On February 20, 2026, the U.S. Supreme Court delivered a landmark decision in Learning Resources, Inc. v. Trump and the companion case Trump v. V.O.S. Selections, Inc., holding that the International Emergency Economic Powers...more
2/23/2026
/ Court of International Trade ,
Customs and Border Protection ,
International Emergency Economic Powers Act (IEEPA) ,
International Trade ,
Learning Resources Inc v Trump ,
Refunds ,
SCOTUS ,
Section 301 ,
Statutory Interpretation ,
Tariffs ,
Trade Act of 1974 ,
Trump Administration ,
US Trade Policies
The second Trump administration has focused heavily on trade regulation, including initiating several investigations under Section 232 of the Trade Expansion Act of 1962 (“Section 232 investigations”). Section 232...more
As 2025 comes to an end, one theme defines the global compliance landscape: volatility. Over the past twelve months, sanctions and export control regimes have shifted quickly as the second Trump administration reshaped...more
12/11/2025
/ Bureau of Industry and Security (BIS) ,
Cartels ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Entity List ,
Executive Orders ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Office of Foreign Assets Control (OFAC) ,
Trade Relations ,
Trump Administration
The new Bureau of Industry and Security (BIS) entity ownership rule published in the Federal Register on September 30, 2025 , marks a significant shift in U.S. export controls enforcement. The rule, which applies a "50...more
10/1/2025
/ Bureau of Industry and Security (BIS) ,
Compliance ,
Due Diligence ,
Economic Sanctions ,
Entity List ,
Export Administration Regulations (EAR) ,
Export Controls ,
International Trade ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Risk Management ,
Supply Chain ,
U.S. Commerce Department
The U.S. Department of Justice’s new Data Security Program (DSP) became effective on April 8, 2025, representing a major development in national security law that imposes rigorous requirements and enforcement mechanisms to...more
Section 847 of the National Defense Authorization Act (NDAA) for Fiscal Year 2020 marks a pivotal evolution in how the Department of Defense (DoD) approaches the risks of foreign ownership, control, or influence (FOCI) across...more
On February 10, 2025, President Trump issued two Proclamations announcing the reinstatement of the 25% tariff on all steel imports and the reinstatement and increase of tariffs on aluminum imports to 25% pursuant to Section...more
6/17/2025
/ Aluminum Sales ,
Bureau of Industry and Security (BIS) ,
Customs and Border Protection ,
Imports ,
National Security ,
Presidential Proclamations ,
Rulemaking Process ,
Section 232 ,
Steel Industry ,
Tariffs ,
Trade Expansion Act of 1962 ,
Trump Administration ,
US Trade Policies
With U.S. trade policy constantly evolving and Customs enforcement increasing, importers face more pressure than ever to ensure customs compliance from the beginning. One misstep – whether it is a misclassified product, an...more
5/2/2025
/ Corporate Counsel ,
Country of Origin ,
Customs ,
Customs and Border Protection ,
Enforcement ,
Imports ,
Penalties ,
Risk Management ,
Supply Chain ,
Tariffs ,
Trade Policy ,
United States-Mexico-Canada Agreement (USMCA) ,
Valuation
This article provides an overview of the most recent tariff updates affecting businesses operating within the semiconductor, pharmaceutical, and critical mineral industries. Below we outline recent tariff exclusions for...more
4/18/2025
/ Executive Orders ,
Imports ,
Investigations ,
National Security ,
Pharmaceutical Industry ,
Popular ,
Public Comment ,
Section 232 ,
Semiconductors ,
Supply Chain ,
Tariffs ,
Trump Administration ,
U.S. Commerce Department
On April 2, 2025, President Trump announced long-awaited reciprocal tariffs on imports of foreign goods into the United States. This action follows the President’s recent announcement on March 26, 2025, of a 25% tariff on...more
On February 21, 2025, President Trump issued a memorandum titled "America First Investment Policy" (the “Policy”), outlining new measures to shape U.S. investment policy. Though the Policy makes it clear that the United...more
Just two days after the tariffs on all Mexican and Canadian products became effective, on March 6, President Trump announced amendments to the tariffs against Mexico and Canada “to minimize disruption to the United States...more
Beginning just after midnight on March 4, 2025, the United States implemented a 25% tariff on imports from Canada and Mexico (except Canadian “energy resources,” which are subject to a 10% tariff), and increased tariffs on...more
3/4/2025
/ Canada ,
China ,
International Emergency Economic Powers Act (IEEPA) ,
International Trade ,
Mexico ,
Regulatory Agenda ,
Retaliatory Tariffs ,
Tariffs ,
Trade Relations ,
Trade Wars ,
Trump Administration ,
US Trade Policies
On February 13, 2025, President Trump issued a Presidential Memorandum on “Reciprocal Trade and Tariffs” (the “Reciprocal Tariffs Memorandum”), introducing the “Fair and Reciprocal Plan” to determine “the equivalent of a...more
3/3/2025
/ America First Trade Policy ,
International Trade ,
Presidential Memorandum ,
Risk Management ,
Section 301 ,
Tariffs ,
Trade Relations ,
Trump Administration ,
US Trade Policies ,
USTR ,
WTO
President Donald Trump has agreed to delay the implementation of tariffs on imports from Mexico and Canada for 30 days, following negotiations with the leaders of both countries. For more information about the threatened...more
2/5/2025
/ Antitrust Provisions ,
Canada ,
China ,
Export Controls ,
Imports ,
Legislative Agendas ,
Mexico ,
Regulatory Agenda ,
Supply Chain ,
Tariffs ,
Trade Relations ,
Trump Administration ,
US Trade Policies
On February 1, 2025, President Trump announced significant new tariffs on imports from Mexico, Canada, and China, set to take effect on February 4, 2025. The tariffs were announced via three separate Executive Orders (EOs)...more
On January 13, 2025, the Department of Commerce Bureau of Industry and Security (BIS) announced new rules restricting the export of advanced artificial intelligence (AI) chips and certain closed AI model weights in an...more
2/3/2025
/ Artificial Intelligence ,
Bureau of Industry and Security (BIS) ,
China ,
Compliance ,
Economic Sanctions ,
Export Controls ,
Foreign Direct Product Rule ,
International Trade ,
Licensing Rules ,
National Security ,
Semiconductors ,
Supply Chain ,
Technology Sector ,
U.S. Commerce Department
Senator Cornyn made the above statement on the Senate floor on November 14, 2023, while advocating for his colleagues to pass the Outbound Investment Transparency Act as part of the 2024 National Defense Authorization Act...more
2/3/2025
/ Advanced Notice of Proposed Rulemaking (ANPRM) ,
CFIUS ,
China ,
Economic Sanctions ,
Export Controls ,
FIRRMA ,
Foreign Direct Investment ,
Foreign Investment ,
Foreign Policy ,
Investment ,
Investors ,
National Security ,
NDAA ,
Technology Sector ,
Transparency
In this continued era of protectionist and mercantilist trade policies arising from the United States, there are strategies that can be carefully evaluated and pursued to maximize Customs duty savings when importing. This...more
On December 23, 2024, the Office of the United States Trade Representative (USTR) launched an investigation of China’s acts, policies, and practices related to targeting of the semiconductor industry for dominance. The...more
In addition to a myriad of issues to consider during M&A transactions, parties should conduct due diligence related to US trade regulations and the often-related foreign investment regulations that arise in the context of an...more
12/20/2024
/ Acquisitions ,
CFIUS ,
China ,
Compliance ,
Court of International Trade ,
Due Diligence ,
FIRRMA ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Investment ,
Imports ,
Mergers ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Publicly-Traded Companies ,
Regulatory Agenda ,
Regulatory Requirements ,
U.S. Customs ,
US Trade Policies
As deals increase in complexity, and ownership structures are oftentimes opaque and obfuscated, it is important to be mindful of CFIUS’s continued stance of requesting identities of Limited Partners (LPs) in transactions...more
The Department of Justice really wants violators of the Foreign Corrupt Practices Act (FCPA) to come forward: following a January 2023 revision of its Corporate Enforcement Policy that incentivized voluntary self-disclosure,...more
The U.S. Department of Commerce's Bureau of Industry and Security (BIS) just issued a significant rule change that reshapes the landscape of export control enforcement.
Published on September 16, 2024, the rule amends the...more
The U.S. Department of State Directorate of Defense Trade Controls is the regulatory organization charged with administering the body of export laws known as the International Traffic in Arms Regulations (ITAR)...more