On October 22, 2025, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) placed Russia’s two largest oil companies on its Specially Designated Nationals (SDN) List. This action was taken by the Treasury Department to “increase pressure on Russia’s energy sector and degrade the Kremlin’s ability to raise revenue for its war machine
President Trump Announces New Section 232 Tariffs on Medium- and Heavy-Duty Trucks, Their Parts, and Buses Starting November 1, 2025
On October 17, 2025, President Donald Trump issued Proclamation 10984 announcing that, effective November 1, 2025, the United States will begin levying a 25% tariff on medium- and heavy-duty vehicles (“MHDVs”), a 25% tariff on medium- and heavy-duty vehicle parts (“MHDVPs”), and a 10% tariff on buses pursuant to Section 232 of the Trade Expansion
USTR Issues Section 301 Determination on Nicaragua’s Abuses of Labor Rights and Human Rights Practices
On October 20, 2025, the United States Trade Representative (USTR) determined under Section 301 of the Trade Act of 1974 that Nicaragua’s acts, policies, and practices related to abuses of labor rights, abuses of human rights and fundamental freedoms, and dismantling of the rule of law are unreasonable and burden or restrict U.S. commerce. The
The Department of Commerce Posts Second Tranche of Items for Potential Inclusion on Section 232 Steel and Aluminum Derivative Product Tariff Lists
On October 7, 2025, BIS posted a second tranche of requests made by the public for inclusion on the list of derivative products subject to Section 232 tariffs on steel and aluminum derivative products. BIS received 95 inclusion requests in the second submission period that opened on September 15 and closed on September 29. The
BIS Rescinds Previous Firearms Interim Final Rule and Revises ECCNs for Firearms and Ammunition
On September 30, 2025, the Department of Commerce’s Bureau of Industry and Security (BIS) issued a Final Rule in which it announced that it was rescinding in its entirety an earlier Interim Final Rule issued during President Joseph Biden’s Administration that imposed new export license requirements for firearms and related ammunition and components. The Final
Status of Trade-Related Agency Operations During Government Shutdown
As of October 1, 2025, federal funding lapsed for numerous U.S. government agencies, including those engaged in sanctions, export control, and customs compliance and enforcement. Due to the lack of funding, export licensing functions have been significantly curtailed. Below is an overview of the status of key operations at OFAC, DDTC, BIS, and CBP.
Department
BIS Expands Entity List End-User Controls to Cover Affiliates of Listed Entities
On September 30, 2025, the Department of Commerce’s Bureau of Industry and Security (BIS) issued an Interim Final Rule that expands the export control restrictions of its Entity List to cover any affiliates that are at least 50% owned by one (or more) entities on the Entity List or the Military End-User (MEU) List. Previously
President Trump Issues Proclamation Adjusting Tariffs on Imports of Timber, Lumber and their Derivative Products
On September 29, 2025, President Donald Trump issued a proclamation announcing that the Department of Commerce had concluded its investigation into the effects of imports of timber, lumber, and their derivative products (collectively, wood products) pursuant to Section 232 of the Trade Expansion Act of 1962 and found certain wood products are being imported into
OFAC Again Extends Russia General License 13 Authorizing Transactions Ordinarily Incident and Necessary for Operations in Russia
On September 29, 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 13O, “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 Signs Executive Order on China’s Divestment of TikTok
On September 25, 2025, President Donald Trump issued an Executive Order (EO), “Saving TikTok While Protecting National Security”, stating that “a plan has been presented to me to undergo a qualified divestiture of TikTok’s United States operations, as outlined in a framework agreement.” While the agreement has not been made public, the EO indicates that: