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A Time Machine and a Bag of Hammers: U.S. Tariffs are not Over

If the White House wants tariffs, but the courts strike down the Reciprocal Tariffs, what other options are out there? This is the question we asked ourselves and the answer is: there are plenty of other options. If it...more

Federal Court Strikes Down IEEPA Tariffs

On May 28, 2025, a three-judge panel of the U.S. Court of International Trade (CIT) unanimously struck down the extensive tariffs imposed by President Trump under the International Emergency Economic Powers Act (IEEPA). The...more

Not What You Think: Some Trump Tariffs Exempt Your Goods from Other Trump Tariffs

Some importers are finding, to their surprise, that the Trump Administration’s 25% tariffs on aluminum and steel create an exemption from the 125% tariffs on Chinese goods. The Trump tariff agenda has been complex, to say...more

A Roadmap for Export Controls? Project 2025 and the Future of U.S. Exports – Part III

The second Trump administration has come flying out of the starting blocks on international trade policy actions—imposing and rescinding, shaping and reshaping tariffs, sanctions, and export controls. The executive orders and...more

Blockading the Ports: U.S. Imposes 10% Global Tariff; Higher Reciprocal Tariff Rates by Country

On April 2, President Trump issued an Executive Order (EO) imposing global reciprocal tariffs (White House Fact Sheet). The EO drew enough parallels to the Smoot-Hawley Tariff Act that Trump mentioned it in his Rose Garden...more

The First Wave: U.S. Imposes Tariffs on Canada (or not?), Mexico (or not?), and China (well, yeah, probably so)

On February 1, 2025, President Trump issued three executive orders imposing tariffs on nearly all imports from Canada, Mexico, and China. However, on February 3, the President said on social media that the tariffs on Canada...more

New Russia Sanctions Intensify Pressure on Banks Worldwide

On December 22, 2023, President Biden signed a new Executive Order (E.O. 14114) containing the latest round of sanctions against the Russian Federation. Shortly thereafter, Treasury Secretary Janet Yellen stated that the...more

New Outbound Investment Restrictions Affect China, Semiconductors, Artificial Intelligence, and Quantum Computing

On August 9, 2023, President Biden issued an Executive Order (E.O.) ordering the issuance of outbound investment restrictions. This E.O. comes after nearly a year of anticipation (as we have documented on several occasions...more

Will We Ring in the New Year with Outbound Investment Restrictions?

As we close out a wild year for international trade regulation, after hearing much talk about outbound investment review mechanisms, we may see a final dramatic change before the ball drops...more

Securing the U.S. Bulk Power System: An Assessment of Executive Order 13920

On May 1, 2020, President Trump issued Executive Order 13920 (“Executive Order”), which prohibited certain transactions involving bulk-power system electric equipment manufactured or supplied by persons owned by, controlled...more

Negotiation By Tweet: The Uncertain Future of U.S.-Cuba Relations

After the announcement of Fidel Castro’s death on November 26, 2016, President Barack Obama sent a message to the Cuban people highlighting his administration’s efforts to improve relations between the United States and Cuba....more

OFAC Issues Cuban Asset Control Regulations Focused on the U.S. Financial Sector

On January 15, 2015, the Department of Treasury’s Office of Foreign Assets Control (OFAC) amended the Cuban Assets Control Regulations to implement changes in U.S. policy toward Cuba announced by President Obama on December...more

The Gloves are Off: U.S. Sanctions Block Aggressors in Crimea

In response to Russia’s military presence in the Crimean region of Ukraine, President Obama issued an Executive Order (“EO”) on March 6, 2014, authorizing the blocking of property of individuals and entities involved in the...more

Streamlining the System: More Baby Steps Toward Reducing Export Compliance Burdens

Since 2011, President Barack Obama’s administration has actively pursued export control reform designed to reduce the regulatory burdens on U.S. companies and enhance U.S. national security (as reported here). On March 7,...more

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