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Tariffs Loom for Imports of Semiconductor and Pharmaceutical Products and Critical Minerals as Trump Administration Initiates...

The Trump administration is pursuing additional national security investigations that will likely lead to tariffs on imports of semiconductors, semiconductor manufacturing equipment (“SME”), and derivative articles,...more

Trump Administration’s Sweeping Reciprocal Tariffs – What Companies Need to Know

An update to our ongoing insights into the Trump administration’s broad tariffs on imports from Canada, Mexico and China. On April 2, 2025, President Trump unveiled a new so-called “reciprocal” tariff regime. The...more

Updated Beneficial Ownership Reporting Rules: All U.S. Companies Are Exempt; Only Foreign Companies Must Report

On March 21, 2025, the Financial Crimes Enforcement Network of the U.S. Treasury Department (“FinCEN”) narrowed the scope of the beneficial ownership information (“BOI”) filing requirement under the Corporate Transparency Act...more

Trump Administration Import Tariffs Update – What Companies Need to Know

An update to our ongoing insights into the Trump administration’s broad tariffs on imports from Canada, Mexico and China, plus targeted tariffs on key commodities and processed products worldwide. Until at least April 2, it...more

New Duties on Imports from Canada, Mexico and Increased Duties on Chinese Imports – What Companies Need to Know

An update to our previous alert on new tariffs on Mexican and Canadian imports. Yesterday, as announced in several early February Executive Orders, the U.S. government imposed new duties on most imports from Canada and...more

FinCEN Pauses Beneficial Ownership Reporting Enforcement: New Rule and Deadlines Coming by March 21, 2025

FinCEN announced that by March 21, 2025, it plans to issue an interim final rule that will extend the current beneficial ownership information (BOI) reporting deadlines under the Corporate Transparency Act. Until the new rule...more

White House to Expand Restrictions on Chinese Investment While Streamlining Investment Reviews for Allies

On February 21, 2025, a Presidential Memorandum, “America First Investment Policy” (the “Memorandum”), announced planned changes to the Committee on Foreign Investment in the United States (“CFIUS”) and outbound investment...more

Corporate Transparency Act Beneficial Reporting Back in Effect – Stay Tuned

The Corporate Transparency Act (CTA) is back in effect − at least for now − and companies covered by the CTA are once again required to file beneficial ownership information (BOI) reports with FinCEN. On February 17, 2025, in...more

New Duties on Imports from Canada, Mexico and China – What Companies Need to Know – Update

The United States has announced, subject to reported suspensions with the two countries, 25% duties on most imports from Canada and Mexico, as well as 10% duties on most imports from China. These duties build on existing...more

New Export Controls on Advanced Computing Items and AI Model Weights

The Commerce Department has issued a rule that increases export controls on AI-related items.  The rule: Most of the restrictions are scheduled to take effect on May 15, 2025, although some do not come into effect until...more

Corporate Transparency Act Beneficial Reporting Still on Hold Nationwide – Stay Tuned

On January 23, 2025, the U.S. Supreme Court vacated one nationwide stay (Texas Top Cop Shop, Inc. v. McHenry – formerly, Texas Top Cop Shop v. Garland) which blocked the U.S. government from enforcing the Corporate...more

Corporate Transparency Act On Hold Nationwide

A federal judge has blocked the U.S. government from enforcing the Corporate Transparency Act (CTA) and its implementing regulations nationwide. As a result, companies affected by the CTA do not have to report information...more

Financial Institutions Face Greater Export Controls Compliance Risk Under New BIS Guidance

Financial institutions face significant new compliance obligations under export control guidance issued by the Commerce Department’s Bureau of Industry and Security (BIS) last month.  ...more

The Corporate Transparency Act: Beneficial Ownership Reporting Deadline Approaches

The deadline is quickly approaching for companies created or registered to do business in the United States before 2024 to report beneficial ownership information as required by the Corporate Transparency Act (CTA). The CTA...more

U.S. Joins Allies to Impose Export Controls on Quantum Computing and Other Emerging Technologies

On September 6, 2024, the Bureau of Industry and Security (BIS) of the U.S. Commerce Department issued an interim final rule expanding export controls on certain emerging technologies: Quantum Computing: Quantum computers,...more

Sweeping New U.S. Sanctions and Export Controls Intensify Pressure on Russia and Belarus As Russia Transitions to a Full War...

The United States has substantially expanded economic sanctions and export controls targeting Russia and Belarus, imposing new restrictions that could have a major impact on companies with business activities in or relating...more

New U.S. Legislation Extends Sanctions Statute of Limitations and Authorizes New Sanctions: What Companies Need to Know

The 21st Century Peace Through Strength Act became law recently as part of H.R. 815, which also provided aid to Ukraine, Israel and Taiwan. The law contains important sanctions measures that: Extend the statute of...more

OFAC Signals Willingness to Use FinCEN Whistleblower Incentive Program for Sanctions Violations

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has announced two enforcement actions this year. Both reference the Financial Crimes Enforcement Network's (FinCEN) whistleblower program,...more

CFIUS’s Proposed Regulatory Enhancements Would Increase Transactional Risks

The Committee on Foreign Investment in the United States (CFIUS) has taken another significant step in transforming from a limited jurisdiction interagency committee that primarily reviewed voluntary filings into a body with...more

U.S. Authorizes Sanctions on Foreign Financial Institutions That Support Russia’s Military-Industrial Base and Expands Scope of...

President Biden issued an executive order on December 22, 2023 targeting evasion of U.S. sanctions on Russia. Executive Order 14,114: Authorizes sanctions on foreign financial institutions (“FFIs”) determined to have...more

Russia Sanctions and Export Controls: New Measures in a U.S. Crackdown

The United States has strengthened economic sanctions and export controls targeting Russia, following through on commitments made at a G7 summit this month. The EU and UK also plan to substantially expand measures targeting...more

$300 Million Seagate Export Control Penalty Shows New, Aggressive China-Trade Enforcement

On April 19, 2023, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) imposed a $300 million civil penalty on Seagate Technology LLC, a U.S. supplier of data-storage products. BIS found that...more

U.S., EU, and UK Price Cap Sanctions Prohibiting Services for Maritime Transport of Russian Petroleum Products

Effective February 5, 2023, a coalition of G7 countries, Australia, and the European Union have generally forbidden service providers to provide certain services relating to the maritime transport of certain Russia-origin...more

U.S., EU, and UK Price Cap Sanctions Prohibiting Services for Maritime Transport of Russian Oil

Effective December 5, 2022, a coalition of G7 countries, Australia, and the European Union have generally forbidden service providers to provide certain services relating to the maritime transport of Russia-origin crude oil...more

Commerce Department Issues Preliminary Affirmative Determinations of Circumvention Regarding Solar Modules from Southeast Asia

On December 2, 2022, the U.S. Department of Commerce (“Commerce”) issued preliminary affirmative determinations of circumvention with respect to crystalline silicon photovoltaic (“CSPV”) cells and modules exported to the...more

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