Jennifer Diaz, President, Diaz Trade Law

Amber Pirson, Attorney, Diaz Trade Law

FinCEN’s March 30, 2026, Notice of Proposed Rulemaking (NPRM) marks a major step toward fully operationalizing the agency’s whistleblower program, designed to incentivize reporting of Bank Secrecy Act (BSA), sanctions, IEEPA, and other illicit finance violations. The proposal outlines how whistleblowers can securely submit information, how awards will be determined, and what protections will be available.  

This development reflects the Treasury Department’s broader strategy to strengthen financial system integrity and encourage actionable tips that support enforcement efforts. For financial institutions, compliance professionals, and potential whistleblowers, the NPRM provides long‑awaited clarity on program structure and expectations. 

Overview of the Proposed Rule 

FinCEN’s NPRM proposes a comprehensive framework for administering whistleblower submissions and awards. Key elements include: 

• Secure submission procedures for individuals reporting suspected violations of the BSA, OFAC sanctions, and related laws. 
• Eligibility criteria for whistleblower awards, including documentation requirements and timelines. 
• Award ranges of 10–30% of monetary penalties collected when a whistleblower’s information leads to a successful enforcement action. 
• Robust protections for individuals who provide information, including confidentiality and anti‑retaliation safeguards. 

These provisions aim to encourage early, detailed reporting while ensuring whistleblowers are shielded from adverse consequences. 

Why FinCEN Is Prioritizing Whistleblower Incentives 

The NPRM aligns with Treasury’s broader efforts to combat fraud, sanctions evasion, and illicit finance. On the same day, FinCEN issued an advisory highlighting how transnational criminal organizations exploit federal and state health care programs—underscoring the need for timely, credible tips from insiders. Treasury Secretary Scott Bessent emphasized that whistleblowers play a critical role in protecting U.S. national security and ensuring taxpayer funds are not diverted to criminal activity. 

By formalizing award structures and protections, FinCEN seeks to increase the volume and quality of reports that can lead to enforcement actions. 

What Financial Institutions Should Know 

Financial institutions should closely review the NPRM and consider how it may affect internal compliance programs. Key considerations include… 

• Enhanced reporting expectations: Institutions may see increased whistleblower activity and should ensure internal reporting channels are well‑defined. 
• Documentation and recordkeeping: Detailed records may become even more important as whistleblower tips could trigger investigations. 
• Training and awareness: Employees should understand both internal reporting options and the existence of FinCEN’s external whistleblower portal. 

FinCEN encourages public comments within 60 days of the NPRM’s publication in the Federal Register. The official notice is available here. 

Whistleblowing and IEEPA 

While the proposed rule offers rewards for reporting fraud-related violations of IEEPA, it is unclear whether FinCEN will consider reports of unpaid IEEPA duties to be valid claims of fraud. Given the U.S. Supreme Court’s ruling, which determined that President Trump’s use of IEEPA to impose tariffs was unlawful, companies subject to such whistleblowing reports may have a strong claim of defense.   

Final Thoughts: Take Action Today! 

FinCEN’s proposed whistleblower framework represents a significant shift in how illicit finance violations may come to light. Financial institutions, compliance officers, and legal practitioners should proactively assess the NPRM’s implications and prepare for increased scrutiny and reporting activity. If your organization needs guidance navigating BSA/AML obligations, whistleblower‑related risks, or comment submission strategies, Diaz Trade Law is ready to assist with FinCEN compliance. 

Learn more: 

• DOJ Targets Trade Fraud: Importers Now on Notice as Criminal Division Ramps Up Enforcement 
• Bloomberg Law: Voluntary Self-Disclosures: Recent Guidance From BIS, OFAC & DOJ 
• BIS Issues Guidance to Financial Institutions on Best Practices for Compliance with the Export Administration Regulations 

The Court rejected the Trump Administration’s assertion that the statutory text of IEEPA delegates Congressional tariff powers to the President, finding that Congress would not have delegated “highly consequential power” through ambiguous language.

The majority wrote, “Based on two words separated by 16 others in … IEEPA, ‘regulate’ and ‘importation’–the President asserts the independent power to impose tariffs on imports from any country, of any product, at any rate, for any amount of time. Those words cannot bear such weight.”

The decision was 6-3, with Justice Thomas, Alito, and Kavanaugh dissenting.

What This Means for Importers

The Trump Administration has made clear that, regardless of the Supreme Court’s decision, tariffs will remain a cornerstone of their trade and “America First” policy. 

On January 9, 2026, National Economic Council Director Kevin Hassett said of the Supreme Court case: “Our expectation is that we’re going to win, and if we don’t win, then we know that we’ve got other tools that we can use that get us to the same place.” He also said in a Fox Business Interview that the Administration has a backup plan ready to go that would allow tariffs to be put “back into place almost immediately, should the Supreme Court rule against us.”

IEEPA is just one of the legislative avenues the Administration has to impose tariffs. Below is a summary of tariff tools available to the Administration.

The Administration will almost certainly pivot to another legal authority to maintain the current tariffs. 

Because the Supreme Court has upheld the Federal Circuit’s decision, the case is remanded to the Court of International Trade to determine whether it can issue a nationwide injunction, which we hope the Court of International Trade will resolve quickly.  

Importers who have filed suit at the Court of International Trade should be eligible to get their own injunction. Further, an individual injunction may not be required, given the Supreme Court decision. The key at this moment is how the Court of International Trade will implement the Supreme Court’s decision.  

We are confident that importers who have filed suit in the Court of International Trade should be eligible to receive refunds for the IEEPA Tariffs they paid. However, the Court of International Trade will need to provide specific instructions for issuing refunds. We are actively monitoring and will advise as soon as we have more information from the Court of International Trade.  

What Importers Should Do

Importers should view the current tariff environment as a long-term reality and proactively invest in strategies that legally minimize their duty exposure. There are several ways to LEGALLY minimize tariffs, including:

• Duty drawback
• Tariff engineering
• Country of origin change
• First sale
• Duty deferral
• Negotiate DDP Incoterms

Importers should also invest in compliance. The U.S. government has signaled that enforcement of trade law is a top priority and has levied hefty fines and even initiated criminal cases against importers evading duties.

Importers should:

• Conduct internal audits
• Refresh classification procedures
• Ensure the accuracy of valuation practices
• Revisit supplier agreements
• Tighten broker oversight
• Leverage technology
• Develop training for staff
• Strengthen recordkeeping practices
• Prepare for audits

Our office will continue to closely monitor and will keep you informed. Please review the following resources to stay informed on tariff updates and jumpstart your 2026 compliance program.

• Live Resource – Tariffs and Trade Deals
• Bloomberg Law: Tariff Classification Basics
• Bloomberg Law: Import Compliance & Training Programs
• Bloomberg Law: CBP’s Recordkeeping Requirements
• Navigating Tariff Increases: Strategies to Minimize Tariff Costs Under the Trump Administration
• Webinar: Navigating Tariff Challenges: Mitigation Tools & Tactics
• Webinar: IEEPA Tariffs, Supreme Court Developments, & Refund Implications

Diaz Trade Law can assist in auditing and/or developing importer compliance programs, setting up importer ACE accounts, and executing strategies to minimize duties. If you have questions about the IEEPA case or questions regarding any other import or export-related matter, please do not hesitate to contact our office at info@diaztradelaw.com.

Reporter Lori Ann LaRocco dives into the recent rise in customs bond insufficiency notices in her Feb. 6 article: President Trump’s tariffs fueled U.S. Customs bond market boom. Now billions hang on Supreme Court ruling.

Here are two excerpts from the piece:

“Jennifer Diaz, board-certified international attorney at Diaz Trade Law, said the number of bond insufficiency notices issued has quadrupled since 2017 and has accelerated recently due to the volatile tariff environment.”

“David Craven, counsel to Diaz Trade, said the threat of new replacement tariffs, coupled with the existing liability facing surety companies, suggests that any refunds would not be immediate. “The fact that liability has gone up, and Customs is now asking the sureties for collateral … operations are at risk, and sureties understandably don’t want to be caught holding the bag,” Craven said.”

Read the full article here.

Jennifer Diaz was also featured in a separate CNBC piece on Feb. 12: Trump tariffs leave importers with record-breaking $3.5 billion U.S. Customs bond funding shortfall.

Jen said:

“In totality, it makes sense that insufficiencies are more than double,” said Jennifer Diaz, attorney at Diaz Trade Law. “Many companies take it for granted that a $50,000 bond should be able to cover you for a one-year period,” she said. “But it might not. They are not utilizing set calculations, and don’t have anyone in their corner telling them that their bond obligation is higher.”

Read the full article here.

Extending 301 Exclusions

There are currently 178 effective exclusions in the Section 301 investigation of China’s acts, policies, and practices related to technology transfer, intellectual property, and innovation. These products are exempt from additional 301 duties. USTR has extended these exclusions several times, including a recent 90-day extension through November 29, 2025. USTR is seeking public comment on whether any of the 178 effective exclusions warrant further extension beyond November 29, 2025.

Comments are due October 16, 2025.

National Trade Estimate Report

Each year, USTR publishes the National Trade Estimate Report on Foreign Trade Barriers (NTE Report). USTR is seeking input to assist it in identifying significant foreign barriers to, or distortions of, U.S. exports of goods and services and U.S. foreign direct investment. 

Commenters should submit information related to one or more of the following categories of foreign trade barriers:

• Import policies
• Technical barriers to trade
• Sanitary and phytosanitary measures
• Government procurement
• Intellectual property protection
• Services
• Investment
• Subsidies
• Anticompetitive practices
• State-owned enterprises
• Other non-market policies and practices
• Labor
• Environment
• Other barriers

Comments are due October 30, 2025.

Joint Review of USMCA

Article 34.7 of the United States Mexico Canada Agreement (USMCA) requires government representatives from the three countries to meet on the sixth anniversary of the agreement (July 1, 2026) to conduct a Joint Review of the operation of the Agreement. Ahead of this meeting, the USTR is seeking input from the public and trade community in advance of the joint review. 

In particular, USTR invites comments regarding:

• Any aspect of the operation or implementation of the USMCA.
• Any issues of compliance with the Agreement.
• Recommendations for specific actions that USTR should propose ahead of the Joint Review.
• Factors affecting the investment climate in North America and in the territories of each Party
• Effectiveness of the USMCA in promoting investment that strengthens U.S. competitiveness, productivity, and technological leadership.
• Strategies for strengthening North American economic security and competitiveness.

Comments are due November 3, 2025.

Make your voice heard by filing a comment! Diaz Trade Law can assist you in preparing a filing and also help determine how these initiatives impact your business. Contact us at 305-456-3830 or info@diaztradelaw.com.

Read more:

• USTR Finalizes Action on 301 Tariffs
• White House Announces Further Section 301 Tariff Hikes on Chinese Goods
• Tariffs are Bad, So Are Non-tariff Barriers
• Bloomberg Law: USMCA Import Considerations for Practitioners

The Federal register notices are available here (UAS) and here (polysilicon).

BIS is specifically interested in the following information:

1. The current and projected demand for these products and the extent to which domestic production can meet this demand
2. The role of foreign supply chains, particularly of major exporters, in meeting United States demand 
3. The concentration of U.S. imports from a small number of suppliers and the associated risks
4. The impact of foreign government subsidies and predatory trade practices 
5. The economic impact of artificially suppressed prices due to foreign unfair trade practices and state-sponsored overproduction
6. The potential for export restrictions by foreign nations
7. The feasibility of increasing domestic capacity to reduce import reliance
8. The impact of current trade policies on domestic production and whether additional measures, including tariffs or quotas, are necessary to protect national security

The deadline to submit comments is August 6, 2025.

The investigations could result in new trade restrictions, including tariffs. If you import products covered under these investigations, make your voice heard by filing a comment.

Contact Diaz Trade Law for assistance in drafting comments and for help in determining how these investigations may impact your business. 

Learn more:

• BIS Releases New Edition of “Don’t Let This Happen to You”
• BIS Issues Final Rule on VSD Policies and Penalty Guidelines
• BIS Issues Guidance to Financial Institutions on Best Practices for Compliance with the Export Administration Regulations
• ICYMI: BIS Updates Boycott Requester List

301 Background

Section 301 of the Trade Act of 1974 is designed to address unfair foreign practices affecting U.S. commerce. It grants USTR a range of authorities to investigate unfair trade practices and to enforce U.S. rights under trade agreements.

Under 301, the U.S. government may impose trade sanctions on foreign countries that engage in acts that are burdensome to U.S. commerce or that violate trade agreements.

The law does not limit the scope of investigations, but it does mention several categories of activities that are subject to 301 action, including:

(1) a violation that denies U.S. rights under a trade agreement

(2) an “unjustifiable” action that “burdens or restricts” U.S. commerce

(3) an “unreasonable” or “discriminatory” action that “burdens or restricts” U.S. commerce.

“Commerce” is defined to include goods, services, and investment.

Previous examples of 301 investigations include investigations into China’s technology transfer practices, Vietnam’s currency manipulation, and Digital Services Taxes in various countries.

Nicaragua Investigation

The investigation into Nicaragua’s acts follows numerous credible reports that the Ortega-Murillo regime engages in human rights and labor rights violations and dismantling the rule of law. Activities cited by USTR include:

• Politically-motivated arrests and imprisonments
• Repression of members of religious groups and non-governmental organizations
• Extrajudicial killings
• Cruel, inhuman or degrading treatment
• Restrictions on freedom of expression and movement
• Violence against members of marginalized groups
• Repression of freedom of association and collective bargaining
• Forced labor, human trafficking, eliminating legislative and judicial independence
• Spurious seizures of property, arbitrary fines and rulings, and other harmful acts

According to USTR, the Government of Nicaragua has not responded to concerns raised by the United States or others. The stated goal of the investigation is to address and resolve these concerns to ensure U.S. companies and workers are treated fairly and with equal respect under a rule of law system.

USTR is seeking public comments on this matter, which are due January 8, 2025. The agency will also hold a public hearing on January 16, 2025.

Diaz Trade Law has extensive expertise in Section 301 matters. If you have questions about Section 301 investigations or would like to participate in this investigation, get in touch at info@diaztradelaw.com.

Learn more:

• Why Should Your Product Not Be on The 301 List
• USTR Targets Vietnam in 301 Investigation
• Section 301 Digital Services Taxes
• Know Your Supply Chain: Forced Labor
• Forced Labor Guidance: What Importers Need to Know
• Bloomberg Law: U.S. Customs Targets Use of Forced Labor

301 Investigation Background

In August 2017, USTR initiated an investigation into China’s acts, policies, and practices related to technology transfer, intellectual property, and innovation. The agency released a report of its findings in March 2018 and in June 2018 began imposing additional duties on products of China in four tranches.

Under the Trade Act of 1974, the USTR is required to conduct a four-year review if they receive an appropriate request to continue an action taken under Section 301. The agency is required to review:

• (A) the effectiveness in achieving the objectives of section 301 of (i) such action, and (ii) other actions that could be taken (including actions against other products or services), and
• (B) the effects of such actions on the United States economy, including consumers.

In accordance with this requirement, USTR announced in May 2022 that it was commencing this review and opened a docket for interested persons to submit comments.

The agency received nearly 1,500 comments. Throughout 2023 and early 2024, USTR and the Section 301 Committee (a USTR-led, interagency Trade Policy Staff Committee) held numerous meetings with agency experts to consider the comments received.

In May 2024, USTR issued a formal proposal in the Federal Register to increase tariffs on specific products in strategic sectors. The agency considered more than 1,100 public comments.

On September 18, 2024, the U.S. Trade Representative announced certain modifications to the actions taken in the Section 301 investigation including a list of subheadings eligible for consideration of temporary exclusion under an exclusion process for certain machinery used in domestic manufacturing.

Machinery Exclusions

This announcement sets forth the process to request exclusions for certain machinery used in domestic manufacturing. The exclusion process covers particular machinery used in domestic manufacturing classified within a subheading under chapters 84 and 85 of the Harmonized Tariff Schedule of the United States (HTSUS).  A list of eligible subheadings is available here.

The docket for submitting exclusions opened on October 15, 2024. The deadline for submitting exclusion requests is March 31, 2025.

Each request must identify a particular product, and provide supporting data and the rationale for the exclusion. USTR will evaluate each request on a case-by-case basis. USTR will accept exclusion requests on a rolling basis and will periodically announce decisions on pending requests.

What Importers Should Do

Importers can make their voices heard by filing an exclusion request with USTR. Diaz Trade Law can help prepare filings and assist importers in understanding how these exclusions may impact their business.

Contact Diaz Trade Law for assistance at 305-456-3830 or info@diaztradelaw.com.

Learn more:

• Upcoming Deadline to File Comments: USTRs Section 301 China Tariff Exclusions Proceeding
• White House Announces Further Section 301 Tariff Hikes on Chinese Goods
• ICYMI: USTR Announces Extension of Reinstated Section 301 Exclusions and COVID-Related Exclusions
• Webinar: Building and Maintaining an Effective Import Compliance Plan

301 Investigation Background

In August 2017, USTR initiated an investigation into China’s acts, policies, and practices related to technology transfer, intellectual property, and innovation. The agency released a report of its findings in March 2018 and in June 2018 began imposing additional duties on products of China in four tranches. 

Under the Trade Act of 1974, the USTR is required to conduct a four-year review if they receive an appropriate request to continue an action taken under Section 301. The agency is required to review:

• (A) the effectiveness in achieving the objectives of section 301 of (i) such action, and (ii) other actions that could be taken (including actions against other products or services), and
• (B) the effects of such actions on the United States economy, including consumers.

In accordance with this requirement, USTR announced in May 2022 that it was commencing this review and opened a docket for interested persons to submit comments. 

The agency received nearly 1,500 comments. Throughout 2023 and early 2024, USTR and the Section 301 Committee (a USTR-led, interagency Trade Policy Staff Committee) held numerous meetings with agency experts to consider the comments received. 

In May 2024, USTR issued a formal proposal in the Federal Register to increase tariffs on specific products in strategic sectors. The agency considered more than 1,100 public comments

Final Modifications

The modifications proposed in May 2024 were largely adopted.

Tariff increases will impact the following products:

• Battery parts (non-lithium-ion batteries) – Increase rate to 25% in 2024 
• Electric vehicles – Increase rate to 100% in 2024
• Facemasks – Increase rate to no less than 25% in 2024 
• Lithium-ion electrical vehicle batteries – Increase rate to 25% in 2024 
• Lithium-ion non-electrical vehicle batteries – Increase rate to 25% in 2026 
• Medical gloves – Increase rate to no less than 25% in 2026 
• Natural graphite – Increase rate to 25% in 2026 
• Other critical minerals – Increase rate to 25% in 2024 
• Permanent magnets – Increase rate to 25% in 2026 
• Semiconductors – Increase rate to 50% in 2025 
• Ship-to-shore cranes – Increase rate to 25% in 2024 
• Solar cells (whether or not assembled into modules) – Increase rate to 50% in 2024  Steel and aluminum products – Increase rate to 25% in 2024 
• Syringes and needles – Increase rate to no less than 50% in 2024 

Exclusions:

Solar manufacturing equipment – The final modifications include 14 temporary exclusions of wafer and cell manufacturing equipment from the 301 tariffs. The exclusions are retroactive and applicable to products imported on or after Jan. 1, 2024, and through May 31, 2025.

Machinery exclusions – In response to a directive from the President to establish a process by which interested persons may request that machinery used in domestic manufacturing be excluded, USTR added 312 subheadings to be eligible for consideration for temporary exclusions. 

What Importers Should Do

For importers impacted by additional duties it is crucial to know when the additional duties are effective and must be paid. We urge importers to clearly understand which duties their products are subject to and develop a business plan on how to prepare for additional import costs.

Contact Diaz Trade Law for assistance at 305-456-3830 or info@diaztradelaw.com.

Learn more:

• Upcoming Deadline to File Comments: USTRs Section 301 China Tariff Exclusions Proceeding
• White House Announces Further Section 301 Tariff Hikes on Chinese Goods
• ICYMI: USTR Announces Extension of Reinstated Section 301 Exclusions and COVID-Related Exclusions
• Webinar: Building and Maintaining an Effective Import Compliance Plan

The exclusions refer to additional duties imposed on goods from China pursuant to an earlier Section 301 investigation of China’s acts, policies, and practices related to technology transfer, intellectual property, and innovation.

In December 2022, the agency determined to extend the exclusions and extended them again in May 2023 and September 2023 through December 31, 2023. This latest Federal Register notice announces the agency’s determination to further extend the exclusions until May 31, 2024 and open up the ability to comment on the exclusions. The public docket will open on January 22, 2024 and will close on February 21, 2024.

This latest extension provides USTR additional time to orderly phase out certain exclusions and align others with the objectives determined during the agency’s ongoing four-year review of Section 301 China tariffs.

The agency also announced that it will open a docket to gather public comments on whether to further extend particular exclusions. The focus of the evaluation will be on:

• The availability of products covered by the exclusion from sources outside China
• Efforts undertaken to source products covered by the exclusion
• Why additional time is needed
• On what timeline, if any, the sourcing of products covered by the exclusion is likely to shift outside of China

USTR will also consider whether or not extending the exclusion will impact U.S. interests.

 Exclusion Background

In August 2017, USTR initiated an investigation into China’s acts, policies, and practices related to technology transfer, intellectual property, and innovation. The agency released a report of its findings in March 2018 and in June 2018 began imposing additional duties on products of China in four tranches. The USTR established a process by which U.S. stakeholders could request the exclusion of particular products subject to additional duties. Starting in November 2019, the agency invited public comments on whether to extend particular expulsions it had granted. Through this process, 352 exclusions have been extended.

 COVID Exclusions

In March 2020, USTR requested public comments on proposed modifications to exclude from additional duties certain medical-care products related to the U.S. response to COVID. USTR granted exclusions for 99 products. Throughout 2021 and 2022, USTR sought and evaluated public comments and extended 77 of the COVID-related exclusions through September 30, 2023.

 Statutory Four-Year Review

Under the Trade Act of 1974, the USTR is required to conduct a four-year review if they receive an appropriate request to continue an action taken under Section 301. The agency is required to review:

• (A) the effectiveness in achieving the objectives of section 301 of (i) such action, and (ii) other actions that could be taken (including actions against other products or services), and
• (B) the effects of such actions on the United States economy, including consumers.

In accordance with this requirement, USTR announced in May 2022 that it was commencing this review. The review is ongoing and there is no statutory deadline. U.S. Commerce Secretary Gina Raimondo has stated that she does not expect any revisions to the Section 301 duties until the four-year review is complete.

What Importers Should Do

Importers should continue to follow this review and prepare for revisions to the Section 301 duties. For importers being hit by additional duties it is crucial to know when the additional duties are effective and must be paid. We urge importers to clearly understand which duties their products are subject to and develop a business plan on how to prepare for additional import costs.

To make your voice heard, ensure you provide a comment to the USTR from January 22, 2024 to February 21, 2024.  Contact Diaz Trade Law for assistance writing and submitting an exclusion comment and/or for assistance understanding the next steps in the implementation of Section 301.

In December 2022, the agency determined to extend the exclusions and extended them again in May 2023 through September 30, 2023. This latest notice announces the agency’s determination to further extend the exclusions until December 31, 2023.

The announcement states that the goal of this most recent extension is “[t]o provide a transition period for the expiring exclusions and to allow for further consideration under the four-year review.” 

Exclusion Background

In August 2017, USTR initiated an investigation into China’s acts, policies, and practices related to technology transfer, intellectual property, and innovation. The agency released a report of its findings in March 2018 and in June 2018 began imposing additional duties on products of China in four tranches. The USTR established a process by which U.S. stakeholders could request the exclusion of particular products subject to additional duties. Starting in November 2019, the agency invited public comments on whether to extend particular expulsions it had granted. Through this process, 352 exclusions have been extended. 

COVID Exclusions

In March 2020, USTR requested public comments on proposed modifications to exclude from additional duties certain medical-care products related to the U.S. response to COVID. USTR granted exclusions for 99 products. Throughout 2021 and 2022, USTR sought and evaluated public comments and extended 77 of the COVID-related exclusions through September 30, 2023.

Statutory Four-Year Review

Under the Trade Act of 1974, the USTR is required to conduct a four-year review if they receive an appropriate request to continue an action taken under Section 301. The agency is required to review:

• (A) the effectiveness in achieving the objectives of section 301 of (i) such action, and (ii) other actions that could be taken (including actions against other products or services), and 
• (B) the effects of such actions on the United States economy, including consumers.

In accordance with this requirement, USTR announced in May 2022 that it was commencing this review. The review is ongoing and there is no statutory deadline. U.S. Commerce Secretary Gina Raimondo has stated that she does not expect any revisions to the Section 301 duties until the four-year review is complete.

What Importers Should Do

Importers should continue to follow this review and prepare for revisions to the Section 301 duties at the beginning of next year. For importers being hit by additional duties it is crucial to know when the additional duties are effective and must be paid. We urge importers to clearly understand which duties their products are subject to and develop a business plan on how to prepare for additional import costs.

Diaz Trade Law will continue to monitor these developments. For help in preparing for upcoming 301 changes, get in touch with us today.