International Business Archives | Customs & International Trade Law Blog

DHS Adds 43 Companies to the UFLPA Entity List, the Largest Expansion Yet

On July 31, 2026, the Department of Homeland Security, acting on behalf of the Forced Labor Enforcement Task Force (FLETF), announced the addition of 43 companies to the Uyghur Forced Labor Prevention Act (UFLPA) Entity List, along with technical updates to the official names of two entities already listed.

The New List

The revised list published as an appendix to a Federal Register notice on August 3, 2026, bringing the total to 187 entities, a roughly 30% increase, and the single largest expansion since the UFLPA took effect in 2022. The newly designated companies operate in DHS’s high-priority enforcement sectors, including aluminum, apparel, copper, cotton, and tomatoes and downstream products. Notably, a substantial share of the additions are headquartered outside the Xinjiang Uyghur Autonomous Region (XUAR), in provinces such as Shandong, Jiangsu, and Henan, which highlights that Entity List exposure is not a question of geography alone.

CBP’s UFLPA Authority

Under the UFLPA, U.S. Customs and Border Protection (CBP) applies the UFLPA’s rebuttable presumption under 19 U.S.C. § 1307 to goods mined, produced, or manufactured wholly or in part by any of the newly listed entities, and, critically, to downstream merchandise that incorporates their inputs. There is no de minimis threshold: a single component, raw material, or subassembly traceable to a listed company can support detention of an entire shipment.

To secure release, an importer must either show that the UFLPA […]

By Jennifer Diaz|2026-08-28T14:31:22-04:00August 28, 2026|Enforcement, International Business, International Law, news|Comments Off

FinCEN Permanently Ends BOI Reporting for U.S. Companies and U.S. Persons Under the Corporate Transparency Act

On August 11, 2026, the Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a final rule permanently removing the requirement for U.S. companies and U.S. persons to report beneficial ownership information (BOI) under the Corporate Transparency Act (CTA). FinCEN states that U.S. companies are now exempt from BOI reporting requirements and no longer need to file BOI reports. The final rule also relieves U.S. persons from providing BOI to reporting companies and from updating or correcting information previously submitted to obtain a FinCEN identifier. For many domestic businesses, this marks a significant compliance shift—but foreign entities registered to do business in the United States may still have BOI obligations.

What Changed?

FinCEN’s final rule makes permanent the relief first announced in the March 2025 interim final rule. Under the final rule, U.S. companies are exempt from BOI reporting requirements and therefore are no longer required to file BOI reports. Reporting companies also do not need to report BOI for U.S. person beneficial owners or U.S. person company applicants, and U.S. persons do not need to provide BOI to reporting companies.

FinCEN also announced that U.S. persons with FinCEN identifiers are not required to update or correct the information they previously submitted to FinCEN. This is important for individuals who filed BOI information before the rule changed and who otherwise may have expected ongoing update obligations.

Who Still Has BOI Reporting Obligations?

The final rule does not eliminate […]

By Jennifer Diaz|2026-08-14T11:56:45-04:00August 14, 2026|Enforcement, International Business, International Law, news|Comments Off

Five Tips for SMEs Looking to Scale Wellness Brands in the US

DTL President Jennifer Diaz was featured in Santander Navigator! Read below or on Santander here.

Pre-planning and investing in regulatory compliance measures are key to success

The US is the most lucrative wellness market in the world – and for some small and medium-sized enterprises (SMEs) that produce supplements, the potential for growth and a bigger bottom line is difficult to ignore.

And who would blame them? The US wellness sector is valued at US$2tn and is poised to continue growing, recording an average annual growth rate of 8.3% between 2019 and 2023, according to research by the Global Wellness Institute.

In contrast, China’s market, ranked the second-largest in the world, trails at a more modest US$870bn, followed by Germany at $310bn.

However, rushing in without being fully compliant could result in products being blacklisted or seized at the border, says Jennifer Diaz, an attorney and founding partner at Miami-based Diaz Trade Law, which specializes in customs and US Food and Drug Administration (FDA) laws and compliance.

Here, Diaz offers her top five tips for new brands to stay compliant and off the FDA’s blacklist.

1. Know the regulators

One of the first steps for SMEs planning to import supplements into the US is to register with the FDA, as they are considered a food product, Diaz says.

Companies also need to designate […]

By Jennifer Diaz|2025-06-17T08:40:04-04:00June 17, 2025|Best Practices, Import, Import Alert, International Business, International Trade, Labeling, Pre-compliance|Comments Off

Customs Bulletin Weekly, Vol. 56, November 16, 2022, No. 45

Below is a recap for this week’s Customs Bulletin.

African Growth and Opportunity Act (AGOA) Textile Certificate of Origin
- The African Growth and Opportunity Act (AGOA) was adopted by the U.S. with the enactment of the Trade and Development Act of 2000 (Pub. L. 106–200). The objectives of AGOA are (1) to provide for extension of duty-free treatment under the Generalized System of Preferences (GSP) to import sensitive articles normally excluded from GSP duty treatment, and (2) to provide for the entry of specific textile and apparel articles free of duty and free of any quantitative limits from eligible countries of sub-Saharan Africa.
- For preferential treatment of textile and apparel articles under AGOA, the exporter or producer is required to prepare a certificate of origin and provide it to the importer. The certificate of origin includes information such as name and address of the exporter, producer, and importer; the basis for which preferential treatment is claimed; and a description of the imported article(s). The importers are required to have the certificate in their possession at the time of the claim, and to provide it to Customs and Border Protection (CBP) upon request. The collection of this information is provided for in 19 CFR 10.214, 10.215, and 10.216.
- CBP invites the general public and other Federal agencies to comment on the proposed and/or continuing information collections pursuant to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). This proposed information collection was previously published in the Federal Register […]

By Jennifer Diaz|2022-11-17T09:53:38-05:00November 21, 2022|COVID-19, Federal Register, Import, International Business, International Law, International Trade, U.S. Court of International Trade, U.S. Customs and Border Protection (CBP), Uncategorized|Comments Off

Customs and Trade Law Weekly Snapshot

Here is a recap of the latest customs and international trade law news:

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By Jennifer Diaz|2022-12-25T23:20:09-05:00October 21, 2022|301 INVESTIGATIONS, International Business, International Trade, People's Republic of China, Russia, U.S. Bureau of Industry and Security (BIS), U.S. Customs and Border Protection (CBP), U.S. Department of Commerce (DOC), U.S. Department of Justice (DOJ), U.S. Department of Labor (DOL), U.S. Federal Bureau of Investigation (FBI), U.S. International Trade Commission (USITC), U.S. Office of Foreign Assets Control (OFAC), U.S. Trade Representative (USTR)|Comments Off

Customs and Trade Law Weekly Snapshot

Here is a recap of the latest customs and international trade law news:

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By Jennifer Diaz|2022-08-24T17:53:28-04:00August 26, 2022|Customs Expert, Food, International Business, International Law, International Trade, International Travel, U.S. Customs and Border Protection (CBP), U.S. Food and Drug Administration (FDA), Uncategorized|2 Comments

Complying with Russia-Related Sanctions?

As the U.S. government and the governments of many other countries continue to sanction Russia and Belarus for the Russian invasion into Ukraine, companies around the world are grappling with the consequences that comes with the escalating economic restrictions placed on conducting business in the region. Here at Diaz Trade Law we are working to keep you up to date on all relevant sanction activity and what it could mean for you and your business.

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By Jennifer Diaz|2022-03-07T18:03:26-05:00March 7, 2022|Countries, Export, International Business, International Law, International Trade, Supply Chain, U.S. Customs and Border Protection (CBP), U.S. Office of Foreign Assets Control (OFAC)|Comments Off

Virtual Currencies & U.S. Sanctions

Diaz Trade Law’s President, Jennifer Diaz, and Associate Attorney, Sharath Patil, are enthusiastic to announce that our article, “Virtual Currencies & U.S. Sanctions” was published by the Customs and International Trade Bar Association (CITBA) in its Winter 2021 newsletter.

Our article focuses on virtual currencies scrutiny under U.S. sanctions programs administered by the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) given the potential national security and foreign policy threats posed by their increasingly widespread use.

Below is the article for your reading pleasure.

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By Jennifer Diaz|2022-01-18T18:07:46-05:00January 19, 2022|Best Practices, Export, International Business, International Trade, U.S. Office of Foreign Assets Control (OFAC)|Comments Off

Don’t Let FDA Target Your Medical Device Company

Did you know FDA has issued 1,569 enforcement actions against medical device companies? Now is the time to ensure your medical devices are in compliance with FDA laws and regulations prior to importation. If your business is manufacturing, repackaging, relabeling, and/or importing medical devices into the U.S., or wants to start, our one-hour webinar on “Importing Medical Devices in Compliance with U.S. FDA” is for you. We will provide TOP tips to avoid U.S. Food and Drug Administration (FDA) enforcement action, and best practices to navigate and mitigate FDA enforcement.