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Importers seeking IEEPA tariff refunds should prepare now for the next phase of the refund process. On September 15, 2026, U.S. Custom and Border Protection (CBP) notified the Court of International Trade that (CIT) that the Consolidated Administration and Processing of Entries (“CAPE”) Phase 3 will deploy on October 6, 2026. This marks an important milestone in the implementation of the CAPE process for importers seeking relief.

When Can Importers File Declarations?
According to the CBP, importers who

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Continue Reading Claiming IEEPA Tariff Refunds? Prepare Now for CAPE Phase III Filing Requirements 

Complying with European privacy rules governing the transfer of personal information to the U.S. has always been challenging for U.S. companies. Now, a seemingly unrelated U.S. Supreme Court decision, Trump v. Slaughter, may create new uncertainty around the legal framework governing those transfers, raising fresh considerations for companies that do business in Europe.

A History of EU-U.S. Personal Data Transfer Challenges
For more than two decades, the U.S. and EU have struggled to establish a system that allows U.S.
Continue Reading The Future of EU-U.S. Data Transfers and GDPR Adequacy After Trump v. Slaughter

The U.S. Department of Homeland Security (“DHS”) has issued a proposed rule that, if finalized, would impose a new $103,265 filing fee on cap-subject H-1B petitions, in addition to existing filing fees. DHS has indicated that the fee is intended to recover a portion of the federal government’s cost of administering the lawful immigration system and support immigration-related operations across multiple federal agencies.

The proposed fee would apply broadly to cap-subject H-1B petitions, including petitions eligible for the advanced…
Continue Reading DHS Proposes New $103,265 Fee for Cap-Subject H-1B Petitions

Overview

Multinational companies operating across the U.S. and China increasingly face a difficult compliance dilemma: complying with one country’s sanctions, export controls, or other trade restrictions may create legal risk under the other’s retaliatory laws. As both countries expand the use of export controls, sanctions, and other economic restrictions to advance national security and foreign policy objectives, companies now find themselves subject to competing and sometimes conflicting legal obligations that impact supply chains, customer relationships, operations, and investment

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Continue Reading U.S.-China Sanctions and Export Controls: Managing Compliance Risks in Cross-Border Trade

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U.S. importers should prepare for substantial new tariff exposure following the Trump administration’s imposition of Section 301 forced labor tariffs on imports from 60 countries. The measures affect approximately 99.4 percent of U.S. imports and may result in additional duties, subject to certain exemptions and special tariff treatment.

The tariffs were announced on July 23, 2026, in a presidential memorandum in which the Trump administration stated it would impose tariffs through the Section 301 investigation examining whether foreign

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Continue Reading Trump Administration Imposes New Section 301 Forced Labor Tariffs onImports From 60 Countries

Importers seeking refunds of IEEPA tariffs on finally liquidated entries may need to file suit to secure recovery.

On July 17, 2026, the U.S. Court of International Trade (“CIT”) issued an order directing U.S. Customs and Border Protection (“CBP”) to begin processing refunds for importers that filed civil lawsuits seeking IEEPA tariff refunds. However, the order does not extend to importers that did not file suit, leaving their eligibility for refunds dependent on either future litigation or the outcome

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Continue Reading IEEPA Tariff Refunds Authorized: What Importers Need to Know

Amundsen Davis International Trade Alert

July 21, 2026

On July 20, 2026, President Trump signed three supplementing presidential proclamations under Section 338 of the Tariff Act of 1930 (Section 338 Tariffs), which imposes a 50 percent import tariff on certain products from Canada. The new tariffs will go into effect on August 19, 2026.

Importers should promptly review affected products, evaluate available exemptions, and assess potential cost and supply-chain impacts.
Which Products Are Subject to the New Canada Tariffs?

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Continue Reading Trump Administration to Impose 50% Tariffs on Canadian Imports

On July 15, 2026, the Trump Administration announced a new 25 percent tariff on all imports from Brazil, with certain exemptions under sections 301(b) and 304(a) of the Trade Act of 1974, as amended (“Trade Act”). The new tariffs will go into effect on July 22, 2026.

Importers should promptly review affected products, evaluate available exemptions, and assess potential cost and supply-chain impacts. 
Which Products Are Subject to the New Brazil Tariffs?
The new tariffs apply broadly to imports

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Continue Reading Trump Administration to Impose 25% Tariffs on Brazil Imports

Expanding into global markets presents major opportunities for growth, also introduces new legal, logistical, and financial risks that companies must manage proactively. In our recent webcast, Accessing New Markets While Managing Business Risks, we discussed the most common challenges exporters face and the practical steps every company should take before entering a new country or signing a cross‑border deal. Below are several key insights from the presentation.
1. Understand Whether You Can Legally Sell
Before pursuing any international sales…
Continue Reading Accessing New Markets While Managing Business Risks

U.S. Customs and Border Protection (CBP), in response to an order issued by the Court of International Trade (CIT), proposed on March 6 an administrative process to refund tariffs imposed by President Trump.
As we previously reported, on February 20, 2026, the Supreme Court ruled that the Trump administration’s use of the International Emergency Economic Powers Act (IEEPA) was unconstitutional. As a result of that decision, the case was kicked back to the CIT to address the refund…
Continue Reading Trump Tariffs: CBP Proposes Refund Process Following Court of International Trade Order

Over the past year, escalating protective tariffs have prompted many domestic and foreign medical device manufacturers to reach out for assistance with duty-free entry of their products into the U.S.

In many cases, relief is available under the little-known international agreement, the Nairobi Protocol, formally known as the Protocol to the Agreement on the Importation of Educational, Scientific and Cultural Materials.
How the Nairobi Protocol Provides Duty-Free Entry
The U.S. implements the Nairobi Protocol through special provision of the

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Continue Reading How to Qualify Medical Devices for Duty-Free Import Into the U.S.

This client alert provides updates on our previous guidance related to the September 19, 2025, Presidential Proclamation (the “Proclamation”), Restriction on Entry of Certain Nonimmigrant Workers. On October 20, 2025, U.S. Citizenship and Immigration Services (“USCIS”) published updated guidance on the applicability of the Proclamation. The update clarifies:

  • Who is subject to the $100,000 payment;
  • Who is NOT subject to the payment;
  • How to pay the new fee; and
  • How to request an exception in the National Interest.

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    Continue Reading USCIS Clarification on Restriction on Entry of Certain Nonimmigrants

    Strategic cargo theft—fraudulent schemes where criminals pose as legitimate carriers or brokers to gain possession of freight—has surged across the U.S. freight market. Since the first quarter of 2021, strategic cargo theft has risen more than 1500 percent, with the average loss per shipment now exceeding $200,000. Although this creates mounting challenges for shippers, carriers, brokers, and their insurers, the right safeguards in contracts and protocols can help minimize the risk of a catastrophic uninsured loss.
    Disputes Over

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    Continue Reading Fighting Strategic Cargo Theft: Risk Management for Rising Claims Disputesand Liability Challenges

    Over the past several months since the flurries of tariffs implemented by the Trump administration went into effect, we have noticed an uptick in questions regarding products used in agriculture. Specifically, on compliance strategies to mitigate the impact of these tariffs on business. Through the special provisions of the Harmonized Tariff Code of United States (HTSUS), 9817.00.50 and 9817.00.60, U.S. law provides a duty-free mechanism that allows eligible machinery, tools, and equipment that are genuinely used for farming

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    Continue Reading Duty-Free Entry for Products Used in Agriculture and Horticulture

    Late last week, the White House issued a Proclamation which added a payment requirement of $100,000 to new H-1B petitions. The Proclamation provides a narrow exception for persons whose employment is determined in the Secretary of Homeland Security’s discretion to be in the national interest of the United States. This new requirement went into effect on September 21, 2025, and expires after 12 months absent extension.

    A memorandum issued by USCIS later clarified that the proclamation only applies to…
    Continue Reading Presidential Proclamation Creates $100,000 Payment Requirement for New H-1B Petitions

    On June 9, 2025, the Trump Administration’s sweeping travel ban took effect, suspending entry for citizens of twelve countries and imposing partial restrictions on nationals from seven more.[1] The measure was introduced as part of a broader effort to address national security and vetting concerns, signaling that the restrictions were only the beginning of a broader enforcement approach.
    Escalation of U.S. Travel Restrictions
    Since the initial ban, the Administration has escalated its efforts. In late June, the White…
    Continue Reading Travel Restrictions on the Rise: Why Employers Should Advise Caution