News Articles

DDTC

Advisory Opinions From DDTC – What Are They?

The Directorate of Defense Trade Controls (DDTC) that administers and enforces the ITAR also issues Advisory Opinions (AO). What the heck is an AO? If you come from a Customs compliance background you know about Customs rulings and may have applied for some. An AO is sort of like a Customs ruling in that it is a written interpretation of the regulations.

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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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Section 232 Automotive

Self-Declaring Under the Section 232 Automotive and MHDVP Programs

The October 17, 2025 Presidential Proclamation 10984 Adjusting Imports of Medium- and Heavy-Duty Vehicles, Medium- and Heavy-Duty Vehicle Parts, and Buses into the United States included a provision to self-declare certain auto and truck parts and components as being subject to the tariffs with certain requirements.

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Mercosur

Mercosur Update

Let’s rewind to December 6, 2024. A deal more than 25 years in the making, covering over 700 million people and a combined GDP approaching $22 trillion, became realized. Since then, the agreement has made notable institutional progress while encountering renewed legal and political resistance that will shape its path to implementation. What’s happened recently?

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BRICS

BRICS: An Update and a Challenge

Has BRICS finally produced an alternative to the “petrodollar” after twenty years? And does it live up to the hype? Depending on where you look online, key details are being left out. So, let’s slow down and review what’s actually happening.

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EU and India

After Two Decades of Failing to Come to an Agreement “The Mother of All Deals” is Done – Kudos to India and the EU

As of 1/27/2026, India and the EU have finalized a free trade agreement described by both sides as the “mother of all deals” that slashes tariffs, opens markets, and creates a combined economic region of roughly two billion people. This FTA stands as one of the most consequential global trade realignments in years, driven in part by U.S. tariff pressure and a shift in strategy toward diversifying one’s supply chains.

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Davos Canada

Hot Topics in International Trade – The Davos Speech by Canadian Prime Minister Mark Carney The Middle Powers Playbook and a Global Trade Realignment in the Making

For whatever reason, if you missed the spectacle created by President Trump on the world stage recently in Davos, Switzerland at the World Economic Forum, you really need to pay close attention now to the fall out. Top business executives in global economies were watching and probably also wondering just who the hell was going to stand-up to the U.S. pressure campaign, and that’s where Canadian Prime Minister Mark Carney stepped up to the mic and delivered a speech that sent shockwaves across continents.

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Coercion in International Trade

Is Coercion the Best Approach to North American Trade?

The Trump Administration has demonstrated a willingness to apply new tariffs to goods entering the U.S. as a viable tactic under its America First strategy to achieve greater fairness in its dealings with other countries. The application of tariffs is authorized under a number of standard legal procedures, such as trade remedy investigations to mitigate dumping of goods at less than fair value into the U.S. market or eliminating the unfair price advantages of government subsidies, and use of section 301 duties to respond to unfair trade practices by other countries. However, the broad-brush use of tariffs to coerce our trading partners to make concessions in non-trade areas to resolve a domestic crisis is relatively new.

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madman theory

Trade War and the Madman Theory: A Personal Reflection

I can’t help but reflect on a negotiation seminar I took in law school, where we studied the Madman Theory, popularized by Richard Nixon. The theory suggests that acting unpredictably or being willing to take extreme actions can create leverage. If your opponent believes you might “blow it all up,” they may feel forced to make concessions. This strategy clearly echoes Trump’s approach to trade policy.

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external revenue service

The External Revenue Service: A Bureaucratic Overreach or Necessary Reform?

President Donald Trump made headlines when he announced an External Revenue Service (ERS) agency to collect tariff incomes. The announcement sparked a heated debate among trade experts, economists, and business leaders. But, what exactly would be the purpose of the agency? Well, we can take the words spoken from his inauguration address as an answer.

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china's growing influence in latin america

China’s Growing Influence in Latin America: Infrastructure Investments and Implications for the Panama Canal

China has significantly expanded its economic and geopolitical footprint in Latin America, particularly through the acquisition and development of critical infrastructure such as ports, airfields, and railways. This strategic move has raised questions about the long-term implications for regional sovereignty, global trade routes, and the future of the Panama Canal, a linchpin of international maritime commerce.

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Chemical Classification

Chemical Classification, It Matters, Now More Than Ever-To Most

If you have a company that imports chemicals – whether they are used as raw materials or components for onward manufacturing, or finished goods containing chemical components – you have been facing significant challenges over the last half-dozen years. Some of these challenges include the trade wars with China (I’m looking at you, Section 301) and the disruptive impact of COVID-19 to global supply chains. In response to these challenges, you have maybe modified your supply chain to reduce your dependence on Chinese chemical imports.  Or perhaps your supply chain was not largely affected by Section 301 tariffs (if so, consider yourself lucky – and may your luck hold!).

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Customs broker license exam

The U.S. Customs Broker License Exam: Tips and Perspectives

A customs broker license is issued to a person who has successfully passed a grueling licensing exam (after paying the exam fee), submitted a license application (along with another fee), and passed the subsequent FBI background investigation. The open-book exam, which lasts 4½ hours and comprises 80 multiple-choice questions, is ostensibly intended to measure one’s knowledge about various customs-related regulations and practices yet experience or employment in a customs-related job is not a prerequisite.

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Harmonized Tax Schedule

Punctuation in the Harmonized Tariff Schedule of the United States

Punctuation matters. I’ve always remembered a poster on the wall of a co-worker’s office—this was back in the 80s—that showed baby seals dancing at a disco under a four-word caption: STOP CLUBBING, BABY SEALS. The poster (which has become an internet meme forty years later) cleverly showed how something as seemingly minor as a comma can change the meaning of a phrase or sentence. If a comma can flip the meaning of a four-word sentence, is it hard to imagine the effect that punctuation, or lack of punctuation, might have on our interpretation of a law or regulation?

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tariffs

Beyond the Tariff: Proactive Strategies to Mitigate Trade Remedy Impacts

In today’s complex global marketplace, businesses are increasingly confronted with the challenges of supply chain disruptions, rising costs, and fierce competition—all exacerbated by trade remedy tariffs. While many of these tariffs are already in play, President-elect Trump has promised to impose new tariffs and increase old ones.

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Mercosur

Mercosur-EU – A New Potential Powerhouse in Trade Blocs if Ratified

After 25 years of negotiations, the European Union and the Southern Common Market, commonly known as Mercosur, comprised of Brazil, Argentina, Uruguay, and Paraguay, signed a free trade agreement. I think this, among many more regional deals to come was suddenly expedited due to the anticipated land mines with the upcoming Trump 2.0 administration and trade policy regarding tariffs for all.

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tariffs

Tariffs, and the Temptation to Use Them as Geopolitical Leverage

The United States has a long history of using tariffs. The first significant tariff legislation was the Tariff Act of 1789, signed by President George Washington. Tariffs have been used for various purposes over the years, including protecting domestic industries, generating government revenue, and negotiating trade agreements. The use of tariffs however has evolved, with significant changes during different historical periods, such as the high tariffs of the 19th century and the shift towards free trade in the mid-20th century, as well as the current U.S. trade war with China, and possibly soon to be with Mexico and Canada.

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