Schulz Trade Tribune: September 12-19, 2025
- Schulz Trade Law
- Sep 22
- 3 min read
Schulz Trade Tribune: September 12-19, 2025
September 22, 2025
U.S.-Japan Trade Agreement in Effect
The International Trade Administration has announced that, effective September 16, 2025, certain portions of the U.S. Japan Trade agreement shall be enforced.
As a result, a baseline 15% tariff has been applied to most Japan-origin goods, along with certain exemptions for passenger vehicles, light trucks, civil aircraft, and parts thereof. Appropriate changes have been made to the Harmonized Tariff Schedule of the United States (HTSUS).
Please contact Michelle Schulz with questions.
DOJ: Georgia CEO Violates FCPA
On September 15, 2025, the U.S. Department of Justice (DOJ) announced the
conviction of Atlanco LLC’s CEO Carl Zaglin, for violations of the Foreign Corrupt
Practices Act (FCPA).
From March 2015 to November 2019, DOJ evidence shows Zaglin paid bribes and
laundered money to both Honduran government officials and U.S.-based third-party intermediaries, in order to secure $10 million worth of procurement contracts with a Honduran governmental entity.
Zaglin, Honduran government officials, and U.S.-based third-party intermediaries
attempted to conceal this scheme through the use of personal email accounts, coded and ambiguous language, and encrypted messaging applications.
Zaglin has since been convicted of FCPA and money laundering violations, along with conspiracy to commit acts thereof. As a result, the Georgia-based CEO could face a maximum penalty of 30 years in prison.
Please contact Mark Jenkins, Josh Rodman, or Kelly McCorkle with questions.
Section 232: Automobiles and Auto-parts Inclusion
On September 16, 2025, the U.S. Department of Commerce (Commerce) published an interim final rule that outlines the inclusion process of automobiles and auto-parts under Section 232.
The two-week comment period will begin on October 1, 2025, and will allow the
following entities to submit inclusion requests to the International Trade Administration:
domestic producers of automobiles;
domestic producers of automobile parts articles; or
any industry association representing one or more such producers.
Please contact Marina Mekheil or Matt Savage with questions.
Section 232: Steel and Aluminum Inclusion
Commerce has opened the two-week comment period for derivative aluminum and steel articles under Section 232. Those able to file an inclusion request must submit their request by September 29, 2025.
Please contact Marina Mekheil or Matt Savage with questions.
Additions to OFAC’s SDN List
On September 16, 2025, the Office of Foreign Assets Control (OFAC) added four
individuals from the United Arab Emirates (UAE), Iran, and Hong Kong to its Specially Designated Nationals (SDN) list. In addition, multiple entities from the UAE and Hong Kong were added to the SDN List.
The U.S. Department of Treasury identified the individuals’ and entities’ participation in Iranian “shadow banking” – which is the illicit use of financial facilitators to evade sanctions and provide benefits to Iranian governmental entities – as the rationale for OFAC’s additions to its SDN list.
Please contact Josh Rodman, or Kelly McCorkle with questions.
Schulz Trade Law’s Role in Supporting Clients
While these changes may feel overwhelming for companies operating within their respective global sectors, Schulz Trade Law PLLC actively tracks these developments and offers advice on how to mitigate risk, assess tariff exposure, and adapt your compliance strategies. Our team is here to provide timely, tailored support and, importantly, help you make the trade.
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