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
Aaron C. Mandelbaum
Aaron focuses his practice on advising clients on compliance with international economic sanctions, export controls, and U.S. import laws and regulations. He is also involved in assisting clients with complex cross-border transactions, anti-dumping and countervailing duty litigation, utilization of international and preferential trade agreements, and customs classifications. Most recently, Aaron has counseled clients navigating requirements under the Export Administration Regulations.
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).
USTR Initiates Public Consultation Process for USMCA Joint Review
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…
Annual Blocked Property Reports Due to OFAC by September 30
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.
U.S. Supreme Court to Review the Legality of Trump Administration’s IEEPA-Based 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…
