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

News & Articles

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

U.S. Department of Labor Introduces New Tools to Support Supply Chain Integrity and Address Unfair Foreign Labor Practices

On April 8, 2026, the U.S. Department of Labor (DOL) announced the launch of several tools to empower U.S. companies to strengthen their supply chains and defend against unfair competition stemming from overseas labor abuses.

Self-Assessment Tools

DOL launched four voluntary self-assessment tools that provide practical, user-friendly guidance to help companies map supply-chain risks and evaluate labor practices. The tools can also guide companies in taking steps to ensure alignment with U.S. forced labor laws and strengthen supply chains that support American workers and American industry.

The new tools are: 

  • LaborShield: A mobile app that features information on egregious labor violations in over 145 countries (formerly the Sweat and Toil app).
  • ImportWatch: A resource that brings together the department’s labor abuse research with U.S. import data from the U.S. Census Bureau to produce a red-flag list of all high-risk goods for U.S. importers.
  • SourcingStrong: A tool to help U.S. businesses build strong labor due diligence systems to identify and manage risk in their supply chains.
  • Supply Chain Traceability Portal: The portal provides visibility across supply chains and beyond the first tier to expose where exploitative labor hides.

Announcement Insights 

Diaz Trade Law was in attendance at the launch event in Washington, D.C. – hosted by the DOL and […]

By |2026-04-09T16:06:30-04:00April 9, 2026|Enforcement, Forced Labor, Import, U.S. Department of Labor (DOL)|0 Comments
Read More

Breaking Trade News: New 232 Proclamation, CBP Update on IEEPA Refunds, OFAC Sanctions Advisory

Here is a recap of the latest customs and international trade law news: 

Administration

  • On April 2, 2026, the President issued a proclamation strengthening Section 232 actions to adjust imports of aluminum, steel, and copper, continuing to cite national security concerns and the need to reinforce domestic metals industries. 

Customs and Border Protection (CBP)    

  • CBP filed an update on the progress of the Consolidated Administration and Processing of Entries (CAPE) system that will be used to refund the tariffs imposed under the IEEPA.   
  • On April 1, CBP released a modernized ACE Secure Data Portal account application for the trade community.  
  • CBP said in a notice that it is no longer actively investigating allegations that cocoa from Cote d’Ivoire is being made with forced labor. 
  • CBP filed a stipulated judgment with the CIT stating that products from importer Camel Energy aren’t subject to the Uyghur Forced Labor Prevention Act (UFLPA). The judgment follows a review of Camel’s supply chain, which determined that entries of batteries did not violate the UFLPA.  

United States Trade Representative (USTR) 

By |2026-04-03T14:27:14-04:00April 3, 2026|news, Snapshot|0 Comments
Read More

New OFAC Advisory: Signs of Sham Transactions and Sanctions Evasion

On March 31, 2026, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) released an important advisory addressing the growing use of sham transactions to evade U.S. sanctions. The guidance highlights how sanctioned individuals and entities often attempt to disguise their continuing interest in property through opaque legal structures, proxies, and other intermediaries. OFAC’s message is clear: transactions that merely appear to transfer ownership but do not genuinely extinguish a blocked person’s interest remain prohibited. 

What OFAC Defines as a “Sham Transaction” 

Sham transactions occur when blocked persons “give up their property on paper only,” while continuing to benefit from or control the asset. These arrangements often involve: 

  • Proxies, straw owners, or front companies acting on behalf of sanctioned individuals. 
  • Opaque legal structures, including multi‑layered LLCs, partnerships, or trusts. 
  • Transfers to family members or close associates who may serve as facilitators. 
  • Commercially unreasonable transfers, such as those lacking adequate consideration. 
  • Continued use or control of the asset by the blocked person after the purported transfer. 

Pro Tip: Look beyond legal formalities and identify the economic realities of the transaction. 

Red Flags Identified by OFAC 

The advisory outlines several indicators that a transaction may be a sham designed to evade sanctions. These include: 

By |2026-04-07T16:53:01-04:00April 3, 2026|Enforcement, International Law, International Trade, Investigation, U.S. Office of Foreign Assets Control (OFAC)|0 Comments
Read More

FinCEN Issues NPRM to Fully Implement Whistleblower Program

Authors:

Jennifer Diaz, President, Diaz Trade Law

Amber Pirson, Attorney, Diaz Trade Law

FinCEN’s March 30, 2026, Notice of Proposed Rulemaking (NPRM) marks a major step toward fully operationalizing the agency’s whistleblower program, designed to incentivize reporting of Bank Secrecy Act (BSA), sanctions, IEEPA, and other illicit finance violations. The proposal outlines how whistleblowers can securely submit information, how awards will be determined, and what protections will be available.  

This development reflects the Treasury Department’s broader strategy to strengthen financial system integrity and encourage actionable tips that support enforcement efforts. For financial institutions, compliance professionals, and potential whistleblowers, the NPRM provides long‑awaited clarity on program structure and expectations. 

Overview of the Proposed Rule 

FinCEN’s NPRM proposes a comprehensive framework for administering whistleblower submissions and awards. Key elements include: 

  • Secure submission procedures for individuals reporting suspected violations of the BSA, OFAC sanctions, and related laws. 
  • Eligibility criteria for whistleblower awards, including documentation requirements and timelines. 
  • Award ranges of 10–30% of monetary penalties collected when a whistleblower’s information leads to a successful enforcement action. 
  • Robust protections for individuals who provide information, including confidentiality and anti‑retaliation safeguards. 

These provisions aim to encourage early, detailed reporting while ensuring whistleblowers are shielded from adverse consequences. 

Why FinCEN Is Prioritizing Whistleblower Incentives 

The NPRM aligns with Treasury’s broader […]

By |2026-04-03T10:52:12-04:00April 3, 2026|Enforcement, International Law, Trade Policy, U.S. Department of Justice (DOJ), U.S. Office of Foreign Assets Control (OFAC)|0 Comments
Read More

New Executive Order Adjusting Imports of Aluminum, Steel, and Copper into the United States

Authors:

Jennifer Diaz, President, Diaz Trade Law
Amber Pirson, Attorney, Diaz Trade Law

On April 2, 2026, the President issued a proclamation strengthening Section 232 actions to adjust imports of aluminum, steel, and copper, continuing to cite national security concerns and the need to reinforce domestic metals industries. 

Key elements include: a tiered tariff structure and some products exempt from Sec. 232 tariffs, effective at 12:01 am on April 6, 2026; and manufacturing drawback claims.  

Generally, tariffs will be assessed to the full value of imported products, “regardless of their metal content,” with reduced rates for certain products from the United Kingdom (UK) and the same 200% ad valorem duty for subject metal articles from Russia. 

  • Aluminum and steel articles, most copper articles, and certain derivative articles of aluminum and steel…  
    • 50%, unless either the 25% or 10% rates listed below can apply. 
      • 25% for UK products, the aluminum content of which is composed entirely of aluminum that was smelted or most recently cast in the UK, or the steel content of which is composed entirely of steel that was melted and poured in the UK. 
      • 10% for derivative articles, steel or copper content, when the metal content was smelted and cast in the U.S. 
  • For certain copper and […]
By |2026-04-06T07:20:28-04:00April 3, 2026|Import, International Trade, tariffs, U.S. Customs and Border Protection (CBP)|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