The BR International Trade Report: March 2026

Blank Rome LLP

 

Welcome to this month’s issue of The BR International Trade Report, Blank Rome’s monthly digital newsletter highlighting international trade, cross-border investment, and geopolitical risk issues impacting businesses domestically and abroad. We invite you to share this resource with your colleagues and visit Blank Rome’s International Trade webpage for more information about our team.


Recent Developments

U.S. war with Iran.

  • United States and Israel launch coordinated airstrikes on Iran. On February 28, following unsuccessful negotiations between the United States and Iran regarding Iran’s nuclear program, the United States and Israel launched an assault on Iran, resulting in the death of Iranian Supreme Leader Ayatollah Ali Khamenei and prompting Iranian retaliation across the region.
  • Global oil markets disrupted by war. Global oil prices have swung wildly as Iranian strikes disrupted shipping through the Strait of Hormuz—a key passage through which nearly one fifth of the global oil supply transits.
  • Trump Administration considers waiving certain oil-related sanctions to combat price volatility. On March 9, President Trump told reporters in Florida that the U.S. may “take [certain oil] sanctions off” until the energy market stabilizes. President Trump’s comments follow the U.S. Department of the Treasury’s (“Treasury’s”) issuance of a temporary 30-day general license (“GL”) (expiring April 4) allowing Indian refineries to purchase Russian crude oil and petroleum products. The waiver follows last month’s U.S.-India trade deal wherein the United States removed its 25 percent tariff on Indian goods in exchange for India ceasing its purchases of Russian oil.
  • Iran names Mojtaba Khamenei as new Supreme Leader. On March 8, Iran’s Assembly of Experts voted to appoint Mojtaba Khamenei, Ali Khamenei’s son, as the new Supreme Leader of Iran.

U.S. tariff developments.

  • U.S. Supreme Court strikes down “reciprocal” and “trafficking” tariffs imposed under the International Emergency Economic Powers Act (“IEEPA”). On February 20, in a 6-3 ruling, the Supreme Court overturned tariffs imposed pursuant to IEEPA, reasoning that IEEPA’s authority to “regulate . . . importation,” when read in context with the act’s other verbs, does not authorize the imposition of tariffs. In response, U.S. Customs and Border Protection (“CBP”) ceased collecting IEEPA tariffs on February 24, 2026. It is unclear how the Supreme Court’s decision will impact U.S. trade deals. For additional analysis, see Blank Rome’s February 20 client alert.
  • President Trump issues first-ever tariffs under Section 122 of the Trade Act of 1974. Immediately following the Supreme Court’s decision, President Trump signed Proclamation 11012, imposing a 150-day 10 percent tariff on imports to address “fundamental international payments problems,” effective February 24. Twenty-four state attorneys general have since brought suit in the U.S. Court of International Trade (“CIT”), arguing that the statutory prerequisites for use of Section 122 have not been met.
  • CIT directs CBP to refund IEEPA tariffs. On March 4, the CIT issued a sweeping order directing CBP to liquidate “any and all unliquidated entries entered subject to the IEEPA duties . . . without regard to the IEEPA duties. Any liquidated entries for which liquidation is not final shall be liquidated without regard to IEEPA duties.” In response, CBP filed a declaration with the Court, explaining the technical difficulties associated with complying with the order and describing efforts by CBP to develop a new functionality in the Automated Commercial Environment (“ACE”) to issue refunds in a more timely manner. The CIT subsequently suspended its orderto the extent that it directs immediate compliance.”
  • U.S. launches trade investigations into key trading partners. On March 11, U.S Trade Representative (“USTR”) Jamieson Greer announced a wave of investigations under Section 301 of the Trade Act of 1974 concerning “structural excess capacity and production in manufacturing sectors” of several economies. The investigations will focus on China, the European Union, Bangladesh, Cambodia, Indonesia, India, Japan, Malaysia, Mexico, Norway, Singapore, South Korea, Switzerland, Taiwan, Thailand, and Vietnam. The USTR review will assess whether the practices of these economies burden or restrict U.S. commerce, and whether tariffs or other remedial action would be appropriate.

U.S. trade deal developments.

  • U.S. Department of Commerce announces three Japanese investment projects pursuant to U.S.-Japan trade deal. The projects, totaling over $36 billion, would see Japan invest $33 billion in a natural gas power facility in Ohio, $2.1 billion into a deepwater crude oil export terminal in Texas, and $600 million into a synthetic diamond grit facility in Georgia. Reports indicate that the second round of Japanese investment under the deal may involve a nuclear power project.
  • European Union pauses ratification of U.S.-EU trade deal following U.S. Supreme Court’s tariff decision. The European Parliament has paused efforts to ratify the U.S.-EU trade deal which was announced in July 2025. USTR Greer stated that the United States expects its partners to abide by previously negotiated deals.
  • South Korea takes steps to complete U.S. investment pledge. On March 9, a South Korean parliamentary committee reached agreement on the language for a bill authorizing $350 billion in U.S. investments under a bilateral trade deal between the countries, paving the way for the bill to be put to a final vote in the full National Assembly on March 12. The bill would will set up an investment vehicle and a risk management committee to implement a 2025 agreement in which South Korea agreed to invest in sectors such as shipbuilding and semiconductors in return for lower U.S. tariffs.
  • U.S. and Indonesia finalize trade agreement. Finalized the day before the Supreme Court’s tariff decision, the trade deal would see Indonesia eliminate tariffs on over 99 percent of imported U.S.-origin products and address certain non-tariff barriers. In exchange, the United States would maintain the 19 percent tariff imposed on Indonesian-origin goods, excluding certain products. It is unclear how the Supreme Court’s tariff decision will impact the deal.
  • White House announces trade deal with North Macedonia. The deal, announced on February 12, would see North Macedonia eliminate its tariffs on “all U.S. industrial and agricultural goods” and agree to purchase U.S. liquefied natural gas. In return, the United States would maintain its 15 percent tariff on most imported North Macedonian-origin goods, excluding certain items. It is unclear how the Supreme Court’s tariff decision will impact the deal.
  • United States and Mexico enter into bilateral talks prior to formal renegotiation of the U.S.-Mexico-Canada Agreement. On March 5, USTR Greer and Mexican Secretary of Economy Marcelo Ebrard announced the bilateral negotiations. Negotiators will meet the week of March 16 to discuss “reducing dependence on imports from outside the region, strengthening rules of origin, and enhancing the security of North American supply chains.
  • Trump Administration reportedly looking into potential economic deal with Cuba. Although specifics of such a deal remain under wraps, reports indicate that such a deal could cover ports, energy, tourism, and sanctions relief.

OFAC issues new guidance regarding authorized business with Venezuela, while Washington and Caracas partner on mining efforts and reestablish diplomatic and consular relations.

  • On March 6, Treasury’s Office of Foreign Assets Control (“OFAC”) issued GL 51, authorizing “established U.S entit[ies]” to export, sell, supply, store, purchase, deliver, and transport Venezuelan-origin gold for import into the United States, the refining of such gold in the United States, and the resale or exportation of such gold from the United States by an established U.S. entity, subject to certain restrictions. GL 51 followed an announcement by Venezuelan interim president Delcy Rodríguez and U.S. Secretary of the Interior Doug Burgum that the two nations would partner on mining development efforts.
  • On March 5, the U.S. Department of State announced that U.S. and Venezuelan authorities had “agreed to re-establish diplomatic and consular relations.”

President Trump designates elemental phosphorus and glyphosate-base herbicides as critical minerals. Executive Order (“EO”) 14387, issued February 18, instructs the Secretary of Agriculture, in consultation with the U.S. Department of Defense, to assess supply chain vulnerabilities and support industry efforts to increase domestic production capabilities.

Canada and India announce US$1.9 billion uranium supply agreement. On March 2, Canada and India signed five memoranda of understanding covering energy and critical minerals, technology, talent, culture, and defense, including a deal for Canada to supply India with US$1.9 billion (C$2.6 billion) in uranium. The two nations also announced that a new Comprehensive Economic Partnership Agreement will be concluded this year, which would double bilateral trade to US$5.15 billion (C$70 billion) by year 2030.

China imposes export controls on 20 Japanese entities. On February 24, China’s Ministry of Commerce (“MOFCOM”) added 20 Japanese entities to its export control restricted list for “participat[ing] in enhancing Japan’s military strength.” The restriction applies both to exports out of China and to reexports of China-origin dual-use items.

White House announces Maritime Action Plan. On February 13, the White House published America’s Maritime Action Plan (the “Action Plan”), a comprehensive strategy to bolster the U.S maritime sector, strengthen the shipbuilding workforce and national defense, and expand marine infrastructure. Originally outlined in EO 14269, the Action Plan’s objectives are supported by four key pillars: (1) rebuilding U.S. shipbuilding capacity and capabilities; (2) reforming workforce education and training; (3) protecting the maritime industrial base; and (4) improving national security, economic security, and industrial reliance. The Action Plan also includes a myriad of proposals to revitalize the U.S. maritime sector, including the creation of a universal fee on every foreign-built vessel entering a U.S. port. For additional analysis, see Blank Rome’s February 19 client alert.

Former South Korean president Yoon Suk Yeol receives life sentence for 2024 martial law declaration. On February 19, Seoul’s Central District Court found the former president guilty of insurrection, sentencing him to life in prison. South Korea’s former Prime Minister, Defense Minister, and Interior Minister were also sentenced to prison.

For continuous, up-to-date information on the evolving administrative landscape, check out Blank Rome’s Trump Administration Resource Hub. Explore previous BR International Trade Reports here.


In Case You Missed It

DOJ Selects Chicago U.S. Attorney's Office as Leading Prosecutorial Partner on Trade Fraud Task Force

Blank Rome partners Anthony Rapa, Jennifer A. Short, Bradley L. Henry, and associate Michael J. Schmandt authored this alert discussing the Department of Justice’s selection of the U.S. Attorney’s Office for the Northern District of Illinois to serve as a lead prosecutorial partner for the cross-agency Trade Fraud Task Force.

Read More >>

Supreme Court Overturns “Reciprocal” and “Trafficking” Tariffs Imposed Under IEEPA

Blank Rome partners Joanne E. Osendarp, Eric S. Parnes, of counsel Timothy J. Hruby, associates Brendan S. Saslow, Rachel D. Evans, and Layla S. Najjar authored this alert discussing the Supreme Court’s recent decision declaring president Trump’s sweeping tariffs on all U.S. trading partners illegal.

Read More >>

OFAC Issues Several New General Licenses Regarding Oil Trade with Venezuela

Blank Rome partners Anthony Rapa, Kenneth J. Nunnenkamp, Matthew J. Thomas, senior counsels Alan G. Kashdan, George T. Boggs, associates Rachel D. Evans, and Carmella R. O'Hanlon authored this alert discussing the developments between the United States and Venezuela, and analyzes OFAC’s new GLs and their implications for companies engaged in Venezuelan energy‑related transactions.

Read More >>

Energy & Utilities Roundup: Market Talk

Blank Rome partner Matthew J. Thomas was featured in this Wall Street Journal article discussing the disruptions in shipping through the Strait of Hormuz amidst the conflict in Iran.

Read More >>

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations. Attorney Advertising.

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