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The Strait of Hormuz Reopens: Why the Global Supply Chain Won’t Recover Overnight The agreement to reopen the critical waterway is a major step forward, but a massive backlog of vessels and ongoing safety concerns mean supply chain relief will take weeks—if not months—to materialize. Summary While news of an agreement to reopen the Strait of Hormuz offers a glimmer of hope for global commerce, international trade experts warn that a return to normal operations is still far off. With over 500 ships stranded for months and critical safety measures like mine-sweeping still required, businesses must brace for continued shipping delays, inventory adjustments, and elevated freight costs in the near term. June 18, 2026 WBAP News Dallas/Ft. Worth The Logistical Logjam: 500 Ships and a Massive Backlog The physical reopening of the Strait of Hormuz is only the first step in a long, complex recovery process. Over the course of the months-long shutdown, a massive backlog of roughly 500 cargo vessels has accumulated, leaving trillions of gallons of oil and critical commercial goods stranded at sea. Clearing this bottleneck will require unprecedented coordination, and operations cannot resume overnight. Furthermore, the maritime environment remains hazardous. Before cargo ships can safely navigate the waterway, authorities must ensure that mines laid earlier this year are fully cleared. As Michelle Schulz noted during a recent interview on WBAP Radio, Dallas-Fort Worth: "It's going to take some time... Keep in mind that ships have been stuck for over 100 days, so beginning operations again is not going to be a quick fix. Assuming that an agreement is reached and that the Strait does open, there are many things that still need to be done. For example, clearing mines that were laid earlier on this year." Because of these safety imperatives, maritime tracking data suggests that it will take weeks, if not months, for the backlog to entirely dissipate and for standard shipping schedules to normalize. Shifting Strategies: How Importers and Exporters are Adapting The prolonged instability in the region has forced global businesses to fundamentally re-evaluate their supply chain resilience. Relying on a single, vulnerable transit route is no longer a viable strategy, leading many companies to explore alternative—and often much costlier—routes, such as circumnavigating the African continent. To mitigate ongoing delays and safeguard their operations, proactive importers and exporters are utilizing specialized customs and trade mechanisms to manage their cash flow and inventory. Michelle Schulz explained how companies are currently navigating these choppy waters: "Our clients are navigating how they're going to ship and the shipping routes. They've been exploring alternate routes and, in addition to that, experiencing delays... Some are looking at mechanisms like bonded warehouses, foreign trade zones, and there's actually no great solution, to be honest. There's no perfect solution. But companies are trying to do their best to strategize to minimize the damages on delays and extra expenses." Ultimately, these extended routes and strategic pivot points come with a price tag. Higher operational expenses and freight fees will continue to trickle down the supply chain, impacting both corporate bottom lines and retail consumers alike. Mitigate Your Trade Risks Navigating global supply chain disruptions requires proactive legal and logistical strategy. Whether you need to review your current shipping contracts, evaluate force majeure clauses, or leverage trade programs like Foreign Trade Zones (FTZs) and bonded warehouses to protect your inventory, Schulz Trade Law is here to help. Contact Schulz Trade Law Today to Schedule a Consultation Subscribe to Schulz Trade Law for more updates.

Navigating the Perfect Storm: How Tariffs and Supply Chain Crises Are Compounding for U.S. Importers The dual pressures of escalating trade barriers and the closure of the Strait of Hormuz are forcing businesses to rethink their global logistics strategies. Overview The international trade landscape has rarely been more volatile. Today, U.S. importers are facing a devastating "one-two punch": the sudden, indefinite disruptions in the Strait of Hormuz alongside rapidly shifting global tariffs. For small and mid-sized businesses, the financial strain of navigating these simultaneous crises is reaching a breaking point, making strategic legal guidance and supply chain adaptation more critical than ever. June 17, 2026 KNX News Los Angeles Stranded Cargo and the Drone Sweep Delay The current maritime crisis in the Middle East has left hundreds of commercial vessels in limbo. With standard shipping lanes effectively blocked or deemed unsafe, companies are facing unprecedented logistical gridlock. The source of the delay isn't just the initial disruption, but the highly technical and slow-moving safety operations required to clear the waters. As Michelle Schulz noted in a recent interview, the timeline for recovery remains incredibly uncertain: "Supposedly there were mines laid earlier on this year, and those mines have to be swept by underwater drones. So, ships and containers are somewhat at risk if if that hasn't been fully cleared. And shipping companies are cautious... they really haven't been many changes to their operations in the region because they don't know yet if it's safe, and they haven't seen a lot of improvement." With shipping companies hesitant to alter their operations without guaranteed safety, importers must prepare for extended inventory delays that could last for months. A Compounding Crisis: The One-Two Punch of Tariffs Logistical delays are only half of the battle. Businesses trying to reroute their goods or manage delayed arrivals are simultaneously being hit by volatile tariff policies. This creates an environment where long-term financial planning becomes nearly impossible, as costs rise on a daily basis. Schulz highlights how these overlapping issues are uniquely overwhelming for businesses right now: "And they're dealing with this and at the same time with tariffs that are escalating and changing every day. It's nearly unmanageable... Many of these clients did not see this coming, and so they're just dealing with multiple issues at the same time. They may have already relocated because of other trade issues, and now we have this issue in this part of the world. So, there's really no place that's safe. We have tariffs in virtually every country, and U.S. importers are paying those. So, it's kind of compounding. That's what I'm seeing is that it's compounding all of these issues." When geopolitical friction and fiscal policy collide, the traditional "safe harbors" for manufacturing and sourcing quickly vanish. The Small Business Breaking Point While multinational corporations often possess the capital reserves and extensive legal departments necessary to weather these systemic shocks, smaller enterprises are facing an existential threat. The margins required to absorb massive, unexpected operational overhead simply do not exist for many manufacturers and importers. The divide between corporate resilience and small business vulnerability is widening rapidly, as Schulz observed: "The clients that I've been working with are struggling. They can't absorb the costs, and especially the smaller businesses can't absorb the additional overhead, the additional tariffs that they're paying. In some cases, you know, 25%, 50%, they simply are struggling and may not make it." For these smaller entities, surviving the current trade climate requires aggressive cost-mitigation strategies, tariff classification reviews, and immediate compliance adjustments. Are Compounding Trade Issues Threatening Your Bottom Line? Navigating shifting tariffs and maritime disruptions requires more than just patience—it demands a proactive legal strategy. Whether you need to audit your tariff classifications, explore alternative sourcing destinations, or review force majeure clauses, Schulz Trade Law is here to help you protect your business. Contact Schulz Trade Law Today for a Comprehensive Strategy Consultation! Subscribe to Schulz Trade Law for more updates.

Scrapping the USMCA? Navigating the High Stakes of North American Trade Uncertainty Insights from Trade Attorney Michelle Schulz on the potential end of the landmark agreement and what it means for businesses. Overview Recent statements indicating a potential decision not to renew the United States-Mexico-Canada Agreement (USMCA) have sent shockwaves through the corporate landscape. In this post, international trade attorney Michelle Schulz breaks down the sudden shift in rhetoric, the severe logistical and financial threats facing U.S. importers, and the strategic pivots companies must prepare for as regional trade stability hangs in the balance. June 12, 2026 This Morning with Gordon Deal "Trump threatens to kill trade deal with Mexico, Canada" Host: Gordon Deal A Surprising Shift in Continental Trade Policy For over three decades, North American supply chains have relied on a predictable framework of regional cooperation. Beginning with the implementation of the North American Free Trade Agreement (NAFTA) in 1993, and later modernized through the USMCA in 2018, cross-border commerce has long been viewed as relatively stable. However, recent developments have suddenly disrupted that assumption, indicating that the entire agreement could be scrapped rather than renewed at its upcoming six-year milestone. While past negotiations pointed toward potential revisions or a shift toward individual bilateral agreements with Canada and Mexico, the prospect of dismantling the trade framework entirely comes as a stark surprise to the business community. As Michelle Schulz notes, "We're learning that the deal is not quite as set in stone as we may have thought... now he's saying, maybe we scrap the whole thing". Cited concerns over structural issues and drafting errors within the text have cast doubt on an agreement previously championed as a major legislative achievement, reminding businesses that continental trade status is never permanently set in stone. The Importers Facing the Hardest Hit If the USMCA is permitted to expire, the consequences will ripple across multiple industries, but U.S. importers will undoubtedly bear the heaviest burden. Countless domestic enterprises utilize the agreement on a daily basis to secure duty-free treatment on critical inputs, components, and finished goods flowing from Canada and Mexico. Without this legal framework, a massive volume of cross-border commerce would immediately become subject to standard tariffs, instantly spiking procurement costs. Schulz emphasizes the gravity of the situation for domestic businesses: "In my view, US importers... use the USMCA daily. We have routine importers that use USMCA to claim duty-free treatment on imports from Canada and Mexico... If this agreement didn't exist, it would be a huge logistical nightmare for companies in the United States". Forcing these deeply integrated, multi-step operations to navigate standard customs barriers without preferential trade status would bottleneck border logistics and disrupt just-in-time production schedules across the continent. From Automotive Parts to Agricultural Essentials The reliance on zero-tariff North American trade spans nearly every sector of the physical economy. The automotive and industrial machinery fields are particularly vulnerable, as they depend entirely on the steady flow of specialized components and car parts moving seamlessly between manufacturing hubs. Similarly, deep ties exist within agriculture and raw materials; the U.S. relies heavily on Canadian lumber, minerals, natural resources, and dairy, while closely co-developing textiles and consumer goods with Mexican partners. A prime example of this integrated ecosystem is the maquiladora business model in Mexico, which allows companies to utilize highly affordable manufacturing and assembly labor before returning the goods to domestic markets. Schulz warns that ending the agreement would completely disrupt these operations: "This would eliminate that entire business model. We would not be able to take advantage of the labor in Mexico. We would have to manufacture everything here, and it would become much more expensive". Prepare Your Supply Chain for Volatility In an environment where trade policy changes from day to day, standing still is a risk your business cannot afford. At Schulz Trade Law, we assist companies in auditing their current USMCA dependencies, modeling alternative tariff scenarios, and building agile logistics strategies to pivot on a dime. Contact our Dallas office today to review your cross-border operations and secure your supply chain against sudden regulatory shifts. Trade on, but trade informed! Subscribe to Schulz Trade Law for more updates.

The $165 Billion Question: Navigating the New Tariff Refund Landscape Michelle Schulz Discusses the Biden Administration's Recent Stance on U.S. Importer Refunds Overview Following the implementation of an automated refund system for U.S. importers, a complex political dynamic has emerged. While $165 billion in tariff refunds is legally owed to businesses, reports suggest the administration is pressuring firms to forgo these claims. Michelle Schulz, founder of Schulz Trade Law, joined WTMJ Radio to break down what this means for the trade community. April 28, 2026 Wisconsin's Afternoon News WTMJ Radio, Milwaukee Reporter: Julia Fello A System Built for Speed The U.S. Bureau of Customs and Border Protection has recently streamlined its processes to handle an unprecedented volume of tariff repayments. Through the Automated Commercial Environment (ACE), a new sub-system known as CAPE (Consolidated Administration and Processing of Entry) was designed to return funds to importers of record within a 60-to-90-day window. "It’s been interesting that the U.S. Bureau of Customs and Border Protection has actually built a system to repay businesses so quickly... they’ve developed an automatic system for refunds that is supposed to return the money to the importer of record within 60 to 90 days." — MICHELLE SCHULZ Political Pressure vs. Legal Entitlement Despite the legal framework entitling companies to these refunds, a new narrative is forming from Washington. Major news outlets report that the administration is discouraging firms from claiming their money, citing various political and economic justifications. "It sounds like now the President has responded by saying, 'You're entitled to those refunds, but if you don't take them, I will remember you.' And so, you get brownie points if you just don't take your money back." — MICHELLE SCHULZ The Economic Reality for Importers For many businesses, these refunds are not just bonuses but significant capital owed for overpaid duties. Choosing to forgo these funds to remain in the administration's "good graces" presents a difficult dilemma for corporate leadership. "To ask companies to just go ahead and not claim the money that they’re duly owed—it’s kind of like asking people not to claim their tax refund." — MICHELLE SCHULZ Is Your Business Owed Tariff Refunds? Navigating the intersection of trade law and federal policy requires expert guidance. Don't leave your capital on the table without understanding the full legal landscape. Contact Schulz Trade Law Today Trade on, but trade informed! Subscribe to Schulz Trade Law for more updates.

Strategic Partnership Article War in the Middle East Time to Review Your Company’s Force Majeure Clauses Guest Article by S. George Alfonso, The Law Offices of S. George Alfonso, PLLC. Presented with permission by the firm’s strategic partner Schulz Trade Law, PLLC. April 28, 2026 Download this Article Disclaimer: This article is strictly limited to the legal analysis of force majeure provisions and is not intended as a political statement. Our goal is solely to provide practical guidance to help businesses maintain operations and review their specific contract clauses. Summary This article outlines key issues facing U.S. and international businesses arising from the Israeli/U.S. war against Iran and its regional proxies, which has expanded into a broader Gulf (if not global) conflict. It also highlights the potential relief available through the invocation of contractual force majeure clauses in contracts, when and if possible. Evaluate your options for invoking force majeure and develop a strategy. Schulz Trade Law offers a library of Trade Law Resources. Download this article The Iran War Effects Far More than the Energy Supply Chain The Israeli/U.S. launch of “Operation Epic Fury” on February 28th initially concentrated risk on the Strait of Hormuz and the global energy supply chain related to that narrow channel of water. Iran’s rapid response - via drone and missile attacks—effectively shut down the Strait by triggering the withdrawal of insurance coverage for tankers who were seeking ingress or egress from through the Strait. This disruption amounts to a de facto embargo on over 20% of the world’s oil resources. However, the consequences extend far beyond fuel markets as petroleum is essential to manufacturing an almost innumerable amount of products, including plastics, textiles, cosmetics, and construction materials, with diesel fuel being essential for global logistics. As a result, the interruption of this supply chain has already and will continue to render performance by parties under countless commercial contracts as impracticable to even impossible around the world. Force Majeure Clause A Force majeure clause (often referred to as an “Act of God” clause) is (or at least should be) standard in all commercial contracts (U.S. and international), as this clause may provide for the delay or excuse of performance by a party for at least an amount of time (if not completely release the party from contractual obligations and compliance), when extraordinary events beyond a party’s control occur. These typically include both natural and human-made disruptions. To successfully invoke such a clause, the triggering event must make contractual performance impracticable, impossible, or illegal—at least temporarily. Depending on the contract’s terms, prolonged disruption may excuse performance in whole or in part. Acts of Nature: Natural events like hurricanes, tsunamis, tidal waves or pandemics. Acts of Man: Human-made events such as war, terrorist attacks, strikes, or tariffs. Key Limitations and Risks Regarding Force Majeure Clause As with all contractual issues or questions - when in doubt, read the directions. The specific Force Majeure language in a commercial contract will control in every instance, which is why it is critical to ensure that this language is concise, well drafted and clear, without ambiguities or inconsistencies. Common issues found in Force Majeure Clauses include: Notice Requirements: Most Force Majeure Clauses will require the party to specifically cite and to some degree timely identify the triggering event(s) which rendered contractual compliance to be impracticable, impossible, or illegal at that time. Some Force Majeure clauses impose a strict “use-it-or-lose-it” notice provisions requiring timely written notification after a triggering event. Failure to comply may waive the right to invoke the clause. Scope of Covered Events: The triggering event must either be explicitly listed or fall within a valid catch-all provision. Ambiguity increases the risk of dispute. Immediate Steps to Undertake After two months of sustained conflict in the Gulf, businesses should take undertake the following proactive steps in order to better prepare for potential disruptions and minimize the financial risks associated with this unpredictable regional conflict. Review Existing Commercial Contracts for Force Majeure Clause (If Any): Confirm whether or not there is a Force Majeure Clause in each commercial contract and assess whether current conditions may qualify and justify the invocation of the Clause under the specific terms of each commercial contract. Update Clauses for Future Contracts: When negotiating new contracts, consider the new risks and evolving geo-political realities to include in the language of the Force Majeure Clause. Renegotiate Existing Contracts: If possible (whether or not a Force Majeure Clause exists in a particular contract), businesses should explore renegotiating the existing contractual terms, in order to avoid formal disputes (whether a dispute could arise due to an absence of a Force Majeure Clause or regarding the drafted and controlling Force Majeure clause). Strategic Decisions and Potential Leverage in the Mere Threat to Invoke the Clause Invoking force majeure carries inherent litigation risk. In some cases, the credible threat of invocation may provide sufficient leverage to renegotiate terms without the need to actually trigger the Clause itself and thereby avoid potentially costly and long formal disputes in litigation or arbitration. A careful, contract-specific analysis is essential before taking action. Conclusion The widening Middle East conflict has far-reaching commercial implications well beyond the energy sector and that region of the globe. Businesses should immediately review their contractual obligations to determine whether force majeure relief is available and if so if it may be advisable to claim (or at least threaten to claim vis-à-vis all contractual parties). Proactive contract review—and, where necessary, revision through possible re-negotiations - will better position companies to manage risk, maintain flexibility, and protect against ongoing and future disruptions in this turbulent global economy. by S. George Alfonso Navigating international trade during a global conflict demands more than just legal knowledge—it requires strategic foresight. At Schulz Trade Law, in partnership with the Law Offices of S. George Alfonso, we help businesses interpret complex clauses in the context of current Middle East developments. Contact us to discuss how we can help you defend your interests and manage performance expectations under your most critical international contracts. S. George Alfonso founded The Law Offices of S. George Alfonso, PLLC over thirty years ago. He provides his unique brand of “Concierge Counsel” to both U.S. and international clients regarding commercial contract negotiations, as well as U.S. litigation and arbitration. Mr. Alfonso’s firm focuses on “Problem Solving” (dispute resolution) in a variety of commercial scenarios, including pre-litigation and arbitration, as well as during litigation and arbitration. The Law Offices of S. George Alfonso, PLLC is a Strategic Partner with Schulz Trade Law, PLLC, providing the firms’ respective clients with elite international trade, contract, and dispute resolution representation. Resource Library Learn more about Trade Law. We have a series of articles highlighting the key components of international trade and compliance. Contact Us Stay ahead of trade law changes! Contact us today for guidance on tariffs and regulations to safeguard your business.

Navigating the $166 Billion IEEPA Refund: Opportunity Amidst Obstacles The Mechanism is Live—But Is Your Business Ready for the Hurdles? Overview The federal government has officially opened the application portal for International Emergency Economic Powers Act (IEEPA) tariff refunds, placing an estimated $166 billion back within reach of American importers. While this marks a historic opportunity for liquidity and price stabilization, early reports from the field indicate that claiming these funds is anything but a "click-and-submit" process. From technical failures to regulatory delays, businesses must navigate a complex landscape to secure their payouts. April 23, 2026 NBC 5 KXAS, Dallas/Fort Worth Reporter: Vince Sims The Reality of the Refund Portal As the portal launched, the immediate surge in traffic created significant technical bottlenecks. For many importers, the excitement of the announcement was quickly met with the frustration of a system unable to handle the load. Ron Henderson, President of Varaluz, recently shared his experience with NBC 5, describing the process as a "rollercoaster." For companies that have had to rebrand tariff costs as "pricing strategies" to remain palatable to consumers, these refunds represent a vital chance to prevent further price hikes. However, Henderson notes that the primary challenge remains simply getting the government’s digital infrastructure to cooperate. Managing Expectations: The Timeline vs. The Reality While the official word suggests a turnaround time for refunds, industry experts advise a more cautious outlook. Michelle Schulz, founder of Schulz Trade Law PLLC, emphasizes that while the existence of a formal mechanism is "great news for people in the industry," the path forward will likely be paved with administrative friction. "Theoretically, it should take 60 to 90 days," Schulz explains. "I expect delays, though. There will be questions, and it may take more than that." Beyond the technical glitches, importers should be prepared for: Government Inquiries: Requests for additional documentation to verify "Importer of Record" status. Compliance Verification: A potential look-back at previous filings triggered by the refund request. Logistical Backlogs: As hundreds of thousands of claims hit the Customs and Border Protection (CBP) desks simultaneously. Strategic Takeaway for Importers The $166 billion is on the table, but it isn't "found money." It is a legal recovery process that requires precision. Importers should ensure their documentation is airtight before attempting to navigate the portal, as errors during the filing process could lead to more than just delays—they could trigger unwanted audits. Is your business prepared to claim its share of the IEEPA refunds? Don't let technical errors or documentation gaps leave your funds in the government's hands. Contact Schulz Trade Law PLLC today for a compliance review and expert guidance on navigating the refund process. Trade on, but trade informed! Subscribe to Schulz Trade Law for more updates.

Supreme Court Tariff Ruling: Who Actually Gets a Refund? The refund portal is open — but for most businesses and consumers, the path to recovering tariff costs is far more complicated than it looks. Overview When the Supreme Court struck down President Trump's emergency tariffs, many businesses assumed a refund was on the way. The federal government has since opened an application portal to process an estimated $127 billion in refunds — but trade law experts warn that eligibility is narrow, the process is complex, and the money may not flow where people expect. April 20, 2026 FOX 26 KRIV TV / Houston Interview shown on 117 Channels Reporter: Tom Zizka Refunds Underway The ruling set off a wave of anticipation across the business community. Major retailers — Walmart, Target, Nike, Kohl's, Costco, FedEx, and thousands of smaller importers — are among the more than 300,000 companies that brought goods into the United States under the now-invalidated tariffs. Walmart alone could be due as much as $10 billion in refunds, according to some Wall Street analysts. The government's online portal opened for applications, and while some users reported sluggish performance, it did not crash under the anticipated demand. Customs and Border Protection has indicated the review process will take 60 to 90 days. However, the legal picture is more complicated for businesses further down the supply chain. Under current trade law, only registered importers and licensed customs brokers are eligible to file refund claims. If your business purchased goods from an importer but did not directly pay the tariffs yourself, you likely have no legal right to file — regardless of how much those tariff costs affected your bottom line. Michelle Schulz, founder of Schulz Trade Law PLLC, underscores the risk for businesses that assumed a refund agreement was implied: "If you were a customer of the importer, you don't technically have a right to file a claim. And if you didn't have an agreement with the importer that you get a refund when they get a refund, you may not have a right to that claim. It can be a legal mess." Even for eligible importers who do receive refunds, there is no obligation to pass those savings on to consumers or business customers. Some companies have signaled they would lower prices; others are reserving judgment until the money arrives. And separately, a number of other tariffs unrelated to the Supreme Court ruling remain in effect — meaning the broader trade landscape is still very much in flux. Not Sure Where Your Business Stands? Let's Talk. Tariff refund eligibility is a nuanced area of trade law, and the window to act is limited. Whether you're a direct importer evaluating your claim or a business trying to understand your options, Schulz Trade Law PLLC can help you navigate the process with clarity and confidence. Contact us today for a consultation. Trade on, but trade informed! Subscribe to Schulz Trade Law for more updates.

Beyond the Blockade: Navigating the Economic Aftershocks of Global Trade Instability Michelle Schulz joins SiriusXM’s Road Dog Trucking to discuss the Strait of Hormuz, the "ACE" refund system, and the looming threat of a 2026 recession. Overview As military maneuvers intensify in the Strait of Hormuz and diplomatic tensions rise with our North American neighbors, the U.S. economy is entering a period of "choppy waters." In a comprehensive interview on Road Dog Trucking with Dan Ronen, international trade attorney Michelle Schulz detailed how these global disruptions are trickling down to the American consumer. From surging gas prices to the rerouting of shipping containers around the Cape of Good Hope, the "state of confusion" in global logistics is forcing many U.S. importers to fight for their survival. April 14, 2026 Road Dog Trucking SiriusXM Host: Dan Ronan, Senior Reporter at Transport Topics The Logistics Crisis and the Path to Recovery The conversation highlighted a critical shift in the trade landscape: the movement toward "near-shoring" is stalling due to instability within the USMCA, while the domestic trucking industry faces a significant dip in container volumes. Michelle emphasizes that for businesses to survive this volatility, they must move beyond traditional logistics and explore technical trade solutions like Foreign Trade Zones (FTZs) and bonded warehouses to manage rising costs. Perhaps most pressing for many businesses is the legal battle over tariffs. While many emergency tariffs have been deemed unconstitutional, Michelle warns that reclaiming those funds will be a marathon, not a sprint. "Getting the money back is going to be much harder than putting the money in. Customs typically drag their feet on refunds. The good thing about this is it is electronic and it is supposed to be automatic... but it will not be fast. I don’t expect it’ll be a quick turnaround." To facilitate this, Michelle advises importers to immediately utilize the Automated Commercial Environment (ACE) system to identify entries and begin the claim process, even as the government prepares for a "long, slow, litigious process." Secure Your Refunds and Future-Proof Your Supply Chain.  Whether you are navigating the complexities of the ACE refund system or looking to implement a Foreign Trade Zone to defer rising tariffs, expert guidance is your best defense. Contact Schulz Trade Law to connect with a technical expert who can help your company save money and stay compliant in a volatile market. Trade on, but trade informed! Subscribe to Schulz Trade Law for more updates.

Resource Article So You Want to Export Semiconductors Ashlyn Koenig Smith, Schulz Trade Law PLLC Feb 24, 2026 Download this Article Understanding the Regulatory Landscape  for Semiconductor Exports In 2024, the total export trade value of semiconductors reached $70.1 billion, making it one of the largest exporting industries in the U.S. It propels much of modern technology and plays an important role in the global economy. As such, we will discuss three U.S. agencies that may exercise authority over semiconductor transactions: the U.S. Department of State Directorate of Defense Trade Controls (DDTC), the U.S. Department of Commerce Bureau of Industry and Security (BIS), and the U.S. Department of the Treasury Office of Foreign Assets Control (OFAC). The DDTC administers the International Traffic in Arms Regulations (ITAR), BIS administers the Export Administration Regulations (EAR), and OFAC administers economic and trade sanctions. We’ll explore each agency’s export authority, its licensing requirements and process, and potential violations under each. Although this is not a comprehensive list of the agencies that may be involved in semiconductor transactions, nor is it legal advice, understanding these agencies will help you navigate this complex process. Navigate Export Regulations with Confidence Schulz Trade Law  offers a library of Trade Law Resources. Download this article ITAR The first question to ask is whether or not the semiconductor or its technical data is listed on the United States Munitions List (USML). The USML lists items and activities pertinent to national security that pertain to defense and aerospace. It's comprised of twenty-two categories, such as Category IX: Military Training Equipment and Training, and Category XII: Fire Control, Laser, Imaging, and Guidance Equipment. Both of these categories specifically mention semiconductors. However, this list is not exclusive, and other categories may also apply. Licensing Process If a semiconductor or its technical data is listed on the USML, then it is subject to the ITAR, which means that any entity that manufactures, brokers, exports, or reexports is required to register with the DDTC . To do so, exporters must first sign up for a DECCS account here . However, registration alone does not grant export privileges. When a license is required, typically, one must apply for an export license or other authorization through the governing agency. The online registration process is recommended; however, if one’s application includes sensitive information,  a hard copy may be submitted instead. Violations ITAR violations may subject companies and individuals to civil and criminal penalties. As of January 2026, civil penalties may result in fines of $1 million+ per violation and debarment, which means the violator is prohibited from directly or indirectly participating in the exportation of defense articles and services. Criminal penalties may also result in fines of $1 million+ per violation, and/or twenty years’ imprisonment per violation, and debarment. BIS BIS has regulatory jurisdiction over items and activities subject to the EAR. 15 CFR § 734.3 specifically lists the items over which the agency has authority, which mostly pertain to items and technologies that have dual commercial and military use.  Although a license is not required for every transaction subject to the EAR, BIS maintains strict policies concerning the exporting and reexporting of semiconductors, having strengthened restrictions on semiconductor exports in December 2024. It is therefore essential to confirm if/when a semiconductor transaction requires licensing before exporting.  To determine if BIS requires a license for an export transaction, the first step is to determine whether the item is listed under the Commerce Control List (CCL) , which is organized into ten categories. To determine if an item is subject to the CCL and which category applies, consult the Export Control Classification Number (ECCN). If it is classified under an ECCN, reference the Commerce Country Chart to determine if its designated category requires licensing for a particular country.  As an example, ECCN 3B001 concerns “Equipment for the manufacturing of semiconductor devices, materials, or related equipment, as follows (see List of Items Controlled) and “specially designed” “components” and “accessories” therefor.”  An item classified as 3B001.c.1.a is controlled for National Security (NS) and is subject to Worldwide control, which means it requires a license regardless of its destination. Again, this is only one example and is not meant to advise on specific licensing processes. Additionally, the ECCN is subject to change, so just because a product isn’t currently classified under the CCL doesn’t mean that it won’t be there in the future.  In some cases, an item on the CCL may be eligible for a license exception . See 15 CFR § 740. Some exceptions may include, but are not limited to: Shipments of limited value (LVS), Technology and software under restriction (TSR), Encryption commodities, software, and technology (ENC), and License Exception Strategic Trade Authorization (STA). If a transaction qualifies, an exporter must properly document the license exception symbol along with the ECCN and keep records of the transaction in accordance with 15 CFR § 762. Exceptions are only valid when properly claimed. However, even if the item does not fall under the CCL, it may still require licensing, depending upon its end-use or end-user. Furthermore, BIS maintains a Denied Persons List (DPL) , which details entities that are denied export privileges. Exporters must screen potential transactions against the DPL to ensure export compliance in accordance with the EAR. Licensing Process If a semiconductor transaction requires licensing via BIS according to 15 C.F.R. § 730-774, exporters can apply for such licensing via the SNAP-R portal .  The status of an application can be tracked via STELA . Violations While ensuring export compliance may require companies to incur additional costs, in the long run, it can curb hefty fines and serious penalties that may result from export violations. According to the Export Control Reform Act of 2018, an EAR violation may result in penalties “of up to 20 years of imprisonment and up to $1 million in fines per violation, or both.”  OFAC OFAC regulatory jurisdiction typically relates to economic sanctions against countries, individuals or groups. Economic sanctions vary depending on the country or persons they target, but may prohibit transactions within certain sectors of a country's economy. For instance, since March 31st, 2022, E.O 14024 prohibits any significant transactions involving Russia’s electronics sector, which specifically includes semiconductors.  A comprehensive list of OFAC-sanctioned entities and the types of sanctions said entities are subject to can be found here.  Notably, OFAC does not maintain a specific country list, as those subject to such sanctions may change locations and/or conduct business in places one would not expect. Therefore, exporters must stay up-to-date on OFAC’s sanction list when determining license requirements from the agency to export semiconductors to a specific entity.  Additionally, one agency's policy change does not necessarily mean that another agency changed its policy as well. For instance, on January 13, 2026, BIS issued a rule that stated the agency will now review export licenses for semiconductors such as Nvidia H200, AMD MI325X, and similar chips destined for China on a case-by-case basis. Previously, such transactions were subject to a presumption of denial. However, even if the new policy applies to a transaction, export compliance due diligence still requires exporters to ensure an item is not destined for an OFAC-sanctioned entity. In other words,  do not assume export compliance simply because a transaction is compliant with one agency.  Licensing Process If a semiconductor transaction requires a license from OFAC, exporters can apply for such licensing here  via the agency's online portal. In the application, provide detailed, fact-based information as to the purpose of the transaction and why it requires licensing. After the application is submitted, it can be tracked through that same portal. Violations As of January 2026, those who violate the International Emergency Economic Powers Act (IEEPA), the Trading With the Enemy Act (TWEA), and any other OFAC sanctions  may be subject to maximum civil penalties per violation as follows: IEEPA Violations:  $377,700 or twice the amount of the underlying transactions. TWEA Violations:  $111,308. Since a transaction may be subject to both OFAC sanctions and the EAR, it may require licensing from more than one agency. Therefore, a transaction can violate more than one agency's license requirements and, as such, may result in penalties from multiple agencies. For instance, according to an April 2023 press release via OFAC, BIS and OFAC ordered Microsoft to pay a total of $3.3 million in combined penalties for allegedly violating the EAR and OFAC sanction regulations. Conclusion In short, DDTC regulates transactions subject to the ITAR, while BIS regulates transactions subject to the EAR, and OFAC regulates transactions with sanctioned entities. Throughout the semiconductor transaction process, exporters are required to conduct thorough due diligence regarding the product's application, end use, and end user to determine if the transaction requires a license from a particular agency to export or re-export. Remember, just because an item requires a license to export through one agency does not mean that a license through another agency is not required as well.  Even though ensuring export compliance may require additional time, money, and resources, it can prevent lengthy legal proceedings and/or massive fines that may arise from export violations. For further assistance in navigating semiconductor exports, contact one of the experienced trade attorneys at If you’re ready to navigate the semiconductor export landscape effectively, reach out to our knowledgeable team today! For further assistance, contact one of the trade attorneys at Schulz Trade Law PLLC Sources U.S. Department of State Directorate of Defense Trade Controls (DDTC) Link to DDTC website U.S. Department of Commerce Bureau of Industry and Security (BIS) Link to BIS website U.S. Department of the Treasury Office of Foreign Assets Control (OFAC) Link to OFAC website International Traffic in Arms Regulations (ITAR) Link to ITAR regulations Export Administration Regulations (EAR) Link to EAR regulations Economic and Trade Sanctions Link to economic sanctions information Resource Library Learn more about Trade Law. We have a series of articles highlighting the key components of international trade and compliance. Contact Us Stay ahead of trade law changes! 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Energy in Crisis: How the Conflict in Iran is Reshaping Global Trade Expert insights from Michelle Schulz on surging oil prices, insurance standstills, and the ripple effect on American consumers. Overview The intensifying conflict with Iran has sent shockwaves through the global economy, pushing crude oil prices past $100 a barrel for the first time in four years. With approximately 20% of the world’s oil supply flowing through the Strait of Hormuz , the halt of tanker traffic has created a supply bottleneck that threatens to drive up costs across nearly every sector of the U.S. economy —from transportation and manufacturing to the price of groceries. March 9, 2026 Local News Live Gray Media/TV Host: Stetson Miller The Logistics of a Standstill In a recent interview with Gray Media’s Local News Live , Michelle Schulz, founder of Schulz Trade Law, explained that the primary driver behind the sudden halt in traffic isn't just the physical conflict, but the collapse of the necessary financial and insurance infrastructure that allows global trade to function. As shipping lanes become combat zones, the cost of risk becomes prohibitive. Michelle noted the immediate impact on the maritime industry: "There was a risk that those ships would come under attack from Iran, and as soon as it seemed to become a reasonable possibility, insurers like, you know, Lloyds of London, insurers refused to insure the ships going through. And that basically stopped traffic in its tracks." This interruption is more than a logistical hurdle; it is a catalyst for broader inflation. Because oil and gas are foundational to modern industry, the spike at the pump is only the beginning. As Michelle emphasized during the segment, "Those prices are going to go up, and they will make other prices go up." Navigate Global Volatility with Confidence. In an era where geopolitical shifts can disrupt your supply chain overnight, proactive legal strategy is essential. Contact Schulz Trade Law  to discuss how we can help you mitigate risk and maintain compliance during times of global crisis. Trade on, but trade informed! Subscribe  to Schulz Trade Law for more updates.

The Billion-Dollar Wait: Navigating Post-Ruling Tariff Refunds Why recent legal victories for Texas importers may face a long, complex road to actual reimbursement. Overview Following a landmark U.S. Supreme Court ruling that more than $126 billion  in emergency tariffs were collected illegally, the U.S. Court of International Trade has ordered the administration to begin refunds. While U.S. Customs and Border Protection aims to begin processing these claims within 45 days, legal experts warn that the process will be neither swift nor simple. March 9, 2026 " Texas businesses could wait years for tariff reimbursements — if they come at all — despite court rulings . " Publication: Houston Public Media PBS / NPR The Challenge of Recovery While the judicial path has cleared, the administrative hurdles remain significant. Importers must weigh the benefit of a refund against the potential for increased government scrutiny. Michelle Schulz , a Dallas-based trade attorney, highlights a critical risk for businesses entering the refund system: "They will have a system whereby they’ll refund your money. The problem is, Customs is also going to be looking in that same system to see if you made any mistakes, and they can go back five years." - Michelle Schulz As the administration signals potential shifts toward new 15% global tariffs under different statutes, the actual long-term impact of these hard-won refunds remains to be seen. Protect Your Compliance Record While Seeking Redress. Navigating the refund process requires a clean five-year audit trail to avoid unexpected liabilities. Contact Schulz Trade Law today  to review your records before you file for reimbursement. Trade on, but trade informed! Subscribe  to Schulz Trade Law for more updates.

Navigating the Ripple Effects: Global Trade and the Iran Conflict The Hidden Costs of Disruption in the Strait of Hormuz Overview The current tensions in the Middle East have sent tremors through the global supply chain, extending far beyond the gas pump. As conflict disrupts one of the world's most critical maritime arteries—the Strait of Hormuz —importers and exporters face a complex landscape of rising costs and logistical hurdles. International trade attorney Michelle Schulz recently joined This Morning with Gordon Deal  to break down what this means for businesses and consumers alike. March 6, 2026 This Morning with Gordon Deal Gordon Deal Show Host: Gordon Deal While energy prices often dominate the headlines during Middle East (Iran) conflicts, the economic impact is much broader. The Strait of Hormuz is a vital transit point for a significant portion of the world's petroleum and liquefied natural gas. However, as Michelle Schulz points out, the "ripple effect" hits manufacturing and consumer goods almost immediately. The Plastic and Production Squeeze The cost of raw materials is intrinsically linked to energy stability. Because plastics are derived from petroleum and natural gas, any disruption in the Strait quickly translates to higher production costs for everything from household goods to industrial components. "Plastics are based around oil or natural gas. Heating, air conditioning, cooking—all that stuff gets more expensive when there's a shortage... anything surrounding the oil and gas industry is also going to be impacted." — Michelle Schulz Logistics and the "Plan B" Reality For companies moving goods through the region, the choice is often between high-risk transit or expensive, time-consuming detours. Safety concerns for personnel and cargo are forcing many to implement secondary logistics strategies, such as rerouting around the Cape of Good Hope. "They have to consider whether they will wait, whether it's safe for their personnel to go in those areas... they're having to reroute, and they have different routes that they pursue. They do have to make longer hours for pilots, extra jet fuel... you'll see higher shipping bills." — Michelle Schulz The Shifting Regulatory Landscape Beyond physical logistics, the legal and regulatory environment is equally volatile. Sanctions and political instability can change the viability of trade agreements and export licenses overnight, requiring businesses to be more agile than ever. "Depending on the political situation, you may or may not get your license approved. That can change from day to day... We will definitely change our advice to clients depending on the situation at the time." — Michelle Schulz Is Your Supply Chain Prepared? In a global economy, local conflicts rarely stay local. Whether you are dealing with increased shipping bills, licensing delays, or the need for alternative sourcing, having a robust legal and logistical strategy is essential. Don't wait for the next disruption to secure your trade routes.   Contact Schulz Trade Law today to review your export licenses and develop a resilient "Plan B" for your global operations. Trade on, but trade informed! Subscribe  to Schulz Trade Law for more updates.