Adams and Reese Partner Cole Callihan, a leading member of the Global Trade, Transportation, and Logistics Team, had his article, “Gateway to Trade: How Does International Compliance Impact New Orleans?” published in New Orleans CityBusiness.
New Orleans is a city known for its diversity of cultures, foods, and people. Part of and perhaps a reflection of this diversity derives from our location as a gateway to trade, both domestically and internationally. Today, an array of goods flow in and out of our ports from Mardi Gras throws and coffee to oil and gas and construction equipment.
In 2023, New Orleans exported $160 billion and imported $120 billion, making it the fifth largest exporter and eighth largest importer in the U.S., according to the Observatory of Economic Council (OEC). With the Port of New Orleans investing $1.8 billion in a container terminal project – The Louisiana International Terminal – the goods flowing in and out of the state’s homes and businesses will continue to grow.
“International trade touches economies all over the globe. And as such, the individuals in and around New Orleans who keep these goods flowing throughout the region are caught in a myriad of ever-evolving international trade compliance regulations,” writes Callihan. “Impacts of matters taking place in seemingly remote parts of the globe – the war in Ukraine, supply chain disruptions from Houthi rebels, forced labor concerns – are directly felt here at home for a lot of businesses.”
Callihan said the recent uptick in trade enforcement is a new normal as administrations continue using trade as a key tool in national security and public policy efforts.
“Efforts of companies to keep up with these changing trade winds also proves more difficult as these enforcement efforts continue to increase,” Callihan writes. “Supply chain due diligence continues to be a moving target as countries and companies look for ways to evade sanctions and other trade restrictions through shell companies, third party intermediaries, and transshipments.”
Callihan said it is more vital than ever for companies to have a robust compliance program tailored to their types of products and business risks.
“A company’s program should involve thorough audits of its supply chain, and periodic review of existing and potential transactions, contracts, and relationships with persons or entities that may be subject to the new measures,” he writes. “Other proactive measures should include regular monitoring of developments and updates from DHS and OFAC. Companies also should take advantage of the tools available for screening vendors and other business partners through the UFLPA and SDN lists and databases.”
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Callihan is a member of the Adams and Reese Intersection of Business and Government Practice. He focuses primarily on regulatory affairs, with an emphasis on customs and international trade. He counsels and represents clients on matters before the Department of Commerce (DOC), U.S. Customs and Border Protection (CBP), U.S. Trade Representative (USTR), Department of Transportation (DOT), Maritime Administration (MARAD), Federal Maritime Commission (FMC), the Federal Motor Carrier Safety Administration (FMCSA), and the U.S. Coast Guard (USCG).
Callihan is the author of the International Compliance Digest, a monthly newsletter recapping compliance and enforcement updates, including issuances from the Department of Justice, Department of Commerce, and U.S. Customs and Border Protection, as well as notable enforcement actions.