On April 2, 2025, the Trump Administration announced new, comprehensive tariff rates representing the most significant change in US trade policy in a generation—a paradigm shift from an era of low tariffs to an approach based...more
4/10/2025
/ China ,
Executive Orders ,
International Emergency Economic Powers Act (IEEPA) ,
International Trade ,
Reciprocity Rules ,
Regulatory Agenda ,
Retaliatory Tariffs ,
Tariffs ,
Trade Relations ,
Trade Wars ,
Trump Administration ,
US Trade Policies
On 2 April 2025, President Trump announced new tariffs on all imports into the United States. In this briefing, we summarise the key measures and the expected impact on global trade.
The new “reciprocal” tariffs -
The...more
4/4/2025
/ Canada ,
China ,
EU ,
Executive Orders ,
India ,
International Trade ,
Mexico ,
South Korea ,
Tariffs ,
Trade Relations ,
Trump Administration ,
UK ,
United States-Mexico-Canada Agreement (USMCA) ,
US Trade Policies ,
Vietnam
On February 21, 2025, President Trump issued a memorandum “America First Investment Policy” (the Investment Memo or Memo), in which the President aims to modify the US Government’s approach to inbound and outbound foreign...more
In his first tangible action implementing his campaign promise to impose broad tariffs, on February 1, 2025, President Trump issued three Executive Orders (the EOs) directing that across-the-board tariffs be imposed on goods...more
2/11/2025
/ Canada ,
China ,
Energy Sector ,
Executive Orders ,
Imports ,
International Emergency Economic Powers Act (IEEPA) ,
Legislative Agendas ,
Mexico ,
National Security ,
Regulatory Agenda ,
Tariffs ,
Trade Act of 1974 ,
Trump Administration
On February 5, 2025, the US Department of Justice (DOJ) issued two memoranda, General Policy Regarding Charging, Plea Negotiations, and Sentencing and Total Elimination of Cartels and Transnational Criminal Organizations,...more
2/10/2025
/ Anti-Bribery ,
Anti-Money Laundering ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement Actions ,
Enforcement Priorities ,
Export Controls ,
Foreign Corrupt Practices Act (FCPA) ,
Human Trafficking ,
Immigration Enforcement ,
Immigration Reform ,
National Security ,
Trump Administration
On January 15, 2025, the US Department of Commerce Bureau of Industry and Security (BIS) published an interim final rule (IFR) that imposes new controls on advanced computing integrated circuits (Advanced ICs) and certain...more
1/20/2025
/ Artificial Intelligence ,
Bureau of Industry and Security (BIS) ,
Export Controls ,
Final Rules ,
Foreign Policy ,
Interim Final Rules (IFR) ,
National Security ,
Regulatory Agenda ,
Supply Chain ,
Technology Sector ,
U.S. Commerce Department
On January 10, 2025, the Biden Administration issued a broad sanctions package targeting the Russian energy sector, 10 days in advance of the transition to the incoming Trump Administration. The new sanctions also added two...more
1/14/2025
/ Biden Administration ,
Blocked Person ,
Department of Energy (DOE) ,
Economic Sanctions ,
Energy Sector ,
Enforcement Actions ,
Foreign Policy ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Russia ,
U.S. Treasury ,
UK
On June 21, 2024, the US Department of the Treasury (Treasury) released proposed new federal regulations (Proposed Rules) that, if implemented, would prohibit or require notification of a broad range of outbound investment...more
7/9/2024
/ Advanced Notice of Proposed Rulemaking (ANPRM) ,
China ,
Covered Person ,
Covered Transactions ,
Data Privacy ,
Data Security ,
Foreign Persons ,
Information Technology ,
Investment ,
National Security ,
Popular ,
Prohibited Transactions ,
Proposed Regulation ,
Regulatory Agenda ,
U.S. Treasury
The measure also harmonizes Russia sanctions rules with allies, and intensifies penalties against Iran -
The National Security Act, 2024 (Pub. L No 118-50) was enacted on April 24, 2024. In addition to the Act’s provisions...more
4/29/2024
/ China ,
EU ,
Export Administration Regulations (EAR) ,
Export Controls ,
Foreign Direct Product Rule ,
Iran ,
National Security ,
Regulatory Agenda ,
Regulatory Reform ,
Russia ,
Sanction Violations ,
Statute of Limitations ,
Trade Policy ,
UK
Contemporaneous with the European Union’s adoption of its 13th package of Russia sanctions, on February 23, 2024, the United States imposed sanctions against nearly 500 targets in continued response to Russia’s aggression...more
2/27/2024
/ Biden Administration ,
Defense Sector ,
Economic Sanctions ,
Executive Orders ,
Federal Procurement Systems ,
Financial Institutions ,
Financial Transactions ,
FinTech ,
Foreign Policy ,
General Licenses ,
Military Conflict ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Payment Systems ,
Russia ,
Russian Military Procurement ,
SDN List ,
Ukraine ,
US State Departments
In response to an agreement reached on Tuesday between President Nicolás Maduro’s representatives and the Venezuelan political opposition about a road map for the 2024 Venezuelan presidential election, on October 18, the...more
After months of deliberation, on August 9, 2023, President Biden issued the executive order “Addressing United States Investments in Certain National Security Technologies and Products in Countries of Concern” (Order), with...more
On July 31, 2023, the US Department of the Treasury-led Committee on Foreign Investment in the United States (CFIUS or the Committee) released its annual report for calendar year 2022 (2022 Report), which provides insight...more
On May 19, 2023, the Biden Administration along with leaders of the Group of Seven (G7), unveiled a new package of sanctions. The G7 leaders released a joint statement reaffirming their commitment to offer “the financial,...more
6/6/2023
/ Biden Administration ,
Bureau of Industry and Security (BIS) ,
Defense Sector ,
Economic Sanctions ,
Energy Sector ,
Entity List ,
Evasion ,
Executive Orders ,
Export Controls ,
Foreign Policy ,
G7 ,
General Licenses ,
Military Conflict ,
Office of Foreign Assets Control (OFAC) ,
Prohibited Transactions ,
Russia ,
SDN List ,
Third-Party ,
U.S. Commerce Department ,
Ukraine
On April 19, 2023, the US Department of Commerce Bureau of Industry and Security (BIS) entered into a settlement agreement wherein Seagate Technology LLC and Seagate Singapore International Headquarters Pte. Ltd....more
4/27/2023
/ Bureau of Industry and Security (BIS) ,
Civil Monetary Penalty ,
Enforcement Actions ,
Entity List ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Huawei ,
Sanction Violations ,
Settlement Agreements ,
U.S. Commerce Department
In recognition of the one-year anniversary of Russia’s invasion of Ukraine, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) and US Department of Commerce’s Bureau of Industry and Security (BIS)...more
3/6/2023
/ Biden Administration ,
Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
Embargo ,
EU ,
Executive Orders ,
Export Administration Regulations (EAR) ,
Export Controls ,
Financial Transactions ,
Foreign Policy ,
Foreign Relations ,
Foreign Trade Regulations ,
General Licenses ,
Military Conflict ,
Office of Foreign Assets Control (OFAC) ,
Oil Prices ,
Petroleum ,
Russia ,
SDN List ,
Switzerland ,
Ukraine
On February 5, 2023, the G7 announced that the “price cap” on western-backed seaborne trades of Russian-origin petroleum products to third countries would be set at $45 per barrel ($45/bbl) for Discount to Crude petroleum...more
2/27/2023
/ EU ,
Exports ,
G7 ,
Goods or Services ,
Imports ,
Maritime Transport ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Oil Prices ,
Petroleum ,
Russia ,
Sanction Violations ,
Shipping ,
Suppliers ,
Supply Contracts ,
Ukraine
Amid the 4,000 pages of provisions in the recently enacted Fiscal Year 2023 National Defense Authorization Act (NDAA) are prohibitions and associated requirements relating to the federal procurement of certain Chinese...more
1/3/2023
/ China ,
Covered Entities ,
Defense Sector ,
Department of Defense (DOD) ,
Federal Acquisition Regulations (FAR) ,
Federal Contractors ,
Information Technology ,
National Security ,
NDAA ,
Procurement Guidelines ,
Semiconductors ,
Telecommunications
Oil price cap -
The oil price cap has been co-ordinated by the G7 in order to make EU, UK and US services (including (re)insurance) available to third country importers and exporters as long as the price paid for...more
12/12/2022
/ Asset Freeze ,
Belarus ,
Belarus Sanctions ,
Biden Administration ,
Crude Oil ,
Economic Sanctions ,
EU ,
Export Controls ,
Exports ,
G7 ,
General Licenses ,
Imports ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Oil Prices ,
Russia ,
SDN List ,
Switzerland ,
Third Country Entities (TCEs) ,
UK ,
Ukraine
The Office of Foreign Assets Control (OFAC) of the US Treasury Department has issued its eagerly awaited guidance on the mechanisms of its “maritime services” policy and “price cap exception” for the global transport of...more
Recently, the US Department of Commerce Bureau of Industry and Security (BIS) issued an interim final rule imposing additional export controls on certain advanced computing and semiconductor manufacturing items and for...more
11/4/2022
/ Bureau of Industry and Security (BIS) ,
China ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Interim Final Rules (IFR) ,
Manufacturers ,
Military End Use ,
National Security ,
Technology Sector ,
U.S. Commerce Department
Recently, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) has taken additional actions against Russia in response to its continued invasion of Ukraine. Specifically, OFAC:
..Issued guidance...more
10/31/2022
/ Asset Freeze ,
Belarus ,
Blocked Entities ,
Blocked Person ,
Economic Sanctions ,
EU ,
Export Controls ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Switzerland ,
Trade Restrictions ,
UK ,
Ukraine
Recently, the Biden Administration adopted additional sanctions in response to Russia’s attempts to annex parts of sovereign Ukrainian territory, including the designation of 14 persons in Russia’s military industrial...more
10/13/2022
/ Belarus ,
Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
Entity List ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Military Conflict ,
Military End Use ,
New Guidance ,
Russia ,
Third Country Entities (TCEs) ,
U.S. Commerce Department ,
Ukraine
Over the past few weeks, the Office of Foreign Assets Control (OFAC) of the US Department of the Treasury ramped up sanctions pressure against Russia with the announcement of a new ban on certain services in seaborne Russian...more
9/23/2022
/ Asset Freeze ,
Belarus ,
Belarus Sanctions ,
Blocked Entities ,
Blocked Person ,
Economic Sanctions ,
Export Controls ,
General Licenses ,
Office of Financial Sanctions Implementation (OFSI) ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Russia ,
Ukraine
As a follow up to our alert of September 7th regarding the G7 proposal to implement a price cap with respect to seaborne Russian-origin crude oil and petroleum products, the Office of Foreign Assets Control (OFAC)...more
9/13/2022
/ Crude Oil ,
Economic Sanctions ,
Embargo ,
EU ,
Maritime Transport ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Oil Prices ,
Recordkeeping Requirements ,
Russia ,
Safe Harbors ,
Shipping