Joiner Law Firm PLLC

Joiner Law Firm PLLC Joiner Law Firm has extensive experience representing companies based in the U.S. and abroad on a wide range of international trade compliance matters.

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In furtherance of the President’s May 8, 2018 decision to withdraw from the Iran nuclear deal, OFAC has officially revok...
06/28/2018

In furtherance of the President’s May 8, 2018 decision to withdraw from the Iran nuclear deal, OFAC has officially revoked Iran-related General Licenses H and I. Specifically, OFAC has issued two new general licenses authorizing the wind down, through August 6, 2018, of transactions previously authorized under General License I, and the wind down, through November 4, 2018, of transactions previously authorized under General License H. More details and related FAQs can be found on OFAC’s website.

Today, in response to requests for additional time, the U.S. Department of Commerce announced that it is extending the c...
06/21/2018

Today, in response to requests for additional time, the U.S. Department of Commerce announced that it is extending the comment period for the May 30, 2018 notice which requested comments regarding the effects on national security of imports of automobiles and automotive parts. Comments and requests to appear at the public hearings were originally due by June 22, 2018, but will now be accepted until June 29, 2018. Additionally, the rebuttal period has been extended to July 13, 2018.

Today, the Office of the U.S. Trade Representative (USTR) published a notice announcing the imposition of an additional ...
06/20/2018

Today, the Office of the U.S. Trade Representative (USTR) published a notice announcing the imposition of an additional ad valorem duty of 25 percent on certain products from China that have an approximate annual trade value of $34 billion, effective July 6, 2018. The administration is still accepting comments and will hold a public hearing on whether the duty will be imposed on additional products with an approximate trade value of $16 billion. This coincides with the administration’s plan to impose a tariff of $50 billion on goods imported from China containing industrially significant technology.

Last week, Secretary of Commerce Ross announced that ZTE Corporation and ZTE Kangxun Telecommunications Ltd. (collective...
06/11/2018

Last week, Secretary of Commerce Ross announced that ZTE Corporation and ZTE Kangxun Telecommunications Ltd. (collectively, “ZTE”) have agreed to severe additional penalties and compliance measures to remove the BIS denial order imposed as a result of ZTE’s violations of its March 2017 settlement agreement. ZTE must pay $1 billion and place an additional $400 million in suspended penalty money in escrow before BIS will remove ZTE from the Denied Persons List. These penalties are in addition to the $892 million in penalties ZTE has already paid to the U.S government under the March 2017 settlement agreement. ZTE must also retain a team of special compliance coordinators selected by and answerable to BIS for a period of 10 years and replace the entire board of directors and senior leadership for both entities.

Yesterday, OFAC issued Ukraine-/Russia-related General License 16.  General License 16 authorizes U.S. persons to engage...
06/05/2018

Yesterday, OFAC issued Ukraine-/Russia-related General License 16. General License 16 authorizes U.S. persons to engage in specified transactions related to winding down or maintaining business involving EN+ Group PLC, JSC EuroSibEnergo, or any entity in which EN+ Group PLC or JSC EuroSibEnergo owns, directly or indirectly, a 50 percent or greater interest, until Oct. 23, 2018.

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06/05/2018

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Today, OFAC issued Ukraine-/Russia-related General License 15 which authorizes U.S. persons to engage in specified trans...
05/22/2018

Today, OFAC issued Ukraine-/Russia-related General License 15 which authorizes U.S. persons to engage in specified transactions related to winding down or maintaining business with GAZ Group and its subsidiaries until Oct. 23, 2018. OFAC also issued Ukraine-/Russia-related General License 12C, which replaces and supersedes General License 12B in its entirety. General License 12C permits originating and intermediary U.S. financial institutions to process funds transfers (that they would otherwise block) to an account held by a blocked U.S. person at a U.S. financial institution. It also clarifies that U.S. financial institutions can release such funds for authorized maintenance and wind-down purposes. Lastly, OFAC posted six new FAQs and revisions to existing FAQs about these general licenses.

Today, President Trump signed an Executive Order to further prohibit Venezuelan-related transactions. Among other restri...
05/21/2018

Today, President Trump signed an Executive Order to further prohibit Venezuelan-related transactions. Among other restrictions, today’s Executive Order prohibits persons in the U.S. from purchasing any debt or collateral owed to the government of Venezuela. This order follows sanctions imposed in March and is in response to Venezuelan President Nicolás Maduro’s victory and second term in an election that U.S. officials classify as corrupt and in direct opposition to democratic order.

State, Commerce Issue Proposed Rules Transferring Certain Cat. I, II & III Items from USML to CCLThis week, the U.S. Dep...
05/16/2018
Joiner Law Firm PLLC - State, Commerce Issue Proposed Rules Transferring Certain Cat. I, II & III Items from USML to CCL 5.15.18

State, Commerce Issue Proposed Rules Transferring Certain Cat. I, II & III Items from USML to CCL

This week, the U.S. Department of State posted a proposed rule that would amend the International Traffic in Arms Regulations to revise Categories I (firearms, close assault weapons and combat shotguns), II (guns and armament) and III (ammunition and ordnance) of the U.S. Munitions List (USML) to describe more precisely the articles warranting export and temporary import control on the USML. Read more: https://bit.ly/2rRfXwC

This week, the U.S. Department of State posted a proposed rule that would amend the International Traffic in Arms Regulations to revise Categories I (firearms, close assault weapons and combat shotguns), II (guns and armament) and III (ammunition and ordnance) of the U.S. Munitions List (USML) to de...

Joiner Law Firm joins the U.S., the world’s largest importer and exporter of goods and services, to celebrate World Trad...
05/15/2018

Joiner Law Firm joins the U.S., the world’s largest importer and exporter of goods and services, to celebrate World Trade Month during the month of May. This month-long celebration is to highlight and promote companies that export goods and services around the world. As a business whose mission is to serve, educate, and empower global organizations through ethics and compliance, we are always willing and able to celebrate global trade and the people and businesses who make it possible.

All that we are and all that we hope to be can be attributed to a mother’s love. Joiner Law Firm wishes a very happy Mot...
05/11/2018

All that we are and all that we hope to be can be attributed to a mother’s love. Joiner Law Firm wishes a very happy Mother’s Day to all of the selfless and loving mothers in our lives and yours.

Today, Pres. Trump announced that the U.S. will withdraw from the Iran nuclear deal and will begin re-imposing the U.S. ...
05/08/2018
Joiner Law Firm PLLC - U.S. Withdraws from Iran Nuclear Deal 5.8.18

Today, Pres. Trump announced that the U.S. will withdraw from the Iran nuclear deal and will begin re-imposing the U.S. nuclear-related sanctions that were lifted pursuant to the Iran nuclear deal. The Departments of State and Treasury will take steps necessary to establish a 90-day and a 180-day wind-down period for activities involving Iran that were consistent with the U.S. sanctions relief afforded under the Iran nuclear deal.

Read More: https://bit.ly/2I8MvsC

Pres. Trump announced today that the U.S. will withdraw from the Iran nuclear deal (officially, the Joint Comprehensive Plan of Action or JCPOA) and will begin re-imposing, following a wind-down period, the U.S. nuclear-related sanctions that were lifted pursuant to the JCPOA. The Departments of S....

Today, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) extended for another six months the...
04/27/2018

Today, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) extended for another six months the authorization that generally permits U.S. persons to engage in transactions with certain sanctioned Belarusian entities (including petrochemical conglomerate Belneftekhim). The new general license authorizing these transactions under certain conditions is effective until October 30, 2018. The previous general license was set to expire on April 30th.

Today, OFAC, in consultation with the State Department, designated seven Russian oligarchs and 12 companies they own or ...
04/06/2018

Today, OFAC, in consultation with the State Department, designated seven Russian oligarchs and 12 companies they own or control, 17 senior Russian government officials, and a state-owned Russian weapons trading company and its subsidiary, a Russian bank. The Treasury Department stated that the actions target a number of individuals listed in its CAATSA Section 241 report (released in late January 2018). OFAC concurrently issued two general licenses to minimize immediate disruptions to U.S. persons, partners, and allies, as well as related FAQs.

As part of the U.S. response to China’s unfair trade practices, the Office of the U.S. Trade Representative (USTR) publi...
04/04/2018

As part of the U.S. response to China’s unfair trade practices, the Office of the U.S. Trade Representative (USTR) published a proposed list of products imported from China that could be subject to additional tariffs. This follows President Trump’s announcement in March 2018 that the United States would impose tariffs on $50 billion worth of Chinese imports and take other actions in response to China’s policies that require U.S. companies to transfer their technology and intellectual property to Chinese firms. The USTR stated that sectors subject to the proposed tariffs include industries such as aerospace, information and communication technology, robotics, and machinery. The USTR also confirmed that the proposed list will undergo further review in a public notice and comment process, including a hearing, prior to the release of the final list.

President Trump recently announced a sweeping new trade action – which he called “the first of many” – to increase tarif...
03/22/2018

President Trump recently announced a sweeping new trade action – which he called “the first of many” – to increase tariffs on Chinese goods as a result of unfair practices that may be harming U.S. intellectual property rights, innovation and technology development. The United States Trade Representative (USTR) must publish within 15 days a proposed list of Chinese products and that will be subject to tariff increases. According to a fact sheet, the list will include products from the aerospace, information and communication technology, and machinery industries. After a public comment period, the USTR will publish a final product list with increased tariff amounts. Read more: https://bit.ly/2Gh92pC

The Department of Commerce has issued an interim final rule establishing the requirements for seeking exclusion from, an...
03/20/2018
Client Alert: Commerce Implements Process for Seeking Exclusion From New Steel and Aluminum Tariffs

The Department of Commerce has issued an interim final rule establishing the requirements for seeking exclusion from, and objecting to the granting of an exclusion request for, the recently-announced tariffs on steel and aluminum imports. These new tariffs – which amount to 25% for steel and 10% for aluminum – will take effect on March 23, 2018. Exclusion requests can only be submitted by individuals and organizations that use certain steel and aluminum articles in business activities located in the U.S., while objections to exclusion requests can be submitted by any individual or organization in the U.S. http://bit.ly/2psdAQl

The Department of Commerce has issued an interim final rule establishing the requirements for seeking exclusion from, and objecting to the granting of an exclusion request for, the recently-announced tariffs on steel and aluminum imports resulting from the recent investigation under Section 232 of t...

Today, the Treasury Department announced that it will adjust its civil monetary penalties for inflation, as mandated by ...
03/16/2018

Today, the Treasury Department announced that it will adjust its civil monetary penalties for inflation, as mandated by the Federal Civil Penalties Inflation Adjustment Act of 1990. The final rule will adjust civil monetary penalties within the jurisdiction of certain components of the Treasury Department (including OFAC) to the maximum amount required by law. The statutory maximum civil penalty for a violation of the International Emergency Economic Powers Act (IEEPA) is now the greater of $295,141 or twice the amount of the underlying transaction. The statutory maximum civil penalty for the Trade with the Enemy Act (TWEA) has been adjusted to $86,976.

Today, OFAC published several updates related to the Countering America’s Adversaries Through Sanctions Act (CAATSA), in...
03/15/2018
Joiner Law Firm PLLC - OFAC Posts Several CAATSA-Related Updates 3.15.18

Today, OFAC published several updates related to the Countering America’s Adversaries Through Sanctions Act (CAATSA), including amended Cyber General License No. 1A (GL 1A) in connection with the designation of the Federal Security Service (aka FSB) under CAATSA; four updated FAQs relating GL 1A; one updated CAATSA-related FAQ; and additional CAATSA/Russia-related Designations. OFAC stated that the changes to Cyber General License No. 1 (regarding the FSB) are limited to adding CAATSA authorities. http://bit.ly/2DuTFoa

Today, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) published several updates related to the Countering America’s Adversaries Through Sanctions Act (CAATSA), including amended Cyber General License No. 1A (GL 1A) in connection with the designation of the Federal ...

Following through on an announcement made last week, President Trump signed presidential proclamations imposing 25 perce...
03/08/2018

Following through on an announcement made last week, President Trump signed presidential proclamations imposing 25 percent tariffs on imports of steel, and ten percent tariffs on aluminum; however, the President exempted Canada and Mexico from the tariffs (for now) and has also “left open an avenue for potentially modifying or removing a tariff under certain conditions for individual countries.” The proclamations also provide a mechanism for U.S. parties to apply for exclusion of specific products based on demand that is unmet by domestic production or on specific national security considerations. The tariffs become effective on March 23, 2018.

Today, on International Women’s Day, and every day, Joiner Law Firm stands with those who #PressForProgress for gender i...
03/08/2018

Today, on International Women’s Day, and every day, Joiner Law Firm stands with those who #PressForProgress for gender inclusivity and gender parity. Though research tells us that gender parity is over 200 years away, it is important to take action daily to promote the advancement and equality of women. #IWD2018

Trump Announces Tariff Increases for Steel, Aluminum Imports During a recent meeting with industry executives, President...
03/02/2018

Trump Announces Tariff Increases for Steel, Aluminum Imports

During a recent meeting with industry executives, President Trump announced that he will be signing trade measures that would institute stiff new tariffs on imports of steel and aluminum. The measures, which arise from the recently completed investigation under Section 232 of the Trade Expansion Act of 1962, will result in 25 percent tariffs on imports of steel, and 10 percent tariffs on imports of aluminum. Trump is expected to formally sign the new trade measures in the coming weeks.

Today, OFAC announced new North Korea-related sanctions aimed at disrupting North Korean shipping and trading companies ...
02/23/2018

Today, OFAC announced new North Korea-related sanctions aimed at disrupting North Korean shipping and trading companies and vessels. The sanctions target one individual, 27 entities and 28 vessels.

Yesterday, OFAC published two new Venezuela-related FAQs to provide additional guidance on the debt-related prohibitions...
02/13/2018

Yesterday, OFAC published two new Venezuela-related FAQs to provide additional guidance on the debt-related prohibitions in Executive Order (E.O.) 13808, including the meaning of “new debt” for purposes of E.O. 13808 and the receipt of certain late payments from the Government of Venezuela (including Petroleos de Venezuela, S.A.).

The U.S. Department of State announced that it will request comments from the public to inform its review of the control...
02/09/2018

The U.S. Department of State announced that it will request comments from the public to inform its review of the controls implemented in recent revisions to Categories V, X, and XI of the United States Munitions List (USML). The State Department periodically reviews USML categories to ensure that they are clear, do not inadvertently control items in normal commercial use, account for technological developments, and properly implement the national security and foreign policy objectives of the United States. The U.S. Department of Commerce’s Bureau of Industry and Security (BIS) will also seek public comments to perform a complementary review of items on the Commerce Control List.

Today, the U.S. Department of State announced that it is implementing restrictions on the export of defense articles and...
02/02/2018

Today, the U.S. Department of State announced that it is implementing restrictions on the export of defense articles and defense services into South Sudan in response to the continued violence and humanitarian crises there. The State Department confirmed that it will amend the International Traffic in Arms Regulations (ITAR) to update the defense trade policy toward South Sudan, specifically, by applying a policy of denial, with limited exceptions, on the export of defense articles and defense services to South Sudan, including to all parties involved in the conflict. The U.S. is currently seeking support for a UN Security Council embargo on arms flows into South Sudan.

Ashley Moore, an Associate Attorney at Joiner Law Firm, was recently appointed by the U.S. Secretary of Commerce to serv...
02/01/2018
Houston District Export Council

Ashley Moore, an Associate Attorney at Joiner Law Firm, was recently appointed by the U.S. Secretary of Commerce to serve as an official member of the Houston District Export Council (HDEC). The mission of HDEC is to help foster U.S. economic growth and create American jobs by stimulating and facilitating the export of goods and services from companies located in Southeast Texas. For more information about HDEC, please visit www.houstondec.org.

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January 24, 2018 Today, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned nine en...
01/24/2018

January 24, 2018 Today, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned nine entities, 16 individuals, and six vessels as part of an ongoing effort to thwart North Korea’s ongoing development of weapons of mass destruction (WMD) and continued violations of UN Security Council Resolutions. Treasury Secretary Mnuchin stated that pursuant to these UN resolutions, the U.S. is targeting “illicit actors in China, Russia, and elsewhere who are working on behalf of North Korean financial networks, and calling for their expulsion from the territories where they reside,” as well as sanctioning more oil, shipping, and trading companies that continue to help fuel North Korea’s nuclear pursuits and destabilizing activities

Today, the U.S. Department of State published a correction to its Jan. 3, 2018 notice announcing adjustments to civil mo...
01/19/2018

Today, the U.S. Department of State published a correction to its Jan. 3, 2018 notice announcing adjustments to civil monetary penalties for regulatory provisions maintained and enforced by the State Department. Specifically, the State Department revised the civil penalty amount for 22 CFR 127.10(a)(1)(ii) – part of the International Traffic in Arms Regulations (ITAR) – from "$808,458," to read “$824,959, or five times the amount of the prohibited incentive payment, whichever is greater.” The correction is effective today.

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