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National Security Economic Sanctions International Emergency Economic Powers Act (IEEPA)

ArentFox Schiff

As the (Customs and Trade) World Turns: July 2025

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Welcome to the July 2025 issue of “As the (Customs and Trade) World Turns,” our monthly newsletter where we compile essential updates from the customs and trade world over the past month. We bring you the most recent and...more

Morrison & Foerster LLP

Terrorism Designations Primer: Process, Authorities, and Recourse

Since the mid-1990s, the Executive Branch has sought to target foreign terrorist organizations, and those individuals and organizations supporting them, in order to degrade their funding and support. Organizations and...more

Miles & Stockbridge P.C.

Lifting Sanctions On Syria: A Preview of the Process

President Donald Trump announced Tuesday during his trip to the Middle East that his administration would lift U.S. sanctions on Syria. Since the shock collapse of Bashar al-Assad’s regime in Syria late last year, the...more

WilmerHale

Limits of IEEPA’s Designation Authority

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Over the first 100 days and beyond, the Trump Administration has deployed national security authorities in novel ways. Perhaps most notably, President Trump has asserted authority under the International Emergency Economic...more

Blank Rome LLP

Liberation Day: President Trump Unveils Global, Reciprocal Tariffs – What You Need to Know

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President Trump announced new tariffs on April 2, 2025, which he referred to as “reciprocal tariffs,” on almost all imports into the United States. The tariff package will be rolled out in two phases. Tariffs of 10 percent...more

Bracewell LLP

Trump Administration Efforts to Eliminate Cartels Pose Heightened Risk for Financial Institutions

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As discussed in Bracewell’s February 11 and February 26 updates, the executive branch is prioritizing the “total elimination” of cartels and transnational criminal organizations, both through edicts from the Oval Office and...more

Kelley Drye & Warren LLP

Trump Announces Sweeping Reciprocal Tariffs

On April 2, 2025, President Trump signed an Executive Order (EO) imposing reciprocal tariffs on most nations. The new tariffs, which include a baseline rate of 10 percent as well as higher rates for dozens of trading...more

Kelley Drye & Warren LLP

Oil and Autos: Another Round of Tariff Activity

President Trump issued two major tariff-related executive orders in the past 48 hours. The first, pursuant to the International Emergency Economic Powers Act (IEEPA), authorizes the Secretary of State to impose tariffs on...more

K2 Integrity

The Tornado Cash Delisting And Sanctions Compliance Implications For Crypto

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On 21 March 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) removed Tornado Cash, a virtual currency mixer, from its list of Specially Designated Nationals and Blocked Persons (SDN List),...more

A&O Shearman

U.S. tariffs in the pharmaceutical sector

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Since taking office in January 2025, the Trump Administration has announced, imposed, or reimposed various tariff-related restrictions on articles imported into the United States. These proposed tariffs and their...more

Hogan Lovells

Caught in the crosshairs: Mitigating supply chain risks from Cartel FTO designations

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On February 20, the U.S. Department of State (State) designated eight cartels as Foreign Terrorist Organizations (FTOs). These designations are the latest development in the Trump administration’s realignment of the U.S....more

Foley & Lardner LLP

What Every Multinational Company (Doing Business in Mexico) Should Know About … Mitigating Risks From ATA Scrutiny in a New...

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Mexican cartels dominate large swaths of the Mexico-United States border and the Bajío region (an area encompassing relevant parts of Queretaro, Guanajuato, Aguascalientes, San Luis Potosí, Jalisco, and Michoacán), and they...more

K2 Integrity

Escalation Against Cartels: U.S. Designates International Cartels as Foreign Terrorist Organizations and Specially Designated...

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On 20 February 2025, the United States (U.S.) Department of State designated eight international cartels as Foreign Terrorist Organizations (FTOs) and Specially Designated Global Terrorists (SDGTs). The designation of...more

Latham & Watkins LLP

Trump Administration Targets Cartels With First Wave of Terrorism Designations

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The designations expand US tools and jurisdictional reach, and raise the stakes for foreign financial institutions and non-US companies to avoid dealing with designated entities....more

DLA Piper

Trump Administration Designates Eight Transnational Organizations as Foreign Terrorist Organizations and Specially Designated...

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Effective February 20, 2025, the Secretary of State designated eight Latin American organizations as Foreign Terrorist Organizations (FTOs) under Section 219 of the Immigration and Nationality Act (INA) and as Specially...more

Dorsey & Whitney LLP

Attorney General Bondi Reorients National Security Enforcement Resources to Focus on Illegal Immigration and Drug Trafficking

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Upon being sworn in on February 5, 2025, Attorney General Pamela Bondi immediately issued memoranda reorienting national security enforcement resources of the U.S. Department of Justice (“DOJ”) to focus on addressing illegal...more

Husch Blackwell LLP

Customs Confirms Scope of China IEEPA Tariffs and Removes, Then Reinstates, De Minimis Exemption for Most Low-Value Entries

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Following President Trump’s removal of the de minimis exemption earlier this week, on Friday, February 7, 2025, President Trump issued an amendment to his original Executive Order and temporarily reinstated the exemption...more

Hogan Lovells

OFAC takes the position that certain kinds of SDN participation in public conferences is not a prohibited service under U.S....

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The U.S. Department of Treasury’s Office of Foreign Assets Control issued a formal guidance letter stating that certain kinds of Specially Designated Nationals could speak at a public conference to share their individual...more

White & Case LLP

China Imposes Retaliatory Tariffs and Non-Tariff Measures in Response to Trump Tariffs

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On February 4, 2025, China announced it would impose additional tariffs on certain US imports from February 10, 2025 in retaliation to President Trump's executive order issued under the International Emergency Economic Powers...more

Holland & Knight LLP

Executive Order: Designating Cartels and Other Organizations as Foreign Terrorist Organizations and Specially Designated Global...

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Date Issued: Jan. 20, 2025 This executive order initiates the process of designating certain international cartels as Foreign Terrorist Organizations (FTOs) to address the rise in violence and terror across the western...more

Troutman Pepper Locke

Tornado Cash Whiplash – What’s Next for Sanctions?

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We find ourselves in the midst of a raucous debate among sanctions practitioners about the impact of the Fifth Circuit’s recent decision upholding a challenge against the sanctions the Office of Foreign Assets Control (OFAC)...more

White & Case LLP

Policy Watch: Status of US 25% Tariffs on Mexican Imports

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On February 1, 2025, President Trump imposed tariffs on imports from Canada, Mexico, and China, to take effect on February 4, 2025. The tariffs are an additional 25% ad valorem rate of duty to all imports from Canada and...more

BakerHostetler

Criminal Enforcement of the Trump Tariffs Is Likely - Here’s What It Will Look Like

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On Saturday, President Trump signed executive orders imposing stiff tariffs on three of the United States’ biggest trading partners. The orders impose a 25 percent tax on most imports from Canada and Mexico, while goods from...more

King & Spalding

President Trump Deploys Novel Use of IEEPA Authority to Impose Sweeping Tariffs on Mexico, Canada, and China

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The President has issued three executive orders that impose universal tariffs on Mexico, Canada, and China, deploying IEEPA in a sweeping manner to address the President’s declaration of a national emergency regarding illegal...more

Akin Gump Strauss Hauer & Feld LLP

Imposing Duties to Address the Synthetic Opioid Supply Chain in the People's Republic of China (Trump EO Tracker)

Summary - On February 1, President Trump signed executive orders imposing additional tariffs on Canada, Mexico, and China under the International Emergency Economic Powers Act (IEEPA) in response to an emergency declared at...more

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