On November 7, 2025, the State Department’s Directorate of Defense Trade Controls (DDTC) issued a Final Rule amending 22 C.F.R. § 126.1 to remove the Kingdom of Cambodia as a proscribed country under the International Traffic in Arms Regulations (ITAR). Effective immediately, requests for the export of defense articles and services to Cambodia will now
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.
President Trump Issues Executive Orders Addressing China Tariff Rates
Following the October 31, 2025 meeting between President Donald Trump and Chinese President Xi Jinping, President Trump on November 4, 2025, issued two Executive Orders related to and reducing certain tariffs on China.
In the first Executive Order, President Trump modified duties on imports from China. In February and March 2025, in response to…
White House Announces One-Year Suspension of the BIS “Affiliates Rule”
On November 1, 2025, the White House published a Fact Sheet announcing that the Department of Commerce’s Bureau of Industry and Security (“BIS”) will suspend the new “50% Rule”—also known as the “Affiliates Rule”—for one year, beginning November 10, 2025. The suspension was among several concessions reached during trade negotiations between the United States and…
United States and China Reach Deal to Ease Trade Tensions
- China
United States and Malaysia Sign Reciprocal Trade Agreement
On October 26, 2025, the United States and the Government of Malaysia signed an Agreement on Reciprocal Trade. The agreement is intended to “enhance reciprocity in their bilateral trade relationship by addressing tariff and non-tariff barriers;” and seeks to “strengthen their commercial relationship through increased alignment on national and regional economic security matters.” …
United States and Cambodia Sign Reciprocal Trade Agreement
On October 26, 2025, the United States and the Kingdom of Cambodia signed an Agreement on Reciprocal Trade. The agreement is intended to “enhance reciprocity in their bilateral trade relationship by addressing tariff and non-tariff barriers;” and seeks to “strengthen their commercial relationship through increased alignment on national and regional economic security matters.” …
United States and Vietnam Agree to Framework Agreement on Reciprocal Trade
- Vietnam’s preferential market access for substantially all U.S. industrial and agricultural exports.
- The continuation of U.S. reciprocal tariffs
United States and Thailand Agree to Framework Agreement on Reciprocal Trade
- Thailand’s elimination of tariff barriers on approximately 99 percent of goods, covering a full range of U.S. industrial, food
OFAC Sanctions Russia’s Two Largest Oil Companies
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…
