On March 24, 2025, President Donald Trump signed an Executive Order (EO) declaring that any country purchasing oil from Venezuela, “whether directly from Venezuela or indirectly through third parties,” will pay a 25% tariff on their exports to the United States. The EO tasks the Secretary of Commerce with determining whether a country buys Venezuelan
OFAC Extends Winding Down Deadline of Venezuela General License 41
On March 24, 2025, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Venezuela General License (GL) 41B extending the expiration date of Venezuela GL 41, which authorized certain transactions related to Chevron Corporation’s joint ventures in Venezuela. Previously, under GL 41A issued earlier this month, all transactions “ordinarily incident and
BIS Seeks Public Comments on Section 232 Investigations of Imports of Copper and Lumber
The Department of Commerce’s Bureau of Industry and Security (BIS) has issued Federal Register notices announcing that interested parties may submit written comments, data or other information pertinent to these investigations. Comments are due no later than April 1, 2025.
Section 232 National Security Investigation of Imports of Copper
This investigation was initiated on February
Trump Administration Imposes Section 232 Steel and Aluminum 25% Tariffs March 12, 2025; EU and Canada Retaliate
As previously announced by President Donald Trump, the Section 232 steel and aluminum 25% ad valorem tariffs went into effect 12:01 a.m., March 12, 2025, against all steel and aluminum articles and all listed derivatives, including many automotive, construction and consumer products. Aluminum articles and their derivative products from Russia are subject to 200% tariffs.
OFAC Once Again Extends Venezuela General License Delaying PdVSA 2020 8.5% Bond-Related Authorizations
On March 6, 2025, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued General License (GL) 5R, “Authorizing Certain Transactions Related to the Petróleos de Venezuela, S.A. 2020 8.5 Percent Bond on or After July 3, 2025,” which continues to delay U.S. persons’ ability to enforce bondholder rights to the CITGO
The United States Delays Implementation of IEEPA Tariffs Against Canada and Mexico for USMCA-Qualifying Goods Until April 2, 2025
President Donald Trump issued two executive orders (“EOs”) on March 6, 2025 delaying the 25% tariffs imposed against imports of products of Canada and Mexico (10% tariffs for imports of energy products of Canada) pursuant to the International Emergency Economic Powers Act (“IEEPA”) until April 2, 2025. The EOs specifically provide that goods qualifying and entered
Reversing the Biden Administration, OFAC Announces the Wind Down of Venezuela General License 41
On March 4, 2025, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued General License 41A within its Venezuela-Related Sanctions Program: “Authorizing the Wind Down of Certain Transactions Related to Chevron Corporation’s Joint Ventures in Venezuela.” The Biden Administration had issued the precursor to General License (GL) 41A, GL 41
President Trump Issues America First Investment Policy Memorandum Impacting FDI into the U.S. and Outbound Investment to Foreign Adversaries
On February 21, 2025, President Trump issued the America First Investment Policy Memorandum (“Memorandum”). The Memorandum aims to promote foreign direct investment (FDI) from “allies and partners” while restricting inbound investment from and outbound investment to “foreign adversaries,” such as China (including Hong Kong and Macau), Cuba, Iran, North Korea, Russia, and the Nicolás Maduro
Reversing the Biden Administration, State Department Recreates the Cuba Restricted List
On February 6, 2025, the State Department republished the “Cuba Restricted List” identifying entities and subentities that are under the control of, or act for or on behalf of, the Cuban military, intelligence, or security services or personnel. The Cuba Restricted List is significant because direct financial transactions with the enumerated entities and subentities are
President Trump Issues Executive Order on Countering Iran’s Malign Influence
On February 4, 2025, President Donald Trump issued an Executive Order (EO) stating that Iran’s malign behavior and influence threaten the national interest of the United States and that it is “in the national interest to impose maximum pressure on the Iranian regime to end its nuclear threat, curtail its ballistic missile program, and stop