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 while the primary targets of enforcement were familiar ones: China, Russia, and Iran. Numerous government agencies issued enforcement regulations and guidance. With the new administration in the U.S., however, there appear to be new priorities. On one hand, the Trump administration may use sanctions and export controls as a tool to broker a resolution to Russia’s war on Ukraine. If successful, however, we could see a rapid reduction in enforcement with respect to Russia-related actions. In the interim, a previously unified Western position on Russia is fracturing, increasing the prospect that enforcement risks for companies operating in Russia will be greater under EU and UK laws than under U.S. law. On the other hand, the Trump administration has shown signs that it intends to more closely focus on China and Iran—which could result in potential increased enforcement related to those jurisdictions. Initial indications also clearly demonstrate that, under the Trump administration, the enforcement environment for non-U.S. companies may be more challenging than for U.S. companies, especially for companies in jurisdictions that the Trump administration targets for trade-related countermeasures (such as tariffs).
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