On June 17, 2026, the U.S. Department of Justice’s (DOJ( National Security Division (NSD) announced that it had issued a declination for Robert Bosch GmbH (Bosch) relating to potential violations of the Export Control Reform Act, 50 U.S.C. § 4819 (ECRA). Specifically, the DOJ declined to criminally prosecute Bosch’s violations of the Export Administration Regulations’ (EAR)
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Crowell & Moring Hosts ACSS New York Chapter Event on Cartels, Foreign Terrorist Organizations, and Financial Crime Compliance
On June 4, 2026, Crowell Partners Caroline Brown and Anand Sithian hosted the ACSS New York Chapter at the New York office for an in-person panel discussion titled “Renewed Focus on Cartels, Transnational Criminal Organizations, and Foreign Terrorist Organizations: Compliance Challenges for Financial Institutions and Multinationals.” The sold-out event brought together practitioners from the financial…
USTR Finds Certain Brazilian Practices in Six Issue Areas Actionable Under Section 301; Proposes 25% Tariffs on Brazilian Goods and Invites Comments
The Office of the United States Trade Representative (USTR) has issued a Notice of Determination and Request for Comments, finding that certain of Brazil’s acts, policies, and practices are actionable under Sections 301(b) and 304(a) of the Trade Act of 1974. If adopted as proposed, USTR would impose additional tariffs of 25% on Brazilian-origin goods,…
USTR Proposes Sweeping Tariffs as Part of Section 301 Forced Labor Import Enforcement Investigation
On June 2, 2026, the U.S. Trade Representative (USTR) announced a landmark set of enforcement actions under Section 301 of the Trade Act of 1974, targeting 60 economies worldwide for failing to prohibit the importation of goods produced with forced labor. This is one of the most sweeping forced labor-related trade enforcement actions in U.S.…
Executive Order on Strengthening Customs Enforcement
On June 3, 2026, the White House issued an Executive Order (“Strengthening Customs Enforcement”) that directs the U.S. Department of Homeland Security (“DHS”) and U.S. Customs and Border Protection (“CBP”) to take a series of actions intended to combat customs fraud, transshipment, forced labor imports, duty evasion, and other trade-related violations. While many of the…
BIS Confirms Advanced Chip License Requirements Extend to D:5 and Macau-Headquartered Entities Worldwide
Key Takeaway: BIS’s latest guidance closes an ambiguity created by the AI Diffusion Rule rollback, confirming that the original 2023 license requirement for advanced computing items exported to Country Group D:5 and Macau-headquartered entities remains in full force – regardless of where those entities are physically located.
On May 31, 2026, the U.S. Department of…
Supply Chain Disruption – Again
Businesses affected by the Strait of Hormuz crisis are likely to be navigating both sides of the contractual liability equation: seeking to enforce protections while simultaneously trying to limit their own exposure. This balancing act will feel familiar to those who managed supply chain disruptions during the Covid pandemic or in response to Russian sanctions.…
ATF Catches Up with Export Control Reform (Better Late than Never!)
Key Takeaway: ATF’s latest final rule closes a regulatory gap left by the Export Control Reform (“ECR”) initiative, acknowledging that the Department of Commerce now shares jurisdiction alongside the Department of State over items on ATF’s United States Munitions Import List (“USMIL”).
On May 6, 2026, the Bureau of Alcohol, Tobacco, Firearms and Explosives (“ATF”)…
DOJ Launches FOCUS Initiative, Seeks Data Miners to Assist in Identifying and Building Fraud Claims
On April 30, 2026, the DOJ announced the launch of the Fraud Oversight through Careful Use of Statistics initiative (FOCUS) to increase coordination between the Department and the growing host of data miners who sift through publicly available government data to identify patterns of alleged fraud. The launch of FOCUS highlights a growing trend in…
2025 Capital Pro Bono Honor Roll Released by DC Courts
A huge congratulations to our 15 International Trade attorneys who were named to the 2025 Capital Pro Bono Honor Roll for providing 50 or more hours of pro bono legal services last year. Of this number, five individuals achieved High Honor distinction for providing 100 hours or more. This accomplishment underscores our continued commitment to…