Client Alerts

CARES Act Provisions to Benefit General Aviation

Client Alert

On March 25, 2020, the Senate passed the Coronavirus Aid, Relief, and Economic Security Act (CARES Act), a $2 trillion stimulus bill. The House of Representatives is expected to approve the legislation, and President Trump has indicated he will quickly sign the bill into law. In addition to general loan programs for small and mid-size […]

COVID-19 and Shelter in Place Orders

Client Alert

Several companies have inquired whether forwarders and customs brokers are prohibited from continuing to provide services during this period in view of various Shelter-In-Place orders issued by state or local agencies. To a certain extent, the answer to that will depend upon the wording of the specific order, so it would be prudent to review any […]

FTC Supports Expanding Advanced Practices Registered Nurses Authority But Raises Antitrust Concerns Over License Board Composition

Client Alert

The FTC recently weighed in on two significant pending healthcare bills advancing through the legislatures in Ohio and Kansas. Both pieces of legislation seek to expand the scope of practice of Advanced Practice Registered Nurses (APRNs), primarily by eliminating the requirements of collaborative practice agreements. Additionally and perhaps most notable, the proposed Kansas bill would […]

FMC Approves New Final Rules

Client Alert

New regulations that the FMC voted to approve January 15, 2020.  The new rules pertain to the actions of agents of NVOs and ocean forwarders.  If the requirements are not met, there is a possibility that both the agent and the licensed OTI may have liability for having violated the Shipping Act.   On January 15, […]

U.S. Department of the Treasury Removes Sanctions on Turkish Ministries and Officials

Client Alert

On October 23, 2019 the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) removed the Specially Designated National (“SDN”) designations on the Government of Turkey’s Ministries of National Defense and Energy, as well as the SDN designations on the Turkish Ministers of National Defense, Energy, and Interior.  On October 14, 2019, President […]

New OFAC Sanctions on Turkey

Client Alert

As you are likely aware, there has been recent news regarding the U.S. economic sanctions imposed on Turkey (i.e., the “Syria-related Sanctions”).  The Treasury’s press release is available here.  Based on our review of the new sanctions, here are some things to note for both US and foreign based forwarders that do business with Turkey. […]

Federal Maritime Commission to Issue New NPRMs

Client Alert

On September 26, 2019, the Federal Maritime Commission issued a Notice of a series of new notices of proposed rulemakings that have significant potential effect on OTIs and vessel operators. At this point, the actual NPRMs have not been issued, so it is not clear what issues are to be specifically addressed. Nevertheless, the press […]

STB Issues Final Offer Rate Review NPRM

Client Alert

On September 12, 2019, the Surface Transportation Board (“Board”) issued a Notice of Proposed Rulemaking that constitutes another attempt by the Board to increase the ability and willingness of captive rail shippers to seek review of rail rates through formal complaint proceedings before the Board.  Under this latest proposal, the Board would establish a Final […]

STB Announces Hearing on Revenue Adequacy Recommendations of the RRTF

Client Alert

On September 12, 2019, the Surface Transportation Board (“Board”) announced it will hold a public hearing on December 12, 2019 in an area of railroad policy that is extremely important to the STB’s regulation of railroad rates and the procedures for challenging them:  railroad “revenue adequacy.”   How “revenue adequacy” is determined by the Board and […]

STB Proposes Streamlined Approach for Pleading Market Dominance in Rate Reasonableness Proceedings

Client Alert

On September 12, 2019, the Surface Transportation Board (“Board’) issued a Notice of Proposed Rulemaking that would streamline the process by which a rail shipper demonstrates the Board has jurisdiction to review whether the shipper’s rates are reasonable because the railroad has “market dominance” over the transportation, i.e., no effective competition exists to discipline the […]

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