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 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 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
As outlined in our recent publication, the United States imposed a 25% additional tariff on all imports from Canada and Mexico starting March 4, with a 10% tariff specifically on Canadian energy products and potash (the...more
3/17/2025
/ Ad Valorem Tax ,
Canada ,
Customs and Border Protection ,
Energy Policy ,
Executive Orders ,
Goods or Services ,
Imports ,
International Emergency Economic Powers Act (IEEPA) ,
Mexico ,
Popular ,
Supply Chain ,
Tariffs ,
Trump Administration ,
United States-Mexico-Canada Agreement (USMCA) ,
US Trade Policies
On March 12, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) allowed General License (GL) 8L under the Russian Harmful Foreign Activities Sanctions Regulations to expire. As a result, broad OFAC...more
3/14/2025
/ Banks ,
Biden Administration ,
Biofuel ,
Economic Sanctions ,
Financial Transactions ,
Foreign Policy ,
Foreign Relations ,
General Licenses ,
Natural Gas ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Popular ,
Prohibited Transactions ,
Russia ,
SDN List ,
Secondary Sanctions ,
Trump Administration ,
U.S. Treasury
The Trump administration continues to ramp up sanctions on Venezuela and Yemen's Houthis, while sending mixed signals about its intentions with respect to Russia. We provide brief updates on these three areas, following up...more
3/11/2025
/ Economic Sanctions ,
Foreign Policy ,
Foreign Relations ,
General Licenses ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Popular ,
Regulatory Reform ,
Russia ,
Terrorist Organizations ,
Trump Administration ,
U.S. Treasury ,
US Trade Policies ,
Venezuela ,
Yemen
Last week consisted of many developments surrounding President Trump's tariff policy. On March 4, his sweeping new tariffs took effect, significantly altering the trade landscape for businesses engaged in international...more
3/10/2025
/ Canada ,
China ,
Executive Orders ,
Exports ,
Foreign Policy ,
Foreign Trade Regulations ,
Goods or Services ,
Imports ,
Infrastructure ,
International Emergency Economic Powers Act (IEEPA) ,
Mexico ,
Popular ,
Retaliatory Tariffs ,
Supply Chain ,
Tariffs ,
Trade Relations ,
Trump Administration ,
United States-Mexico-Canada Agreement (USMCA) ,
US Trade Policies
On February 20, 2025, the U.S. Departments of State and the Treasury designated eight Latin American drug trafficking cartels as Foreign Terrorist Organizations (FTOs) and Specially Designated Global Terrorists (SDGTs), in...more
2/25/2025
/ Anti-Terrorism Financing ,
Cartels ,
Cooperative Compliance Regime ,
Criminal Prosecution ,
Economic Sanctions ,
Enforcement Actions ,
Financial Crimes ,
Foreign Policy ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Sanction Violations ,
SDN List ,
Terrorist Financing Regulations ,
Trafficking ,
Trump Administration
On October 28, 2024, the U.S. Department of the Treasury (the “Treasury”) released final regulations (the “Final Rule”) to implement Executive Order 14105, titled “Addressing United States Investments in Certain National...more
On August 28, 2024, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued a final rule (the “Rule”) that amends the definition of “financial institution” under the Bank Secrecy Act...more
On September 23, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) announced a proposed rule that could reshape the automotive industry by restricting the import and sale of connected vehicles....more
In a recent enforcement action, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) imposed a civil penalty on a U.S. company for violations of the antiboycott provisions under Part 760 of the Export...more
On August 21, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced a series of new initiatives to assist the public to better understand sanctions and the role of the private sector...more
On April 23, 2024, the U.S. Department of Labor (the “DoL”) released its final rule (“Fiduciary Rule”) titled Retirement Security Rule: Definition of an Investment Advice Fiduciary (an “Investment Advice Fiduciary”), which...more
On March 12, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) amended and reissued the Global Magnitsky Sanctions Regulations (the “Regulations”) to further the Global Magnitsky Human...more
On February 13, 2024, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) proposed a new rule that would require federal investment advisers to add Bank Secrecy Act (“BSA”) type anti-money...more
On September 8, 2023, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) released its Financial Trend Analysis (“FTA”). The FTA details FinCEN’s analysis of suspicious activity reports...more
The United States, primarily through Presidential action under the statutory authority of the International Emergency Economic Powers Act (“IEEPA”), has empowered the U.S. Department of the Treasury and its Office of Foreign...more
2/24/2022
/ Biden Administration ,
Economic Sanctions ,
Export Controls ,
Exports ,
Imports ,
International Emergency Economic Powers Act (IEEPA) ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Russia ,
SDN List ,
Ukraine