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U.S. Tariffs on Non-USMCA-Compliant Products Take Effect; Increased Tariff Rate on China Imposed

Between March 4, 2025, and March 6, 2025, U.S. trade policy in North America changed course multiple times as the Trump administration initially implemented previously paused tariffs on imports from Canada and Mexico, and two...more

Trump 2.0: U.S. Imposes Tariffs on Key Trading Partners 

After months of anticipation, on February 1, 2025, President Trump announced the imposition of significant tariffs on Mexico, Canada, and China through three Executive Orders (EOs). While additional details are expected to be...more

BIS Issues Interim Final Rule Establishing a Framework for Artificial Intelligence Diffusion

On January 13, 2025, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) issued an Interim Final Rule (IFR), establishing new export controls targeting advanced artificial intelligence (AI) chips and model...more

BIS Issues Interim Final Rule on Advanced Computing Integrated Circuits, Providing Long-Awaited Guidance on Due Diligence...

On January 15, 2025, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) released an interim final rule (IFR) updating export controls on advanced computing semiconductors. This IFR seeks to ensure that...more

Trump 2.0

An Initial Roundup of Key Policy Issues and Expectations The re-election of Donald Trump—empowered by at least a Republican-led Senate—marks a significant political and administrative change in the United States, with...more

USTR Finalizes Section 301 Tariffs on Chinese Imports with a Focus on Products from “Strategic Sectors”

On September 13, 2024 USTR announced modifications to the tariffs originally imposed under Section 301 of the Trade Act of 1974 to pressure China to eliminate unreasonable policies and practices related to technology transfer...more

Closing the Loophole: Biden Administration Takes Action Against De Minimis Imports from China

On September 12, 2024, the Biden Administration announced a number of new trade-related measures related to imports of Chinese-manufactured goods. This announcement comes as the latest action in the Biden Administration’s...more

BIS Imposes New Export Controls on Quantum, Semiconductor and Additive Manufacturing Technologies

On September 5, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) issued an interim final rule imposing significant new export controls on quantum computing, cryocooling systems, semiconductor...more

USTR Calls for Stakeholder Comments Following the Report on the Four-Year Review of the Section 301 Tariffs

On May 22, USTR followed up the recommendations in its March 14 report with specific proposals for increases in Section 301 tariffs. There will be an exclusion process allowing interested parties to request temporary...more

USTR Issues Long Awaited Report on the 4-Year Review of the Section 301 Tariffs

On May 14, 2024, the U.S. Trade Representative (“USTR”) published the Four-Year Review of Actions Taken in the Section 301 Investigation (“Report”), which addresses the four-year review of China-related tariffs under Section...more

State Department Proposes Exempting Australia, UK from Certain Defense Related Export Controls

On April 30, 2024, the Department of State proposed an amendment to the International Traffic in Arms Regulations (ITAR) intended to facilitate exports of defense articles, the performance of defense services, and brokering...more

Further Enhancing Australia, United Kingdom, United States (AUKUS) Trilateral Security Partnership through Export Controls

On April 19, 2024, the Department of Commerce Bureau of Industry and Security (BIS) issued an interim final rule reducing export control licensing requirements for Australia and the United Kingdom (UK) as a means to further...more

Correcting and Clarifying Export Controls Issued on Advanced Computing and Semiconductor Manufacturing Items

On March 29, 2024, the U.S. Commerce Department’s Bureau of Industry and Security (BIS) issued an interim final rule (“2024 IFR”) clarifying and correcting its October 2023 interim final rules on advanced...more

U.S. Increases Export Restrictions Against Nicaragua

The U.S. Department of Commerce amended the Export Administration Regulations (EAR), effective March 15, 2024, to move Nicaragua from Country Group B to Country Group D, and added it to the list of countries subject to the...more

DoD Publishes Final Rule Implementing Executive Order 14005

The rule conforms applicable DFARS clauses to the final FAR rule that was published on March 7, 2022. Contractors must comply with increasing U.S. and qualifying country content thresholds for manufactured end products—65...more

BIS Issues Additional Enhancements to Voluntary Self-Disclosure Process

Takeaways: On January 16, 2024, the Bureau of Industry and Security (“BIS”) Office of Export Enforcement (“OEE”) announced several updates to its Voluntary Self-Disclosure (VSD) process aimed at enhancing the program’s...more

Closing the Loopholes: Additional Export Controls Issued on Advanced Computing and Semiconductor Manufacturing Items

On November 6, 2023, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) held a public briefing to address industry questions concerning the latest export controls on advanced computing and semiconductor...more

Expansion of Global Capability Centers Requires Anticorruption Compliance Planning

Companies looking to set up global capability centers in India should take steps at the outset to assure compliance with applicable anti-bribery and anti-corruption laws and standards. The FCPA prohibits bribing or...more

OMB Finalizes “Build America, Buy America” Domestic Content Guidance

The Build America, Buy America Act generally requires that non-federal government infrastructure projects that benefit from federal government funding impose requirements for the use of domestic iron and steel and...more

Proposed Rule Increases Buy American Act Content Thresholds for DoD Contracts

The Department of Defense has proposed an amendment to the Defense Federal Acquisition Regulation Supplement to align with the Federal Acquisition Regulatory Council’s update to the Federal Acquisition Regulation in...more

IRS, Department of Treasury Release Guidance on Domestic Content Rules for Energy Projects

The Guidance sets out the requirements for using domestic steel, iron and manufactured products in order for a project to be eligible for the domestic content bonus credit amount. Projects that meet the domestic content...more

DFARS Proposed Export Controls Rule Would Require Supplying DCMA with Copy of Relevant Export Authorizations

On March 22, 2023, the Department of Defense (DoD) published a proposed rule to amend Defense Federal Acquisition Regulation Supplement (DFARS) clause 252.225-7048. This amendment would implement an additional export control...more

4/11/2023  /  DCMA , DFARS , Exports

Additional Sanctions and Export Control Restrictions Imposed on One-Year Anniversary of Russia-Ukraine Conflict

On February 24, 2023, the one-year anniversary of the Russia-Ukraine conflict, the United States released extensive new measures designed to impose additional sanctions on Russia for its aggression against Ukraine. These new...more

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