On May 23, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Syria General License 25 (GL 25), effectively lifting most sanctions imposed under the Syrian Sanctions Regulations (SSR) (31...more
On May 12, President Trump issued an executive order, “Modifying Reciprocal Tariff Rates to Reflect Discussions with the People’s Republic of China” (the Order), temporarily lowering reciprocal tariffs on Chinese imports that...more
5/15/2025
/ China ,
Customs and Border Protection ,
Executive Orders ,
Foreign Policy ,
Foreign Relations ,
Imports ,
order ,
Retaliatory Tariffs ,
Section 301 ,
Tariffs ,
Trade Relations ,
Trump Administration ,
US Trade Policies
On April 30, 2025, Senators Mark Kelly (D-AZ) and Todd Young (R-IN) — joined by a bipartisan group of Senate and House sponsors — reintroduced the Shipbuilding and Harbor Infrastructure for Prosperity and Security (SHIPS) for...more
5/6/2025
/ China ,
Economic Sanctions ,
Imports ,
Infrastructure ,
International Trade ,
Legislative Agendas ,
Maritime Transport ,
National Security ,
Proposed Legislation ,
Shipbuilding ,
Shipping ,
Shipping Cargo ,
Supply Chain ,
Trade Policy ,
USTR ,
Vessels
On April 29, President Trump issued a new proclamation, “Amendments to Adjusting Imports of Automobiles and Automobile Parts into the United States,” modifying Proclamation 10908 “Adjusting Imports of Automobiles and...more
5/1/2025
/ Automotive Industry ,
Critical Infrastructure Sectors ,
Customs and Border Protection ,
Executive Orders ,
Imports ,
Manufacturers ,
Motor Vehicles ,
OEM ,
Regulatory Reform ,
Supply Chain ,
Tariffs ,
Trump Administration ,
U.S. Commerce Department ,
US Trade Policies
On April 17, the Office of the United States Trade Representative (USTR) announced proposed trade actions under Section 301 of the Trade Act of 1974 (Trade Act) to counteract China’s systemic dominance in the maritime,...more
4/23/2025
/ China ,
Economic Sanctions ,
Foreign Policy ,
Foreign Relations ,
Liquid Natural Gas ,
Maritime Transport ,
National Security ,
Ports ,
Section 301 ,
Shipping ,
Supply Chain ,
Tariffs ,
Trade Policy ,
Trump Administration ,
USTR ,
Vessels
On April 9, the President signed an executive order titled “Restoring America’s Maritime Dominance” (the Order), a comprehensive initiative aimed at reversing decades of decline in the U.S. maritime industry. Citing national...more
4/16/2025
/ China ,
Department of Defense (DOD) ,
Executive Orders ,
Foreign Relations ,
Imports ,
Maritime Transport ,
National Security ,
Shipping ,
Shipping Cargo ,
Supply Chain ,
Trade Policy ,
Trump Administration ,
USTR ,
Vessels
On April 11, the White House released a Presidential Memorandum, “Clarification of Exceptions Under Executive Order 14257 of April 2, 2025, as Amended,” which exempts a list of semiconductors and electronics from reciprocal...more
4/16/2025
/ Cell Phones ,
China ,
Critical Infrastructure Sectors ,
Executive Orders ,
Foreign Policy ,
Foreign Relations ,
Imports ,
Innovative Technology ,
Regulatory Reform ,
Semiconductors ,
Suppliers ,
Supply Chain ,
Tariffs ,
Trump Administration ,
U.S. Commerce Department ,
US Trade Policies ,
Wireless Technology
President Trump signed a new executive order, “Modifying Reciprocal Tariff Rates to Reflect Trading Partner Retaliation and Alignment” (the Order) on April 9, marking yet another significant shift in U.S. trade policy. The...more
4/14/2025
/ China ,
Executive Orders ,
Exports ,
Foreign Policy ,
Foreign Relations ,
Imports ,
Retaliatory Tariffs ,
Tariffs ,
Trade Relations ,
Trade Wars ,
Trump Administration ,
US Trade Policies
On February 10, President Trump issued Proclamations 10896, “Adjusting Imports of Steel Into the United States” and 10895 “Adjusting Imports of Aluminum Into the United States,” (together, Proclamations), reasserting U.S....more
4/11/2025
/ Aluminum Sales ,
Construction Project ,
Customs and Border Protection ,
Foreign Trade Zones ,
Harmonized Tariff Schedule of the United States (HTSUS) ,
Imports ,
Infrastructure ,
Section 232 ,
Steel Industry ,
Supply Chain ,
Tariffs ,
Trade Expansion Act of 1962 ,
Trump Administration ,
US Trade Policies
On March 26, President Trump issued Proclamation 10908, “Adjusting Imports of Automobiles and Automobile Parts Into the United States” (Proclamation), imposing a 25% additional tariff on imports of passenger vehicles, light...more
4/9/2025
/ Automotive Industry ,
Canada ,
Executive Orders ,
Foreign Trade Regulations ,
Foreign Trade Zones ,
Harmonized Tariff Schedule of the United States (HTSUS) ,
Imports ,
Infrastructure ,
Japan ,
Mexico ,
Motor Vehicles ,
National Security ,
Popular ,
Section 232 ,
Supply Chain ,
Tariffs ,
Trade Expansion Act of 1962 ,
Trump Administration ,
U.S. Commerce Department ,
United States-Mexico-Canada Agreement (USMCA) ,
US Trade Policies
On April 2, President Trump declared “Liberation Day” and unveiled a series of sweeping tariff measures aimed at addressing trade imbalances and foreign trade practices while boosting domestic manufacturing. Marking the...more
4/8/2025
/ Canada ,
China ,
Executive Orders ,
Foreign Policy ,
Foreign Relations ,
Goods or Services ,
Harmonized Tariff Schedule of the United States (HTSUS) ,
International Emergency Economic Powers Act (IEEPA) ,
International Trade ,
Mexico ,
Popular ,
Retaliatory Tariffs ,
Supply Chain ,
Tariffs ,
Trump Administration ,
United States-Mexico-Canada Agreement (USMCA) ,
US Trade Policies
On March 25, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) announced a significant expansion of its Entity List restrictions, adding 80 entities from China, the United Arab Emirates, South Africa,...more
3/28/2025
/ Artificial Intelligence ,
Bureau of Industry and Security (BIS) ,
China ,
Corporate Counsel ,
Economic Sanctions ,
Enforcement Actions ,
Entity List ,
Export Administration Regulations (EAR) ,
Export Controls ,
Foreign Policy ,
Foreign Relations ,
Machine Learning ,
National Security ,
Regulatory Reform ,
Technology Sector ,
Trump Administration ,
U.S. Commerce Department ,
US Trade Policies
On April 2 — labeled “Liberation Day” by President Trump — the Trump administration is set to add a new sanctions-like boost to its tariff strategy, with a threat to impose unprecedented “secondary tariffs” of 25% on “all...more
3/28/2025
/ Corporate Counsel ,
Economic Sanctions ,
Executive Orders ,
Foreign Policy ,
Foreign Relations ,
Infrastructure ,
Mexico ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Regulatory Oversight ,
Secondary Sanctions ,
Secretary of Commerce ,
Tariffs ,
Trump Administration ,
U.S. Commerce Department ,
United States-Mexico-Canada Agreement (USMCA) ,
US Trade Policies ,
Venezuela
On March 20, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued a final rule extending the recordkeeping requirements under OFAC’s regulations from five years to 10 years. This change...more
3/26/2025
/ Anti-Money Laundering ,
BSA/AML ,
Corporate Counsel ,
Cuban Assets Control Regulations (CACR) ,
Economic Sanctions ,
EU ,
Final Rules ,
Financial Institutions ,
International Emergency Economic Powers Act (IEEPA) ,
Office of Foreign Assets Control (OFAC) ,
Recordkeeping Requirements ,
Regulatory Reform ,
Regulatory Requirements ,
Terrorist Financing Regulations ,
Trading with the Enemy Act ,
U.S. Treasury
Following a petition from five national labor unions seeking an investigation into China’s policies and practices aimed at dominating the maritime, logistics, and shipbuilding industries, the U.S. Trade Representative (USTR)...more
As outlined in our recent publication, the United States imposed a 25% additional tariff on all imports from Canada and Mexico starting March 4, with a 10% tariff specifically on Canadian energy products and potash (the...more
3/17/2025
/ Ad Valorem Tax ,
Canada ,
Customs and Border Protection ,
Energy Policy ,
Executive Orders ,
Goods or Services ,
Imports ,
International Emergency Economic Powers Act (IEEPA) ,
Mexico ,
Popular ,
Supply Chain ,
Tariffs ,
Trump Administration ,
United States-Mexico-Canada Agreement (USMCA) ,
US Trade Policies
On March 12, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) allowed General License (GL) 8L under the Russian Harmful Foreign Activities Sanctions Regulations to expire. As a result, broad OFAC...more
3/14/2025
/ Banks ,
Biden Administration ,
Biofuel ,
Economic Sanctions ,
Financial Transactions ,
Foreign Policy ,
Foreign Relations ,
General Licenses ,
Natural Gas ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Popular ,
Prohibited Transactions ,
Russia ,
SDN List ,
Secondary Sanctions ,
Trump Administration ,
U.S. Treasury
The Trump administration continues to ramp up sanctions on Venezuela and Yemen's Houthis, while sending mixed signals about its intentions with respect to Russia. We provide brief updates on these three areas, following up...more
3/11/2025
/ Economic Sanctions ,
Foreign Policy ,
Foreign Relations ,
General Licenses ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Popular ,
Regulatory Reform ,
Russia ,
Terrorist Organizations ,
Trump Administration ,
U.S. Treasury ,
US Trade Policies ,
Venezuela ,
Yemen
Last week consisted of many developments surrounding President Trump's tariff policy. On March 4, his sweeping new tariffs took effect, significantly altering the trade landscape for businesses engaged in international...more
3/10/2025
/ Canada ,
China ,
Executive Orders ,
Exports ,
Foreign Policy ,
Foreign Trade Regulations ,
Goods or Services ,
Imports ,
Infrastructure ,
International Emergency Economic Powers Act (IEEPA) ,
Mexico ,
Popular ,
Retaliatory Tariffs ,
Supply Chain ,
Tariffs ,
Trade Relations ,
Trump Administration ,
United States-Mexico-Canada Agreement (USMCA) ,
US Trade Policies
With Form ADV annual updating amendments due for many investment advisers by the end of next month, advisers should consider whether to update their proxy voting policies and related disclosure in Part 2A, Item 17 in light of...more
On February 20, 2025, the U.S. Departments of State and the Treasury designated eight Latin American drug trafficking cartels as Foreign Terrorist Organizations (FTOs) and Specially Designated Global Terrorists (SDGTs), in...more
2/25/2025
/ Anti-Terrorism Financing ,
Cartels ,
Cooperative Compliance Regime ,
Criminal Prosecution ,
Economic Sanctions ,
Enforcement Actions ,
Financial Crimes ,
Foreign Policy ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Sanction Violations ,
SDN List ,
Terrorist Financing Regulations ,
Trafficking ,
Trump Administration
A groundbreaking new regulatory regime, imposing rules unlike any in existing U.S. law, may surprise many companies due to its sudden adoption and complexity. This article tries to simplify the changing regulatory landscape,...more
2/19/2025
/ China ,
Cybersecurity ,
Data Privacy ,
Data Protection ,
Data Security ,
Department of Justice (DOJ) ,
Federal Trade Commission (FTC) ,
Final Rules ,
Foreign Adversaries ,
Homeland Security Cybersecurity & Infrastructure Security Agency (CISA) ,
International Data Transfers ,
National Security ,
Protecting Americans Data from Foreign Adversaries Act (PADFA) ,
Regulatory Reform ,
Regulatory Requirements
Days before President Biden leaves the White House, the U.S. government has delivered a major blow against Russia. On January 10, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced...more
1/17/2025
/ Biden Administration ,
Economic Sanctions ,
Energy Sector ,
Export Controls ,
Foreign Policy ,
Infrastructure ,
Liquid Natural Gas ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Russia ,
SDN List ,
U.S. Treasury
The U.S. Department of Commerce's Bureau of Industry and Security (BIS) issued an Advance Notice of Proposed Rulemaking (ANPRM) on January 3, 2025, seeking public input to inform the potential development of a rule to secure...more
1/10/2025
/ Advanced Notice of Proposed Rulemaking (ANPRM) ,
Bureau of Industry and Security (BIS) ,
China ,
Cybersecurity ,
Data Security ,
Drones ,
National Security ,
Proposed Rules ,
Regulatory Agenda ,
Risk Assessment ,
Supply Chain ,
Technology Sector ,
U.S. Commerce Department ,
Unmanned Aircraft Systems
On January 2, 2025, the U.S. Department of Commerce's Bureau of Industry and Security (BIS) Export Enforcement published its 2024 Year in Review, spotlighting key accomplishments in protecting U.S. national security. In this...more