February 2024 - Braumiller Law Group

BIS Unveils Enhanced Voluntary Self Disclosure Protocols

February 6, 2024

By: Adrienne Braumiller, Founder of Braumiller Law Group

On January 16, 2024, the Bureau of Industry and Security (BIS) under Assistant Secretary for Export Enforcement, Matthew Axelrod, disclosed significant enhancements to the process for Voluntary Self-Disclosures (VSDs) related to the Export Administration Regulations (EAR). These adjustments are strategically designed to streamline export control compliance for U.S. governmental bodies, the commercial sector, and academic entities.

Who is the Importer of Record: Security Interests and the Right to Act As IOR

February 6, 2024

By: Adrienne Braumiller, Partner & Founder and Gavin Andersen, Trade Advisor
Last June (2023), in response to a ruling request from Your Special Delivery Services Specialty Logistics (YSDS), Customs and Border Protection (CBP) issued HQ H324098, clarifying what it means to be an “owner or purchaser” with sufficient financial interest to act as importer of record (IOR).

Suspensión del Padron de Importadores

February 6, 2024

Por Brenda Cordova, Mexico Attorney, Braumiller Law Group

Uno de los requisitos más importantes para importar mercancías a México es estar registrado como importador en el registro de importadores mexicanos. Hay 2 tipos de registros para importadores, uno es para importadores generales (Padrón de Importadores) y el otro es para importadores de sectores industriales específicos (Padrón de Importadores de Sectores Específicos) que pueden importar mercancías identificadas por el código arancelario MX (es decir, productos químicos, armas de fuego, puros, calzado, textiles, alcohol, hidrocarburos, siderurgia, automoción, etc.). Generalmente, estos 2 registros son listados con información de personas y entidades autorizadas para importar mercancías a México.

Suspension of Mexican Importer Registration (Padron de Importadores)

February 6, 2024

By: Brenda Cordova, Mexico Attorney, Braumiller Law Group

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.

Parallel Imports, A Global Phenomenon, And a Very Grey Area Regarding International Trade

February 5, 2024

By Bob Brewer, Braumiller Law Group

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.

Maximizing Duty Savings Series Leveraging Bonded Warehouse and Foreign Trade Zones

February 5, 2024

By: Kerry Wang, Senior Associate, Braumiller Law Group

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).

What is the “First Sale” Rule and How Does it Affect Me?

February 5, 2024

By Bruce Leeds, Senior Counsel, Braumiller Law Group

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.

Assessing the Benefits and Challenges of Tokenizing Real World Assets

February 5, 2024

By: James R. Holbein, Of Counsel and Justin Holbein

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.

Taiwan, Invasion & Trade, Part 2

February 5, 2024

By: Victoria Holmes, Braumiller Law Group
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?

Punctuation in the Harmonized Tariff Schedule of the United States

December 19, 2024

By Mike Smiszek, Senior Trade Advisor, Braumiller Consulting Group

Punctuation matters. I’ve always remembered a poster on the wall of a co-worker’s office—this was back in the

Beyond the Tariff: Proactive Strategies to Mitigate Trade Remedy Impacts

December 11, 2024

By: Adrienne Braumiller, Founder of Braumiller Law Group

In today’s complex global marketplace, businesses are increasingly confronted with the challenges of supply chain disruptions, rising costs, and

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

December 11, 2024

By Bob Brewer, Braumiller Law Group

After 25 years of negotiations, the European Union and the Southern Common Market, commonly known as Mercosur, comprised of Brazil, Argentina,

Tariffs, and the Temptation to Use Them as Geopolitical Leverage

December 11, 2024

By Bob Brewer, Braumiller Law Group

The United States has a long history of using tariffs. The first significant tariff legislation was the Tariff Act of 1789,

Trump import duties on goods from Mexico

Mexico’s Response to Trump’s Increase to Import Duties on Goods Coming from Mexico into the United States

December 11, 2024

By: Brenda Cordova, Mexico Attorney, Braumiller Law Group

Recently, US elected President Trump threatened that when he takes office one of his first orders will be a

Out of This World! Proposed New Regulations on Space and Spacecraft

December 11, 2024

By Bruce Leeds, Senior Counsel, Braumiller Law Group

On October 23, 2024, the Directorate of Defense Trade Controls published proposed changes to the International Traffic in Arms

Presidential Authority to Unilaterally Raise Tariffs

December 11, 2024

By: James R. Holbein, Of Counsel

This article examines the constitutional authorities and various statutes that reserve tariff authorities for Congress and some legal authorities in which

The Ghost of CDSOA Still Haunts Us

December 11, 2024

By Mike Smiszek, Senior Trade Advisor, Braumiller Consulting Group

For the better part of a decade, the United States waged an ugly dispute with the WTO over

From Awareness to Action: A Deep Dive into CTPAT Training

December 11, 2024

By: Judy Davis, Senior Trade Advisor, Braumiller Consulting Group
In the global trade universe, where time holds huge importance, weak security practices in your international operations could be detrimental

Tariffs, Trade & Trump

December 11, 2024

By: Victoria Holmes, Braumiller Law Group
Historically, trade agreements have focused on reducing barriers to trade—such as tariffs and quotas—while encouraging economic integration and growth. Environmental protection was often

Customs Fraud Investigations Expected to Increase Under Trump Tariffs

December 11, 2024

By Sarah Wirskye, Wirskye Law Firm, Of Counsel, Braumiller Law Group

President-elect Trump has repeatedly stated that he will increase tariffs. While it is unclear to what

Jurisdiction and History of Tariff Classification Litigation in the U.S.

December 4, 2024

By Mike Smiszek, Senior Trade Advisor, Braumiller Consulting Group

Several tribunals and courts were established at various periods of America’s history to resolve trade-related litigation, both at

Amendments to the MX Customs General Rules for 2024 and to Annexes 1, 2, 5 and 24 (Reglas Generales de Comercio Exterior para 2024)

October 21, 2024

By: Brenda Cordova, Mexico Attorney, Braumiller Law Group

On September 15th, 2024, the Mexican Congress published on the Diario Oficial de la Federacion (Mexican Official Gazette) a

Navigating Trade Waters: A Deep Dive into the USMCA Joint Review Process and Its Impact on China and Mexico – Part Two: The Mexico-US Trade Landscape and Harris’s Potential Vision

October 7, 2024

By: Adrienne Braumiller, Founder of Braumiller Law Group and Gavin Andersen, Senior Trade Advisor, Braumiller Consulting Group and Law Clerk

This is the second of a three-part

China and Walmart, Please, for the Love of ____, Let’s Observe a Silver Lining Partnership in an Otherwise Dismal Global Landscape

October 7, 2024

By Bob Brewer, Braumiller Law Group

At a glance, gauging where we stand in our relationship with China overall, one would assume the key operative word in

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