On July 11, 2025, President Donald Trump issued an Executive Order directing that the February 2020 acquisition of Jupiter Systems, LLC of Delaware, and several of its foreign based subsidiaries (Jupiter), by Suirui International Co., Ltd. (Suirui), a Hong Kong/Chinese company, be unwound.  Stating only that there is “credible evidence” Suirui might take action that threatens to impair the national security of the United States, the president has ordered that divestment occur within the next 120 days, unless an extension is granted.

The authority of the president to suspend or prohibit certain foreign investment transactions is pursuant to section 721 to the Defense Production Act of 1950, as amended, and implementing regulations governing the Committee on Foreign Investment in the United States (CFIUS).   The Executive Order requires that Suirui divest “all interests and rights” in Jupiter, Jupiter’s tangible and intangible assets or property, including its intellectual property, non-public source code associated with Jupiter products, and most customer contracts.  The assets and operations of two Jupiter subsidiaries located in China and Hong Kong are not required to be divested, so long as such assets and operations were acquired or created after the February 2020 acquisition by Suirui.

Beginning immediately, Suirui must ensure that their personnel “refrain from accessing Jupiter’s non-public source code, non-public technical information, information technology systems, products, parts and components, books and records, or facilities in the United States, unless otherwise approved by CFIUS.” 

In order to effectuate the divestment, Suirui must identify and obtain approval from CFIUS for the intended buyer of Jupiter and its assets.  In doing so, it must certify in writing to CFIUS that it has destroyed or transferred all intellectual property or non-public source code associated with Jupiter products in their possession or control.  CFIUS has authority to audit the divestment to ensure such destruction or transfer has occurred.  CFIUS will implement measures it deems necessary and appropriate to verify and enforce compliance with this Executive Order and any conditions imposed by CFIUS during the period of divestment.

On July 8, 2025, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) again extended previous Russia-related General License (GL) 13 by issuing a revised GL 13N, “Authorizing Certain Administrative Transactions Prohibited by Directive 4 under Executive Order 14024,” which states that U.S. persons are authorized to pay taxes, fees, or import duties, and purchase or receive permits, licenses, registrations, certifications, or tax refunds to the extent such transactions are prohibited by Directive 4. Such transactions are allowable provided they are ordinarily incident and necessary to such persons’ day-to-day operations in the Russian Federation. Directive 4 prohibits any transaction involving the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation, including any transfer of assets to such entities or any foreign exchange transaction for or on behalf of such entities.

Previous GL 13N was set to expire on July 9, 2025; the revised GL 13N is set to expire on October 9, 2025.

On July 7, 2025, based on “additional information and recommendation from various senior officials”, President Donald Trump issued an Executive Order determining that it is “necessary and appropriate” to again extend the suspension on reciprocal tariffs originally implemented by an earlier Executive Order on April 2, 2025. The proposed reciprocal tariffs will be suspended until 12:01 a.m. EDT on August 1, 2025.

In his original April 2, 2025 Executive Order, President Trump announced baseline tariffs of 10% for all countries starting April 5, 2025, and, as applicable, additional duty rates increasing up to 50% starting April 9, 2025, on specific countries with which the United States has the largest trade-in-goods deficits or that impose non-tariff barriers on U.S. goods. See Thompson Hine Update of April 3, 2025. Shortly thereafter, however, the president announced he was pausing until July 9, 2025, the country-specific reciprocal tariffs and, instead, leaving in place for 90 days the baseline 10% tariffs (with the exception of certain tariffs on China that remain in place) to allow for negotiations and efforts to achieve agreements with other countries. See Thompson Hine Update of April 10. 2025.

While negotiations with other countries continue, President Trump sent letters to certain trade partner countries — Indonesia, Japan, Malaysia, South Korea, Thailand, and others — informing each of the reciprocal tariff rate that will be applied on August 1, 2025. These reciprocal tariffs appear to range from 25% to 40%, with the possibility of lower rates if acceptable agreements are reached, or of further increases if there is no agreement or the other country raises its tariff rates. In addition, in a social media post, President Trump separately threatened to place an additional 10% tariff on “any country aligning themselves with the anti-American policies of BRICS [Brazil, Russia, India, China, South Africa and six other countries].”

For the first time, the Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) invoked the Fentanyl Sanctions Act and the Fend OFF Fentanyl Act on June 25, 2025, to issue three separate orders that each designate a Mexico-based financial institution as a “primary money laundering concern in connection with illicit opioid trafficking.” The three banks are CIBanco S.A., Institution de Banca Multiple (“CIBanco”); Intercam Banco S.A., Institución de Banca Multiple (“Intercam”); and Vector Casa de Bolsa, S.A. de C.V. (“Vector”). Effective July 21, the three orders prohibit covered financial institutions from engaging in “transmittals of funds” involving the designated institutions.

The specific conduct giving rise to these designations varies by institution, but FinCEN found that each engaged in a “long-standing pattern of associations, transactions, and provision of financial services that facilitate illicit opioid trafficking by Mexico-based cartels,” including the procurement of precursor chemicals from China for unlawful purposes.

These orders prohibit any “covered financial institution,” as defined in 31 C.F.R. § 1010.100(t), from engaging in “transmittals of funds.” A “covered financial institution” refers to an agent, agency, branch, or office within the United States of any (i) bank (except bank credit card systems), (ii) broker or dealer in securities, (iii) money services business (i.e., a person that accepts checks or money in an amount greater than $1,000 on a given day in return for currency or a combination of currency and other monetary instruments), (iv) telegraph company, (v) authorized casino, (vi) card club or similar gaming establishment, (vii) person subject to supervision by any state or Federal bank supervisory authority, (viii) futures commission merchant, (ix) introducing broker in commodities, or (x) mutual fund. Engaging in “transmittals of funds” means “sending and receiving of funds, including convertible virtual currency.”

As noted in the orders, the sanctions are effective 21 days from their date of publication in the Federal Register to ensure compliance (i.e., until July 21, 2025). Violations may result in civil penalties of up to twice the value of transaction or $1,776,364 per violation, and criminal penalties of up to $1 million per transaction for willful violations.

Although the sanctions only directly impact covered financial institutions, other parties should consider that it may be difficult to process payments to or from accounts at these banks, as payments may not be processed by covered financial institutions. Furthermore, additional due diligence may be advisable for any transactions involving these banks, as they may raise red flags related to money laundering.

On June 30, 2025, President Donald Trump issued an Executive Order (EO) that removes sanctions on Syria, provides for the issuance of waivers that will permit the relaxation of export controls and other restrictions on Syria, and otherwise seeks to support “the positive actions” taken by the new Syrian government under President Ahmed al-Sharaa. The EO does not provide relief to certain officials and persons of the former regime of Bashar al-Assad, ISIS or other terrorist organizations, human rights abusers, those linked to chemical weapons or proliferation-related activities, or other persons that threaten the peace, security, or stability of the United States, Syria, and its neighbors. 

The below offers an overview and summary of the numerous actions taken under the EO. Note, however, certain sanctions and controls prohibiting exports of U.S.-origin products remain in place as they were mandatorily implemented under legal statutes. The Secretary of State will be required to submit to the appropriate Congressional committees reports and certifications required by two Acts (noted below) prior to the actual implementation of any relaxation of covered sanctions or export controls.

As such, a close review of the June 30, 2025 EO is necessary to ensure whether a U.S. company or person can now fully engage in activities in Syria and/or with Syrian entities or persons.

Revoking OFAC Syria Sanctions but Maintaining Designations on Bashar al-Assad and His Associates

Effective July 1, 2025, the EO terminates the national emergency declared by the United States regarding Syria and revokes six past EOs that implemented sanctions and blocked property of various persons in Syria and senior officials in the Government of Syria. 

In revoking the numerous EOs the Department of the Treasury’s Office of Foreign Assets Control (OFAC) has concurrently removed 518 individuals and entities from the Specially Designated Nationals (SDN) List sanctioned under the Syria sanctions program, thus “lifting sanctions on such individuals and entities critical to Syria’s development, the operation of its government, and the rebuilding of the country’s social fabric.” The list of persons and entities removed from the SDN List can be found here.

As a result of President Trump’s June 30 EO, OFAC will also remove the Syrian Sanctions Regulations, 31 C.F.R. part 542 from the Code of Federal Regulations following the July 1, 2025 revocation.

However, the scope of sanctions on certain persons impacted by EO 13894 (October 14, 2019, providing for menu-based sanctions including travel restrictions to the United States and isolation from the United States’ financial system for foreign persons who engage in or finance the obstruction, prevention, or disruption of a ceasefire or political solution to the conflict in Syria) and EO 14142 (January 15, 2025) have been amended in order to continue “to ensure meaningful accountability for perpetrators of war crimes, human rights violations and abuses, and the proliferation of narcotics trafficking networks in and in relation to Syria during the former regime of Bashar al-Assad and by those associated with it.” 

As such, OFAC designated 139 individuals and entities pursuant to EO 13894 and placed them on the SDN List. These individuals and entities include former government officials of the former regime of Bashar al-Assad (including family members), his associates, human rights abusers, drug traffickers, persons linked to chemical weapons activities, ISIS or its affiliates, Iranian proxies, and others who may engage in the disruption or prevention of efforts to promote a stable Syria. The list of persons and entities added to the SDN List can be found here.

OFAC has also released Frequently Asked Questions 1220-1223 to provide guidance on continued reliance on OFAC Syria General License 25 and addressing other aspects of President Trump’s EO of June 30, 2025.

Suspension of Certain Statutory Sanctions under the Caesar Syria Civilian Protection Act

The EO directs the Secretary of State to examine whether certain criteria set forth in the Caesar Act have been met and evaluate suspending sanctions. This law, enacted in 2019, established mandatory sanctions to target foreign persons who facilitated the Assad regime’s acquisition of goods, services, or technologies that supported the regime’s military activities as well as its aviation and oil and gas production industries. If such criteria have been met, the Secretary of State may suspend the imposition of such sanctions, so long as continued review of the situation in Syria is undertaken to ensure that reimposition of any sanctions are not necessary.

Note that the Treasury and State Departments in May 2025 waived sanctions under the Caesar Act. See Thompson Hine Update of May 27, 2025. With the June 30, 2025 EO, the State Department has now formally terminated economic sanctions against various Syrian entities and, as previously noted, OFAC has removed such persons and entities from its SDN List. Thus, all property and interests in property of such designated persons that are in the United States or in possession or control of U.S. persons are unblocked. Additionally, all entities owned, either directly or indirectly, 50% or more by one or more blocked persons are also unblocked. 

In a brief statement, Secretary of State Marco Rubio stated that he would now “examine the potential full suspension of the Caesar Act.”

Waiver of Export Controls under the Syria Accountability and Lebanese Sovereignty Restoration Act of 2003

The EO also waives and relaxes the application of certain export controls on items on the Commerce Control List and certain provisions of the Syria Accountability Act. President Trump has determined that it is in the national security interests of the United States to waive such restrictions and has directed the Secretary of State to submit to the appropriate Congressional committees the report and certification required by this Act. 

This Act requires the President to implement two or more sanctions from a menu-based list and includes prohibiting the export of U.S. origin products (other than food and medicine) to Syria. It should be noted, however, that while the President has made the required determination that Syria meets the requirements for sanctions relief under the Syria Accountability Act, as of June 30, 2025, such a determination has not been certified to Congress. Thus, the lifting of the prohibition of exports to Syria of items on the Commerce Control List of dual-use items in the Export Administration Regulations (EAR), identifying which export controls will be relaxed, and establishing any continuing requirements to obtain necessary licenses from the Department of Commerce’s Bureau of Industry and Security (BIS) have not been implemented and these sanctions have not been immediately lifted.

Waiver of Sanctions under the Chemical Biological Weapons Control and Warfare Elimination (CBW) Act

The EO also waives various sanctions imposed on Syrian under the CBW Act due to the prior use of chemical weapons under the former regime of Bashar al-Assad. This includes the lifting of restrictions on foreign assistance; restrictions on U.S. government credit, credit guarantees, or other financial assistance; restrictions on the export of certain national security-sensitive goods and technology; and restrictions on U.S. banks from making loans or providing credit to the Government of Syria. Again, while the President has made the determination that Syria meets the requirements for sanctions relief under this Act, such a determination and a report must be transmitted to Congress. The EO states that these waivers to allow the resumption of financial aid will be effective 20 days after appropriate notice has been made to the Congress.

Other Actions

The EO also directs the Secretary of State to undertake all appropriate action with respect to the designation of certain Syrian persons and entities, including Hay’at Tahrir al-Sham’s (HTS), as “Specially Designated Global Terrorists” and to review the designation of Syria as a State Sponsor of Terrorism. The Secretary of State is also directed to take appropriate steps to advance U.S. policy objectives at the United Nations to support a Syria that is stable and at peace and to explore avenues at the United Nations to provide sanctions relief.

In a related Fact Sheet issued by the White House, it is noted that President Trump “is committed to supporting a Syria that is stable, unified, and at peace with itself and its neighbors.” However, the United States will seek to “reengage constructively,” thus the Trump Administration will continue “to guard against all threats and monitor progress on key priorities.”

Thompson Hine will continue to monitor the relaxation of sanctions and exports controls on Syria and report further developments as necessary.

On June 30, 2025, President Donald Trump reissued National Security Presidential Memorandum (NSPM-5) to address U.S. policy towards Cuba. This version of NSPM-5 revises and amends the earlier version of NSPM-5 issued in June 2017 (see Thompson Hine Update of June 20, 2017).

NSPM-5 includes several policy statements including continued support of economic embargo of Cuba as set forth in the Cuban Liberty and Democratic Solidarity (LIBERTAD) Act of 1996, including by opposing measures that call for an end to the embargo at the United Nations and other international forums. The administration is also directed to ensure adherence to the statutory ban on tourism to Cuba (relaxed during the Obama administration) and to not reinstate the “Wet Foot, Dry Foot” policy which encouraged “unlawful” travel by Cuban nationals to the United States.

The memorandum notes that policy interests include: advancing Cuban human rights; encouraging the growth of a Cuban private sector independent of government control; enforcing final orders of removal against Cuban nationals in the United States; protecting the national security and public health and safety of the United States, including through proper engagement on criminal cases and working to ensure the return of fugitives from American justice living in Cuba or being harbored by the Cuban government; supporting United States agriculture and protecting plant and animal health; advancing the understanding of the United States regarding scientific and environmental challenges; and facilitating safe civil aviation.

Accordingly, by July 30, 2025, the Secretary of the Treasury and the Secretary of Commerce, as appropriate and in coordination with the Secretary of State and the Secretary of Transportation, are directed to initiate a process to adjust current regulations regarding transactions with Cuba. Such efforts will include, but are not limited to:

  • The Secretary of State identifying any entities that are under the control of, or act for or on behalf of, or for the benefit of, the Cuban military, intelligence, or security services or personnel, and publish a list of those identified entities and prohibit direct or indirect financial transactions with such entities.
  • The Secretary of the Treasury initiating a process to adjust current regulations to ensure adherence to the statutory ban on tourism to Cuba, and regularly auditing travel to Cuba to ensure that travelers are complying with relevant statutes and regulations.
  • The Department of the Treasury expanding its current regulation defining the term “prohibited officials of the Government of Cuba” to include additional Cuban government ministers, state agencies, and certain employees of the Ministry of the Interior, Ministry of Defense, and Cuban state-run media organizations.
  • The Secretary of State convening a task force to examine the technological challenges and opportunities for expanding internet access in Cuba, including through federal government support of programs and activities that encourage freedom of expression through independent media and internet freedom in Cuba.
  • The Secretary of State and the Secretary of Homeland Security continuing to discourage unlawful migration from Cuba and carrying out duties regarding interdiction of migrants.

Accordingly, parties engaged in transactions involving Cuba should closely monitor developments and any forthcoming regulatory changes.

On June 24, 2025, in a press release, the Department of Commerce’s International Trade Administration (ITA) announced new procedures for U.S. producers of auto parts to request that additional auto parts be included in the list of auto parts that are subject to 25% tariffs under the Section 232 review of automobiles and auto parts. These procedures are established pursuant to President Trump’s Proclamation issued on March 26, 2025. For additional background, see Thompson Hine Update of March 27, 2025 and Update of April 30, 2025.

ITA is establishing four two-week submission windows per year in January, April, July, and October respectively. The first ever window is scheduled to open on July 1, 2025. During each window, the ITA will review requests on a rolling basis. After the closing of each window, a non-confidential version of each valid request will be posted and open to public comment for fourteen days. The ITA will make a determination within sixty days of receiving the request.

Each request must include (1) the requester’s identification, (2) a description of the item, (3) the eight or ten-digit classification number from the Harmonized Tariff Schedule of the United States (HTSUS) requested for tariff inclusion, (4) an explanation of why the item is an auto part, (5) information on the domestic industry affected by imports of the item, (6) statistics on imports and domestic production of the item, and (7) a description of how and to what extent imports of the item have increased in a manner that threatens to impair national security or undermine the objectives of the automobile tariffs under Section 232.

In addition to this request mechanism, the Secretary of Commerce can also add more auto parts to the tariff list without requests from producers, according to the March 26, 2025 Proclamation. Parties interested in pursuing tariffs on imported auto parts may consider submission of a request. However, parties wishing to exclude tariffs on imported auto parts may plan to monitor the requests during every quarterly period and consider submission of public comment opposing the requested tariffs.

The U.S. Department of Commerce’s International Trade Administration (ITA) has published a Federal Register notice indicating that effective June 30, 2025, in consultation with U.S. Customs and Border Protection and the U.S. International Trade Commission, it has revised relevant provisions of the Harmonized Tariff Schedule of the United State (HTSUS) to conform with changes specified in an Executive Order by President Donald Trump regarding implementation of the June 16, 2025 General Terms for the United States of America and the United Kingdom of Great Britain and Northern Ireland Economic Prosperity Deal (the “General Terms”). The General Terms reached with the United Kingdom concern tariffs on imports of (i) automobiles and automobile parts; (ii) civil aircraft; and (iii) future relief on imports of aluminum and steel articles and their derivatives. See Thompson Hine update of June 18, 2025.

The General Terms provide, inter alia, that the United States intends to create an annual quota of 100,000 vehicles for imports of U.K. automobiles that are classified in heading 8703 of the HTSUS at a combined 10% tariff rate. Effective June 30, 2025, the covered subheadings as set forth in Annex I, Section A of the Federal Register notice, are: 8703.22.01; 8703.23.01; 8703.24.01; 8703.31.01; 8703.32.01; 8703.33.01; 8703.40.00; 8703.50.00; 8703.60.00; 8703.70.00; 8703.80.00; and 8703.90.01. Also effective June 30 is modified duty treatment for certain parts of passenger vehicles and light trucks that are products of the United Kingdom. Annex I, Section B lists numerous covered HTSUS subheadings under Chapters 40, 70, 73, 83, 84, 85, 87, 90, and 94. Annex I, Sections A and B provide additional details on the implementation and scope of the modified customs duty treatment for covered automobiles and automobile parts and should be closely reviewed.

The General Terms also provide that products of the United Kingdom that fall under the World Trade Organization (WTO) Agreement on Trade in Civil Aircraft are no longer subject to tariffs previously imposed. Effective June 30, 2025, numerous articles of civil aircraft (all aircraft other than military aircraft), their engines, parts, and components, other related parts, components, and subassemblies, and ground flight simulators and their parts and components that are products of the United Kingdom will no longer be subject to additional duties that resulted from the long-running WTO dispute between the United States and European Union on subsidies provided for large civil aircraft manufacturers. Annex I, Section 3 of the Federal Register notice sets forth numerous HTSUS subheadings that are covered by this modified customs duty treatment.

While the United States and the United Kingdom committed under the General Terms to adopt a structured, negotiated approach to addressing U.S. national security concerns regarding imports of aluminum and steel articles and their derivatives subject to tariffs under Section 232 of the Trade Expansion Act of 1962, this topic is not addressed in the June 30, 2025 Federal Register notice.

The Ninth Circuit Court of Appeals has upheld a $26 million fraud verdict against a pipe importer for violating the False Claims Act (FCA) by making false statements on customs forms to avoid paying antidumping duties on Chinese-made pipe fittings. The court rejected the importer’s argument that the Tariff Act provides the exclusive remedy for customs fraud, affirming that the FCA can also be used to pursue such claims.

The case originated from a whistleblower lawsuit filed by a competitor. The complaint alleged that the importer at issue and its partners misclassified and misrepresented the products imported from China, declaring to customs that they are steel couplings, and later marketing them to its customers as welded outlets, in order to evade a 182.9% antidumping duty, depriving the U.S. government of significant revenue. In response, the importer contended that (1) its products were not subject to the tariffs and (2) that, regardless, the Tariff Act, not the FCA, should govern such disputes. However, the court found that Congress intended both statutes to coexist and that the FCA’s broad scope covers customs duty evasion.

Under Section 1592 of the Tariff Act, the United States can pursue enforcement actions to recover unpaid customs duties and/or impose civil penalties for customs violations by fraud, gross negligence, or negligence. A customs violation by fraud is punishable by a civil penalty in an amount not to exceed the domestic value of the merchandise. The FCA, on the other hand, allows for civil penalties, including three times of the amount of suffered damages (the underpaid duties, in the case of customs violations). The whistleblowers who bring a qui tam action under the FCA can be awarded between 15%-25% of the total recovered amount.

The 9th Circuit’s decision confirms that Section 1592 of the Tariff Act does not displace the FCA, and both statutes may operate in parallel to address customs duty evasions. The original jury verdict at issue found that the importer was liable for violating the FCA and that it owed $8 million in damages, which was tripled under the FCA, plus civil penalties, resulting in the $26 million judgment.

On June 18, 2025, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Russia-related General License (GL) 55D, “Authorizing Certain Services Related to Sakhalin-2.” This general license authorizes certain services that would otherwise be prohibited under OFAC’s Russia sanctions program related to Sakhalin-2 involving the maritime transport of crude oil originating from this oil and gas development on Sakhalin Island, Russia. Originally issued in November 2022, the general license authorized: (i) maritime transport of such crude oil originating from the Sakhalin-2 project, provided that the Sakalin-2 byproduct is solely for importation into Japan; and (ii) certain transactions involving Gazprombank Joint Stock Company (Gazprombank) that are related to the Sakhalin-2 project. 

Revised GL 55D extends such authorizations until December 19, 2025. Certain transactions under each of the general license remain unauthorized and therefore requires close analysis.