On March 25, 2025, the Department of Commerce’s Bureau of Industry and Security (BIS) added over 80 companies to its Entity List through two Final Rules. These are the first listings by BIS under President Donald Trump’s second term and the listings heavily focus on China. According to BIS, these entities “have been determined by
Trump Signs EO Imposing an Additional 25% Tariff on Countries That Buy Venezuelan Oil
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
CBP Issues Guidance on Energy, Energy Resources and Critical Minerals from Canada Subject to 10% IEEPA Tariffs; President Trump Issues Executive Order Addressing Mineral Production
UPDATE: On March 24, 2025, Customs and Border Protection (CBP) issued a message noting the release of an updated list of impacted HTSUS codes covering “energy” and “energy resources” from Canada that are now subject to 10% tariffs since March 4, 2025. The list now specifically includes all crude and crude mixtures along with
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
USTR Proposes Actions Against China’s Unfair Trade Practices in Maritime, Logistics & Shipbuilding Sectors
Key Notes:
Tariffs Against Canada and Mexico Enter Into Force March 4, 2025
The Trump administration implemented tariffs against Canada and Mexico effective March 4, 2025, arising from declared national emergencies at both the northern and southern U.S. borders pursuant to the International Economic Emergency Powers Act (IEEPA).
Implementation of Tariffs
On March 3, 2025, U.S. Customs and Border Protection (CBP) issued draft Federal Register notices (to be
Tariffs Against China and Hong Kong Increase to 20% on March 4, 2025
On March 3, 2025, the White House issued an Executive Order to further address the synthetic opioid supply chain in China by increasing the current tariffs on all products of China (and Hong Kong) from 10% to 20%. China immediately responded by announcing that it will implement additional tariffs of up to 15% on key