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Reevaluating the Foreign Corrupt Practices Act Enforcement: A New Paradigm

On February 10, 2025, President Trump signed an Executive Order (E.O.) directing a shift in the enforcement of the Foreign Corrupt Practices Act (FCPA). The order effectively pauses new FCPA investigations and enforcement...more

FARA's Pendulum: Shifts in Foreign Agent Regulation

On her first day in office, Attorney General Pamela Bondi issued a memorandum signaling a significant shift in the Department of Justice’s (DOJ) approach to Foreign Agents Registration Act (FARA) enforcement. The memorandum...more

The “What,” “When,” and “How” of President Trump’s New Tariffs Against Canada, Mexico and China: Developing a Legal and Business...

1. What? Tariff Rates and Legal Authority - President Trump signed three executive orders imposing new tariffs against Canada, Mexico, and China, following through on prior campaign and post-inauguration promises. While...more

Trump’s Return to Trade: Preparing for the Tariff Battles

President-elect Trump has indicated that he will immediately increase tariffs as to imports from multiple countries, most notably China, Mexico, and Canada. However, companies involved in international trade are closely...more

Opening the Skies: U.S. Eases Export Controls to Propel Innovation and Global Collaboration

In a significant move to bolster the space industry and strengthen international partnerships, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) announced a series of modifications to export controls on...more

New Tariffs and Metal “Melt-and-Pour” Requirements Implemented to Prevent Chinese Circumvention Through Mexico

On July 10, 2024, the U.S. Government narrowed the tariff exclusions on imports of certain steel and aluminum articles from Mexico, citing national security concerns. These measures effectively impose new tariffs aimed at...more

The ENFORCE Act: Bipartisan Efforts to Decouple from China Target AI Export Controls

Against the backdrop of increasing international competition in the artificial intelligence (AI) space, the Enhancing National Frameworks for Overseas Critical Exports Act (the ENFORCE Act) was recently introduced in the U.S....more

Decoupling: A Closer Look at the Executive Order on U.S. Outbound Investments Into the Chinese Technology Sector

The much anticipated Executive Order (the “E.O.”) on outbound investments directed at the Chinese technology sector was finally released on August 9, 2023. Citing the “unusual and extraordinary threat to national security”...more

New Commerce Rule Injects Uncertainty Into Foreign Transactions Involving Information and Communications Technology

On January 14, 2021, the U.S. Department of Commerce issued an interim final rule to address national security, economic security, and public health and safety concerns related to Information and Communications Technology and...more

President Trump Issues Executive Order Prohibiting Investment in Securities of Chinese Military Companies

On November 12, 2020, President Donald Trump signed an executive order prohibiting “United States persons” from engaging in “transactions” in securities of “Chinese Communist military companies.” The order marks another...more

Trade (Un)Certainty in 2020: U.S. Tariff Policy Toward China and the EU

As 2020 begins, U.S. tariff policy toward China and the European Union (EU) is moving in different directions, with significant implications for U.S. companies. Beginning with China, the U.S. has gradually implemented tariffs...more

UPDATE: Increase in List Three Tariffs Postponed for 90 Days

In a statement issued on December 1, 2018, the White House announced that it reached a deal with China to postpone the scheduled increase of List Three tariffs on Chinese imports for 90 days. The announcement came after a...more

Understanding the 2018 U.S. Tariffs on Chinese Goods: Developing a Game Plan

The United States Trade Representative (“USTR”) recently announced a new set of tariffs on imports of Chinese goods.1 Companies with global supply chains have been scrambling to understand the impact of the tariffs on...more

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