On April 2, 2025, the President announced the imposition of reciprocal tariffs on goods imported into the United States from a broad range of countries at an initial 10% rate. Higher rates for specific countries were...more
On April 2, 2025, President Trump announced reciprocal tariffs on imports into the United States, with a minimum 10% tariff applied to imports from most sources with limited country and product carveouts as discussed below,...more
Background: From 2018 to 2019, the U.S. Department of Commerce (Commerce) conducted an investigation under Section 232 into the national security effects of U.S. automotive imports. In its February 17, 2019 report in the...more
The head of the U.S. Department of Justice (DOJ) branch that oversees False Claims Act (FCA) investigations affirmed the Trump Administration’s commitment to pursue civil fraud cases as part of its focus on achieving...more
2/27/2025
/ Customs ,
Department of Defense (DOD) ,
Department of Health and Human Services (HHS) ,
Department of Justice (DOJ) ,
Enforcement Actions ,
False Claims Act (FCA) ,
Federal Contractors ,
Fraud ,
General Services Administration (GSA) ,
Healthcare Fraud ,
Imports ,
International Trade ,
Qui Tam ,
Tariffs ,
Trade Policy ,
Unfair or Deceptive Trade Practices ,
Whistleblowers
On January 20, 2025, President Trump issued a Presidential memorandum entitled Regulatory Freeze Pending Review (Freeze Order). This action is unsurprising, as previous Presidents have consistently issued similar memoranda at...more
1/27/2025
/ Artificial Intelligence ,
Bureau of Industry and Security (BIS) ,
Consumer Financial Protection Bureau (CFPB) ,
Cybersecurity ,
Department of Justice (DOJ) ,
Executive Orders ,
FCC ,
Federal Trade Commission (FTC) ,
Final Rules ,
Foreign Agents Registration Act (FARA) ,
Government Agencies ,
OFR ,
Proposed Rules ,
Regulatory Freeze ,
Regulatory Reform ,
Telecommunications ,
Trump Administration
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
1/22/2025
/ America First Trade Policy ,
Canada ,
China ,
Department of Homeland Security (DHS) ,
Export Controls ,
Foreign Investment ,
Information and Communication Technology (ICT) ,
International Emergency Economic Powers Act (IEEPA) ,
Mexico ,
National Security ,
OMB ,
Section 232 ,
Section 301 ,
Social Media ,
Tariffs ,
TikTok ,
Trade Relations ,
Trump Administration ,
U.S. Commerce Department ,
U.S. Treasury ,
United States-Mexico-Canada Agreement (USMCA) ,
USTR
On January 13, 2025, the U.S. Department of Commerce, Bureau of Industry and Security (BIS) announced an interim final rule (IFR) that modifies and expands export controls on advanced computing integrated circuits (IC) and...more
1/20/2025
/ Artificial Intelligence ,
Bureau of Industry and Security (BIS) ,
Compliance ,
Data Centers ,
ECCNs ,
Export Administration Regulations (EAR) ,
Export Controls ,
Final Rules ,
Interim Final Rules (IFR) ,
International Trade ,
National Security ,
National Security Agency (NSA) ,
Regulatory Requirements ,
Technology Sector ,
Trump Administration
On January 14, 2025, the Department of Commerce Bureau of Industry and Security (BIS) published its Final Rule (Final Rule or the Rule) on “Securing the Information and Communications Technology and Services Supply Chain:...more
1/17/2025
/ Automotive Industry ,
Bureau of Industry and Security (BIS) ,
China ,
Connected Cars ,
Executive Orders ,
Final Rules ,
Imports ,
National Security ,
PRC ,
Russia ,
Software ,
Supply Chain ,
Technology Sector ,
U.S. Commerce Department
On January 14, 2025, U.S. Customs and Border Protection (CBP) issued a proposal to alter its regulations regarding de minimis imports. Section 321(a)(2) of the Tariff Act of 1930 currently authorizes duty exemptions, as well...more
1/15/2025
/ Biden Administration ,
Customs and Border Protection ,
De Minimus Doctrine ,
Enforcement ,
Imports ,
International Trade ,
National Security ,
Proposed Rules ,
Regulatory Reform ,
Regulatory Requirements ,
Reporting Requirements ,
Rulemaking Process ,
Section 321 ,
Supply Chain ,
Tariff Act of 1930 ,
Tariffs
On November 25, 2024, President-Elect Trump made two posts to his Truth Social account in which he stated that on day one of his second Administration, he would impose additional tariffs of 10% on all products from China, and...more
The United States Department of Commerce, Bureau of Industry and Security (BIS) recently published three new regulatory actions easing administrative burdens under the Export Administration Regulations (EAR) associated with...more
11/1/2024
/ Aerospace ,
Bureau of Industry and Security (BIS) ,
Directorate of Defense Trade Controls (DDTC) ,
ECCNs ,
Export Administration Regulations (EAR) ,
Export Controls ,
ITAR ,
National Security ,
NATO ,
U.S. Commerce Department ,
US State Departments ,
USML
On October 15, 2024, the Office of the U.S. Trade Representative (USTR) began collecting requests for exclusions from Section 301 tariffs for Chinese-made machinery imported for use in domestic manufacturing. As noted in our...more
10/21/2024
/ Buy America ,
China ,
Customs and Border Protection ,
Exclusions ,
Imports ,
Inflation Reduction Act (IRA) ,
International Trade ,
REAP ,
Section 301 ,
Tariffs ,
USTR
On September 13, 2024, the White House announced that it will take several steps to crack down on use of the “de minimis exemption” for imports of unsafe and unfairly traded goods. The de minimis exemption currently allows...more
9/26/2024
/ Anti-Dumping Duty ,
Biden Administration ,
Consumer Product Safety Commission (CPSC) ,
Counterfeiting ,
Countervailing Duties ,
Customs and Border Protection ,
De Minimus Doctrine ,
Forced Labor ,
Health and Safety ,
Importers ,
Imports ,
Proposed Rules ,
Section 301 ,
Tariffs
The U.S. Department of Commerce’s Bureau of Industry and Security (BIS) recently issued two proposed rules that substantially increase the scope of controls under the Export Administration Regulations (EAR) applicable to...more
On July 18, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) published an interim final rule (IFR) amending the U.S. Export Administration Regulations (EAR) so that certain technology and software...more
7/23/2024
/ Bureau of Industry and Security (BIS) ,
Entity List ,
Export Administration Regulations (EAR) ,
Export Controls ,
General Licenses ,
Huawei ,
ITAR ,
National Security ,
Supply Chain ,
Technology ,
U.S. Commerce Department
On July 8, the U.S. Department of the Treasury (Treasury) issued a Notice of Proposed Rulemaking (NPRM) that would expand the jurisdiction of the Committee on Foreign Investment in the United States (CFIUS) to review...more
An August 4 deadline is fast approaching for comments to the U.S. Department of the Treasury’s Notice of Proposed Rulemaking (NPRM) that was issued June 21. The NPRM will restrict, for national security purposes, specific...more
7/16/2024
/ Advanced Notice of Proposed Rulemaking (ANPRM) ,
Artificial Intelligence ,
Covered Transactions ,
Cybersecurity ,
Executive Orders ,
Foreign Nationals ,
Intelligence Services ,
Investment ,
Investment Funds ,
Popular ,
PRC ,
Semiconductors ,
U.S. Treasury
The Biden Administration’s recent expansion of sanctions and export controls to counter Russian aggression will impact non-U.S. financial institutions and increase compliance risks for the business software sector and other...more
6/24/2024
/ Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
Export Administration Regulations (EAR) ,
Export Controls ,
Foreign Financial Institutions (FFI) ,
General Licenses ,
Information Technology ,
Liquid Natural Gas ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
Software ,
U.S. Treasury