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.
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
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
CAFC Maintains President Trump’s IEEPA Tariffs Pending Final Decision
On June 10, 2025, the U.S. Court of Appeals for the Federal Circuit (CAFC) issued a stay keeping both tranches of President Donald Trump’s tariffs implemented under the International Emergency Economic Powers Act of 1977 (IEEPA) (50 U.S.C. § 1701 et seq.) in effect until final adjudication by the appellate court. The per curiam (
CIT Enjoins IEEPA Tariffs but CAFC Issues Temporary Stay – Analysis & Recommendations
- On May 28, the U.S. Court of International Trade (CIT) permanently enjoined tariffs imposed by President Donald Trump under the International Emergency Economic Powers Act (IEEPA), finding that he exceeded statutory and constitutional authority by imposing broad tariffs on imports from China, Canada, Mexico, and other countries.
- The CIT held that IEEPA does
Second Federal Court Determines IEEPA Tariffs Likely Invalid
On May 29, 2025, the U.S. District Court for the District of Columbia (USDC-DC) issued a preliminary injunction ruling staying the imposition of President Donald Trump’s use of the International Emergency Economic Powers Act (IEEPA). This preliminary injunction applies to tariffs that would be paid by the two named plaintiffs – Learning Resources, Inc. and
After CIT Blocks President Trump’s IEEPA Tariffs, CAFC Stays Order Pending Review of the CIT’s Judgment and Injunction
On May 29, 2025, the Court of Appeals for the Federal Circuit (CAFC) stayed the decision of the Court of International Trade (CIT) from the previous day, which had vacated both tranches of President Donald Trump’s tariffs implemented under the International Emergency Economic Powers Act of 1977 (IEEPA) (50 U.S.C. § 1701 et seq.). President
U.S. Coalition Files AD/CVD Petitions on Certain Chassis and Subassemblies from Mexico, Thailand, and Vietnam
On February 26, 2025, two U.S. chassis manufacturers representing the domestic industry – petitioners Cheetak Chassis Corporation and Stoughton Trailers, LLC – filed petitions with the Department of Commerce seeking the initiation of dumping and countervailing duty investigations into certain chassis and subassemblies imported from Mexico, Thailand, and Vietnam that are allegedly being or are
International Trade Administration Amends AD and CVD Regulations
In mid-December 2024, the Department of Commerce’s International Trade Administration (ITA) issued a Final Rule amending its trade remedy regulations for the administration of antidumping duty (AD) and countervailing duty (CVD) laws. These regulatory amendments are effective on January 15, 2025.
In many instances, the ITA has codified existing procedures and methodologies. The amendments, however