James Holbein

Picture of James Holbein

James Holbein

CBP Supply Chain Compliance

CBP Asks for Comments On Supply Chain Compliance by 12/1/2026

CBP issued an Advance notice of proposed rulemaking, “Heightened Import Disclosures for Supply Chain Visibility,” 91 Fed Reg 56408 (FRN), on September 2, 2026. Responses are due to CBP by December 1, 2026, using the Federal eRulemaking Portal: http://www.regulations.gov. Follow the instructions for submitting comments via docket number USCBP–2026–1058.

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iran war

The Iran War: A New Shock to Global Trade

The war with Iran is being fought with missiles, aircraft and naval forces, but some of its most consequential effects are disruptions impacting energy markets, international shipping, insurance, supply chains, and prices, while adding another layer of sanctions and tariff risk to international trade. The result is particularly significant because the Strait of Hormuz, at the center of the conflict, is one of the most important arteries in world commerce.

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GENIUS Act

Agencies Request Comments on GENIUS Act Implementation

The GENIUS Act has authorized several regulatory agencies to issue regulations to develop the first comprehensive federal regulatory framework governing payment stablecoins in the United States. The statute directs multiple federal financial regulators to implement a coordinated supervisory structure governing issuance, reserve management, redemption rights, anti-money laundering compliance, custody, and market structure.

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AI Legislation

AI Legislative Framework Proposed by the White House

On March 20, 2026, the Trump Administration announced that it, “is committed to winning the AI race to usher in a new era of human flourishing, economic competitiveness, and national security for the American people.“ The White House issued a new comprehensive national legislative framework that addresses six key objectives.

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IEEPA

Supreme Court Clarifies Separation of Powers in IEEPA Tariffs Decision

In the final analysis, this case stands as one of the most important separation of powers decisions in the economic domain in U.S. history. It clarifies that tariffs are a form of taxation reserved to Congress, embeds the major questions doctrine in trade law, and reasserts the structural boundary between legislative and executive authority.

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DAO

Integrating DAOs and DUNAs with Stablecoin Ecosystems

We have analyzed Decentralized Autonomous Organizations (DAOs) and how the GENIUS Act will permit regulation of payment stablecoins in prior articles. This article examines how decentralized organizations interact with stablecoin ecosystems and the synergies between organizational and payment infrastructure innovation.

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Haiti

Renewal of Haiti HOPE/HELP and AGOA Trade Preferences Up to Senate

In its usual fashion, Congress has allowed the tariff preferences for Haiti under the United States-Caribbean Basin Trade Partnership Act (CBTPA) and the African Growth and Opportunity Act (AGOA) to expire on September 30, 2025. Two bills passed the House with bipartisan majorities on January 12, 2026, to renew the tariff preferences retroactively to the date of expiration and then extend them to September 30, 2028. Both bills are now in the Senate Finance Committee awaiting action. This article examines the current status and likely outcomes of Senate review.

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Stablecoin

Activating HTTP 402: The x402 Protocol and Legal Framework for Internet-Native Stablecoin Payments

The convergence of payment stablecoins, blockchain settlement infrastructure, and the regulatory clarity provided by the GENIUS Act of 2025 has created conditions for HTTP 402’s activation. The x402 protocol, developed by Coinbase in collaboration with Cloudflare and others through the x402 Foundation, operationalizes this long-reserved status code to enable instant, automated payments: particularly for autonomous AI agents conducting machine-to-machine commerce.

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