President Donald Trump issued two executive orders (“EOs”) on March 6, 2025 delaying the 25% tariffs imposed against imports of products of Canada and Mexico (10% tariffs for imports of energy products of Canada) pursuant to the International Emergency Economic Powers Act (“IEEPA”) until April 2, 2025. The EOs specifically provide that goods qualifying and entered
Reversing the Biden Administration, OFAC Announces the Wind Down of Venezuela General License 41
On March 4, 2025, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued General License 41A within its Venezuela-Related Sanctions Program: “Authorizing the Wind Down of Certain Transactions Related to Chevron Corporation’s Joint Ventures in Venezuela.” The Biden Administration had issued the precursor to General License (GL) 41A, GL 41
President Trump Issues America First Investment Policy Memorandum Impacting FDI into the U.S. and Outbound Investment to Foreign Adversaries
On February 21, 2025, President Trump issued the America First Investment Policy Memorandum (“Memorandum”). The Memorandum aims to promote foreign direct investment (FDI) from “allies and partners” while restricting inbound investment from and outbound investment to “foreign adversaries,” such as China (including Hong Kong and Macau), Cuba, Iran, North Korea, Russia, and the Nicolás Maduro
Reversing the Biden Administration, State Department Recreates the Cuba Restricted List
On February 6, 2025, the State Department republished the “Cuba Restricted List” identifying entities and subentities that are under the control of, or act for or on behalf of, the Cuban military, intelligence, or security services or personnel. The Cuba Restricted List is significant because direct financial transactions with the enumerated entities and subentities are
President Trump Issues Executive Order on Countering Iran’s Malign Influence
On February 4, 2025, President Donald Trump issued an Executive Order (EO) stating that Iran’s malign behavior and influence threaten the national interest of the United States and that it is “in the national interest to impose maximum pressure on the Iranian regime to end its nuclear threat, curtail its ballistic missile program, and stop
Department of Commerce Adjusts Levels of Civil Monetary Penalties for 2025
On January 15, 2025, the Department of Commerce’s inflation-adjusted civil monetary penalties for 2025 went into effect. The adjustments, which the Department of Commerce (“Commerce”) published in the Federal Register on December 30, 2024, update the penalty rates for violations of laws and regulations enforced by the agency and its bureaus.
While over 40 civil
DDTC Issues Interim Final Rule to Amend Provisions of the ITAR and USML Categories
On January 17, 2025, the Department of State’s Directorate of Defense Trade Controls (DDTC) published an Interim Final Rule that will amend §§ 121.0 and 121.1 of the International Traffic in Arms Regulations (ITAR) by revising certain U.S. Munitions List (USML) definitions, adding new definitions, and updating certain parts of the USML under categories II
CBP Publishes Proposed Rule to Limit Duty Exemption for Certain Low-Value Shipments
On January 17, 2025, Customs and Border Protection (CBP) announced a Notice of Proposed Rulemaking (NPRM) intended to tighten the de minimis duty exemption for certain low-value shipments entering the United States. Under the proposed rule, merchandise subject to specific trade and national security actions would no longer qualify for the de minimis exemption and
DHS Updates UFLPA Entity List with Additional Chinese Companies; USTR Releases Trade Strategy to Combat Forced Labor
On January 14, 2025, the Department of Homeland Security (DHS) announced the addition of 37 companies based in China to the Uyghur Forced Labor Prevention Act (UFLPA) Entity List, bringing the total number of entities on the UFLPA Entity List to nearly 150 entities.
According to a press release by DHS, the entities added include globally recognized
OFAC Takes Further Action on Russia’s Attempts to Evade U.S. Sanctions
The Department of the Treasury’s Office of Foreign Asset Controls (OFAC) has issued further sanctions (see also January 15, 2025 Thompson Hine Update) to address Russia’s continued efforts to evade U.S. sanctions. OFAC noted in a press release that this latest action “targets a sanctions evasion scheme established between actors in Russia and [China]