
Who is the Importer of Record: Security Interests and the Right to Act As IOR
By: Gavin Andersen, Law Clerk, LCB and Adrienne Braumiller, Founding Partner, Braumiller Law Group Last June (2023), in response to a ruling request from Your Special

By: Gavin Andersen, Law Clerk, LCB and Adrienne Braumiller, Founding Partner, Braumiller Law Group Last June (2023), in response to a ruling request from Your Special

At the core of the definition, a Parallel import is a non-counterfeit product imported from another country without the permission of the intellectual property owner. They are also goods that are not authorized for importation into the U.S. It’s a global phenomenon, a very grey area, and their presence varies across different parts of the globe.

One of the most important requirements for importing goods into Mexico is to be registered as an importer under the Mexican importer’s registry. There are 2 types of registries for importers, one is for general importers (Padron de Importadores), and the other is for importers of specific industry sectors (Padron the Importadores de Sectores Especificos) which may import goods identified by the MX tariff code (i.e. chemical products, firearms, cigars, footwear, textiles, alcohol, hydrocarbons, steel, automotive, etc.). Generally, these 2 registries are lists with information of individuals and entities authorized to bring goods into Mexico.

Consider this scenario: a client faced the challenge of deferring duty payments while managing a significant volume of imports destined for re-exportation from the U.S. Initially considering duty drawbacks, which proved unsuitable for their specific needs, we turned our attention to bonded warehouses and free trade zones. This scenario is not uncommon in the trade world and highlights a critical decision point for many businesses: choosing between a bonded warehouse and a Foreign Trade Zone (FTZ).

The First Sale Rule applies in circumstances such as the example above. A US company places an order with a middleman in the US. The middleman in turn subcontracts to a foreign supplier. The supplier then ships the product either to the middleman or to the original US company that placed the order, meaning either could be the importer of record. The entered value could be the amount on the original purchase order or the price paid by the middleman to the foreign supplier.

The world of cryptocurrencies on blockchains and the world of traditional assets in markets have often stood in stark contrast to one another since Bitcoin’s creation in 2008. The lack of a reliable bridge between these two worlds has limited the impact of cryptocurrencies on assets in the real-world outside of on-chain speculation and prevented adoption of the benefits that blockchain technologies can bring to real world processes.

President elect Lai Ching-te’s victory in Taipei ignited tensions across the Taiwan strait and now the geopolitical field waits to see if China will kick off World War Three. I’m only slightly joking, but Beijing has exerted diplomatic pressure on nations maintaining close ties with the island in the past and Taiwan’s decision to remain a democracy will no doubt ramp up China’s reunification process in the coming months. But how will that affect trade relations?

In the complex world of international trade compliance, few people possess the expertise, dedication and problem-solving skills that Brad Menard, President of Braumiller Consulting Group, brings to his clients.

In recent years, the global spotlight has illuminated the grave concerns surrounding human rights violations within China’s Xinjiang region, particularly those impacting the Uyghur population. The Uyghur Forced Labor Prevention Act (UFLPA) stands as a pivotal piece of legislation designed to address these concerns and to ensure that products imported into the United States are devoid of forced labor originating from the Xinjiang region.

The implementation of trade policies in what many consider acts of protectionism and manipulation are the norm, and of course China and the U.S. are a prime example. Solutions include nearshoring, reshoring, and protectionism. It’s complicated, so for the purpose of this article, let’s stick with nearshoring.

On any given morning so far in 2026, looking around the globe, one could easily surmise that chaos rules, and the world of trade as result is on fire. The global landscape is filled with trade barriers, tariffs, sanctions, and export controls, from microchips and dairy to lumber, steel and aluminum. We have seen where geopolitical disputes often escalate into trade wars, where countries impose tariffs or targeted restrictions on each other’s goods, but an actual invasion, that’s on a totally different level regarding how it affects trade and global economies.

The exit of a country, such as the U.S., from the USMCA, well, that’s just crazy, right? Afterall, it’s a powerhouse of a trade agreement between the three nations. According to the U.S. International Trade Administration, the United States conducts over $1.3 trillion in annual trade with Mexico and Canada under the USMCA framework and supports roughly 17 million jobs across North America.

The legality of the Fentanyl IEEPA tariffs and the Reciprocal IEEPA tariffs is currently pending in the Supreme Court. A decision is expected in January, although it could come sooner, though the Court may not directly address refund mechanics. Instead, it could remand the issue to the Court of International Trade (CIT), which would delay guidance for several months.

Could BRICS break the dollar’s grip? The answer is coming into sharper focus, and it’s more complicated than either the optimists or skeptics predicted. Since our previous analysis, BRICS has made concrete moves toward de-dollarization while simultaneously confronting harsh economic and political realities. The gap between ambition and achievement has never been clearer.

In the Chinese zodiac calendar, 2025 is the year of the snake. The snake is said to represent wisdom and strategy. As it occasionally sheds its skin, it is also said to represent a change or an inflection point. Whether American trade policy in the year of the snake exemplifies wisdom and strategy depends on one’s political perspective. Whether it exemplifies a major transformation and inflection point is unquestionable.

On November 14, 2025, President Trump issued an Executive Order exempting certain agricultural products from the reciprocal tariffs. The exemptions for certain agricultural products went into effect on November 13, 2025.

On November 19, 2025, a Decree amending, adding and repealing various legal provisions of the Mexican Customs law was published in the Diario Oficial de la Federacion (Mexican Official Gazette). This reform will enter into force on January 1, 2026. Although the Customs Law has been amended multiple times in the last 30 years, this reform is widely considered the most significant since December 15, 1995.

The development of a tequila brand begins with a foundational step: registering a trademark in Mexico, the United States, or any other intended markets. However, trademark protection is only the starting point. Building a tequila brand requires a broader business and regulatory strategy involving multiple teams—Customs and trade, finance, marketing, and legal—to plan for production, cost structures, distribution, sales, and export-related compliance.

Beginning December 9, 2025, importers in Mexico will be required to complete and submit the Electronic Value Manifest through VUCEM (Mexico’s Electronic Single Window). This measure increases the importer’s direct participation and responsibility in determining and declaring the correct customs value of imported goods.

New tariffs, changed tariffs, and reduced tariffs are announced with short notice. The duties on merchandise can change while a shipment is in the middle of the ocean. The status of free trade agreements has become uncertain. New detailed duties are assessed on steel and aluminum and their derivatives. Artificial intelligence is playing an increasing role.