On August 26, 2025, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) published a final rule in the Federal Register announcing it has removed the Syrian Sanctions Regulations and terminated the national emergency on which the regulations were based from the Code of Federal Regulations. Those regulations, codified at 31 C.F.R. Part
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 Further Delays Implementation of Increased Reciprocal Tariff Rates for China
On August 11, 2025, President Donald Trump issued an Executive Order announcing that he was suspending for another 90 days any increase on the reciprocal tariff rate currently in place for China. According to the Executive Order, negotiations continue with China “to address the lack of trade reciprocity in our economic relationship and our resulting…
Treasury Releases Annual CFIUS Report
On August 7, 2025, the Treasury Department, as the lead agency of the Committee on Foreign Investment in the United States (CFIUS), released a public version of its 2024 Annual Report to Congress regarding foreign direct investment in the United States. The report highlights key indicators of the CFIUS process and provides statistics on transactions that…
President Trump Announces Additional Tariffs on India for Russian Federation Oil Purchases
On August 6, 2025, President Donald Trump issued an Executive Order (EO) stating that it “is necessary and appropriate to impose an additional ad valorem duty on imports of articles of India, which is directly or indirectly importing Russian Federation oil.” As a result, beginning on August 27, 2025, an additional tariff of 25% will…
President Trump Announces Higher Reciprocal Tariffs for Canada and Extends Mexico’s Current Tariff Rate for 90 Days During Ongoing Negotiations
On July 31, 2025, President Donald Trump issued an Executive Order amending the tariff rate on imports from Canada and announced that Mexico’s current tariff rate will remain unchanged for an additional 90 days to allow for continued negotiations.
Canada Tariffs – Pursuant to a July 31, 2025 Executive Order, President Trump has modified…
President Trump Announces Implementation of Reciprocal Tariffs under the IEEPA
On July 31, 2025, President Donald Trump issued an Executive Order announcing that he was modifying and implementing the reciprocal tariff first announced on April 2, 2025, to rectify trade practices that his administration has determined contribute to “large and persistent annual United States goods trade deficits.” Effective August 7, 2025, reciprocal tariffs ranging from…
President Trump Announces 50% Tariff on U.S. Imports of Copper
Update: On July 31, 2025, Customs and Border Protection (CBP) released Cargo Systems Messaging Service (CSMS) # 65794272 providing guidance on applying the 50% Section 232 ad valorem duty on all imports of semi-finished copper products and intensive copper derivative products imposed by President Donald Trump on July 30, 2025. This guidance provides instructions on…
USTR Initiates Section 301 Investigation of Brazil’s Trading Practices
On July 15, 2025, the Office of the United States Trade Representative (USTR), at the direction of President Donald Trump, initiated an investigation of Brazil under Section 301 of the Trade Act of 1974. The investigation will seek to determine whether acts, policies, and practices of the government of Brazil related to digital trade and…
Trump Administration Initiates Section 232 Investigation into Imports of Unmanned Aircraft Systems (UAS) and Seeks Public Comments
On July 1, 2025, the Department of Commerce initiated an investigation under Section 232 of the Trade Expansion Act of 1962, as amended, to determine the effects on the national security of imports of unmanned aircraft systems (UAS) and their parts and components. The Department’s Bureau of Industry and Security (BIS) subsequently issued a Notice…
Trump Administration Initiates Section 232 Investigation into Imports of Polysilicon and Seeks Public Comments
On July 1, 2025, the Department of Commerce initiated an investigation under Section 232 of the Trade Expansion Act, as amended, to determine the effects on the national security of imports of polysilicon and its derivatives (items considered to be critical solar energy inputs). The Department’s Bureau of Industry and Security (BIS) subsequently issued a…
