Practice Statement: Restructuring Plans and Schemes – What Does this Mean for the Future? (UK)
We have seen an increasing number of contested restructuring plans (RPs) over the last quarter. With a notable shift of RPs into the litigation arena, and some gentle push back from the judiciary about timetabling and use of court time the judiciary has published a draft practice statement for consultation outlining new case management requirements for those proposing a plan.
Replies to the consultation must be submitted by 13 June, and although there is no official date for publication of the finalised statement, this is expected to be sometime in July.
The practice statement requires the parties to identify areas of contention and opposition early, seemingly seeking to streamline and reduce the number of issues that the court is required to deal with at sanction. In doing that there is a significant shift in process – requiring the plan company to issue a claim form before the court hearing is arranged and requiring the explanatory statement and all appendices to be prepared before the convening hearing.
The statement follows the direction of travel we have seen in recent cases, where the court has introduced case management processes – Madagascar Oil is a recent example where the court ordered a case management conference.
The statement is relevant not only to those proposing a plan, but also those who wish to object – requiring issues to be resolved in an efficient and orderly manner. Last minute opposition is unlikely to find much favour with the court moving forward.
Ultimately what the statement hopes to achieve is a more orderly approach to proceedings, but front loading much of the work comes with its own challenges – timing and costs being two.
Although this statement if not the final version, it is unlikely to change significantly between now and final publication, and in line with the approach we have seen the courts take recently it would be remiss not to apply the principles outlined in the statement now.
DHS Announces Termination of Afghanistan TPS Effective July 2025
On May 12, 2025, Secretary of Homeland Security Kristi Noem announced that the Temporary Protected Status (TPS) for Afghanistan will be terminated effective July 14, 2025. The current TPS designation for Afghanistan is scheduled to expire on May 20, 2025. This announcement is the latest in the current administration’s push to roll back immigration benefits for foreign nationals living and working in the United States. Noem stated that permitting Afghan nationals to remain temporarily in the United States is “contrary to the national interest of the United States.”
Quick Hits
On May 12, 2025, Secretary of Homeland Security Kristi Noem announced the termination of TPS for Afghanistan, effective July 14, 2025, as part of the administration’s efforts to reduce immigration benefits.
DHS deemed that the TPS designation, initially granted in 2022 due to the Taliban takeover, was now unnecessary because returning Afghan nationals would not face significant threats to their safety.
Despite Afghanistan’s “Level 4: Do Not Travel” status due to severe security risks, the TPS termination notice allows TPS beneficiaries 60 days to adjust, with work authorization extended until July 14, 2025.
Background
The Department of Homeland Security (DHS) created the TPS designation to provide temporary status to foreign nationals living in the United States who are unable to return to their home countries due to an event or circumstance present in that country. During a designated TPS period, TPS beneficiaries:
“Are not removable from the United States
Can obtain an employment authorization document (EAD)
May be granted travel authorization.”
Afghanistan received its TPS designation in 2022 after the United States withdrew from the country and the Taliban took over. By removing Afghanistan’s TPS designation, DHS has determined that the return of Afghan nationals to Afghanistan “does not pose a threat to their personal safety due to ongoing-armed conflict or extraordinary and temporary conditions.”
Secretary Noem cites the U.S. Citizenship and Immigration Services’s (USCIS) review of the conditions in Afghanistan as the impetus of this decision, along with a consultation with the U.S. Department of State. For those planning to travel to Afghanistan, the DOS has designated Afghanistan as a “Level 4: Do Not Travel” country. This latest update was made on January 13, 2025, “to reflect the security environment, immigration information, and availability of medical care.” [Emphasis omitted.] Afghanistan’s designation as a “Level 4” country is specifically due to “civil unrest, crime, terrorism, risk of wrongful detention, kidnapping, and limited health facilities.” [Emphasis omitted.]
Practical Impact
While the initial TPS designation for Afghanistan was set to expire on May 20, 2025, DHS regulations require that any recission of TPS benefits be accompanied by a 60-day notice period. The TPS termination for Afghanistan was published in the Federal Register on May 13, 2025, resulting in an effective termination date of TPS benefits for Afghan nationals, including work authorization, on July 14, 2025.
The Federal Register notice specifically confirms that Employment Authorization Documents (EADs) granted to Afghan TPS beneficiaries also will be automatically extended through this 60-day notice period. This signifies that employers may accept, for the purposes of I-9 verification, any TPS EADs presented by Afghan beneficiaries with expiration dates of November 20, 2023, or May 20, 2025, as valid through July 14, 2025.
UK Data (Use and Access) Bill Status Update
As the draft UK Data (Use and Access) Bill (the “DUA Bill”) reaches its final stages, the House of Commons and the House of Lords are still debating several key issues. On May 14, 2025, the House of Commons received a program motion, urging it to deliberate on the amendments proposed by the House of Lords on May 12, 2025. The latest amendments introduced by the House of Lords include:
Scientific Data: Limiting the scope of the ‘scientific data’ provision by setting a higher standard for the reasonableness test such that “scientific research must be conducted according to appropriate ethical, legal and professional frameworks, obligations and standards.” This amendment is contrary to the position taken by the House of Commons, which proposed expanding the scope of the ‘scientific data’ provision by removing the requirement for the processing of ‘scientific data’ to be conducted in the ‘public interest.’
AI Models: Introducing transparency requirements for business data used in relation to AI models. The amendment would require developers of AI models to publish all information used in the pre-training, training, fine-tuning and retrieval-augmented generation of the AI model, and to provide a mechanism for copyright owners to identify any individual works they own that may have been used during such processes. The amendment also introduces transparency obligations in respect of “bots,” including the requirement to disclose information on the (1) name of the bot, (2) responsible legal entity the bot, and (3) specific purpose for which each bot is used.
Sex Data: Introducing requirements for ‘sex data’ to be collected in the context of digital verification services.
The House of Commons will now consider such amendments. With the DUA Bill’s progress accelerating, it is anticipated that the DUA Bill will soon be finalized.
Read the latest amendments proposed by the House of Lords.
For more information on the DUA Bill, read our previous update on the DUA Bill.
Data Transactions: DOJ’s Final Rule’s Implications for Academic Medical Centers with Clinical Research Programs
The Department of Justice (DOJ) published its Final Rule to implement Executive Order 14117 on January 8, 2025, with a correcting amendment issued April 18, 2025. Executive Order 14117, issued on February 28, 2024, titled “Preventing Access to Americans’ Bulk Sensitive Personal Data and United States Government-Related Data by Countries of Concern,” instructed the Attorney General to create regulations that ban or limit U.S. persons from participating in transactions involving property in which a foreign country or its nationals have an interest. Transactions are banned or limited if they involve U.S. government-related data or bulk sensitive personal data (as defined by the final implementing rules), fall into categories deemed by the Attorney General to pose a national security risk (with such security risk arising from potential access to data by identified countries of concern or related individuals), and meet additional criteria outlined in the Executive Order.
The Final Rule outlines categories of transactions that are either banned or limited; designates specific countries and types of individuals or entities with whom transactions involving government-related or bulk U.S. sensitive personal data are restricted; creates a system for granting, modifying, or revoking licenses for otherwise restricted activities and for issuing advisory opinions; and sets requirements for transaction recordkeeping and reporting requirements to support the DOJ’s investigations, enforcement, and regulatory actions in relation to the Executive Order.
Academic Medical Centers (AMCs) and similar entities engaged in clinical research and international collaborations need to be aware of and determine the applicability of the regulatory requirements imposed by the Final Rule. Research partnerships involving biometric identifiers, personal health information, or genomic data may be deemed restricted or prohibited transactions if the partnerships include entities from designated countries of concern.
Summary
The Final Rule is aimed at preventing certain U.S. foreign adversaries — including China, Russia, Iran, North Korea, Cuba, and Venezuela — from accessing sensitive U.S. personal data and government-related information.
Key Definitions. The Final Rule authorizes the DOJ to regulate and enforce restrictions on data transactions with designated “Countries of Concern” and “Covered Persons.”
“Country of Concern” is defined to mean:
any foreign government that, as determined by the Attorney General with the concurrence of the Secretary of State and the Secretary of Commerce, (1) has engaged in a long-term pattern or serious instances of conduct significantly adverse to the national security of the United States or security and safety of United States persons, and (2) poses a significant risk of exploiting government-related data or bulk U.S. sensitive personal data to the detriment of the national security of the United States or security and safety of U.S. persons.
“Covered Person” is defined to include: (1) foreign entities that (a) are fifty percent or more owned, directly or indirectly, by countries of concern or another covered persons; or (b) are organized under the law of, or have their principal place of business in, a Country of Concern; (2) foreign entities that are fifty percent or more owned, directly or indirectly, by Covered Persons, either individuals or entities; (3) foreign individuals who are non-U.S. residents working as employees or contractors of a Country of Concern; (4) foreign individuals primarily residing in Countries of Concern; and (5) other entities or individuals as reasonably determined by the Attorney General based on certain criteria.
Categories of Covered Data. The Final Rule targets eight categories of “Covered Data,” including biometric identifiers, genomic data, health and financial data, precise geolocation information, and personal identifiers that can be linked to other sensitive data. It also includes certain government-related information, such as data tied to U.S. government personnel or the geolocation of sensitive facilities. Notably, the regulations apply regardless of data processing volume when government-related information is involved.
Primary Types of Restricted Transactions. The DOJ identifies three primary types of restricted transactions: employment, investment, and vendor agreements. U.S. businesses must ensure foreign employees, investors, and service providers — especially those linked to Countries of Concern — do not gain access to Covered Data unless strict security protocols are met. This affects a wide range of commercial activities, from hiring and corporate deals to cloud services and software subscriptions, and likely impacts AMCs engaging in clinical research when data is shared with certain employees. Research sponsors, investors and service providers. Prohibitions and restrictions of the Final Rule, however, only apply to Covered Data Transactions with a Country of Concern or Covered Person that involve access by a Country of Concern or Covered Person to government-related data or bulk U.S. sensitive personal data. The Final Rule does not regulate transactions that do not implicate access to government-related data or bulk U.S. sensitive personal data by a Country of Concern or a Covered Person.
Prohibited Transactions. Notably, under the Final Rule certain transactions are absolutely prohibited, such as those involving the sale or licensing of Covered Data to foreign entities in data brokerage arrangements, or those involving biometric data or biospecimens.
Penalties for Non-Compliance. Violations of the Final Rule carry significant fines and penalties. Civil fines can reach the greater of US$368,136 or twice the transaction amount. Willful violations may result in criminal penalties of up to US$1 million and up to 20 years in prison.
The Bottom Line for Clinical Research. To comply with the Final Rule, AMCs must engage in rigorous and thorough diligence on proposed, and existing research activities, collaborations and operations, including on their partners, clients, employees/contractors, and data recipients, to determine if a proposed or existing transaction falls within the ambit of the Final Rule. The scope and penalties for violations of and non-compliance with the Final Rule are a clear indicator that a process to determine and ensure compliance with the Final Rule will be critical for AMCs, and businesses across industries, that engage in activities and transactions involving personal or government-related data.
Implications for Academic Medical Centers with Clinical Research Programs
The Final Rule adds a new layer of regulatory compliance complexity for AMCs and similar entities engaged in clinical research and international collaborations.
Research studies and activities, including research collaborations and partnerships involving biometric identifiers, personal health information or genomic data, may be deemed restricted or prohibited transactions if the partnerships include entities from designated Countries of Concern and/or Covered Persons.
Existing and proposed multi-national studies and data-sharing initiatives must be reviewed to determine if the Final Rule is applicable to the study or activity, and if so, to ensure compliance.
Additionally, AMCs must also ensure that vendors, including cloud and AI service providers, are not affiliated with Countries of Concern and that all data processing activities meet stringent new security and compliance standards. As noted above, ensuring compliance with the Final Rule will necessitate a thorough review of the AMC’s vendor contracts.
Further, the Final Rule necessitates a reassessment by AMCs, of their data-sharing policies and multi-site protocols, and will likely require the incorporation of national security-focused compliance clauses in certain data sharing agreements (such as data use agreements) and the enhancement of institutional data governance frameworks, which frameworks should be designed to avoid and mitigate any legal and regulatory exposure, and ensure that the institution is able to maintain eligibility for receipt of federal funding.
Next Steps
This Final Rule prescribes significant categorical rules that prevent U.S. persons from providing government-related data or U.S. citizens’ bulk, sensitive personal data, including through commercial data-brokerage transactions, to Countries of Concern or Covered Persons. Compliance with the Final Rule specifically necessitates that AMCs and institution implement security measures when engaging in investment transactions, employment agreements, and vendor contracts, that involve either government-related data or large-scale collections of sensitive personal data — such as health records, biometric identifiers, or financial information.
The requirements of the Final Rule are intended to prevent foreign adversaries from indirectly accessing this data through commercial relationships. By identifying these specific transaction types, the Final Rule seeks to address perceived national security gaps and provides clear, enforceable standards that define when and how data-related dealings with foreign actors are restricted.
Failure to comply with these new requirements could result in fines and penalties, regulatory scrutiny, loss of federal funding, and enforcement actions, making compliance with the Final Rule, when and as applicable to a transaction and activity, a critical compliance priority for AMCs and institutions handling large volumes of sensitive personal data.
Application of the Insolvency Claw-Back Barrier under Article 16 of the EU Insolvency Regulation to Cross-Border Shareholder Loans
Article 7(m) of the EU Insolvency Regulation (2015/848) provides that the law of the EU Member State in which insolvency proceedings have been commenced in respect of a company determines whether certain acts carried out prior to the commencement of insolvency proceedings, (such as payments made by the company), are void, voidable or unenforceable and may therefore be clawed back by the insolvency administrator.
However, Article 16 of the same Regulation provides an exception to this. This applies where the relevant relationship under which the payment was made is subject to the law of another EU Member State and under the law of that other Member State the payment cannot be challenged – the claw back barrier provisions.
Application of the “claw back” barrier provisions in practice
The impact of the “claw back” barrier provisions under the EU Insolvency Regulation is currently being considered by the European Court of Justice (ECJ). In this case, an Austrian holding company had provided an Austrian law governed shareholder loan to its German subsidiary. Before insolvency proceedings were opened in Germany against the subsidiary, the Austrian parent received payments of interest and principal under that loan. The German insolvency administrator wishes to claw back these payments and wishes to treat the claims of the Austrian holding company as subordinated to all other creditors of the German subsidiary.
The German Federal Supreme Court (Bundesgerichtshof – “BGH”) in an interim decision dated 16 January 2025 put forward a number of questions for the ECJ to consider, the answers to which will be relevant to how Article 16 of the EU Insolvency Regulation is applied throughout the EU. Although the decision of the BGH relates to Article 13 of EU Insolvency Regulation (1346/2000), that provision is materially identical to Article 16 of the Regulation and thus any judgment of the ECJ is likely also to apply to Article 16.
The reason for the challenge is based on arguments that local laws and rules in the jurisdiction where the insolvent company has its centre of main interest and which are based on corporate law should take priority over Article 16.
Under German insolvency law, shareholder loans granted to a German company would in principle be subordinated in a German insolvency of the German company. Therefore, any payments (like payments of principal and interest) can more easily be challenged and clawed back in the insolvency than other third-party payments. The litigation in this case has arisen, because Austrian law rules differ from such German corporate law rules and therefore the holding company invoked Austrian law and Article 16 in the German proceedings.
Impact of the ECJs findings
The ruling of the ECJ will be significant in determining whether, and to what extent, the risk of claw-back (in the context of shareholder loans) can be mitigated by choosing the law of another EU Member State as the law governing the shareholder loan.
Belgium’s Private Investigations Act: Is Your Internal Investigations Service in Focus?
In December 2024, the new Private Investigations Act came into force. The Act replaced the Private Detectives Act of 1991 and was long overdue, considering how much has changed in the world of private investigations. The 1991 law focused on detectives as sole practitioners, think Columbo or Magnum P.I., a world of uncertain ethics, periodic violence and grubby raincoats, most of which no longer exists outside the small screen. The new Act aims to modernise the applicable legal framework in light of new investigation methods and bring it into line with the General Data Protection Regulation (GDPR), though sadly not to address the traditional private detective issues of implausible dialogue and unhappy dress choices.
The Act imposes a number of obligations on employers instructing investigations on their employees, and we will discuss these changes at length in future blogs, but there is a more pressing issue we need to deal with first, and that regards your internal investigations service. The Act extends its scope from solo private detectives to all types of investigations companies but more importantly, also to internal investigations services. An internal investigations service is defined by the Act as ‘any service organised by a natural or legal person for its own purposes for the systematic performance of private investigation activities’. This definition is very wide and has prompted the legislator to exclude a number of roles and functions, such as lawyers, bailiffs and auditors.
The legislator has taken into account that in practice, internal services are often organised at group level and has therefore provided that investigation activities still qualify as internal when they are performed for the benefit of companies in the same group structure. What the legislator has seemingly not considered, however, is that international groups will often have an investigations team in one location, which is not necessarily Belgium, that will conduct all investigations for the group, including those concerning employees located in Belgium. This means that the Belgian legislator has probably also not fully realised that the registration obligation imposed by the Act may thus also extend to these internal investigations services located outside of Belgium, if their remit extends to this country.
The Act provides an exception for members of the HR team “who carry out private investigation activities on behalf of their own employer within the framework of incident investigations [not defined] involving employees of that employer”. The HR team will not be considered to perform the activities of an internal investigations service, so the registration obligation will not apply to them. The criterion of distinction would be the focus of the team: is it day-to-day HR activities, with an exceptional side activity of investigative work, or is investigation work the main focus for the team?
So what does this registration obligation entail? Internal investigations services must obtain a prior authorisation or licence from the Ministry of Interior to lawfully conduct private investigations in Belgium. The licence is granted for a renewable period of five years. It will only be awarded if the members of the team have a clean criminal record (minus some minor offences), they have undergone specific training and are Belgian nationals or have their main residence in the EEA or Switzerland. This would seem to suggest the end of investigations being carried out more or less remotely by the US parents of local subsidiaries, though it is unclear at this stage just how much (substantial) advisory input into the investigation process and/or decisions there can still be from abroad so long as the team is fronted by someone satisfying the above conditions. The members of the team should also have a certain “desired profile”, meaning that they will honour individuals’ fundamental rights, be loyal and discrete, and not entertain suspicious relations with criminal organisations, etc.
The license is awarded by the Ministry of Interior, which may or should in some cases seek the prior advice of the public prosecutor.
If an internal investigations service was already validly performing private investigation activities on the date of entry into force of the Act, 16 December 2024, they may continue to perform such services, but they will need to make a request to obtain a licence by 16 June 2025. The members of these teams will have 18 months after their company obtained a license to undergo the required training and obtain a licence card. The specific training requirements are in fact still to be defined by Royal Decree.
China’s State Administration for Market Regulation Releases Top 10 Typical Cases of Intellectual Property Law Enforcement for 2024
On April 29, 2025, China’s State Administration for Market Regulation (SAMR) released the Top 10 Typical Cases of Intellectual Property Law Administrative Enforcement for 2024 (2024年知识产权执法十大典型案件). Administrative enforcement is an additional route to enforce intellectual property rights and is often faster than civil litigation. While fines and seizure are available, damages are not. It is also possible that SAMR will refer cases to the procuratorate for criminal prosecution.
A translation of SAMR’s summary follows. The original text is available here (Chinese only).
1. Market supervision departments of nine provinces (autonomous regions and municipalities) jointly investigated and dealt with the case of infringement of the exclusive right to use the registered trademark “Jimi” by Jiangxi Caiying Technology Co., Ltd. and others
Chengdu JmGO Technology Co., Ltd. discovered during market sales that Jiangxi Caiying Technology Co., Ltd. (hereinafter referred to as “Caiying” Company) and its related companies used the “JmGO Nuts” trademark on similar products, suspected of infringing its exclusive right to the “JmGO” registered trademark, causing serious impact on product sales. The infringement involved dozens of entities in processing, warehousing, packaging, sales and other links, across multiple provinces.
After receiving clues about the case, the Law Enforcement Inspection Bureau of the State Administration for Market Regulation immediately convened law enforcement backbones from market supervision departments in nine provinces (autonomous regions and municipalities), including Jiangxi, Guangdong, Beijing, Shanghai, Zhejiang, Jiangsu, Henan, Guangxi, and Sichuan, to jointly study and formulate a thorough action plan. At the same time, it coordinated with e-commerce platforms such as JD.com, Pinduoduo, Taobao, and Douyin to retrieve the sales records of “Jimi Nuts” suspected of infringing goods and collect the evidence of infringement by the parties. On March 6, 2024, the market supervision departments of nine provinces (autonomous regions and municipalities) took unified action to conduct surprise inspections on all the entities involved in the case, and verified the illegal acts of all relevant companies in one fell swoop. The State Administration for Market Regulation sent personnel to Jiangxi and Guangdong to supervise and guide on the spot. Based on the illegal facts found out by the centralized action, the State Administration for Market Regulation designated the Yichun Municipal Market Supervision Bureau of Jiangxi Province to conduct a unified investigation and handling of “Caiying” Company and the related companies controlled by it.
Upon investigation, it was found that Xiao XX, the actual controller of “Caiying” company, registered a total of 10 companies, commissioned others to produce projectors, projection screens and other products, used trademarks such as “Jimi Nuts” on the products and their packaging, and opened 25 online stores for sale on e-commerce platforms such as JD.com, Pinduoduo, Taobao, and Douyin. The Yichun Municipal Market Supervision Bureau of Jiangxi Province made a penalty decision in accordance with the law, confiscated the illegal income of 3.1434 million RMB from 10 companies including “Caiying”, imposed a fine of 1.9287 million RMB, and the total fines and confiscations were 5.0721 million RMB. In this case, “Caiying” company reached a settlement agreement with the right holder, admitted the infringement and compensated for the loss of 4 million RMB. Other companies involved in this case (processing, warehousing and packaging companies, etc.) will be further investigated and handled by the local market supervision department.
2. Beijing Municipal Market Supervision Bureau investigates and punishes Beijing Youyou Education Consulting Co., Ltd. for infringing the exclusive right to use the registered trademark “LEGO”
In May 2024, the Beijing Municipal Market Supervision Bureau received a tip-off from Lego Co., Ltd., stating that Beijing Youyou Education Consulting Co., Ltd. had infringed on the exclusive right to use a registered trademark. After receiving the tip-off, the Beijing Municipal Market Supervision Bureau quickly launched an investigation. When law enforcement officers conducted an on-site inspection at the business premises of Beijing Youyou Education Consulting Co., Ltd., they found that the company’s main business was education and training, which was the same as the trademark verification service items held by Lego Co., Ltd. At the same time, the company used the “乐高”, “LEGO” and ”” trademark logos on the signs of its business premises, classroom doorplates in the store, promotional posters, front desk, etc., and was unable to provide legal license documents for the use of these trademarks. Law enforcement officers questioned and investigated the person in charge of the company, and the person confessed to the use of the relevant trademarks. At the same time, law enforcement officers conducted a detailed analysis of the company’s operating data and determined that the illegal business volume totaled 3.5138 million RMB.
The act of a party using a trademark identical to a registered trademark on the same kind of goods without the permission of the trademark registrant constitutes an infringement of the exclusive right to a registered trademark as stipulated in Article 57 of the Trademark Law of the People’s Republic of China, and the circumstances are serious and suspected of criminal offenses. The Beijing Municipal Market Supervision Bureau will transfer the case to the judicial authorities for handling in accordance with the law.
3. The Market Supervision Bureau of Xindu District, Xingtai City, Hebei Province investigated and dealt with the case of infringement of the exclusive right to use the registered trademark “Huawei”
In December 2023, the Xindu District Market Supervision Bureau of Xingtai City, Hebei Province received a complaint from a consumer that the screen and battery of the Huawei mobile phone they purchased on the Douyin live broadcast platform “Tangtang Youxuan Second-hand Mobile Phone” and “Mijing Youxuan Second-hand Mobile Phone” had problems. The Xingtai Municipal Market Supervision Bureau and the Xindu District Market Supervision Bureau immediately set up a special task force to launch an enforcement investigation.
The Douyin store involved in the case, “Tangtang Optimal Used Phones”, is actually registered under Kuamoutang Network Technology Co., Ltd., and its principal is Mu. The other Douyin store involved in the case, “Mijing Optimal Used Phones”, is actually registered under MiXX Electronic Technology Co., Ltd., and its principal is Xue. Both stores claimed that they sold official genuine mobile phones of the “Huawei” brand through Douyin live broadcast rooms. It was found that the items involved in the case were assembled by the parties themselves without the authorization of the rights holder, and were infringing goods.
On March 26, 2024, the Xingtai Municipal Market Supervision Bureau and the Xingtai Municipal Public Security Bureau dispatched a number of law enforcement officers and police officers at the municipal and county levels, and divided them into 4 evidence collection and arrest teams to carry out a roundup operation simultaneously. 11 people involved in the case were arrested on the spot, 2 mobile phone assembly factories and 2 live broadcast rooms were destroyed, and the mobile phones involved in the case (Mate series, Pura series) and related accessories worth more than 3 million RMB were seized. The amount involved in the online sales of the two stores was as high as 16.408 million RMB.
The party’s act of selling goods that infringe the exclusive right to use a registered trademark constitutes an act of infringing the exclusive right to use a registered trademark as stipulated in Article 57 of the Trademark Law of the People’s Republic of China. As the amount involved is large, it is suspected of constituting a crime, and the law enforcement department has transferred the case to the judicial authority for handling in accordance with the law.
4. Shanghai Municipal Market Supervision Bureau investigates and punishes five companies and individuals including Shanghai Jixu Food Co., Ltd. for infringing the exclusive right to use the “Liuhe” registered trademark
In March 2024, based on reports from rights holders, the Shanghai Municipal Market Supervision Bureau and Suzhou Market Supervision Department launched a joint law enforcement operation, seizing 18 tons of infringing frozen poultry, more than 1,500 counterfeit packages and multiple infringing printing templates, with a total amount involved of more than 5.2 million RMB.
After investigation, it was found that from November 2023 to March 2024, Shanghai Jixu Food Co., Ltd. and Yu XX conspired to entrust relevant enterprises in Changzhou to print packaging boxes containing the Liuhe trademark. Subsequently, Yu used the above-mentioned counterfeit packaging boxes to pack low-priced single frozen chicken breasts and other products. Jixu Company purchased more than 100,000 boxes of the above-mentioned counterfeit products from Yu and sold them to Tang XX. Tang then sold them to the outside through relevant online platforms. The total amount involved in the case of the above-mentioned parties is more than 3.4 million RMB.
It was also found that Shanghai Nuoping Industrial Co., Ltd. purchased more than 30,000 counterfeit Liuhe trademarked packaging boxes from a Suzhou company and Shanghai Gujun Packaging Materials Co., Ltd., and used the counterfeit packaging boxes to pack low-priced single frozen chicken breasts and other products, and sold them through relevant e-commerce platforms, involving more than 1.4 million RMB. Shanghai Gujun Company produced and sold more than 230,000 counterfeit packaging boxes without authorization, involving more than 400,000 RMB.
The actions of the above five companies and individuals violated Article 57 of the Trademark Law of the People’s Republic of China. As the amount involved was large, they were suspected of committing a crime. The case handling department transferred the relevant cases to the public security organs for handling in accordance with the law. At present, the above parties have been prosecuted.
5. The Market Supervision Bureau of Longwan District, Wenzhou City, Zhejiang Province investigated and dealt with the case of Wenzhou Zunxiang Technology Co., Ltd. selling goods that infringed the exclusive right of registered trademarks
The Market Supervision Bureau of Longwan District, Wenzhou City, Zhejiang Province, investigated and dealt with the illegal behavior of Wenzhou Zunxiang Technology Co., Ltd. in selling goods that infringed the exclusive rights of registered trademarks in accordance with the law. The amount involved was more than 10 million RMB. As the party’s behavior was suspected of constituting a crime, the case has been transferred to the public security organs for handling.
At the beginning of 2024, the Market Supervision Bureau of Longwan District, Wenzhou City received reports from many consumers, reporting that Wenzhou Zunxiang Technology Co., Ltd. attracted customers through low-priced mobile phones online, and fabricated “operator subsidies” offline to induce consumers to exchange for Apple Bluetooth headphones. The headphones provided by one of the consumers were identified by Apple, and the outer packaging, printing details and production process were significantly different from the genuine ones. In response, law enforcement officers immediately launched an investigation into the store, extracted a large amount of electronic data on the spot, accurately locked more than 200 false mobile phone sales records and exchange evidence, and completely eradicated the illegal chain of “low-price traffic-induced exchange-high-price fake sales”. Combined with logistics data traceability and geographic information visualization technology, a network map of counterfeiting and selling counterfeit products covering five provinces including Zhejiang, Fujian, Jiangxi, and Guangdong was drawn, and sales and storage locations were accurately located.
In response to the illegal activities, the Longwan District Market Supervision Bureau and the public security organs set up a special task force to carry out a unified cross-provincial crackdown operation, successfully destroying 5 stores selling counterfeit goods and 5 storage locations, and seized more than 1,000 counterfeit Apple Bluetooth headsets and more than 5,000 infringing mobile phone cases on the spot. 32 criminal suspects were arrested, and the total amount involved in the case was more than 10 million RMB.
6. Anhui Province Fuyang Municipal Market Supervision Bureau investigates and punishes Gu Moumou and others for infringing the exclusive rights of registered trademarks such as “Arc’teryx”
In December 2023, the Market Supervision Bureau of Fuyang City, Anhui Province received a case clue that Fuyang Pengfei Clothing Co., Ltd. was suspected of producing infringing clothing. Law enforcement officers immediately launched an investigation and found that the company’s legal representative Zhang XX, in order to increase sales and expand profits, produced a total of 7,323 “Arc’teryx” jackets that infringed on the exclusive rights of others’ registered trademarks under the arrangement of the client Gu XX, involving a total amount of more than 1.44 million RMB.
Because the illegal facts of the case have reached the standard for criminal prosecution, the Fuyang Municipal Market Supervision Bureau transferred the case to the public security organs for investigation on December 28, 2023. Subsequently, the public security and market supervision departments set up a special task force to carry out joint law enforcement. From January to April 2024, the task force went to Ningbo, Anqing, Bozhou, Chizhou, Lu’an, Cangzhou, Langfang and other places to conduct investigations and tracking, seized a large number of infringing clothing, and successfully destroyed more than 20 production, warehousing and sales dens. It was found that since September 2019, Gu, without the permission of the trademark registrant, customized fabrics and accessories according to various well-known brands of clothing, produced counterfeit logos, and commissioned clothing processing factories in many provinces and cities to process clothing that infringed trademark brands such as “Arc’teryx”, “The North Face”, “Adidas”, “Gucci”, “Lululemon”, “Amy”, and “Balenciaga”, and then hired employees to promote and sell them. The amount involved in the case reached more than 200 million RMB. In April 2024, the procuratorate filed a public prosecution against Gu and others for the crime of counterfeiting registered trademarks. So far, 6 people have been sentenced and 15 people have been approved for prosecution.
7. The Market Supervision Bureau of Xiangyang City, Hubei Province investigated and dealt with the case of Shen’s gang producing and selling trademark-infringing “specially supplied wine”
In July 2024, the Market Supervision Bureau of Xiangyang City, Hubei Province received a report from the public that there were illegal production and sales of “special supply wine.” The bureau quickly launched the investigation procedure and established a joint working group with the public security department to jointly handle the case. On July 24, the joint working group launched a surprise operation after careful deployment, and conducted surprise inspections on multiple suspected production and storage locations, successfully destroying 2 major production dens and 10 storage dens, and at the same time destroyed 3 criminal gangs that produced and sold counterfeit well-known brand wines. Law enforcement officers seized more than 1,000 pieces of Moutai liquor with words such as “Great Hall of the People”, “Beijing West Hotel”, “Beijing Military Region” and “State Council” labeled “specially supplied”, as well as counterfeit Moutai, Wuliangye, Guojiao 1573, Baiyunbian and other brand finished liquors; more than 1,000 kilograms of counterfeit raw material base liquor; 5 sets of filling equipment, air pumps, rivet guns and other production tools and more than 210,000 packaging materials. The amount involved in the case was as high as more than 80 million RMB. The sales network covered 15 provinces and cities across the country, and 26 criminal suspects were arrested.
The party involved in the case, Shen’s gang, forged and used the above-mentioned “special supply” trademark logo, misleading consumers into thinking that it was a high-end product customized for a specific institution or occasion. In fact, these so-called “special supply wines” are just ordinary liquors, which are sold at high prices by attaching false labels and counterfeiting well-known brand liquors, seriously infringing on consumers’ right to know and right to choose. The party’s behavior constitutes an illegal act of infringing on the exclusive right of others to use registered trademarks. Because the value of the goods involved is huge and it is suspected of constituting a crime, the case has been transferred to the judicial authorities for handling.
8. The Jieyang Municipal Market Supervision Bureau of Guangdong Province investigated and dealt with the case of Wang XX producing watches with counterfeit registered trademarks of “ROLEX”, “RADO” and “FOSSIL”
In December 2023, the Jieyang Municipal Market Supervision Bureau of Guangdong Province, based on the clues of the report, jointly with the public security organs, inspected a den suspected of producing counterfeit watches of well-known trademark brands. 3,470 finished watches marked with the “ROLEX” logo, 900 dials (semi-finished products), 3,000 straps (semi-finished products), and 300 finished watches marked with the “RADO” and “FOSSIL” logos were found on the spot. The Jieyang Municipal Market Supervision Bureau filed a case on the same day and took administrative compulsory measures to seize the above-mentioned items involved in the case in accordance with the law.
Upon investigation, it was found that the parties, Mr. and Mrs. Wang XX, had hired five workers to process watches with the “ROLEX”, “RADO” and “FOSSIL” logos for them since June 2023 without obtaining a license to use the registered trademarks such as “ROLEX”, “RADO” and “FOSSIL”. According to the identification opinion issued by the domestic legal institution authorized by the right holder, the finished watches marked with the “ROLEX”, “RADO” and “FOSSIL” logos produced by the parties were not produced by the right holder or with its permission.
The party produced watches with “ROLEX”, “RADO” and “FOSSIL” trademarks without the permission of the trademark registrant, which constituted an illegal act of infringement of the exclusive right to use a registered trademark as stipulated in Article 57 (1) of the Trademark Law of the People’s Republic of China, with a value of 116.9465 million yuan. The Jieyang Municipal Market Supervision Bureau transferred the case to the judicial authorities for handling in accordance with the law. At present, the seven suspects have been transferred to the procuratorate for prosecution in accordance with the law.
9. Chongqing Youyang County Market Supervision Bureau and the public security organs jointly investigated and dealt with the case of Chen et al. selling goods that infringed the exclusive rights of registered trademarks such as “LV”
In January 2024, law enforcement officers from the Market Supervision Bureau of Youyang Tujia and Miao Autonomous County, Chongqing City, discovered during an inspection that the Balenciaga, Dior, and LV brand products sold by a store with the sign “Shark Luxury Buyer Store” were suspected of counterfeiting other people’s registered trademarks. Because the party Chen could not provide the authorization basis for the goods sold, law enforcement officers immediately seized more than 490 suspected infringing goods in accordance with the law. After identification by the right holder, the goods sold by the party were all counterfeit registered trademarks of others, and the value of the goods reached more than 2.5 million RMB. His behavior constituted an illegal act as stipulated in Article 57 (3) of the Trademark Law of the People’s Republic of China. Because the amount involved was large and suspected of being a crime, the Youyang County Market Supervision Bureau transferred the case to the public security organs for investigation.
After investigation, it was found that since 2019, the suspects Zhou, Luo, Wen and others have set up processing factories in Guangdong to produce counterfeit brand clothing, bags, and footwear products, and wholesaled them to Chen and others through logistics delivery, and then sold them through e-commerce platforms, offline physical stores, and online social media. From April to May 2024, the market supervision department and the public security organs jointly dispatched more than 60 law enforcement personnel to Chongqing, Guangdong, Fujian, Hunan and other places to carry out case investigation and handling, destroying 5 counterfeiting “black factories” and 18 “black dens”, and seized more than 75,000 counterfeit clothing and bags, more than 20,000 semi-finished products, and more than 80 sets of counterfeiting equipment. The amount involved is as high as more than 300 million RMB. At present, 14 people have been transferred for prosecution, and the case is under further investigation.
10. The Market Supervision Bureau of Luzhou City, Sichuan Province investigated and dealt with the case of Luzhou Brothers Yijia Decoration Engineering Co., Ltd. infringing the exclusive right to use the registered trademark “Brothers Decoration”
In May 2024, Chongqing Municipal Market Supervision Bureau received a report from Chongqing Brothers Decoration Engineering Co., Ltd. (hereinafter referred to as the right holder), claiming that Luzhou Brothers Yijia Decoration Engineering Co., Ltd. (hereinafter referred to as the party) infringed its exclusive right to use the registered trademark No. 52642360 “Brothers Decoration”. As the party is located in Luzhou City, Sichuan Province, Chongqing Municipal Market Supervision Bureau and Sichuan Provincial Market Supervision Bureau held a joint law enforcement cooperation meeting within the framework of Sichuan-Chongqing cooperation to guide the handling of the case, and handed the case over to Luzhou Municipal Market Supervision Bureau for handling.
According to the investigation by the Luzhou Municipal Market Supervision Bureau, the party concerned was established on March 12, 2024 and engaged in interior decoration services. In April 2024, it commissioned an advertising company to replace the “Yi Ge Decoration” on the billboard on the facade of the building with “Brothers Decoration”; and replaced the “Thangka Decoration” above the entrance hall, on the floor distribution sign, and on the front wall of the elevator room with “Brothers Decoration”.
The “Brother Decoration” logo used by the party in advertisements, shop signs and contracts is exactly the same as the registered trademark No. 52642360 “Brother Decoration” in terms of language, text composition, font, arrangement order, etc., and is the same trademark. It was also found that the party signed 23 contracts with consumers, with a total contract amount of 2.74 million RMB. The party’s use of the same logo as the registered trademark of the right holder in advertisements, shop signs and contracts without permission constitutes an infringement of the exclusive right to a registered trademark as stipulated in Article 57 (1) of the Trademark Law of the People’s Republic of China. Because the party is suspected of committing a crime, the Luzhou Municipal Market Supervision Bureau has transferred the case to the public security organs for handling.
United States and China Announce Temporary 115 Percent Reduction in Tariffs While Trade Discussions Continue
After negotiations over the weekend in Geneva, Switzerland, the United States and China reached a new trade deal on Monday, May 12, 2025, to temporarily slash tariffs on each country’s goods by 115 percent for the next 90 days. President Trump issued an executive order the same day reflecting this modification, reducing the 125% “reciprocal” tariff levied on Chinese imports on April 10, 2025, to ten percent. In turn, China will remove the retaliatory tariffs imposed on U.S. imports since April 4, 2025, but will retain a ten percent tariff. The revision to the “reciprocal” tariff will be effective on or after 12:01 a.m. Eastern Daylight Time on May 14, 2025, as the United States and China continue discussions on economic and trade relations.
All other duties imposed on China by the Trump Administration remain in effect, including:
Tariffs ranging from 7.5 to 25 percent imposed on certain categories of imports from China pursuant to Section 301 of the Tariff Act of 1974 (Section 301);
25 percent tariffs on imports of aluminum, steel and cars and car parts implemented pursuant to Section 232 of the Trade Expansion Act of 1962 (Section 232); and
20 percent tariffs on all imports from China imposed under the International Emergency Economic Powers Act (IEEPA) in response to the fentanyl national emergency.
The U.S. and China trade deal follows on the heels of a recent “Economic Prosperity Deal” reached between the United States and the United Kingdom last Thursday, May 8, 2025, which addressed, amongst other things, removal of barriers to make it easier for American and British businesses to operate, invest and trade in both countries. In particular, the United States agreed to exclude UK steel and aluminum from the Section 232 25% duties on imports of steel and aluminum and cut Section 232 tariffs on UK cars and car parts coming into the United States from 25% to 10% for the first 100,000 UK cars.
These trade deals work to address the Trump Administration’s concern over trade imbalances and to deliver, according to the White House, “real, lasting benefits to American workers, farmers and businesses.”
Compelling Rationale for Producing Proprietary Products in U.S. Found in USTR’s Special 301 Report on IP Protection and Enforcement Abroad (Part I)
While the current Trump Administration has based its global trade war on trade imbalances stemming from unfair trade practices of foreign countries, its weapon of choice—increased tariffs—is designed to encourage businesses to relocate manufacturing operations to the U.S., thereby boosting American employment and industrial capacity. The U.S. Trade Representative’s 2025 Special 301 Report, issued on April 29, provides an independent justification for onshoring or reshoring manufacturing, namely the failure of certain trading partners to adequately protect and enforce intellectual property (IP) rights of U.S. IP holders within their borders.
The Special 301 Report is an annual report that evaluates the adequacy and effectiveness of IP protection and enforcement among U.S. trading partners. USTR requested written submissions from the public through a notice published in the Federal Register on December 6, 2024. USTR later conducted a public hearing that provided the opportunity for interested persons to testify before the interagency Special 301 Subcommittee of the Trade Policy Staff Committee (TPSC) about issues relevant to the review. The hearing featured testimony from many witnesses, including representatives of foreign governments, industry, and non-governmental organizations.
USTR reviewed more than 100 trading partners for this year’s Special 301 Report and placed 26 of them on the Priority Watch List or Watch List. The countries on these watch lists are the “countries that have the most onerous or egregious acts, policies, or practices and whose acts, policies, or practices have the greatest adverse impact (actual or potential) on relevant U.S. products.” In this year’s report, trading partners on the Priority Watch List present the most significant concerns regarding insufficient IP protection or enforcement or actions that otherwise limited market access for persons relying on intellectual property protection. Eight countries are on the Priority Watch List: Argentina, Chile, China, India, Indonesia, Mexico, Russia, and Venezuela. According to the report, these countries will be the subject of “particularly intense bilateral engagement during the coming year.” For those failing to address U.S. concerns, the report warns, “USTR will take appropriate actions, which may include enforcement actions under Section 301 of the Trade Act or pursuant to World Trade Organization (WTO) or other trade agreement dispute settlement procedures.”
The 2025 Special 301 report further notes that an important part of the mission of USTR is to support and implement the Administration’s commitment to protect American jobs and workers and to advance the economic interests of the United States. “Fostering innovation and creativity is essential to U.S. economic growth, competitiveness, and the estimated 63 million American jobs that directly or indirectly rely on intellectual property (IP)-intensive industries.” These include manufacturers, technology developers, apparel makers, software publishers, agricultural producers, and producers of creative and cultural works. “Together, these industries generate 41% of the U.S. gross domestic product (GDP). The 47.2 million workers that are directly employed in IP-intensive industries also enjoy pay that is, on average, 60% higher than workers in non-IP-intensive industries.”
According to the report, a common problem with those countries on the Priority Watch List is IP infringement:
IP infringement, including patent infringement, trademark counterfeiting, copyright piracy, and trade secret theft, causes significant financial losses for right holders and legitimate businesses. IP infringement can undermine U.S. competitive advantages in innovation and creativity, to the detriment of American workers and businesses. In its most pernicious forms, IP infringement endangers the public, including through exposure to health and safety risks from counterfeit products, such as semiconductors, automobile parts, apparel, footwear, toys, and medicines. In addition, trade in counterfeit and pirated products often fuels cross-border organized criminal networks, increases the vulnerability of workers to exploitative labor practices, and hinders sustainable economic development in many countries.
Inadequate and ineffective IP protection and enforcement is hardly a new complaint by the U.S. government regarding trading partners such as China—it is a chronic problem. Still, the USTR Special 301 Report should serve as a warning to U.S. IP holders that these IP threats are real and not going away, at least anytime soon. While sourcing innovative products from lower cost countries with less regulatory burdens supports short-term profitability objectives, it can come at a steep long-term cost as many companies have learned. The loss or diminution of IP rights due to substandard IP protection and enforcement regimes abroad can cause significant damage to enterprise value, including enabling competition by infringers to rise up. This constant threat in the new “America First” era in which higher tariffs are the norm, however, may cause IP-intensive businesses to rethink their sourcing strategy and decide to onshore or reshore the production of proprietary products or components. Though the U.S. IP laws are imperfect, they are still considered the gold standard by many, including the U.S. Chamber of Commerce, and thus provide a better support system for long-term protection and enforcement of IP and financial success.
Continued Developments in the Anti-Bribery/Anti-Corruption Sector: A Potential Expansion of the International Anti-Corruption Prosecutorial Taskforce on the Horizon
There have been a number of developments in the anti-bribery/anti-corruption sector following the start of President Trump’s second term. First, on February 5th, Attorney General Pamela Bondi issued a memo titled, “Total Elimination of Cartels and Transnational Criminal Organizations” in which she instructed the Foreign Corrupt Practices Act (FCPA) Unit at DOJ to focus on “investigations related to foreign bribery that facilitate the criminal operations of Cartels” and Transnational Criminal Organizations (TCOs). She also suspended the requirement that the Fraud Section lead investigations involving the FCPA and Foreign Extortion Prevention Act if the investigation is into “foreign bribery associated with Cartels and TCOs.”
That memo was followed by President Trump signing Executive Order 14209 titled, “Pausing Foreign Corrupt Practices Act Enforcement to Further American Economic and National Security.” In that order, President Trump noted that FCPA enforcement has been “stretched beyond proper bounds and abused in a manner that harms” the U.S. He further explained that FCPA enforcement compromises the U.S.’s foreign policy goals, “the President’s Article II authority over foreign affairs,” national security, and the ability of the U.S. “and its companies gaining strategic business advantages.” President Trump ordered Attorney General Bondi to revise DOJ guidelines and policies related to the FCPA, require new FCPA investigations and enforcement actions to have Attorney General Bondi’s approval, review pending FCPA investigations and enforcement actions to ensure their compliance with the order, and identify whether any remedial actions are necessary. This order was accompanied by a fact sheet that echoed the points described above.
In response to the federal government’s shift with FCPA enforcement, states have indicated they may step up their bribery enforcement actions. For example, California’s Attorney General Rob Bonta issued a legal advisory “reminding businesses operating in California that it is illegal to make payments to foreign-government officials to obtain or retain business.” Attorney General Bonta explained that FCPA violations can be the basis for actions under California’s Unfair Competition Law. Similarly, the District Attorney for Manhattan shared that his office was exploring methods for taking on various enforcement priorities that the DOJ has indicated it will not be pursuing as heavily as it once did, including domestic bribery and corruption.
Internationally, the UK, France, and Switzerland announced the launch of the International Anti-Corruption Prosecutorial Taskforce. The taskforce includes (1) the UK’s Serious Fraud Office, (2) France’s National Financial Prosecutor’s Office, and (3) the Office of the Attorney General of Switzerland. Among other things, the taskforce announced its commitment to tackling “the significant threat of bribery and corruption and the severe harm that it causes.” The taskforce also noted that it would “invite other like-minded agencies” to join the taskforce’s efforts. To accomplish its goal, the taskforce identified four action items: (1) regularly exchanging “insight and strategy,” (2) “devising proposals for co-operation on cases,” (3) sharing best practices “to make full use of” the taskforce’s “combined expertise,” and (4) “seizing opportunities for operational collaboration.”
Last week, Jean-Francois Bohnert, the head of France’s agency tasked with bringing enforcement actions against, among other things, corruption, mentioned that other countries have contacted the taskforce to discuss their interest in potentially cooperating with the taskforce. Those countries included Germany, Italy, the Netherlands, Spain, and multiple unnamed countries in Latin America.
These developments have led some to question the trajectory of the FCPA enforcement landscape for the duration of the Trump administration. That said, speculation that FCPA enforcement would be relatively non-existent appears to be overstated at this point given that although the federal government has refrained from proceeding with some pending FCPA trials, they have proceeded with others. As for state enforcement actions in this area, it remains to be seen just how robust those actions can be given restrictions such as jurisdictional limitations and limited state resources (which are already stretched in numerous areas currently).
Given these considerations, the International Anti-Corruption Prosecutorial Taskforce is poised to have a significant impact on the anti-bribery/anti-corruption enforcement landscape. If additional countries join (which it appears that at least some number of countries may join or otherwise assist the taskforce), then the taskforce’s impact in this sector will be heightened. It would not be surprising to see the taskforce take on a role similar to the role the federal government held in prior years with respect to anti-bribery/anti-corruption investigations that encompass multiple countries. Companies should thus ensure they continue to maintain robust compliance programs, and properly functioning compliance programs are even more essential for those companies operating overseas.
Cross-Border Catch-Up: Understanding Chile’s Karin Law on Harassment and Violence [Podcast]
In this episode of our Cross-Border Catch-Up podcast series, Goli Rahimi (Chicago) and Lina Fernandez (Boston) discuss Chile’s new Karin Law, officially known as Law Number 21.647, and break down the law’s key provisions and its implications for employers. Lina and Goli explain how this comprehensive legislation aims to prevent and address workplace harassment and violence by establishing clear definitions, procedures, and preventive measures to promote safer and more respectful work environments. They also outline the responsibilities of employers to create internal protocols, educate employees on how to report misconduct, and investigate complaints in a timely manner.
TPS Program Updates (May 13, 2025)
This post serves as a regularly updated resource to keep employers informed regarding TPS designations, extensions, cancellations, and other policy changes. This post was last updated on April 2, 2025.
Afghanistan
DHS Secretary Kristin Noem determined that the country conditions in Afghanistan no longer merit Temporary Protected Status (TPS) in the United States and that designation will not be renewed. The program will expire on May 20, 2025. Afghani citizens holding TPS will revert to the status they held prior to their grant of TPS status, unless they have acquired another immigration status allowing them to lawfully remain in the United States.
Cameroon
DHS Secretary Kristin Noem determined that the country conditions in Cameroon no longer merit Temporary Protected Status (TPS) in the United States and that designation will not be renewed. The program will expire on June 7, 2025. Citizens of Cameroon holding TPS will revert to the status they held prior to their grant of TPS status, unless they have acquired another immigration status allowing them to lawfully remain in the United States.
Our previous discussions about TPS can be found in our original blog entry.