On August 29, 2025, the U.S. Department of Justice (DOJ) announced a new Trade Fraud Task Force, an interagency initiative aimed at “robust enforcement” against importers and other parties who defraud the United States by evading tariffs or importing prohibited goods. The task force will coordinate closely with DHS agencies, including U.S. Customs and Border
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.
FinCEN Issues Advisory and Financial Trend Analysis on Chinese Money Laundering Networks
Continuing U.S. Enforcement Targeting of Cartels and Related Support
On August 28, 2025, the Financial Crimes Enforcement Network (FinCEN) issued Advisory FIN-2025-A003 and an accompanying Financial Trend Analysis to alert U.S. financial institutions of the significant and escalating threat posed by Chinese money laundering networks (CMLNs).
The first component, Advisory FIN-2025-A003, urges vigilance in detecting…
Department of Commerce Relaxes Export Controls for Syria
On September 2, 2025, the Department of Commerce’s Bureau of Industry and Security (BIS) published a Final Rule in the Federal Register easing licensing requirements for civilian exports to Syria. The rule implements the policy on Syria established in Executive Order 14312, “Providing for the Revocation of Syria Sanctions” (June 30, 2025) that called for…
Federal Circuit Rules that Trafficking and Reciprocal Tariffs Violate IEEPA
On August 29, 2025, the U.S. Court of Appeals for the Federal Circuit (“the Court” or “Federal Circuit”) in a 7-4 ruling determined that President Donald Trump exceeded his authority by imposing certain tariffs under the International Emergency Economic Powers Act (IEEPA). The Court also affirmed the grant of declaratory relief of the U.S. Court…
OFAC Removes the Syrian Sanctions Regulations (codified at 31 C.F.R. Part 542)
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…
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…
