On November 13, 2025, the Office of the U.S. Trade Representative (“USTR”) published a notice in the Federal Register announcing a nearly one-year suspension—until November 10, 2026—of countermeasures it imposed under Section 301 of the Trade Act of 1974, as amended, on Chinese vessels and maritime transport operations.  Section 301 authorizes the USTR to investigate…

Key Notes

  • Tariff undervaluation may result in criminal charges.
  • False country of origin may result in government procurement-related fraud charges, not only tariff-related fraud charges.

The Department of Justice (DOJ) in September announced the unsealing of an indictment charging two Colorado companies and three executives with a multiyear scheme to sell Chinese made forklifts to…

On November 5, 2025, the U.S. Supreme Court heard oral arguments in a high-profile consolidated appeal challenging whether President Donald Trump lawfully invoked the International Emergency Economic Powers Act (“IEEPA”) to impose tariffs.  The cases challenge two sets of tariffs Trump implemented earlier this year: (1) tariffs against Canada, China, and Mexico in response to…

On November 7, 2025, the State Department’s Directorate of Defense Trade Controls (DDTC) issued a Final Rule amending 22 C.F.R. § 126.1 to remove the Kingdom of Cambodia as a proscribed country under the International Traffic in Arms Regulations (ITAR).  Effective immediately, requests for the export of defense articles and services to Cambodia will now…

Following the October 31, 2025 meeting between President Donald Trump and Chinese President Xi Jinping, President Trump on November 4, 2025, issued two Executive Orders related to and reducing certain tariffs on China.

In the first Executive Order, President Trump modified duties on imports from China. In February and March 2025, in response to…

On November 1, 2025, the White House published a Fact Sheet announcing that the Department of Commerce’s Bureau of Industry and Security (“BIS”) will suspend the new “50% Rule”—also known as the “Affiliates Rule”—for one year, beginning November 10, 2025. The suspension was among several concessions reached during trade negotiations between the United States and…

On October 23, 2025, a customs broker operating in both the United States and Mexico pleaded guilty to conspiring to violate the Foreign Corrupt Practices Act (FCPA) before a magistrate judge in the U.S. District Court for the Western District of Texas.  Although the plea agreement remains under seal, it was approved and adopted the…

On October 26, 2025, the United States and the Government of Malaysia signed an Agreement on Reciprocal Trade. The agreement is intended to “enhance reciprocity in their bilateral trade relationship by addressing tariff and non-tariff barriers;” and seeks to “strengthen their commercial relationship through increased alignment on national and regional economic security matters.” …