My Supplier Changed Its Name. Do I Still Need to Screen the Old One for Sanctions?

What happened

• The supplier: On May 30, 2023, OFAC sanctioned Youli Technology Development Co., Ltd., a Chinese maker of pill press and packaging equipment, under its illicit drug trade program. The SDN List entry included Youli's phone number and email. Youli then renamed itself Huizhou Youli Fushi Co., Ltd. Its phone number and email stayed the same.
• The order: In August 2023, a U.S. nutritional supplement company hired Pegasus Worldwide Logistics, a California freight forwarder of about a dozen people, to bring in a $5,950 sugar packet-filling machine from Youli. The buyer had used Youli and Pegasus before.
• The screening miss: The shipping documents carried the new name and the old phone number. Pegasus checked only the new name against the SDN List, got no match, and filed the Importer Security Filing. Its own written policy said to screen name, address, email, and phone. OFAC says a basic internet search of the other identifiers would have found Youli.
• The warning it ignored: CBP detained the machine at Long Beach on November 3, 2023, with a notice naming OFAC. Pegasus did not look further and paid the $1,463.55 duty and fee invoice anyway. CBP seized the machine on December 6, 2023.
• The subpoena: Pegasus told OFAC in February 2024 that it had no responsive records, then corrected its answer six months later. OFAC counted six separate reporting violations for that.
• The result: A base penalty of $205,900, settled at $175,015. OFAC called it non-egregious and not voluntarily disclosed, and Pegasus must hire an outside consultant and report to OFAC for an extended period.

My take on this

The forwarder paid the fine, but the buyer lost the machine. If you are the importer, your forwarder's screening is your exposure too. And notice the timing: Pegasus screened just before the machine left China, after it had already emailed the sanctioned supplier. Screening belongs at the purchase order, not at the dock.

OFAC's own words: name screening "is a baseline tool." A sanctioned company that changes its name usually keeps something else, a phone number, an email, an address, a bank account. That is what you screen.

Procurement Action

• Screen every new supplier by name, former names, address, phone, and email before the first purchase order.
• Ask your freight forwarder and broker, in writing, what identifiers they screen and when.
• Treat any CBP detention notice that names OFAC as a stop-work order until compliance clears it.

OFAC enforcement release (PDF): Pegasus Worldwide Logistics settles with OFAC for $175,015 (October 9, 2026). Announcement: OFAC recent actions, October 9, 2026

Does It Matter Which Factory in Mexico Made My Part?

What happened

• One plant, not one country: On October 8, 2026, USTR invoked the USMCA Rapid Response Labor Mechanism against GLM Components Mexico, S.A. de C.V., an auto-parts plant in Puebla.
• The hold: USTR directed Treasury to suspend liquidation of unliquidated entries of goods from that facility. Entries from other Mexican plants are not affected.
• The allegation: An independent union petitioned on September 8, 2026, alleging the company interfered with union activity and fired workers in retaliation.
• The clock: Mexico has 10 days, to about October 18, to agree to a review, and 45 days from October 8, to about November 22, to finish it.
• Other plants under the same mechanism: Yokohama Tire's plant in Coahuila has had liquidation suspended since September 25, 2026.

My take on this

Country of origin is not enough here. You need to know which plant made the part. Most buyers know their tier-one supplier, not where that supplier sources its sub-components. A distributor in Texas can be selling you parts from this exact plant, and your paperwork would say only "Mexico."

A suspended entry is not a duty increase. It is an open file that cannot close, and if the case goes badly, the remedies can include penalties or denied entry for that facility's goods.

Procurement Action

• Ask each Mexican auto-parts supplier, in writing, which plant made each part you buy.
• Flag any entry from GLM Components or Yokohama's Coahuila plant so finance does not treat it as closed.
• Put October 18 and November 22 on the calendar for the GLM case.

USTR: United States seeks Mexico's review of alleged denial of workers' rights at GLM Components Mexico (October 8, 2026)

Two Korean Steel Mills, Two Different Duty Rates. Which One Do I Pay?

What happened

• The rates: Commerce's final results of the 2023 countervailing duty review on certain hot-rolled steel flat products from Korea, published October 9, 2026, set Hyundai Steel at 1.28% and POSCO at 3.68%.
• When they apply: These are the new cash deposit rates for entries on or after October 9, 2026. Assessment instructions for the 2023 entries go to CBP no earlier than 35 days after publication.
• Everyone else: Companies not in this review keep their most recent company-specific rate, or the all-others rate.
• The stack: The deposit sits on top of the Section 232 steel duty and any antidumping duty. The 3.68% is never the whole bill.

My take on this

The question to ask is not "is this Korean steel?" It is "which mill rolled it, and who exported it?" If you buy through a trading company or a service center, the invoice may not name the mill. Ask for the mill certificate. The producer and exporter combination decides the rate, and a 2.4-point gap adds up fast on steel volumes.

Procurement Action

• Get the producing mill on every Korean hot-rolled purchase order and mill certificate.
• Update your rate table with one row per mill, not one row for Korea.
• Have your broker confirm the deposit rate on entries from October 9, 2026 forward.

Federal Register: hot-rolled steel flat products from Korea, final results of CVD review (FR 2026-20778)

My Thai Tire Supplier Got a 1.14% Rate. Does That Lower My Deposit Now?

What happened

• The calculation: Commerce's preliminary results of the antidumping review on passenger vehicle and light truck tires from Thailand, published October 9, 2026, calculated 1.14% for Sumitomo Rubber (Thailand) for July 1, 2024 through June 30, 2025.
• Who else gets 1.14%: The same preliminary rate applies to the non-examined companies in the review: S.R. Tyres, Siam Rubber, Vee Tyre & Rubber, Yokohama Rubber, and Yokohama Tire Manufacturing (Thailand).
• Who was dropped: The review was rescinded for Bridgestone, Deestone, General Rubber, Maxxis, Otani, and Sentury. Their entries for the period are assessed at the deposit already paid.
• Everyone else: Thai exporters outside the review stay at the 17.06% all-others rate from the original investigation.
• Nothing changes yet: New deposit rates apply only after the final results. Case briefs are due October 30, 2026.

My take on this

Three Thai tire suppliers can now sit at three different answers: a preliminary 1.14%, a rescinded review that settles at the old deposit, and 17.06% for anyone outside the review. If your supplier list just says "Thailand," you cannot tell which one you are paying. And a preliminary number is not a price cut. Do not reprice your tires on it.

Procurement Action

• Match every Thai tire supplier to its exporter name in the review notice.
• Keep current deposits in landed cost until the final results publish.
• Model the 1.14% as a scenario, not a budget number.

Federal Register: passenger vehicle and light truck tires from Thailand, preliminary results and partial rescission (FR 2026-20779)