On February 2, 2026, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued General License (GL) 5U, “Authorizing Certain Transactions Related to the Petróleos de Venezuela, S.A. 2020 8.5 Percent Bond on or After March 20, 2026,” which continues to delay U.S. persons’ ability to enforce bondholder rights to the CITGO
President Trump Announces New 25% Section 232 Tariff on Narrow Category of Semiconductors Critical to AI
On January 14, 2026, President Donald Trump issued Proclamation 11002, announcing that, effective January 15, 2026, the United States is levying a 25% tariff on “a very narrow category of semiconductors” critical to the artificial intelligence (AI) sector, unless those semiconductors are imported “to support the buildout of the United States supply chain.” The
No Section 232 Tariff Now on Processed Critical Minerals and Their Derivative Products
On January 14, 2026, President Donald Trump issued Proclamation 11001, concluding that processed critical minerals and their derivative products (PCMDPs) would not be subject now to an additional tariff under Section 232 of the Trade Expansion Act of 1962. Section 232 authorizes the president to adjust duties on goods imported in quantities or under
OFAC Again Extends Russia General License 13 Authorizing Transactions Ordinarily Incident and Necessary for Operations in Russia
On January 6, 2026, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) again extended Russia-related General License (GL) 13 by issuing a revised GL 13P, “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
CBP to Issue All Refunds Electronically Starting February 6, 2026
On January 2, 2026, U.S. Customs and Border Protection (“CBP”), an agency within the U.S. Department of Homeland Security, published an interim final rule announcing it will move to an all-electronic refund system beginning February 6, 2026. As a result, the agency will no longer issue paper checks for refunds—including tariff refunds—absent a waiver approved
Importers of Record Flood CIT with IEEPA Tariff Refund Complaints
- Hundreds of new cases have been filed at the U.S. Court of International Trade (“CIT”) since the November 5, 2025 oral arguments at the U.S. Supreme Court (“SCOTUS”) in the appeal challenging the legality of the International Emergency Economic Powers Act (“IEEPA”) as the statutory authority to impose tariffs and seeking to preserve
USTR Announces Section 301 Tariffs on Nicaragua
On December 10, 2025, the Office of the United States Trade Representative (USTR) issued a Federal Register notice announcing actions under Section 301 of the Trade Act of 1974 to address Nicaragua’s acts, policies, and practices related to abuses of labor rights, abuses of human rights and fundamental freedoms, and the dismantling of the rule
CBP Issues WRO on Garments and Apparel Manufactured in Mauritius
On November 18, 2025, U.S. Customs and Border Protection (CBP) announced the issuance of a Withhold Release Order (WRO) against garments, apparel, and textiles manufactured in Mauritius by Firemount Group Ltd. The WRO follows an investigation into the company where CBP discovered several indicators of forced labor use, including abuse of vulnerability, debt bondage, deception
United States and Ecuador Reach Framework Agreement on Reciprocal Trade
According to a Joint Statement issued by the White House on November 13, 2025, the United States and the Republic of Ecuador have entered into a Framework for an Agreement on Reciprocal Trade to “provide access to each other’s markets and increase alignment on economic and national security matters.” As noted in a separate White
President Trump Issues Executive Order Exempting Various Agricultural Products from the Reciprocal Tariff Regime
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