- the Entity List
BIS Adds 407 Derivative Products Now Subject to the Section 232 Tariff on Steel and Aluminum
On August 15, 2025, the Department of Commerce’s Bureau of Industry and Security (BIS) published a Federal Register notice adding 407 codes from the Harmonized Tariff Schedule of the United States (HTSUS) to the list of steel and aluminum derivative products. As a result, these products will now be subject to the Section 232 tariff
President Trump Further Delays Implementation of Increased Reciprocal Tariff Rates for China
On August 11, 2025, President Donald Trump issued an Executive Order announcing that he was suspending for another 90 days any increase on the reciprocal tariff rate currently in place for China. According to the Executive Order, negotiations continue with China “to address the lack of trade reciprocity in our economic relationship and our resulting
Invoking IEEPA, President Trump Imposes an Additional 40% Tariff on Brazil
Following a threat posted on his social media site Truth Social in early July, President Donald Trump issued an Executive Order (“EO”) on July 30, 2025, imposing an additional 40% tariff on U.S. imports from Brazil, effective August 6, 2025. With the 10% baseline reciprocal tariff established by President Trump’s April 2, 2025 EO, tariffs
President Trump Announces 50% Tariff on U.S. Imports of Copper
Update: On July 31, 2025, Customs and Border Protection (CBP) released Cargo Systems Messaging Service (CSMS) # 65794272 providing guidance on applying the 50% Section 232 ad valorem duty on all imports of semi-finished copper products and intensive copper derivative products imposed by President Donald Trump on July 30, 2025. This guidance provides instructions on
OFAC Continues to Extend Russia General License 13 Authorizing Transactions Ordinarily Incident and Necessary for Operations in Russia
On July 8, 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 13N, “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
FinCEN Issues Landmark Orders Sanctioning Foreign Banks for Alleged Opioid-Related Money Laundering
For the first time, the Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) invoked the Fentanyl Sanctions Act and the Fend OFF Fentanyl Act on June 25, 2025, to issue three separate orders that each designate a Mexico-based financial institution as a “primary money laundering concern in connection with illicit opioid trafficking.” The three
Department of Commerce Announces New Procedures to Request Tariffs on Auto Parts
On June 24, 2025, in a press release, the Department of Commerce’s International Trade Administration (ITA) announced new procedures for U.S. producers of auto parts to request that additional auto parts be included in the list of auto parts that are subject to 25% tariffs under the Section 232 review of automobiles and auto
9th Circuit Upholds a $26 Million Civil Penalty Against a Pipe Importer for Violating the False Claims Act
The Ninth Circuit Court of Appeals has upheld a $26 million fraud verdict against a pipe importer for violating the False Claims Act (FCA) by making false statements on customs forms to avoid paying antidumping duties on Chinese-made pipe fittings. The court rejected the importer’s argument that the Tariff Act provides the exclusive remedy for
OFAC Amends Russia General License 55 Relating to the Sakhalin-2 Oil and Gas Project
On June 18, 2025, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Russia-related General License (GL) 55D, “Authorizing Certain Services Related to Sakhalin-2.” This general license authorizes certain services that would otherwise be prohibited under OFAC’s Russia sanctions program related to Sakhalin-2 involving the maritime transport of crude oil originating from