On March 11 and 12, the Office of the United States Trade Representative (USTR) announced two sets of investigations under Section 301 of the Trade Act of 1974. While tariffs are not a guaranteed outcome of these new...more
While the US Supreme Court ruled on February 20 that the International Emergency Economic Powers Act (IEEPA) does not authorize the President to impose tariffs, the Court did not address the question of how duties assessed...more
3/5/2026
/ Constitutional Challenges ,
Court of International Trade ,
Customs and Border Protection ,
Imports ,
International Emergency Economic Powers Act (IEEPA) ,
Lack of Authority ,
Learning Resources Inc v Trump ,
Reimbursements ,
Risk Management ,
Statutory Interpretation ,
Tariffs ,
Trump Administration ,
Trump v VOS Selections ,
US Trade Policies
The US Supreme Court (Court) ruled on Friday, February 20, by a 6-3 vote, that the International Emergency Economic Powers Act (IEEPA) “does not authorize the President to impose tariffs.” ...more
2/23/2026
/ Constitutional Challenges ,
Court of International Trade ,
International Emergency Economic Powers Act (IEEPA) ,
Learning Resources Inc v Trump ,
Refunds ,
SCOTUS ,
Section 301 ,
Statutory Interpretation ,
Tariffs ,
Trade Agreements ,
Trump Administration ,
Trump v VOS Selections ,
US Trade Policies
The Trump Administration, through the Office of Foreign Assets Control (OFAC), has issued a series of new Venezuela General Licenses (GLs) building off of the initial trading and diluent authorizations it recently published...more
The Trump Administration has issued two new General Licenses (GLs) authorizing limited engagement in Venezuela’s oil trading sector. More licenses are anticipated in the coming days or weeks, affecting upstream and downstream...more
This year’s National Defense Authorization Act (NDAA), signed into law on December 18, 2025, introduces a series of US defense policy updates, ranging from reform of the defense acquisition system and workforce development to...more
On October 22, 2025 the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned Open Joint Stock Company Rosneft Oil Company (Rosneft) and Lukoil OAO (Lukoil), placing both companies, including all...more
As anticipated, the US Department of Commerce Bureau of Industry and Security (BIS) issued an interim final rule to expand certain end-user restrictions under the Export Administration Regulations (EAR) to entities that are...more
On May 23, 2025, the Office of Foreign Assets Control (OFAC) issued General License 25 (GL 25), authorizing transactions prohibited by the Syrian Sanctions Regulations, effectively lifting sanctions on Syria. This comes 10...more
5/30/2025
/ Banking Sector ,
Economic Sanctions ,
Energy Sector ,
EU ,
Foreign Policy ,
Investment ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Syria ,
Trump Administration ,
UK
The new US-UK Economic Prosperity Deal (“EPD”), announced last week (8 May 2025), is promising to bring back economic stability and will be welcomed by businesses at a time of increased geopolitical uncertainty....more
On April 2, 2025, the Trump Administration announced new, comprehensive tariff rates representing the most significant change in US trade policy in a generation—a paradigm shift from an era of low tariffs to an approach based...more
4/10/2025
/ China ,
Executive Orders ,
International Emergency Economic Powers Act (IEEPA) ,
International Trade ,
Reciprocity Rules ,
Regulatory Agenda ,
Retaliatory Tariffs ,
Tariffs ,
Trade Relations ,
Trade Wars ,
Trump Administration ,
US Trade Policies
On 2 April 2025, President Trump announced new tariffs on all imports into the United States. In this briefing, we summarise the key measures and the expected impact on global trade.
The new “reciprocal” tariffs -
The...more
4/4/2025
/ Canada ,
China ,
EU ,
Executive Orders ,
India ,
International Trade ,
Mexico ,
South Korea ,
Tariffs ,
Trade Relations ,
Trump Administration ,
UK ,
United States-Mexico-Canada Agreement (USMCA) ,
US Trade Policies ,
Vietnam
On February 21, 2025, President Trump issued a memorandum “America First Investment Policy” (the Investment Memo or Memo), in which the President aims to modify the US Government’s approach to inbound and outbound foreign...more
In his first tangible action implementing his campaign promise to impose broad tariffs, on February 1, 2025, President Trump issued three Executive Orders (the EOs) directing that across-the-board tariffs be imposed on goods...more
2/11/2025
/ Canada ,
China ,
Energy Sector ,
Executive Orders ,
Imports ,
International Emergency Economic Powers Act (IEEPA) ,
Legislative Agendas ,
Mexico ,
National Security ,
Regulatory Agenda ,
Tariffs ,
Trade Act of 1974 ,
Trump Administration
On February 5, 2025, the US Department of Justice (DOJ) issued two memoranda, General Policy Regarding Charging, Plea Negotiations, and Sentencing and Total Elimination of Cartels and Transnational Criminal Organizations,...more
2/10/2025
/ Anti-Bribery ,
Anti-Money Laundering ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement Actions ,
Enforcement Priorities ,
Export Controls ,
Foreign Corrupt Practices Act (FCPA) ,
Human Trafficking ,
Immigration Enforcement ,
Immigration Reform ,
National Security ,
Trump Administration
On January 15, 2025, the US Department of Commerce Bureau of Industry and Security (BIS) published an interim final rule (IFR) that imposes new controls on advanced computing integrated circuits (Advanced ICs) and certain...more
1/20/2025
/ Artificial Intelligence ,
Bureau of Industry and Security (BIS) ,
Export Controls ,
Final Rules ,
Foreign Policy ,
Interim Final Rules (IFR) ,
National Security ,
Regulatory Agenda ,
Supply Chain ,
Technology Sector ,
U.S. Commerce Department
On January 10, 2025, the Biden Administration issued a broad sanctions package targeting the Russian energy sector, 10 days in advance of the transition to the incoming Trump Administration. The new sanctions also added two...more
1/14/2025
/ Biden Administration ,
Blocked Person ,
Department of Energy (DOE) ,
Economic Sanctions ,
Energy Sector ,
Enforcement Actions ,
Foreign Policy ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Russia ,
U.S. Treasury ,
UK
On June 21, 2024, the US Department of the Treasury (Treasury) released proposed new federal regulations (Proposed Rules) that, if implemented, would prohibit or require notification of a broad range of outbound investment...more
7/9/2024
/ Advanced Notice of Proposed Rulemaking (ANPRM) ,
China ,
Covered Person ,
Covered Transactions ,
Data Privacy ,
Data Security ,
Foreign Persons ,
Information Technology ,
Investment ,
National Security ,
Popular ,
Prohibited Transactions ,
Proposed Regulation ,
Regulatory Agenda ,
U.S. Treasury
The measure also harmonizes Russia sanctions rules with allies, and intensifies penalties against Iran -
The National Security Act, 2024 (Pub. L No 118-50) was enacted on April 24, 2024. In addition to the Act’s provisions...more
4/29/2024
/ China ,
EU ,
Export Administration Regulations (EAR) ,
Export Controls ,
Foreign Direct Product Rule ,
Iran ,
National Security ,
Regulatory Agenda ,
Regulatory Reform ,
Russia ,
Sanction Violations ,
Statute of Limitations ,
Trade Policy ,
UK
Contemporaneous with the European Union’s adoption of its 13th package of Russia sanctions, on February 23, 2024, the United States imposed sanctions against nearly 500 targets in continued response to Russia’s aggression...more
2/27/2024
/ Biden Administration ,
Defense Sector ,
Economic Sanctions ,
Executive Orders ,
Federal Procurement Systems ,
Financial Institutions ,
Financial Transactions ,
FinTech ,
Foreign Policy ,
General Licenses ,
Military Conflict ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Payment Systems ,
Russia ,
Russian Military Procurement ,
SDN List ,
Ukraine ,
US State Departments
In response to an agreement reached on Tuesday between President Nicolás Maduro’s representatives and the Venezuelan political opposition about a road map for the 2024 Venezuelan presidential election, on October 18, the...more
After months of deliberation, on August 9, 2023, President Biden issued the executive order “Addressing United States Investments in Certain National Security Technologies and Products in Countries of Concern” (Order), with...more
On July 31, 2023, the US Department of the Treasury-led Committee on Foreign Investment in the United States (CFIUS or the Committee) released its annual report for calendar year 2022 (2022 Report), which provides insight...more
On May 19, 2023, the Biden Administration along with leaders of the Group of Seven (G7), unveiled a new package of sanctions. The G7 leaders released a joint statement reaffirming their commitment to offer “the financial,...more
6/6/2023
/ Biden Administration ,
Bureau of Industry and Security (BIS) ,
Defense Sector ,
Economic Sanctions ,
Energy Sector ,
Entity List ,
Evasion ,
Executive Orders ,
Export Controls ,
Foreign Policy ,
G7 ,
General Licenses ,
Military Conflict ,
Office of Foreign Assets Control (OFAC) ,
Prohibited Transactions ,
Russia ,
SDN List ,
Third-Party ,
U.S. Commerce Department ,
Ukraine
On April 19, 2023, the US Department of Commerce Bureau of Industry and Security (BIS) entered into a settlement agreement wherein Seagate Technology LLC and Seagate Singapore International Headquarters Pte. Ltd....more
4/27/2023
/ Bureau of Industry and Security (BIS) ,
Civil Monetary Penalty ,
Enforcement Actions ,
Entity List ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Huawei ,
Sanction Violations ,
Settlement Agreements ,
U.S. Commerce Department