On July 11, 2025, President Donald Trump issued an Executive Order directing that the February 2020 acquisition of Jupiter Systems, LLC of Delaware, and several of its foreign based subsidiaries (Jupiter), by Suirui International Co., Ltd. (Suirui), a Hong Kong/Chinese company, be unwound. Stating only that there is “credible evidence” Suirui might take action that

Francesca M.S. Guerrero
Francesca counsels clients on compliance with export controls, sanctions, import regulations, human rights and forced labor, and the FCPA and antibribery laws. She works closely with companies to develop tailored compliance programs that fit their specific needs, and routinely advises clients on some of their most challenging international transactions, involving dealings in high-risk jurisdictions or with high-risk counterparties. Francesca also counsels companies through all phases of internal investigations of potential trade and antibribery violations and represents companies across industries before related government agencies.
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…
President Trump Extends the Deadline for Implementing Reciprocal Tariffs
On July 7, 2025, based on “additional information and recommendation from various senior officials”, President Donald Trump issued an Executive Order determining that it is “necessary and appropriate” to again extend the suspension on reciprocal tariffs originally implemented by an earlier Executive Order on April 2, 2025. The proposed reciprocal tariffs will be suspended until…
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…
President Trump Announces Revocation of Syria Sanctions and Waiver of Other Sanctions and Export Controls
On June 30, 2025, President Donald Trump issued an Executive Order (EO) that removes sanctions on Syria, provides for the issuance of waivers that will permit the relaxation of export controls and other restrictions on Syria, and otherwise seeks to support “the positive actions” taken by the new Syrian government under President Ahmed al-Sharaa. The…
Reissuance of 2017 National Security Presidential Memorandum on Policy Towards Cuba
On June 30, 2025, President Donald Trump reissued National Security Presidential Memorandum (NSPM-5) to address U.S. policy towards Cuba. This version of NSPM-5 revises and amends the earlier version of NSPM-5 issued in June 2017 (see Thompson Hine Update of June 20, 2017).
NSPM-5 includes several policy statements including continued support of economic…
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…
Commerce Publishes Federal Register Notice Modifying HTSUS for Implementing General Terms of U.S. and UK Trade Deal
The U.S. Department of Commerce’s International Trade Administration (ITA) has published a Federal Register notice indicating that effective June 30, 2025, in consultation with U.S. Customs and Border Protection and the U.S. International Trade Commission, it has revised relevant provisions of the Harmonized Tariff Schedule of the United State (HTSUS) to conform with changes specified…
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…