Controlled Goods Program

Persons who are registered with the Controlled Goods Directorate must notify the Minister of Public Services and Procurement of any actual or potential data breach within 3 days of discovery of the breach.  Since the requirement includes potential data breaches, Controlled Goods Registrants should report any hacking incidents, potential data breaches, employees taking company data,

Canadian companies whose business operations involve Controlled Goods must report changes to their Controlled Goods Directorate registration before an acquisition. This means that companies and their in-house and outside lawyers must ensure that the closing checklist includes the Controlled Goods Directorate reporting requirement. The due diligence checklist should also include questions about Controlled Goods registrations

There are many ways employers may run afoul of the anti-discrimination provisions in U.S. immigration law.  As a very clear starting point, the general rule for a long time has been and remains an employer may not make hiring, firing, or recruitment / referral decisions based on a worker’s citizenship status. However, there are notable

In March, there was a good deal of consternation in the general press trying to understand news that President Trump had overruled the actions of the Office of Foreign Assets Control (“OFAC”) to impose additional sanctions on North Korea. Beside the oddity of a President overruling actions by a part of the Executive branch after

Originally published by the Journal of Commerce in January 2019

One of the topics that consistently makes the top 5 in just about every survey of issues of concern to companies is the cost of regulatory compliance. This is true in large measure because the complexity of the issues covered by those regulations keeps increasing

Originally published by the Journal of Commerce in November 2018

One of the many frustrations facing international traders trying to import goods into the U.S. is whether or not they will be accepted as importer of record by Customs and Border Protection (“CBP”).   CBP established a program to deal with what it views as the

In the current tit for tat environment that overhangs international trade, below is an update regarding the 232 tariffs on steel and aluminum, the 301 tariffs related to China’s intellectual property rights and other business practices, and the 232 tariffs threatened on automobiles and parts.

Steel and Aluminum Tariffs:

As everyone by now knows,

Earlier today, March 8, 2018, President Trump signed two Presidential Proclamations, one dealing with additional tariffs on steel and the other with additional tariffs on aluminum. As has been widely reported in the general press, those rates are 25% on steel and 10% on aluminum. The only countries exempted are Canada and Mexico.

Steel articles

Originally published by the Journal of Commerce in December 2017

While Special Counsel Robert Mueller continues his investigation, the recent guilty plea entered by Trump former National Security Advisor Lt. Gen. Michael Flynn (Ret.) serves as a reminder that when you are interviewed by a law enforcement agent, you better be sure what you say

In the September 18, 2017 Federal Register notice (see 82 FR 43556) , U.S. Citizenship and Immigration made clear it will now routinely require those applying to enter the U.S. to provide social media handles. As such, the obvious starting point for these tips must be a reminder that Customs and Border Protection (“CBP”) officers