President Trump exceeded his emergency authority when he imposed tariffs on Canadian, Chinese, and Mexican origin goods citing border issues, and global reciprocal tariffs the U.S. Court of International Trade (“CIT”) said on...more
5/30/2025
/ Appeals ,
Canada ,
China ,
Constitutional Challenges ,
Executive Orders ,
Injunctions ,
International Emergency Economic Powers Act (IEEPA) ,
International Trade ,
Judicial Authority ,
Mexico ,
Tariffs ,
Trump Administration ,
US Trade Policies
On May 12, 2025, President Trump issued an executive order temporarily reducing the “reciprocal” tariffs on China, Hong Kong, and Macau origin goods from 125% to 10%, and lowering tariffs imposed on international mail parcels...more
5/15/2025
/ Aircraft ,
Aircraft Equipment ,
China ,
Executive Orders ,
Hong Kong ,
International Emergency Economic Powers Act (IEEPA) ,
International Trade ,
Macau ,
Section 232 ,
Tariffs ,
Trade Relations ,
Trump Administration ,
UK ,
US Trade Policies
Not long after announcing new global “reciprocal” tariffs on imports from around the world at the beginning of April 2025, which we previously reported in a recent eUpdate, President Trump began modifying that tariff action....more
4/28/2025
/ China ,
Court of International Trade ,
Executive Orders ,
Imports ,
International Emergency Economic Powers Act (IEEPA) ,
International Trade ,
National Security ,
Popular ,
Section 232 ,
Section 301 ,
Tariffs ,
Trade Act of 1974 ,
Trump Administration ,
USTR
On April 2, 2025, President Trump announced a new 10% global “reciprocal” tariff on U.S. imports from all countries, with higher tariff rates for a large number of countries that range from 11 to 50% ad valorem (the...more
4/7/2025
/ China ,
Customs and Border Protection ,
Executive Orders ,
Harmonized Tariff Schedule of the United States (HTSUS) ,
Hong Kong ,
Imports ,
International Emergency Economic Powers Act (IEEPA) ,
International Trade ,
Supply Chain ,
Tariff Act of 1930 ,
Tariffs ,
Trump Administration ,
US Trade Policies
On March 4, 2025, the Trump Administration imposed 25% import tariffs on nearly all Canadian and Mexican origin goods under the International Emergency Economic Powers Act (“IEEPA”)....more
3/10/2025
/ Aluminum Sales ,
America First Trade Policy ,
Canada ,
China ,
Executive Orders ,
International Emergency Economic Powers Act (IEEPA) ,
International Trade ,
Mexico ,
Section 232 ,
Steel Industry ,
Tariffs ,
Trump Administration ,
U.S. Commerce Department ,
United States-Mexico-Canada Agreement (USMCA) ,
US Trade Policies ,
USTR
On Saturday, February 1, 2025, the Trump Administration initially announced U.S. import tariffs on Canadian, Chinese, and Mexican origin products. These tariffs would have subjected many Canadian and Mexican origin products...more
2/7/2025
/ Canada ,
China ,
Executive Orders ,
Imports ,
International Emergency Economic Powers Act (IEEPA) ,
International Trade ,
Mexico ,
National Security ,
Retaliatory Tariffs ,
Section 301 ,
Tariffs ,
Trade Wars ,
Trump Administration ,
United States-Mexico-Canada Agreement (USMCA) ,
US Trade Policies
The U.S. Department of Justice (“DOJ”) published its final rule (“Final Rule”) on January 8, 2025, that will prohibit or restrict transfer of certain data of U.S. persons to countries of concern, including to China. The Final...more
1/15/2025
/ China ,
Compliance ,
Cybersecurity Information Sharing Act (CISA) ,
Data Privacy ,
Data Protection ,
Department of Justice (DOJ) ,
Executive Orders ,
Final Rules ,
International Data Transfers ,
International Emergency Economic Powers Act (IEEPA) ,
National Security ,
Personal Data ,
Privacy Laws ,
Regulatory Requirements ,
Sensitive Personal Information
The U.S. Department of Justice (“DOJ”) released a Notice of Proposed Rulemaking (“Proposed Rule”) on October 21 that would prohibit or restrict the transfer of certain data of U.S. persons to China and other countries of...more
In a notice published on September 9, 2024, announcing a proposed rule and request for comment (“Proposed Rule”), the U.S. Department of Commerce called for new reporting requirements for the development of certain advanced...more
10/3/2024
/ Artificial Intelligence ,
Biden Administration ,
Bureau of Industry and Security (BIS) ,
Data Collection ,
Data-Sharing ,
Defense Production Act ,
Defense Sector ,
Executive Orders ,
Know Your Customers ,
Machine Learning ,
NDAA ,
NPRM ,
Proposed Rules ,
Reporting Requirements ,
Software Developers ,
Technology ,
Technology Sector ,
U.S. Commerce Department
The U.S. Department of the Treasury (“Treasury”) issued a Notice of Proposed Rulemaking (“NPRM”) to implement Executive Order 14105 (“EO 14105”) “Addressing United States Investments in Certain National Security Technologies...more
7/19/2024
/ Biden Administration ,
China ,
Covered Transactions ,
Executive Orders ,
Foreign Investment ,
National Security ,
NPRM ,
Outbound Transactions ,
Popular ,
Proposed Rules ,
Technology ,
Technology Sector ,
U.S. Treasury
As the February 2022 Russian invasion of neighboring Ukraine approaches its second anniversary and as Russia has increasingly turned to covert relationships with third country providers to avoid U.S., European Union and other...more
2/6/2024
/ Banking Sector ,
CAPTA List ,
Economic Sanctions ,
Executive Orders ,
Foreign Financial Institutions (FFI) ,
Foreign Policy ,
Foreign Relations ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Russia
On August 9, President Biden issued Executive Order 14105 (“EO 14105”) on Addressing United States Investments in Certain National Security Technologies and Products in Countries of Concern. EO 14105 significantly reshapes...more
8/16/2023
/ Advanced Notice of Proposed Rulemaking (ANPRM) ,
Biden Administration ,
China ,
Civil Monetary Penalty ,
Economic Sanctions ,
Executive Orders ,
Foreign Investment ,
Hong Kong ,
Macau ,
National Security ,
Notice Requirements ,
Office of Foreign Assets Control (OFAC) ,
Outbound Transactions ,
Public Comment ,
Regulatory Agenda ,
Technology Sector ,
U.S. Commerce Department ,
U.S. Treasury
On September 15, 2022, President Biden issued Executive Order 14083 (“EO 14083”) that the White House describes as a “first-ever presidential directive defining additional national security factors for CFIUS to consider in...more
On June 6, 2022, the Office of Foreign Assets Control (“OFAC”) within the U.S. Department of the Treasury announced new Frequently Answered Questions (“FAQs”) that interpret several previous Executive Orders (“EOs”) issued by...more
6/10/2022
/ Accounting ,
Biden Administration ,
Consultants ,
Contract Management ,
Economic Sanctions ,
Executive Orders ,
Export Controls ,
Exports ,
Financial Services Industry ,
Foreign Investment ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Ukraine
The United States has announced yet another round of economic sanctions against Russia that builds on existing sanctions and extends them to new sectors of the Russian economy. The U.S. Department of the Treasury’s Office of...more
5/18/2022
/ Bureau of Industry and Security (BIS) ,
Commerce Control List ,
Consultants ,
Duties ,
Economic Sanctions ,
Executive Orders ,
Export Administration Regulations (EAR) ,
Export Controls ,
Financial Services Agency ,
General Licenses ,
Imports ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
Trade Restrictions
On April 6, 2022, the U.S. Government announced its latest round of sanctions against the Russian Federation in coordination with the European Union (“EU”) and other allies. President Biden issued Executive Order 14071 (“EO...more
4/11/2022
/ Biden Administration ,
Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
Executive Orders ,
Export Administration Regulations (EAR) ,
Export Controls ,
Most-Favored Nations ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Tariffs ,
Trade Restrictions ,
Ukraine
As part of its expanding sanctions against Russia, the Biden Administration on March 8, 2022, issued Executive Order 14066 (“EO 14066,” see here) to bar imports into the United States of Russian crude oil, petroleum;...more
3/14/2022
/ Biden Administration ,
Blocked Entities ,
Blocked Person ,
Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
Executive Orders ,
Export Administration Regulations (EAR) ,
Export Controls ,
Foreign Policy ,
General Licenses ,
Imports ,
Most-Favored Nations ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Tariffs ,
Ukraine
President Biden signed into law on December 23 legislation that will, for the first time, require U.S. Customs and Border Protection (“CBP”) to detain all imports that are made wholly or partly in the Xinjiang Uyghur...more
12/29/2021
/ Asia ,
Biden Administration ,
China ,
Customs and Border Protection ,
Department of Homeland Security (DHS) ,
Economic Sanctions ,
Executive Orders ,
Forced Labor ,
Foreign Policy ,
Human Rights ,
Imports ,
National Security ,
New Guidance ,
Office of Foreign Assets Control (OFAC) ,
Procurement Guidelines ,
Rebuttable Presumptions ,
Reputation Management ,
Risk Management ,
Supply Chain ,
Technology Sector ,
Third-Party ,
Upstream Contracts ,
USTR
The Biden Administration last week substantially modified restrictions on U.S. person investments in certain Chinese companies, focusing those new restrictions particularly on entities with ties to the Chinese defense or...more
6/11/2021
/ Biden Administration ,
China ,
Department of Defense (DOD) ,
Executive Orders ,
Military End Use ,
NDAA ,
Office of Foreign Assets Control (OFAC) ,
Publicly-Traded Companies ,
SDN List ,
Surveillance ,
Technology Sector ,
Trump Administration
Effective June 1, 2021, the U.S. Department of the Treasury's Office of Foreign Assets Control (“OFAC”) published new Burmese Sanctions Regulations (“BSR”) that implement President Biden’s February 10, 2021, Executive Order...more
6/7/2021
/ Biden Administration ,
Blocked Person ,
Bureau of Industry and Security (BIS) ,
Burma ,
Economic Sanctions ,
Executive Orders ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
George W Bush ,
ITAR ,
Myanmar ,
Obama Administration ,
Office of Foreign Assets Control (OFAC) ,
President Clinton
With only two weeks left in its term in office, the Trump Administration issued yet another 11th hour Executive Order (“EO”) on January 5 that purports to create a new legal framework to ban transactions with certain Chinese...more
On November 12, 2020, President Trump issued Executive Order 139591 (“the Order”) that will shortly bar any U.S. person from “any transaction in publicly traded securities, or any securities that are derivative of, or are...more
11/20/2020
/ China ,
Corporate Counsel ,
Defense Sector ,
Department of Defense (DOD) ,
Divestment ,
Entity List ,
Executive Orders ,
Foreign Investment ,
International Emergency Economic Powers Act (IEEPA) ,
National Security ,
NDAA ,
Office of Foreign Assets Control (OFAC) ,
Publicly-Traded Companies ,
Trump Administration ,
US Trade Policies