US–China Trade Daily Hightlights | 2026-09-11

1) Executive Summary

Seven events are covered today, led by the U.S. International Trade Commission (ITC) and the Department of the Treasury’s Office of Foreign Assets Control (OFAC). The ITC scheduled the final phase of antidumping and countervailing duty (AD/CVD) investigations on citric acid and certain citrate salts. OFAC published SDN List updates and multiple sanctions-related general licenses under Iran, Venezuela, Nicaragua, Global Terrorism, and Illicit Drug Trade programs. Key policy instruments include AD/CVD proceedings, sanctions listings/updates, and general licenses authorizing time-limited wind-down activities.

2) Updates by Authority

ITC (U.S. International Trade Commission)

Citric acid and certain citrate salts — AD/CVD (TRADE_REMEDY)

The ITC scheduled the final phase of investigations Nos. 701-TA-783-784 and 731-TA-1771-1772 (Final) to determine whether a U.S. industry is materially injured or threatened with material injury by imports of citric acid and certain citrate salts. The proceedings concern imports from China preliminarily determined by Commerce to be subsidized and sold at less-than-fair-value, and imports from Canada preliminarily determined to be subsidized but not sold at less-than-fair-value.

  • Authority: INTERNATIONAL TRADE COMMISSION
  • Policy Type: AD_CVD
  • Event Type: TRADE_REMEDY
  • China Indicator: EXPLICIT
  • Key identifiers: Investigation Nos. 701-TA-783-784 and 731-TA-1771-1772 (Final)
  • Key dates: Staff report (nonpublic) due Dec 28, 2026; Hearing Jan 12, 2027; Requests to appear due Jan 6, 2027; Prehearing briefs due Jan 5, 2027; Posthearing briefs due Jan 20, 2027; Additional information placed on record Feb 2, 2027; Final comments due Feb 4, 2027

Source:
https://lawyerfanzhang.com/citric-acid-and-certain-citrate-salts-from-canada-and-india-scheduling-of-the-final-phase-of-countervailing-duty-and-antidumping-duty-investigations/

OFAC (Office of Foreign Assets Control, U.S. Department of the Treasury)

SDN List updates and removals — Sanctions Listing (SANCTIONS)

OFAC published updates to identifying information for one or more persons on the Specially Designated Nationals and Blocked Persons (SDN) List. OFAC also announced one or more persons whose property and interests in property were unblocked and removed from the SDN List.

  • Authority: DEPARTMENT OF THE TREASURY, Office of Foreign Assets Control
  • Policy Type: SANCTIONS_LISTING
  • Event Type: SANCTIONS
  • Key dates: OFAC determined on June 11, 2026, that certain persons were unblocked and removed from the SDN List
  • Key identifiers: Specific parties are listed in the notice

Source:
https://lawyerfanzhang.com/notice-of-ofac-sanctions-actions-16/

Iran-related General Licenses CC and DD — Sanctions Listing (SANCTIONS)

OFAC published Iran-related General License (GL) CC authorizing, through 12:01 a.m. EDT on September 19, 2026, transactions ordinarily incident and necessary to the wind down of dealings with specified blocked persons pursuant to E.O. 13902. OFAC also published GL DD authorizing, through 12:01 a.m. EDT on September 23, 2026, certain wind down transactions previously authorized under 31 CFR 560.522, 560.529, and Iran GL J-1.

  • Authority: DEPARTMENT OF THE TREASURY, Office of Foreign Assets Control
  • Policy Type: SANCTIONS_LISTING
  • Event Type: SANCTIONS
  • Key dates: GL CC issued Sept 4, 2026; GL DD issued Sept 8, 2026; GL CC valid through Sept 19, 2026; GL DD valid through Sept 23, 2026
  • Key identifiers: GL CC covers Golden Global Yatirim Bankasi A.S., Golden Global Varlik Kiralama A.S., Golden Global Portfoy Yonetimi A.S., and entities owned ≥50% by them; GL DD references ITSR 31 CFR 560.522, 560.529, and Iran GL J-1

Source:
https://lawyerfanzhang.com/publication-of-iran-related-web-general-licenses-cc-and-dd/

Venezuela GLs 50A and 51A — Sanctions Listing (SANCTIONS)

OFAC published GL 50A authorizing transactions related to oil or gas sector operations in Venezuela for entities listed in the annex (and their subsidiaries), with conditions on governing law, payment routing, and reporting, and prohibitions on specified counterparties. OFAC also published GL 51A authorizing certain activities involving Venezuelan-origin minerals, including gold, by established U.S. entities, with due diligence, payment, reporting conditions, and explicit exclusions, including processing/refining in specified jurisdictions.

  • Authority: DEPARTMENT OF THE TREASURY, Office of Foreign Assets Control
  • Policy Type: SANCTIONS_LISTING
  • Event Type: SANCTIONS
  • China Indicator: IMPLICIT
  • Key dates: GL 50A issued Feb 18, 2026 (replaced GL 50); GL 51A issued Mar 27, 2026 (replaced GL 51)
  • Key identifiers: GL 50A annex entities include BP PLC, Chevron Corporation, Eni S.p.A., Etablissements Maurel & Prom SA, Repsol S.A., Shell PLC; GLs include prohibitions on transactions involving persons in or entities owned/controlled by persons in specified jurisdictions

Source:
https://lawyerfanzhang.com/publication-of-venezuela-sanctions-regulations-web-general-licenses-50a-and-51a/

Venezuela GLs 30B and 51 — Sanctions Listing (SANCTIONS)

OFAC published GL 30B authorizing transactions ordinarily incident and necessary to operations or use of ports and airports in Venezuela involving the Government of Venezuela and INEA (and its majority-owned entities), subject to limitations. OFAC also published GL 51 authorizing specified activities involving Venezuelan-origin gold for importation, refining in the United States, and resale/export by established U.S. entities, with conditions on contracting, payments, reporting, and exclusions, including restrictions related to certain jurisdictions.

  • Authority: DEPARTMENT OF THE TREASURY, Office of Foreign Assets Control
  • Policy Type: SANCTIONS_LISTING
  • Event Type: SANCTIONS
  • China Indicator: EXPLICIT
  • Key dates: GL 30B issued Feb 10, 2026 (replaced GL 30A); GL 51 issued Mar 6, 2026
  • Key identifiers: GL 30B references E.O. 13884 and E.O. 13850 (as amended); GL 51 includes reporting requirements and limitations on counterparties and activities

Source:
https://lawyerfanzhang.com/publication-of-venezuela-sanctions-regulations-web-general-licenses-30b-and-51/

Nicaragua GL 5 — Sanctions Listing (SANCTIONS)

OFAC published GL 5 authorizing the wind down of transactions involving Exportadora de Metales Sociedad Anonima (EMSA) and entities it owns 50% or more, through 12:01 a.m. EDT on May 16, 2026. Payments to blocked persons must be made into a blocked account in accordance with the Nicaragua Sanctions Regulations.

  • Authority: DEPARTMENT OF THE TREASURY, Office of Foreign Assets Control
  • Policy Type: SANCTIONS_LISTING
  • Event Type: SANCTIONS
  • Key dates: GL 5 issued Apr 16, 2026; Valid through 12:01 a.m. EDT May 16, 2026
  • Key identifiers: EMSA and its ≥50%-owned entities

Source:
https://lawyerfanzhang.com/publication-of-nicaragua-sanctions-regulations-web-general-license-5/

Global Terrorism and Illicit Drug Trade GL 35 — Sanctions Listing (SANCTIONS)

OFAC published GL 35 authorizing wind down transactions, through 12:01 a.m. EDT on May 14, 2026, involving three entities designated on April 14, 2026: Comercializadora y Arrendadora de Mexico, S.A. de C.V. (CAMSA), Casino Centenario, and Diamante Casino, including their majority-owned entities. Payments to blocked persons must be made into a blocked account under applicable regulations.

  • Authority: DEPARTMENT OF THE TREASURY, Office of Foreign Assets Control
  • Policy Type: SANCTIONS_LISTING
  • Event Type: SANCTIONS
  • Key dates: GL 35 issued Apr 14, 2026; Expires 12:01 a.m. EDT May 14, 2026
  • Key identifiers: CAMSA; Casino Centenario; Diamante Casino

Source:
https://lawyerfanzhang.com/publication-of-global-terrorism-sanctions-regulations-and-illicit-drug-trade-sanctions-regulations-web-general-license-35/

3) Key Takeaways (Factual)

  • The ITC scheduled the final phase of AD/CVD investigations on citric acid and certain citrate salts, with hearings and filing deadlines set through early 2027.
  • OFAC issued multiple sanctions-related publications, including SDN List updates and a series of general licenses across Iran, Venezuela, Nicaragua, and counterterrorism/illicit drug trade programs.
  • Several general licenses provide time-limited wind-down authorizations with specific payment routing, reporting, and due diligence requirements.
  • Venezuela-focused GLs (50A, 51A, 51) include restrictions on transactions involving specified jurisdictions and counterparties, with explicit or implicit references to limitations involving persons in the People’s Republic of China.
  • Publication dates and validity periods are specified for each license, with several replacing and superseding prior versions.

4) Full Source Links (Index)

5) Legal Disclaimer

This article includes content collected and summarized from publicly available U.S. government materials, including the Federal Register (federalregister.gov). The content presented is not an official government publication and does not represent the views of any U.S. government authority.

This article is provided for informational and research purposes only and does not constitute legal advice, compliance advice, or recommendations for any specific entity or transaction. Readers should refer to the original official documents and consult qualified professionals before making decisions based on this information.