2025

On November 10, 2025, the U.S. Department of State, the U.S. Department of Commerce, and the U.S. Department of the Treasury’s Office of Foreign Assets Control, issued a Tri-Seal Advisory on sanctions and export controls relief for Syria.

The advisory provides that the United States no longer imposes comprehensive sanctions on Syria and that the

On November 14, 2025, President Donald Trump issued an executive order exempting various agricultural products from the reciprocal tariff regime established under the International Emergency Economic Powers Act (“IEEPA”). Listed in Annex I of the executive order by their tariff codes within the Harmonized Tariff Schedule of the United States (“HTSUS”), these agricultural products include

On November 14, 2025, the United States, the Swiss Confederation (Switzerland), and the Principality of Liechtenstein (Liechtenstein) agreed to a framework for negotiations on an Agreement on Reciprocal Trade.  While representatives from the three countries continue to negotiate the formal agreement and hope to conclude any agreement during the first quarter of 2026, the key

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