In an April 2, 2026 Proclamation, the Trump administration made significant changes to the implementation of the existing tariffs on steel, copper, and aluminum products and derivative articles under Section 232 of the Trade...more
4/7/2026
/ Customs and Border Protection ,
Imports ,
International Trade ,
National Security ,
Section 232 ,
Supply Chain ,
Tariffs ,
Trade Agreements ,
Trump Administration ,
U.S. Commerce Department ,
US Trade Policies ,
USTR
On March 18, 2026, the U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC) issued Venezuela General License 52 (GL 52). The license broadly authorizes established U.S. entities to engage in transactions with...more
3/26/2026
/ Cross-Border Transactions ,
Economic Sanctions ,
Energy Sector ,
Executive Orders ,
Export Controls ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Reporting Requirements ,
U.S. Treasury ,
Venezuela
On March 5, news outlets reported that the U.S. government is drafting new export control regulations for AI chips. A copy of the draft regulations is not publicly available. According to reports, the draft regulations would...more
3/16/2026
/ Artificial Intelligence ,
Bureau of Industry and Security (BIS) ,
China ,
Export Administration Regulations (EAR) ,
Export Controls ,
International Trade ,
Machine Learning ,
National Security ,
Proposed Rules ,
Semiconductors ,
Technology Sector ,
Trump Administration ,
U.S. Commerce Department ,
US Trade Policies
In recent weeks, the U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC) has greatly expanded the scope of authorized activities and transactions that U.S. persons may undertake regarding energy projects in...more
2/24/2026
/ Economic Sanctions ,
Energy Projects ,
Energy Sector ,
Export Controls ,
General Licenses ,
International Trade ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Popular ,
Regulatory Requirements ,
Reporting Requirements ,
Sanctions ,
U.S. Treasury ,
Venezuela
On February 20, 2026, the U.S. Supreme Court issued a 6–3 decision (in Learning Resources v. Trump) holding 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 ,
Customs and Border Protection ,
Executive Orders ,
International Emergency Economic Powers Act (IEEPA) ,
International Trade ,
SCOTUS ,
Statutory Interpretation ,
Tariffs ,
Trump Administration ,
US Trade Policies
Following the removal of Venezuelan President Nicolás Maduro on January 3, 2026, the Trump administration has taken actions to expand Venezuela-related oil trade and investment opportunities, primarily for U.S. companies....more
2/10/2026
/ Critical Infrastructure Sectors ,
Economic Sanctions ,
Executive Orders ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Popular ,
Trump Administration ,
U.S. Treasury ,
US Trade Policies ,
Venezuela
In recent weeks, the Trump administration has taken several actions to implement its policy toward the export of advanced AI commodities to China. These include the Department of Commerce (Commerce) Bureau of Industry’s (BIS)...more
1/29/2026
/ Artificial Intelligence ,
Bureau of Industry and Security (BIS) ,
China ,
End-Users ,
Export Administration Regulations (EAR) ,
Export Controls ,
National Security ,
NVIDIA ,
Popular ,
Section 232 ,
Semiconductors ,
Tariffs ,
Trump Administration ,
USTR
On September 29, 2025, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) issued a long-anticipated interim final rule (IFR) amending the Export Administration Regulations (EAR) to extend Entity List and...more
10/3/2025
/ Affiliates ,
Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
Entity List ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Foreign Direct Product Rule ,
Foreign Entities ,
Foreign Relations ,
Foreign Trade Regulations ,
General Licenses ,
Interim Final Rules (IFR) ,
Majority Shareholders ,
Military End Use ,
Office of Foreign Assets Control (OFAC) ,
U.S. Commerce Department ,
US Trade Policies
In the past several weeks the Trump Administration has taken multiple actions on tariffs, based on several different legal authorities. The landscape is shifting almost continuously, and more changes are likely coming....more
Two days before its scheduled effective date, the Department of Commerce’s Bureau of Industry and Security (BIS) announced the rescission of the Biden administration’s Artificial Intelligence (AI) Diffusion Rule on May 13....more
Recent changes in U.S. trade policy necessitate a thorough understanding of FAR and DFARS clauses related to cost recovery, duties and taxes....more
5/8/2025
/ Contract Disputes ,
Contract Terms ,
Corporate Counsel ,
Defense Contracts ,
Department of Defense (DOD) ,
Federal Acquisition Regulations (FAR) ,
Government Agencies ,
Imports ,
Supply Chain ,
Tariffs ,
US Trade Policies
In recent years, a multinational focus on preventing forced labor within supply chains has shaped due diligence requirements for companies worldwide. Recent changes to global policies and potential shifts in enforcement...more
5/5/2025
/ Corporate Counsel ,
Customs and Border Protection ,
Due Diligence ,
Enforcement ,
EU ,
Forced Labor ,
Human Rights ,
Imports ,
International Trade ,
New Legislation ,
Supply Chain ,
Uyghur Forced Labor Prevention Act (UFLPA)
Between March 4, 2025, and March 6, 2025, U.S. trade policy in North America changed course multiple times as the Trump administration initially implemented previously paused tariffs on imports from Canada and Mexico, and two...more
3/11/2025
/ Canada ,
China ,
Duties ,
Imports ,
International Emergency Economic Powers Act (IEEPA) ,
International Trade ,
Mexico ,
Retaliation ,
Tariffs ,
Trade Policy ,
Trade Wars ,
Trump Administration ,
United States-Mexico-Canada Agreement (USMCA) ,
US Trade Policies ,
USTR
After months of anticipation, on February 1, 2025, President Trump announced the imposition of significant tariffs on Mexico, Canada, and China through three Executive Orders (EOs). While additional details are expected to be...more
2/2/2025
/ Canada ,
China ,
Imports ,
International Emergency Economic Powers Act (IEEPA) ,
Mexico ,
National Security ,
Supply Chain ,
Tariffs ,
Trade Relations ,
Trump Administration ,
US Trade Policies ,
WTO
On January 13, 2025, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) issued an Interim Final Rule (IFR), establishing new export controls targeting advanced artificial intelligence (AI) chips and model...more
1/24/2025
/ Artificial Intelligence ,
Bureau of Industry and Security (BIS) ,
Data Centers ,
Data Security ,
Export Administration Regulations (EAR) ,
Export Controls ,
Intellectual Property Protection ,
Machine Learning ,
National Security ,
Regulatory Requirements ,
Technology Sector
On January 15, 2025, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) released an interim final rule (IFR) updating export controls on advanced computing semiconductors. This IFR seeks to ensure that...more
Broad Tariff Increases Could Reshape Global Trade: The aggressive use of tariffs could create significant trade disruptions for businesses dependent on global supply chains, and pair novel use of authorities with existing...more
11/25/2024
/ Artificial Intelligence ,
CFIUS ,
China ,
Cuba ,
Dual Use Goods ,
Economic Sanctions ,
Export Controls ,
FIRRMA ,
Forced Labor ,
Foreign Investment ,
International Emergency Economic Powers Act (IEEPA) ,
International Trade ,
Iran ,
Jurisdiction ,
Middle East ,
Popular ,
Russia ,
Section 301 ,
Semiconductors ,
Supply Chain ,
Tariffs ,
Trade Act of 1974 ,
Trade Expansion Act of 1962 ,
United States-Mexico-Canada Agreement (USMCA) ,
USTR ,
Uyghur Forced Labor Prevention Act (UFLPA) ,
Venezuela
An Initial Roundup of Key Policy Issues and Expectations
The re-election of Donald Trump—empowered by at least a Republican-led Senate—marks a significant political and administrative change in the United States, with...more
11/8/2024
/ Affordable Care Act ,
China ,
Congressional Review Act ,
Corporate Counsel ,
Cryptocurrency ,
Deregulation ,
Energy Sector ,
Environmental Protection Agency (EPA) ,
Federal Budget ,
Foreign Investment ,
Foreign Policy ,
Immigration Procedures ,
Inflation Reduction Act (IRA) ,
Iran ,
Israel ,
Russia ,
Saudi Arabia ,
Securities and Exchange Commission (SEC) ,
Tariffs ,
Tax Cuts and Jobs Act ,
Trade Policy ,
Ukraine
On September 13, 2024 USTR announced modifications to the tariffs originally imposed under Section 301 of the Trade Act of 1974 to pressure China to eliminate unreasonable policies and practices related to technology transfer...more
9/23/2024
/ Batteries ,
China ,
Electric Vehicles ,
Imports ,
Section 301 ,
Semiconductors ,
Supply Chain ,
Tariffs ,
Trade Relations ,
US Trade Policies ,
USTR
On September 12, 2024, the Biden Administration announced a number of new trade-related measures related to imports of Chinese-manufactured goods. This announcement comes as the latest action in the Biden Administration’s...more
On September 5, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) issued an interim final rule imposing significant new export controls on quantum computing, cryocooling systems, semiconductor...more
On May 22, USTR followed up the recommendations in its March 14 report with specific proposals for increases in Section 301 tariffs.
There will be an exclusion process allowing interested parties to request temporary...more
On May 14, 2024, the U.S. Trade Representative (“USTR”) published the Four-Year Review of Actions Taken in the Section 301 Investigation (“Report”), which addresses the four-year review of China-related tariffs under Section...more
On April 30, 2024, the Department of State proposed an amendment to the International Traffic in Arms Regulations (ITAR) intended to facilitate exports of defense articles, the performance of defense services, and brokering...more
5/9/2024
/ AUKUS ,
Australia ,
Directorate of Defense Trade Controls (DDTC) ,
Exemptions ,
Export Controls ,
Exports ,
ITAR ,
Popular ,
Proposed Regulation ,
Proposed Rules ,
UK ,
US Department of State
On April 19, 2024, the Department of Commerce Bureau of Industry and Security (BIS) issued an interim final rule reducing export control licensing requirements for Australia and the United Kingdom (UK) as a means to further...more