“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 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
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 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 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
On March 25, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) announced a significant expansion of its Entity List restrictions, adding 80 entities from China, the United Arab Emirates, South Africa,...more
3/28/2025
/ Artificial Intelligence ,
Bureau of Industry and Security (BIS) ,
China ,
Corporate Counsel ,
Economic Sanctions ,
Enforcement Actions ,
Entity List ,
Export Administration Regulations (EAR) ,
Export Controls ,
Foreign Policy ,
Foreign Relations ,
Machine Learning ,
National Security ,
Regulatory Reform ,
Technology Sector ,
Trump Administration ,
U.S. Commerce Department ,
US Trade Policies
On April 2 — labeled “Liberation Day” by President Trump — the Trump administration is set to add a new sanctions-like boost to its tariff strategy, with a threat to impose unprecedented “secondary tariffs” of 25% on “all...more
3/28/2025
/ Corporate Counsel ,
Economic Sanctions ,
Executive Orders ,
Foreign Policy ,
Foreign Relations ,
Infrastructure ,
Mexico ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Regulatory Oversight ,
Secondary Sanctions ,
Secretary of Commerce ,
Tariffs ,
Trump Administration ,
U.S. Commerce Department ,
United States-Mexico-Canada Agreement (USMCA) ,
US Trade Policies ,
Venezuela
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