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Tariff Update: Reciprocal Tariffs and Other Recent Changes

On August 7, 2025, President Trump’s reciprocal tariffs fully came into effect. The overall U.S. effective tariff rate has now risen to an estimated 18.6%, which is the highest rate since 1934. Several countries continue to...more

Throwing Away the Toaster: Where AI Controls Are Now and May be Heading

Anyhow, on a possibly related note, on May 14, 2025, BIS announced that it will rescind the AI Diffusion Rule and that, until the time of the official recission, would not enforce the Biden-era regulation. Stop-Gap Stopped...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

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

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

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

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 Persistence of (High Bandwidth) Memory: Semiconductor Manufacturing Equipment and Korean Semiconductor Manufactures Face...

On December 2, 2024, the Department of Commerce, Bureau of Industry and Security (BIS) issued a new set of regulations targeting semiconductors manufacturing equipment (SME) and high-bandwidth memory (HBM) chips. The updates...more

Closing the Southern Border to Indirect Chinese Imports: U.S. Proclamations on Steel and Aluminum Imports from Mexico

Effective July 10, 2024, President Biden issued two Presidential Proclamations aimed at refining the tariff exclusions under Section 232 of the Trade Expansion Act of 1962 for steel and aluminum imports from Mexico. Together,...more

China Semiconductor Export Regulations, Episode V – Updates and Corrections to the Advanced Computing and Semiconductor...

On March 29, 2024, BIS issued an interim final rule (IFR) updating and correcting its advanced computing and semiconductor regulations published in October 2023 (which we discuss here in Episode III). This marks the third...more

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