Breaking Trade News: New Requirements for Foreign IORs, Expanded Iran and Cuba Sanctions

This week’s recap of the latest customs and international trade news:

President Trump told reporters that the Administration has “the concept of a very good deal with Canada” and indicated that a final trade deal could be signed in the coming weeks.

CBP released an interim final rule on November 5, 2026 under which a foreign importer of record must be validated under the Customs Trade Partnership Against Terrorism (CTPAT), or use a CTPAT-validated customs broker, to file formal and informal entries beginning January 5, 2027.
CBP announced a pilot test of a new centralized ACE case management system. The Client Representative Technical Assistance Portal (CRTAP) will provide a centralized location and standardized method for the trade community to submit requests and for client reps to resolve technical issues. The pilot, which will begin Dec. 4 and run for 45 days, is limited to nine participants.
CBP officers at the Port of Louisville stopped a shipment containing 460 counterfeit watches. Had these watches been genuine, the shipment would have had a combined Manufacturer’s Suggested Retail Price of over $66 million.

Plaintiffs filed a consolidated complaint in the U.S. District Court for the Western District of Tennessee in their tariff case against FedEx. FedEx has until December 4, 2026 to respond.

Commerce issued affirmative preliminary antidumping determinations for oil country tubular goods from Austria, Taiwan, and the United Arab Emirates, with preliminary dumping margins of 47.21% for Austria and 51.19%–54.74% for Taiwan.
Commerce initiated antidumping and countervailing duty investigations into certain wooden fence components from China, with alleged dumping margins ranging from 109.01% to 232.23%.

OFAC announced sanctions targeting two individuals alleging the use of fraudulent vessel registrations, flags, and certifications to support Iran’s shadow fleet and petroleum transportation.
OFAC sanctioned four individuals and 41 entities that support the business network of Prince Group Transnational Criminal Organization (TCO) previously sanctioned by the United States for its role in cyber-enabled fraud, money laundering, and human trafficking.
OFAC expanded sanctions under Executive Order 14404 to cover the electronics, manufacturing, marine, and technology sectors of Cuba’s economy. Foreign persons determined to operate or have operated in these sectors may be subject to U.S. sanctions.
OFAC issued an alert alert in support of Operation Economic Outcast to highlight the substantial risk of designation or penalties for providing services to vessels using false flags to evade U.S. sanctions on Iran.

The State Department announced sanctions targeting fraudulent ship registries and aviation support connected to Iran, as part of coordinated U.S. actions against sanctions-evasion networks.

U.S. Trade Representative Jamieson Greer announced that South Africa and Rwanda won’t be part of the African Growth and Opportunity Act trade preferences program next year, finding that the governments of these countries are engaging in practices that are inconsistent with AGOA’s eligibility criteria.

FDA posted new and revised Import Alerts on the detention without physical examination of:
- 99-41: Foods imported from foreign suppliers by importers not in compliance with the requirements of the Foreign Supplier Verification Program (FSVP) Regulation.
- 99-39: Imported Food Products that appear to be Misbranded.
- 99-05: Raw Agricultural Products for Pesticides.
- 53-06: Cosmetics that are Adulterated and/or Misbranded due to Color Additive Violations.

Acting CPSC Chairman Peter A. Feldman delivered keynote remarks at the 19th International Law Enforcement Intellectual Property Crime Conference outlining CPSC’s efforts to combat dangerous imports, strengthen criminal enforcement, and address trade fraud and counterfeiting.

House Representative Hakeem Jeffries, expected to be House speaker next year, wrote a letter to his colleagues, stating the House should vote to end the Trump tariffs in the first 100 days after Democrats take control of the House in January.
House Representative Val Hoyle introduced the Protecting American Hemp Farmers Act which would impose a 50% tariff on hemp products imported from China and create new mandatory testing requirements.

The Liberty Justice Center launched Operation Refund Rescue, a legal assistance initiative to help small importers seek IEEPA tariff refunds. The Center will file suit on the importer’s behalf for finally liquidated entries, seek a reliquidation order and offer guidance to the importers about the refund process.

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