News & Analysis as of

Export Controls U.S. Treasury

Husch Blackwell LLP

Week Seventeen in Trade

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CBP Issues Facility Requirements for Bonded Warehouses In a Cargo Systems Messaging Service (“CSMS”) message, U.S. Customs and Border Protection (“CBP”) clarified that bonded warehouses, as defined in 19 C.F.R. § 19.1, do...more

Miles & Stockbridge P.C.

Lifting Sanctions On Syria: A Preview of the Process

President Donald Trump announced Tuesday during his trip to the Middle East that his administration would lift U.S. sanctions on Syria. Since the shock collapse of Bashar al-Assad’s regime in Syria late last year, the...more

Husch Blackwell LLP

Week Sixteen in Trade

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In its FAQs, U.S. Custom and Border Protection (CBP) clarified the exemption from reciprocal tariffs for goods subject to steel/aluminum Section 232 duties under HTSUS 9903.01.33. CBP clarified that the exemption only applies...more

Mayer Brown

Russia/Ukraine Sanctions Update - Month of April 2025

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I. U.S. SANCTIONS  - White House Reportedly Considering Lifting Sanctions on Russian Energy Assets: On April 23, Politico reported that the White House is debating lifting sanctions on Russia’s Nord Stream 2 natural gas...more

Foley Hoag LLP - White Collar Law &...

Review of International Trade Enforcement in the U.S., E.U., and UK in 2024 and What to Expect in 2025

This is the final in our 2025 Year in Preview series examining important trends in white collar law and investigations in the coming year. Throughout 2024, enforcement of international trade laws continued to gather pace...more

Seward & Kissel LLP

OFAC Announces Wind Down of Chevron’s Oil Operations in Venezuela

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On March 4, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Venezuela General License 41A, “Authorizing the Wind Down of Certain Transactions Related to Chevron Corporation’s Joint...more

Wilson Sonsini Goodrich & Rosati

President Trump Issues “America First Investment Policy”

On February 21, 2025, the White House released a memorandum titled, “America First Investment Policy” (the Memorandum). The Memorandum describes how this Administration plans to address U.S. national security risks stemming...more

Jones Day

Mitigating Risk From the Designation of Cartels as FTOs and SDGTs

Jones Day on

The Situation: After President Trump issued an Executive Order ("EO") that creates a process to designate international cartels and other organizations as "Foreign Terrorist Organizations" ("FTOs") or "Specially Designated...more

Holland & Knight LLP

America First Investment Policy

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President Donald Trump on Feb. 21, 2025, issued a National Security Presidential Memorandum (NSPM) titled "America First Investment Policy," outlining the administration's priorities regarding inbound and outbound...more

Fox Rothschild LLP

Update on Outbound U.S. Investment Restrictions and Export Controls

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New U.S. investment and export control measures are shaping how businesses engage with foreign markets, particularly China. From limiting outbound investments to tightening export licenses, these evolving policies from the...more

Akin Gump Strauss Hauer & Feld LLP

America First Trade Policy (Trump EO Tracker)

Requires a variety of reports and recommendations to be delivered to the President by April 1, 2025: on the causes of the persistent trade deficit, how to establish the External Revenue Service, unfair foreign trade...more

K2 Integrity

2024 in Review: A Year of Expanded Sanctions and Trade Controls and Increased Enforcement Actions

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In 2024, global sanctions and trade controls continued to expand, with the United States (U.S.), European Union (EU), and United Kingdom (UK) leading the charge against actors threatening international security and financial...more

Akin Gump Strauss Hauer & Feld LLP

America First Trade Policy (Trump EO Tracker)

Requires a variety of reports and recommendations to be delivered to the President by April 1, 2025: on the causes of the persistent trade deficit, how to establish the External Revenue Service, unfair foreign trade...more

Seward & Kissel LLP

President Trump Seeks “Maximum Pressure” on Iran Through Expansion of Sanctions Targeting Iran’s Oil Exports

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As has been widely reported, the U.S. policy of “maximum pressure” towards Iran has returned. On February 4, 2025, the Trump administration (the “Administration”) issued a national security memorandum (the “Memorandum”)...more

Seward & Kissel LLP

OFAC Announces Two New Waves of Sanctions Targeting Russia’s Oil Production and Exports, Military-Industrial Base, and Sanctions...

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On January 10 and January 15, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced sweeping sanctions targeting Russia’s oil production and exports, military-industrial base, and other...more

Mayer Brown

Russia/Ukraine Sanctions Update - Month of January 2025

Mayer Brown on

I.  US SANCTIONS - U.S. Department of the Treasury Takes Action Against Russian Efforts to Evade U.S. Sanctions: On January 15, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) designated...more

Akin Gump Strauss Hauer & Feld LLP

National Security Presidential Memorandum/NSPM-2 (Trump EO Tracker)

Imposes maximum pressure on the Iranian regime to end its nuclear threat, curtail its ballistic missile program, and stop its support for terrorist groups. Relevant Secretaries are required to impose and enforce sanctions,...more

Kelley Drye & Warren LLP

New Tariffs on Mexico and Canada Delayed by One Month

Today, President Trump reached separate agreements with the leaders of Mexico and Canada to delay implementation of tariffs announced over the weekend and originally set to take effect at 12:01 a.m. tomorrow (February 4). In...more

Foley Hoag LLP

Understanding the U.S.’s New Outbound Investment Rules - January 2025

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Effective in January 2025, the U.S. Department of the Treasury issued a final rule (colloquially known as “Reverse CFIUS”) implementing the Outbound Investment Program, which prohibits U.S. persons from making certain...more

Faegre Drinker Biddle & Reath LLP

Treasury’s Outbound Investment Security Program Focusing on China Is in Effect (for Now)

Treasury’s final rule implementing its outbound investment regime went into effect on January 2, 2025. The final rule implemented Executive Order (E.O.) 14105 of August 9, 2023, which declared a national emergency to address...more

Wilson Sonsini Goodrich & Rosati

All is Fair in Love and Trade War: Valentine's Day Predictions for What Comes Next in U.S. National Security Law

As we head toward Valentine’s Day 2025, everywhere you look, love is all around. Washington, D.C., is no exception—the White House and government agencies seem to be proudly displaying their ardor for changing the country’s...more

BakerHostetler

Current State of U.S. Economic Sanctions Imposed in Response to Russia’s Invasion of Ukraine - January 29, 2025

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In its continuing response to Russia’s ongoing invasion of Ukraine, the U.S. government has deployed a whole-of-government approach to impose sanctions and tighter export controls on Russia and Belarus. This alert summarizes...more

Hogan Lovells

“America First Trade Policy” memorandum directs a comprehensive review of U.S. trade policy, suggests potential new tariffs and...

Hogan Lovells on

President Trump’s Day 1 presidential memorandum directs a top-to-bottom review of U.S. trade and economic policy and requests that his Administration provide policy recommendations with respect to: the U.S. trade deficit and...more

Akin Gump Strauss Hauer & Feld LLP

America First Trade Policy

Requires a variety of reports and recommendations to be delivered to the President by April 1, 2025: on the causes of the persistent trade deficit, how to establish the External Revenue Service, unfair foreign trade...more

Wiley Rein LLP

President Trump Issues “America First” Trade Policy and Previews Additional Tariffs on Canada, Mexico, and China - UPDATED 1/22/25

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This alert was originally published on January 21, 2025, and updated on January 22, 2025, to reflect President Trump’s comments that additional 10% tariffs may be imposed on China on February 1. On January 20, 2025,...more

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