On August 29, 2025, the U.S. Department of Justice (DOJ) announced a new Trade Fraud Task Force, an interagency initiative aimed at “robust enforcement” against importers and other parties who defraud the United States by evading tariffs or importing prohibited goods. The task force will coordinate closely with DHS agencies, including U.S. Customs and Border
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.
FinCEN Issues Advisory and Financial Trend Analysis on Chinese Money Laundering Networks
Continuing U.S. Enforcement Targeting of Cartels and Related Support
On August 28, 2025, the Financial Crimes Enforcement Network (FinCEN) issued Advisory FIN-2025-A003 and an accompanying Financial Trend Analysis to alert U.S. financial institutions of the significant and escalating threat posed by Chinese money laundering networks (CMLNs).
The first component, Advisory FIN-2025-A003, urges vigilance in detecting…
Department of Commerce Relaxes Export Controls for Syria
On September 2, 2025, the Department of Commerce’s Bureau of Industry and Security (BIS) published a Final Rule in the Federal Register easing licensing requirements for civilian exports to Syria. The rule implements the policy on Syria established in Executive Order 14312, “Providing for the Revocation of Syria Sanctions” (June 30, 2025) that called for…
Federal Circuit Rules that Trafficking and Reciprocal Tariffs Violate IEEPA
On August 29, 2025, the U.S. Court of Appeals for the Federal Circuit (“the Court” or “Federal Circuit”) in a 7-4 ruling determined that President Donald Trump exceeded his authority by imposing certain tariffs under the International Emergency Economic Powers Act (IEEPA). The Court also affirmed the grant of declaratory relief of the U.S. Court…
OFAC Removes the Syrian Sanctions Regulations (codified at 31 C.F.R. Part 542)
On August 26, 2025, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) published a final rule in the Federal Register announcing it has removed the Syrian Sanctions Regulations and terminated the national emergency on which the regulations were based from the Code of Federal Regulations. Those regulations, codified at 31 C.F.R. Part…
Department of Commerce Initiates Section 232 Investigation of Imports of Wind Turbines and Seeks Public Comments
On August 13, 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 wind turbines and their parts and components. Interested parties may submit written comments, data, analyses, or other information to the…
Details Emerge on the U.S.-EU Trade Deal Announced in July
On August 21, 2025, the White House published a joint statement from the United States and the European Union (“EU”) announcing “key details” of a Framework on an Agreement on Reciprocal, Fair, and Balanced Trade (“Framework Agreement”). Though presented as a new accord, the Framework Agreement elaborates on a trade deal first announced in late July…
UFLPA Annual Strategy Update: U.S. Department of Homeland Security Designates New High-Priority Sectors and Adds 78 Entities to Forced Labor List
- 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…
