Law Office of Yuri Starikov, LLC

05/30/2025

Conversation at Deliberate Solos About Current U.S. Trade Policy

https://vimeo.com/1089134831?share=copy =0

Even before being sworn in as the U.S. President, Trump Administration hit off the ground running with initiatives that drastically change the international trade regime. In the months that followed, we have seen huge fluctuations within U.S. import tariffs rates directed towards China, Mexico, Canada, and the rest of the world. On May 21, 2025, we met with Deliberate Solos group to discuss what to do and how to react to current international trade landscape. Importantly, we discussed history that laid foundation to today’s U.S. international trade policy and how to use that foundation to navigate through contemporary fluctuations of U.S. import tariffs.
If you would like to become a part of Deliberate Solos group, you are welcome to email [email protected]. You do not have to be an attorney to join!
Yuri Starikov can be reached at [email protected] or 347-871-2759.

Even before being sworn in as the U.S. President, Trump Administration hit off the ground running with initiatives that drastically change the international trade…

04/29/2025

Reducing Tariff Impact on Goods from China Under 20% Rule

Trump Administration introduced two major tariff provisions upon Chinese goods that significantly impacted U.S.-China trade relations: IEEPA Fentanyl tariff currently at 20% and IEEPA Reciprocal tariff currently at 125%. Imposition of these rates caused importing community to search for ways that can reduce newly imposed 145% rates of duty. This article explores one of the ways to reduce the impact by taking advantage of 20% Rule.

https://www.lawcustoms.com/2025/04/29/reducing-tariff-impact-on-goods-from-china-under-20-rule/

02/11/2025

Launching of VIP Member Area Dedicated to CBLE Preparation

www.StarikovLaw.vip

We just launched VIP Member Area with training videos and lectures designed for folks that are preparing for the forthcoming U.S. Licensed Customs Broker Examination (CBLE). Previously, these videos were exclusively available to individuals that signed up for classes, or those that purchased training books.

Best part of the VIP Member Area is the organization of training material previously unavailable to wide viewers, which includes:

Full CBLE Lectures broken down by Seasons (each CBLE = Season);
Real CBLE Q&As, also broken down by Seasons;
CBLE Topics, focusing on particular areas of customs law tested on CBLE.

The organization implements modern AI, which breaks each video content to chapters, transcript, and closed captions. Search menu allows prospective examinees to master topics that represent particular difficulties, such as classification or CFR (e.g. if your like more practice on CBLEs that test on HTSUS Chapter 69, then type “Chapter 69” in the search box; if 19 CFR 111.1, then type “111.1” in the search box to learn more… etc.)

You have a free trial period, followed by a month-to-month subscription or annual subscription. Please use limited time promo code – 0425CBLE – to get your 50% off discount for the first month (valid through Feb. 28, 2025).

New exclusive videos are being added on on-going basis, as we have over a decade of lectures and training for CBLE. We invite you to visit the VIP Member Area at:

www.StarikovLaw.vip

10/01/2024

FDA Biennial Food Facility Registration

FDA’s 2024 Food Facility Registration biennial renewal kick’s off today. Registration affects multiple parties within supply chain, including overseas warehouses. To report or not report, and if to report, how and under what title? This article explores definitions that matter.

https://www.lawcustoms.com/2024/10/01/fda-biennial-food-facility-registration/

09/16/2024

DSNY Tickets: Challenge or Pay?

Regulatory penalty regime for DSNY adopts an increasing fee pattern, almost like "buy one get one free," but in reverse order: violate twice, pay at 50% increase; violate three times, pay 50% on top of that.

https://starikovlaw.com/dsny-tickets-challenge-or-pay/

08/20/2024

Corporate Transparency Act Reporting

Pursuant to CTA, FinCEN issued a final rule on September 30, 2022. The rule went into effect on January 1, 2024. 87 FR 59498. The rule is also codified under 31 C.F.R. 1010.380. Significance of the CTA is that by January 1, 2025 most of the small and medium sized businesses are required to report information about their natural owners or face “$500 per day civil penalty and up to $10,000 in fines and 2 years in federal prison.” 31 U.S.C. 5336(h)(1). I.e. failure of medium and small sized businesses to report their ownership information can land owners with a 2-year prison term in a federal penitentiary! This is a big deal! Therefore please read on.

https://starikovlaw.com/corporate-transparency-act-reporting/

02/20/2024

Notice of Customs Broker License Exam (CBLE) – May 1, 2024
CBP opened registration today through March 21 to register for the forthcoming CBLE scheduled on 05/01/2024.

Announcement Link:

Securing America's Borders

11/10/2023

Modernization of Cosmetics Regulation Act of 2022 (“MoCRA”)

Folks who import and distribute cosmetic products used to enjoy relative freedom from FDA registration requirements, unlike their food and drug product counterparts. Cosmetic registration (in its mandatory form) is not a new phenomenon. Cosmetic industry heavily relies on animal products (by-products), and therefore must secure approval from USDA’s veterinary services. Now, FDA tightens its control hold on the industry. Control is two-fold: (1) facility focus, and (2) product focus. On facility end, like with food under Bioterrorism Act, manufacturers (and processors) are required to register their facilities. On the product end, it should be “listed.” It can be a manufacturer. But, in the world of modern marketing, labeling, and trademarking, theses tasks can be relayed to folks on the product label.

If you are in the business of cosmetic production or distribution, please mark the following links:

FDA’s Dedicated Page on MoCRA: https://www.fda.gov/cosmetics/cosmetics-laws-regulations/modernization-cosmetics-regulation-act-2022-mocra

Cosmetics Constituent Update (FDA): https://www.fda.gov/cosmetics/cosmetics-news-events/fda-issues-compliance-policy-cosmetic-product-facility-registration-and-cosmetic-product-listing

FDA Guidance for Industry: compliance Policy for Cosmetic Product Facility Registration and Cosmetic Product Listing: https://www.fda.gov/regulatory-information/search-fda-guidance-documents/guidance-industry-compliance-policy-cosmetic-product-facility-registration-and-cosmetic-product

07/03/2023

Continuing Education for Licensed Customs Brokers

CBP published a final rule creating mandatory requirements – 19 CFR 111.102 among many other updates – for licensed customs brokers to continuously educate themselves. This rule kicks in July 24, 2023, with certification via triennial status report starting 2027. Standard is 36 credit hours every three years pursuant to 19 CFR 111.102(b). Failure to continuously educate oneself results in suspension and then revocation of the license.

For many brokers it is will not be an issue, because they do that anyway. Many folks who are not brokers still take interest in the field. We cannot help but notice the curiosity of the mind narrative via subscribers to our social media channels: YouTube, Vimeo, Twitter, Facebook.

In the coming months, CBP will be working out the details regarding the bureaucracy. We also expect to see a flurry of educational venues that would seek qualifications. For now, please read the final rule: 88 FR 41224 (June 23, 2023)

https://www.federalregister.gov/documents/2023/06/23/2023-12921/continuing-education-for-licensed-customs-brokers

05/25/2023

CBP & First Sale

U.S. Customs and Border Protection (“CBP”) has a dedicated page to the “First Sale” rule, which is here: https://www.cbp.gov/trade/programs-administration/entry-summary/first-sale-declaration

In simple terms, “First Sale” is declaration technique that emphasized declaration to CBP based on original factory prices, instead of middle person or agent company prices. It is safe to say that “first sale” is not embraced with enthusiasm in some CBP circles, and has a history of litigation, with most famous case being Nissho Iwai v. U.S., 982 F.2d 505 (CAFC, 1992), available at https://scholar.google.com/scholar_case?case=12325922544708333037&q=nissho+iwai+american+corp+and+first+sale&hl=en&as_sdt=3,33

But the rule is available, and CBP dedicated webpage is a friendly reminder to the trade community about its use.

Securing America's Borders

05/17/2023

Mr. Chae’s CBLE Appeal Journey

Folks who took their April 2023 Customs Broker License Exam (“CBLE”) are receiving their results letters. Those who passed, congratulations! Those who did not, may either prepare for October 2023 or appeal April 2023 or both. Irrespective of the situation, the literature that recently came out from the Court of Appeals for the Federal Circuit is good read. It is a story of examinee who took the exam in April 2018 and received a score of 65%. Then, Mr. Chae appealed to CBP and raised score to 67.5%. Mr. Chae did his second appeal, and elevated the score to 71.25%. After exhausting his appellate review with an agency, Mr. Chae went to trial court, and had his score elevate to 72.5%. Mr. Chae did not stop and went to the appellate court and scored point there. Did Mr. Chae win the CBLE battle? Read the case.

https://cafc.uscourts.gov/opinions-orders/22-2017.OPINION.4-25-2023_2116213.pdf

04/19/2023

2023 Trade Facilitation and Cargo Security (TFCS) Summit is taking place in person and virtually. Aside from the benefits of seeing wonderful people from many levels of CBP, it is also an opportunity to learn the thinking methodology of agency’s actors, including the literature and authority. In the world of seizures, on such authority is Seized Asset Management and Enforcement Procedures Handbook or SAMEPH. One of the CBP presenters in the summit referred to SAMEPH as the “bible” of the Fines Penalties & Forfeitures Office. Google and FOIA searches revealed one release of 2002 version posted by “governmentattic.”

https://www.governmentattic.org/32docs/CBPsAMEPHdbk_2002.pdf

https://www.cbp.gov/trade/stakeholder-engagement/trade-facilitation-and-cargo-security-summit