“Secondary tariffs” strike again, with India now squarely in the crosshairs of the latest U.S. trade action. On August 6, President Trump issued an executive order “Addressing Threats to the United States by the Government of...more
8/8/2025
/ Ad Valorem Tax ,
Economic Sanctions ,
Effective Date ,
Executive Orders ,
Foreign Policy ,
Goods or Services ,
Imports ,
India ,
International Emergency Economic Powers Act (IEEPA) ,
Oil & Gas ,
Regulatory Reform ,
Russia ,
Tariffs ,
Trump Administration ,
US Trade Policies
On July 31, 2025, President Trump issued two executive orders that further refine U.S. trade policy. The first executive order, “Further Modifying the Reciprocal Tariff Rates” (the RT Order), adjusts tariff rates for various...more
8/4/2025
/ Canada ,
Executive Orders ,
Exports ,
Free Trade Agreements ,
Imports ,
Mexico ,
Popular ,
Retaliatory Tariffs ,
Tariffs ,
Trade Agreements ,
Trade Policy ,
Trump Administration ,
United States-Mexico-Canada Agreement (USMCA) ,
US Trade Policies
On July 30, President Trump took two actions that represent a significant escalation in the administration’s evolving trade strategy: (1) a presidential proclamation (the proclamation) imposing a 50% ad valorem tariff on...more
8/4/2025
/ Commodities ,
Customs and Border Protection ,
De Minimus Quantity Exemption ,
Executive Orders ,
Imports ,
International Emergency Economic Powers Act (IEEPA) ,
International Trade ,
Metals ,
Presidential Proclamations ,
Section 232 ,
Tariffs ,
Trade Expansion Act of 1962 ,
Trump Administration ,
U.S. Commerce Department ,
US Trade Policies
On July 21, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced its intention to delay the effective date of the final rule imposing anti-money laundering (AML) obligations on...more
7/23/2025
/ Anti-Money Laundering ,
BSA/AML ,
Effective Date ,
Exemptions ,
Final Rules ,
Financial Crimes ,
Financial Regulatory Reform ,
Financial Services Industry ,
FinCEN ,
Investment ,
Investment Adviser ,
Regulatory Requirements ,
Reporting Requirements ,
Rulemaking Process
On July 8, in the wake of the Federal Trade Commission’s (FTC) designation of July as “Made in the USA” (MUSA) Month, the FTC issued warning letters to four companies suspected of violating the FTC’s Made in USA Labeling Rule...more
The U.S. Department of Justice (DOJ) has announced that it is expanding its enforcement priorities to include a focus on import-related fraud — particularly schemes aimed at evading U.S. tariffs and duties. This marks a...more
7/17/2025
/ Corporate Counsel ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Enforcement Priorities ,
Fraud ,
Goods or Services ,
Imports ,
Investigations ,
Regulatory Agenda ,
Tariffs ,
US Trade Policies ,
White Collar Crimes
On July 2, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) reached a settlement with Key Holding, LLC (Key Holding) concerning its non-U.S. subsidiary’s violations of the Cuban Assets...more
7/15/2025
/ Acquisition Agreements ,
Cuban Assets Control Regulations (CACR) ,
Due Diligence ,
Economic Sanctions ,
Enforcement Actions ,
Foreign Subsidiaries ,
International Trade ,
Merger Agreements ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Sanction Violations ,
Sanctions ,
U.S. Treasury
On July 7, 2025, President Trump signed an executive order (the Order) once again extending the temporary suspension of reciprocal tariffs that were originally set forth in his April 2 “Liberation Day” Executive Order 14257...more
7/10/2025
/ Executive Orders ,
Foreign Policy ,
Foreign Trade Regulations ,
Imports ,
Retaliatory Tariffs ,
Supply Chain ,
Tariffs ,
Trade Agreements ,
Trade Relations ,
Trump Administration ,
US Trade Policies
On June 30, 2025, President Trump issued an executive order (EO) that, effective July 1, revokes the U.S. sanctions program on Syria, and calls for the removal of the Syrian Sanctions Regulations from the Code of Federal...more
On June 23, the New York State Department of Financial Services (NYDFS) issued an industry letter to all regulated entities — banks, insurers, money transmitters, virtual currency companies, and others — cautioning that...more
On June 12, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) imposed a civil penalty of approximately $216 million on GVA Capital Ltd., a venture capital firm based in San Francisco, for...more
6/17/2025
/ Civil Monetary Penalty ,
Corporate Counsel ,
Economic Sanctions ,
Enforcement Actions ,
Financial Crimes ,
Financial Institutions ,
Investment ,
Investment Funds ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Sanction Violations ,
Subpoenas ,
Venture Capital
FUNDamentals is a periodic digest of news and information specifically for private funds and their managers. In this issue, we highlight some fundraising trends, new marketing rule FAQs, fund liquidity trends (limited...more
6/17/2025
/ Federal Budget ,
Financial Markets ,
Financial Services Industry ,
Fund Managers ,
Investment ,
Investment Funds ,
Investment Management ,
Limited Partnerships ,
Liquidity ,
Private Equity ,
Private Equity Funds ,
Proposed Legislation ,
Regulatory Reform ,
Regulatory Requirements ,
Trump Administration
On May 28, the U.S. Court of International Trade ruled that the tariffs imposed by President Trump under the International Emergency Economic Powers Act (IEEPA) were unlawful. In the case of V.O.S. v. United States, the court...more
6/13/2025
/ Aluminum Sales ,
Appeals ,
Constitutional Challenges ,
Critical Infrastructure Sectors ,
International Emergency Economic Powers Act (IEEPA) ,
International Trade ,
Judicial Authority ,
Mexico ,
Real Estate Development ,
Section 301 ,
Statutory Interpretation ,
Steel Industry ,
Tariffs ,
Taxation ,
Trump Administration ,
US Trade Policies
On May 31, 2025, the Office of the United States Trade Representative (USTR) issued a Federal Register notice extending specific product exclusions from Section 301 tariffs on Chinese imports. This extension affects 164...more
6/6/2025
/ China ,
Critical Infrastructure Sectors ,
Customs and Border Protection ,
Foreign Relations ,
Imports ,
Retail Market ,
Section 301 ,
Suppliers ,
Supply Chain ,
Tariffs ,
US Trade Policies ,
USTR
On May 23, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Syria General License 25 (GL 25), effectively lifting most sanctions imposed under the Syrian Sanctions Regulations (SSR) (31...more
On May 12, President Trump issued an executive order, “Modifying Reciprocal Tariff Rates to Reflect Discussions with the People’s Republic of China” (the Order), temporarily lowering reciprocal tariffs on Chinese imports that...more
5/15/2025
/ China ,
Customs and Border Protection ,
Executive Orders ,
Foreign Policy ,
Foreign Relations ,
Imports ,
order ,
Retaliatory Tariffs ,
Section 301 ,
Tariffs ,
Trade Relations ,
Trump Administration ,
US Trade Policies
On April 30, 2025, Senators Mark Kelly (D-AZ) and Todd Young (R-IN) — joined by a bipartisan group of Senate and House sponsors — reintroduced the Shipbuilding and Harbor Infrastructure for Prosperity and Security (SHIPS) for...more
5/6/2025
/ China ,
Economic Sanctions ,
Imports ,
Infrastructure ,
International Trade ,
Legislative Agendas ,
Maritime Transport ,
National Security ,
Proposed Legislation ,
Shipbuilding ,
Shipping ,
Shipping Cargo ,
Supply Chain ,
Trade Policy ,
USTR ,
Vessels
On April 29, President Trump issued a new proclamation, “Amendments to Adjusting Imports of Automobiles and Automobile Parts into the United States,” modifying Proclamation 10908 “Adjusting Imports of Automobiles and...more
5/1/2025
/ Automotive Industry ,
Critical Infrastructure Sectors ,
Customs and Border Protection ,
Executive Orders ,
Imports ,
Manufacturers ,
Motor Vehicles ,
OEM ,
Regulatory Reform ,
Supply Chain ,
Tariffs ,
Trump Administration ,
U.S. Commerce Department ,
US Trade Policies
On April 17, the Office of the United States Trade Representative (USTR) announced proposed trade actions under Section 301 of the Trade Act of 1974 (Trade Act) to counteract China’s systemic dominance in the maritime,...more
4/23/2025
/ China ,
Economic Sanctions ,
Foreign Policy ,
Foreign Relations ,
Liquid Natural Gas ,
Maritime Transport ,
National Security ,
Ports ,
Section 301 ,
Shipping ,
Supply Chain ,
Tariffs ,
Trade Policy ,
Trump Administration ,
USTR ,
Vessels
On April 9, the President signed an executive order titled “Restoring America’s Maritime Dominance” (the Order), a comprehensive initiative aimed at reversing decades of decline in the U.S. maritime industry. Citing national...more
4/16/2025
/ China ,
Department of Defense (DOD) ,
Executive Orders ,
Foreign Relations ,
Imports ,
Maritime Transport ,
National Security ,
Shipping ,
Shipping Cargo ,
Supply Chain ,
Trade Policy ,
Trump Administration ,
USTR ,
Vessels
On April 11, the White House released a Presidential Memorandum, “Clarification of Exceptions Under Executive Order 14257 of April 2, 2025, as Amended,” which exempts a list of semiconductors and electronics from reciprocal...more
4/16/2025
/ Cell Phones ,
China ,
Critical Infrastructure Sectors ,
Executive Orders ,
Foreign Policy ,
Foreign Relations ,
Imports ,
Innovative Technology ,
Regulatory Reform ,
Semiconductors ,
Suppliers ,
Supply Chain ,
Tariffs ,
Trump Administration ,
U.S. Commerce Department ,
US Trade Policies ,
Wireless Technology
President Trump signed a new executive order, “Modifying Reciprocal Tariff Rates to Reflect Trading Partner Retaliation and Alignment” (the Order) on April 9, marking yet another significant shift in U.S. trade policy. The...more
4/14/2025
/ China ,
Executive Orders ,
Exports ,
Foreign Policy ,
Foreign Relations ,
Imports ,
Retaliatory Tariffs ,
Tariffs ,
Trade Relations ,
Trade Wars ,
Trump Administration ,
US Trade Policies
On February 10, President Trump issued Proclamations 10896, “Adjusting Imports of Steel Into the United States” and 10895 “Adjusting Imports of Aluminum Into the United States,” (together, Proclamations), reasserting U.S....more
4/11/2025
/ Aluminum Sales ,
Construction Project ,
Customs and Border Protection ,
Foreign Trade Zones ,
Harmonized Tariff Schedule of the United States (HTSUS) ,
Imports ,
Infrastructure ,
Section 232 ,
Steel Industry ,
Supply Chain ,
Tariffs ,
Trade Expansion Act of 1962 ,
Trump Administration ,
US Trade Policies
On March 26, President Trump issued Proclamation 10908, “Adjusting Imports of Automobiles and Automobile Parts Into the United States” (Proclamation), imposing a 25% additional tariff on imports of passenger vehicles, light...more
4/9/2025
/ Automotive Industry ,
Canada ,
Executive Orders ,
Foreign Trade Regulations ,
Foreign Trade Zones ,
Harmonized Tariff Schedule of the United States (HTSUS) ,
Imports ,
Infrastructure ,
Japan ,
Mexico ,
Motor Vehicles ,
National Security ,
Popular ,
Section 232 ,
Supply Chain ,
Tariffs ,
Trade Expansion Act of 1962 ,
Trump Administration ,
U.S. Commerce Department ,
United States-Mexico-Canada Agreement (USMCA) ,
US Trade Policies
On April 2, President Trump declared “Liberation Day” and unveiled a series of sweeping tariff measures aimed at addressing trade imbalances and foreign trade practices while boosting domestic manufacturing. Marking the...more
4/8/2025
/ Canada ,
China ,
Executive Orders ,
Foreign Policy ,
Foreign Relations ,
Goods or Services ,
Harmonized Tariff Schedule of the United States (HTSUS) ,
International Emergency Economic Powers Act (IEEPA) ,
International Trade ,
Mexico ,
Popular ,
Retaliatory Tariffs ,
Supply Chain ,
Tariffs ,
Trump Administration ,
United States-Mexico-Canada Agreement (USMCA) ,
US Trade Policies