September 2025

In Proclamation 10908, “Adjusting Imports of Automobiles and Automobile Parts into The United States,” on March 26, 2025, President Trump ordered the Secretary of Commerce to create a process for including additional automobile parts for passenger vehicles and light trucks to Section 232 tariffs on imports. A new interim final rule published on September 17…

On September 17, 2025, the Bureau of Industry and Security (BIS) published a Federal Register notice that it will again accept requests for new derivative products to be subject to Section 232 tariffs on steel and aluminum articles. The request window is open from September 15 through September 29, 2025. Requests must provide detailed information…

Update: On November 7, 2025, the Office of the U.S. Trade Representative issued a notice rescheduling the public hearing on the operation of the Agreement between the United States of America, the United Mexican States, and Canada (USMCA). Originally scheduled for November 17, the hearing will now take place from December 3 to 5…

On September 16, 2025, the Office of the U.S. Trade Representative (USTR) issued a notice and request for public comments on the possible extension of the remaining 178 product exclusions in the Section 301 investigation of China’s acts, policies, and practices related to technology transfer, intellectual property, and innovation. The USTR has extended these exclusions…

All persons subject to U.S. jurisdiction holding property blocked pursuant to various Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctions programs must file their Annual Report of Blocked Property (ARBP) by September 30, 2025. This does applies to all relevant persons, not only financial institutions.

This report is pursuant to 31 C.F.R.

On September 16, 2025, the Department of Commerce’s International Trade Administration (ITA) released a Federal Register notice announcing changes to the Harmonized Tariff Schedule of the United States (HTSUS) as to general tariffs on imports of Japanese goods in order to implement the United States-Japan Agreement (see Executive Order 14345).  Under the original framework…

Executive Order 14346 (EO 14346) provides new procedures for implementing trade and security agreements and modifies the Trump administration’s approach to reciprocal tariffs. EO 14346 builds on previous trade actions, particularly those established under EO 14257, by expanding Annex II to EO 14257 – the list of items that are exempt from the reciprocal tariffs…

On September 9, 2025, the U.S. Supreme Court agreed to review a consolidation of two cases challenging the legality of tariffs imposed by President Donald Trump under the International Emergency Economic Powers Act (IEEPA).  It has scheduled oral arguments for the first week of November, an unusually swift timeline for the Court.

The first case…

On August 29, 2025, the U.S. Department of Justice (DOJ) announced a new Trade Fraud Task Force, an interagency initiative aimed at “robust enforcement” against importers and other parties who defraud the United States by evading tariffs or importing prohibited goods. The task force will coordinate closely with DHS agencies, including U.S. Customs and Border…

Continuing U.S. Enforcement Targeting of Cartels and Related Support

On August 28, 2025, the Financial Crimes Enforcement Network (FinCEN) issued Advisory FIN-2025-A003 and an accompanying Financial Trend Analysis to alert U.S. financial institutions of the significant and escalating threat posed by Chinese money laundering networks (CMLNs).

The first component, Advisory FIN-2025-A003, urges vigilance in detecting…