On October 17, 2025, President Donald Trump issued Proclamation 10984 announcing that, effective November 1, 2025, the United States will begin levying a 25% tariff on medium- and heavy-duty vehicles (“MHDVs”), a 25% tariff on medium- and heavy-duty vehicle parts (“MHDVPs”), and a 10% tariff on buses pursuant to Section 232 of the Trade Expansion
Status of Trade-Related Agency Operations During Government Shutdown
As of October 1, 2025, federal funding lapsed for numerous U.S. government agencies, including those engaged in sanctions, export control, and customs compliance and enforcement. Due to the lack of funding, export licensing functions have been significantly curtailed. Below is an overview of the status of key operations at OFAC, DDTC, BIS, and CBP.
Department
BIS Expands Entity List End-User Controls to Cover Affiliates of Listed Entities
On September 30, 2025, the Department of Commerce’s Bureau of Industry and Security (BIS) issued an Interim Final Rule that expands the export control restrictions of its Entity List to cover any affiliates that are at least 50% owned by one (or more) entities on the Entity List or the Military End-User (MEU) List. Previously
President Trump Issues Proclamation Adjusting Tariffs on Imports of Timber, Lumber and their Derivative Products
On September 29, 2025, President Donald Trump issued a proclamation announcing that the Department of Commerce had concluded its investigation into the effects of imports of timber, lumber, and their derivative products (collectively, wood products) pursuant to Section 232 of the Trade Expansion Act of 1962 and found certain wood products are being imported into
OFAC Again Extends Russia General License 13 Authorizing Transactions Ordinarily Incident and Necessary for Operations in Russia
On September 29, 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 13O, “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
President Trump Announces Section 232 Tariffs on Heavy-Duty Trucks, Cabinetry, Upholstered Furniture, and Branded/Patented Pharmaceuticals Starting October 1, 2025
On September 25, 2025, President Donald Trump announced on social media that the United States will impose a 25% tariff on heavy-duty trucks beginning October 1, 2025. The social media post did not specify the legal basis for the tariff but indicated it was necessary “for many reasons, but above all else, for national security
Department of Commerce Lists EU Tariff Exemptions
On September 24, 2025, the U.S. Department of Commerce announced tariff exemptions for certain goods imported from the EU. The notice modified additional duty rates applicable to certain imported products of EU member countries.
On August 21, 2025, the United States and the EU announced an agreement that adjusted tariffs on certain EU products, including
Department of Commerce Initiates Section 232 Investigation of Imports of Personal Protective Equipment, Medical Consumables, and Medical Equipment
On September 2, 2025, the Department of Commerce (Commerce) initiated an investigation under Section 232 of the Trade Expansion Act of 1962, as amended, to determine the effects on the national security of imports of personal protective equipment (PPE), medical consumables, and medical equipment including devices. Interested parties may submit written comments, data, analyses, or
Department of Commerce Initiates Section 232 Investigation of Imports of Robotics and Industrial Machinery
On September 2, 2025, the Department of Commerce (Commerce) initiated an investigation under Section 232 of the Trade Expansion Act of 1962, as amended, to determine the effects on the national security of imports of robotics and industrial machinery. According to the notice, the term “robotics and industrial machinery” for this investigation includes, among other things
OFAC Amends Remaining Syria-Related Sanctions Regulations
The Office of Foreign Assets Control (OFAC) issued a Final Rule effective September 25, 2025 amending the Syria-Related Sanctions Regulations at 31 C.F.R. Part 569. The heading of these regulations is being changed to the “Promoting Accountability for Assad and Regional Stabilization Sanctions Regulations.” These amended regulations further implement Syria-related Executive Order 14312 (June 30, 2025).