The President also signed an Executive Order that will eliminate duty-free de minimis treatment and create a new duty collection process for low-value postal shipments from China and Hong Kong.
On April 2, 2025, President...more
4/7/2025
/ Canada ,
China ,
Executive Orders ,
Foreign Trade Regulations ,
Hong Kong ,
Imports ,
International Emergency Economic Powers Act (IEEPA) ,
International Trade ,
Mexico ,
Popular ,
Tariffs ,
Trump Administration ,
United States-Mexico-Canada Agreement (USMCA) ,
US Trade Policies ,
Value-Added Tax (VAT)
The President has issued three executive orders that impose universal tariffs on Mexico, Canada, and China, deploying IEEPA in a sweeping manner to address the President’s declaration of a national emergency regarding illegal...more
2/4/2025
/ Canada ,
China ,
Customs and Border Protection ,
Economic Sanctions ,
Executive Orders ,
Foreign Policy ,
Imports ,
International Emergency Economic Powers Act (IEEPA) ,
International Trade ,
Mexico ,
National Security ,
Tariffs ,
Trade Relations ,
Trade Retaliation
The President’s memorandum does not implement tariffs or other immediate relief, but previews the statutory authorities that will guide future trade action.
On January 20, 2025, President Trump issued a memorandum...more
1/24/2025
/ Anti-Dumping Duty ,
China ,
Competition ,
Countervailing Duties ,
International Emergency Economic Powers Act (IEEPA) ,
International Trade ,
National Security ,
Section 301 ,
Supply Chain ,
Tariffs ,
Trade Deficit ,
Trade Relations ,
Trump Administration ,
United States-Mexico-Canada Agreement (USMCA)
The Proposed Rule imposes substantial new reporting, diligence, and compliance obligations for companies in the automotive supply chain -
On September 26, 2024, the U.S. Department of Commerce’s Bureau of Industry and...more
10/22/2024
/ Advanced Notice of Proposed Rulemaking (ANPRM) ,
Advisory Opinions ,
Automation Systems ,
Automotive Industry ,
Biden Administration ,
Cannabis Products ,
China ,
Compliance ,
Driverless Cars ,
Due Diligence ,
Foreign Adversaries ,
General Authorization ,
Hardware ,
Importers ,
International Emergency Economic Powers Act (IEEPA) ,
Office of Foreign Assets Control (OFAC) ,
Proposed Rules ,
Recordkeeping Requirements ,
Reporting Requirements ,
Russia ,
Software ,
Supply Chain
As discussed in our May 7, 2024 alert, on April 24, 2024, President Biden signed into law a foreign military support package (i.e., H.R. 815), which included a provision doubling the statute of limitations (“SOL”) from five...more
9/24/2024
/ Civil Monetary Penalty ,
Cuban Assets Control Regulations (CACR) ,
Department of Labor (DOL) ,
Economic Sanctions ,
Enforcement ,
Interim Final Rules (IFR) ,
International Emergency Economic Powers Act (IEEPA) ,
Investigations ,
Office of Foreign Assets Control (OFAC) ,
Recordkeeping Requirements ,
Regulatory Requirements ,
Statute of Limitations ,
TWEA
Regulations ultimately will implement a new program restricting certain investments related to China-
On June 21, 2024, the U.S. Department of the Treasury (“Treasury”) issued a Notice of Proposed Rulemaking (the “Rule”)...more
7/11/2024
/ Advanced Notice of Proposed Rulemaking (ANPRM) ,
CFIUS ,
Enforcement ,
Foreign Entities ,
Foreign Investment ,
International Emergency Economic Powers Act (IEEPA) ,
Investors ,
National Security ,
Notice of Proposed Rulemaking (NOPR) ,
Outbound Transactions ,
Proposed Rules ,
U.S. Treasury
Implications Related to the Doubling of the Statute of Limitations for Civil and Criminal Violations of Two Primary Sanctions Authorities -
SUMMARY -
On April 24, 2024, President Biden signed into law a foreign military...more
5/8/2024
/ Bureau of Industry and Security (BIS) ,
Department of Justice (DOJ) ,
Due Diligence ,
Export Administration Regulations (EAR) ,
Export Control Reform Act (ECRA) ,
Foreign Corrupt Practices Act (FCPA) ,
International Emergency Economic Powers Act (IEEPA) ,
Office of Foreign Assets Control (OFAC) ,
Policies and Procedures ,
Sanction Violations ,
Self-Disclosure Requirements ,
Statute of Limitations ,
Trading with the Enemy Act ,
Voluntary Disclosure
Prohibitions targeted to prevent China’s exploitation of dual-use technology -
On August 9, 2023, President Biden signed a historic Executive Order on Addressing United States Investments in Certain National Security...more
8/15/2023
/ Advanced Notice of Proposed Rulemaking (ANPRM) ,
CFIUS ,
China ,
Compliance ,
Covered Transactions ,
Debt Financing ,
Executive Orders ,
Foreign Investment ,
International Emergency Economic Powers Act (IEEPA) ,
Joe Biden ,
National Security ,
Penalties ,
Policies and Procedures ,
Screening Procedures ,
Semiconductors ,
Technology Sector ,
U.S. Treasury
On May 1, 2020, President Donald J. Trump signed Executive Order 13920 declaring a national emergency regarding threats posed to the U.S. bulk-power system by electrical equipment supplied by “foreign adversaries.” (BPS EO)...more
5/11/2020
/ Bulk Electric System ,
CFIUS ,
China ,
Department of Energy (DOE) ,
Electricity ,
Energy Sector ,
Executive Orders ,
Foreign Adversaries ,
Foreign Suppliers ,
Huawei ,
Infrastructure ,
International Emergency Economic Powers Act (IEEPA) ,
National Security ,
NDAA ,
Proposed Rules ,
Russia ,
Telecommunications
In the past, sanctioned jurisdictions like Venezuela have embraced virtual currency as a way to bypass channels that involve U.S. dollars, blunting the impact of U.S. economic sanctions policies aimed at isolating those...more
3/12/2020
/ Anti-Money Laundering ,
Bitcoin ,
Blockchain ,
Cryptocurrency ,
Cyber Crimes ,
Cybersecurity ,
Department of Justice (DOJ) ,
International Emergency Economic Powers Act (IEEPA) ,
Iran ,
Law Enforcement ,
National Security ,
North Korea ,
Office of Foreign Assets Control (OFAC) ,
U.S. Treasury ,
Virtual Currency
On December 13, 2019, the Department of Justice (“DOJ”) released an updated Export Control and Sanctions Enforcement Policy for Business Organizations (“Policy”), revising the prior policy governing voluntary self-disclosures...more
1/17/2020
/ Department of Justice (DOJ) ,
Export Control Reform Act (ECRA) ,
Export Controls ,
Exports ,
FCPA Corporate Enforcement Policy (CEP) ,
Foreign Corrupt Practices Act (FCPA) ,
Internal Investigations ,
International Emergency Economic Powers Act (IEEPA) ,
International Sales ,
Non-Prosecution Agreements ,
Regulatory Requirements ,
Sanction Violations ,
Self-Disclosure Requirements
Stepping outside of SWIFT -
Since its inception more than a decade ago, cryptocurrency has been viewed as a way to supplant traditional global methods of exchanging money. Today, as virtual currencies proliferate,...more
2/19/2019
/ Corruption ,
Cryptocurrency ,
Digital Currency ,
Economic Sanctions ,
Initial Coin Offering (ICOs) ,
International Emergency Economic Powers Act (IEEPA) ,
Iran ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
SDN List ,
Securities and Exchange Commission (SEC) ,
Self-Regulatory Organizations ,
SWIFT ,
Virtual Currency