New sustainability regulatory initiatives are establishing requirements for supply chains to collect additional data on a range of sustainability metrics including deforestation, labor conditions, carbon intensity, and recycled content. As one observer noted, “this proliferation of objectives is making value chain management enormously complex.”

Effective beginning November of 2021, U.S. Customs and Border Protection (CBP) updated its Prior Disclosure (or PD) extension request guidelines. The new requirements, which have not been circulated publicly, streamline but shorten the amount of time available for Prior Disclosure filers to perfect their disclosure. Previously, from our firm’s personal experience, CBP routinely granted requests for 180 days to perfect a Prior Disclosure, and if additional extensions were needed they were routinely granted. However, CBP has now significantly shortened extension periods to 30 days with only one additional 60-day extension granted (more details below). Due to the potentially large amount of work needed to perfect a Prior Disclosure, this shortening of the time to perfect makes the Prior Disclosure process more onerous for importers seeking to proactively disclose their suspected violations. Even worse, the limitation of time to perfect a disclosure opens up the possibility that an importer may disclose a violation to CBP, not have the opportunity to perfect the disclosure, and lose the benefits of the PD protection, allowing CBP the ability to penalize the importer. This article provides a background on CBP prior disclosures, explains the new requirements, and identifies best practices.

In response to Russia’s continued invasion of Ukraine, the U.S and its allies have imposed several layers of economic sanctions and actions against Russia and Belarus. In addition to decimating the Ruble to a value of less than $0.01 (USD), the prohibitive actions by the U.S. and its trading partners have left global supply chain participants in a mire of new requirements. This article touches on each of the economic actions by the U.S. government in response to Russia’s invasion of Ukraine.