September 29, 2025.

Entity, MEU List Background

The Entity List identifies persons (including businesses, research institutions, government and private organizations, individuals, and other types of legal persons) reasonably believed to be involved, or to pose a significant risk of being or becoming involved, in activities contrary to the national security or foreign policy interests of the United States. These persons are subject to specific license requirements for the export, reexport, and/or transfer (in-country) of specified items.  

BIS first published the Entity List in 1997. Since its initial publication, grounds for inclusion on the Entity List have expanded to activities sanctioned by the State Department and activities contrary to U.S. […]

By |2025-11-10T18:59:28-05:00October 17, 2025|Enforcement, Export, International Trade, U.S. Bureau of Industry and Security (BIS), U.S. Department of Commerce (DOC)|0 Comments
Read More

Census Bureau Releases Final Rule Clarifying Filing Requirements for In-Transit Shipments 

On August 14, 2025, The Census Bureau issued a final rule to clarify its regulations governing in-transit shipments from foreign countries through the United States that are subsequently exported to a foreign destination. The rule takes effect September 15, 2025. 

Background

The Census Bureau is responsible for collecting, compiling, and publishing import and export trade statistics for the United States. As part of this responsibility, the Census collects Electronic Export Information (EEI) in concert with the export control and enforcement functions of U.S. Customs and Border Protection (CBP) of the Department of Homeland Security (DHS), the Bureau of Industry and Security (BIS), and the Directorate of Defense Trade Controls (DDTC).

Public Law 107-228 directed the Census to publish regulations requiring exporters to file Shippers’ Export Declarations. As a result, the bureau experienced an increase in the number of inquiries regarding in-transit movements. Accordingly, in October of 2024 the Census solicited comments on a proposed rule to clarify its regulations governing in-transit shipments. The bureau received 11 letters and emails commenting on the proposed rule.

Key Changes

In addition to making definitional, grammatical and style changes, the rule: (i) clarifies who is the USPPI; (ii) makes changes to mandatory filing requirements; (iii) makes changes to voluntary self-disclosures.  

Who is the USPPI

The U.S. Principal Party in Interest (USPPI) is the person or legal entity in the United States that receives the primary benefit, […]

By |2025-08-15T09:26:51-04:00August 15, 2025|Brokers, EEI, Enforcement, Export, International Trade, Pre-compliance, U.S. Census Bureau|0 Comments
Read More

ICYMI: Technology Company Pleads Guilty to Export Control Violations, Agrees to $140M Fine

The U.S. Attorney’s Office for the Northern District of California and the Counterintelligence and Export Control Section (CES) of the Department of Justice’s (DoJ) National Security Division announced that Cadence Design Systems, Inc. of San Jose, California, agreed to plead guilty to resolve criminal violations of export controls. 

As part of the plea agreement, Cadence will pay criminal penalties of nearly $118 million. 

In addition to the charges, the Department of Commerce’s Bureau of Industry and Security (BIS) also announced the resolution of a civil enforcement action against the company in which Cadence agreed to pay over $95 million in civil penalties. 

The DoJ and BIS have coordinated the resolution of the parallel investigation, and each agreed to a partial credit against their fine for payments made to satisfy the other agency’s fine. Under the coordinated agreement, Cadence will pay criminal and civil penalties of more than $140 million.

Cadence committed criminal violations of the export control laws by selling hardware, software, and semiconductor design intellectual property to the National University of Defense Technology (NUDT) in China. NUDT was added to the Department of Commerce’s Entity List in February 2015. The university was involved in the development of supercomputers with applications for military and nuclear explosive simulations. 

Cadence and its Chinese subsidiary engaged in a conspiracy to commit export control violations by exporting this technology to NUDT without obtaining the requisite licenses from […]

By |2025-08-07T11:02:32-04:00August 7, 2025|EAR, Enforcement, Export, International Trade, Technology, U.S. Bureau of Industry and Security (BIS), U.S. Department of Justice (DOJ)|0 Comments
Read More
This website uses cookies and third party services. By continuing to use our website, you agree to the Privacy Policy. OK
Skip to content
Go to Top