USMCA Updates and OFAC COVID-19 Guidance

Date: 04/21/2020

This trade bulletin summarizes important developments affecting international trade. 

USMCA Interim Implementing Instructions
COVID-19 or not the United States Mexico Canada agreement’s (USMCA) implementation date is fast approaching. The U.S. Customs and Border Protection has issued Interim Implementing Instructions to provide early guidance on the new requirements under the USMCA, including on claiming USMCA preferential treatment for goods. The Final Implementing Instructions will be released prior to the date the USMCA enters into force.

For the Interim Implementing Instructions click here. Don't hesitate to contact us with questions.
Procedures for the Submission of Petitions by North American Producers of Passenger Vehicles and Light Trucks

North American producers of passenger vehicles and light trucks may request an alternative to the standard staging regime for the rules of origin for automotive goods under the USMCA as outlined in a notice published by the Office of the United States Trade Representative on April 21, 2020 (link below). This would allow for longer period of transition and ensure compliance with the USMCA rules of origin. The alternative staging regime differs from the standard staging regime by providing additional time and a different phase-in of the new requirements. It provides an alternative to certain rules of origin requirements for passenger vehicles and light trucks and does not replace any other rules of origin or provisions of general applicability.

For the full Federal Register notice, click here.
OFAC Issues Sanctions Programs Guidance and COVID-19
On April 16, 2020, the Office of Foreign Assets Control (OFAC) published a detailed Fact Sheet that summarizes existing exemptions and authorizations to provide humanitarian assistance in the context of the Iran, Venezuela, North Korea, Syria, Cuba, and Ukraine/Russia-related​ sanctions programs.

OFAC advises financial institutions or other businesses affected by the COVID-19 global pandemic to reach out to OFAC as soon as practicable, if its experiencing delays in its ability to meet deadlines associated with regulatory requirements (e.g., filing blocking and reject reports within ten business days, reports required by general or specific licenses, etc.).

Voluntary Self-Disclosures: OFAC encourages persons to submit Voluntary Self-Disclosures to the email account ( rather than through physical mail. Please refer to OFAC’s Data Delivery Standards for detailed electronic submission guidance.

Important OFAC Contact Information
  • Blocking / Reject Reports: 202-622-2490 / 800-540-6322 or  
  • Administrative Subpoenas: Please contact the case officer identified on the particular administrative subpoena.
  • License Reports: 202-622-2480, ​or through the online licensing portal.
  • Requests for Reconsideration of a Listing as an SDN (Petitions): Please contact
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